EERE Information Center Search Help More Search Options

Printable Version 

### Energy Conservation Standards for Battery Chargers and Class A External Power Supplies This page presents additional information on energy conservation standards, the upcoming public meeting, instructions for submitting comments, contact information, and more for Docket Number EERE-2008- BT-STD-0005

.
Return to the Battery Charger and External Power Supplies page for information on all of the U.S. Department of Energy's (DOE) activities related to these products. Background Section 301 of the Energy Independence and Security Act of 2007 (EISA) establishes standards for Class A EPSs effective July 1, 2008, and directs DOE to conduct two successive rulemakings to review and possibly amend the energy conservation standards for external power supplies, the first of which is to be completed by July 1, 2011.
Section 309 of EISA requires DOE to issue a final rule prescribing energy conservation standards for BCs, if technologically feasible and economically justified, by July 1, 2011. (42 U.S.C. 6295(u)(1)(E)(i)(II))

DOE is bundling the battery charger rulemaking proceeding with a review and possible amendment to the energy conservation standards for Class A external power supplies. Current Rulemaking DOE has issued a notice of public meeting and availability of framework document. In the notice, DOE outlines its plans for developing new energy conservation standards for battery chargers, and for reviewing and possibly amending energy conservation standards for external power supplies. In addition, DOE has developed a supplemental draft technical report, which describes past DOE analysis on battery chargers and external power supplies.
Notice of Public Meeting and Availability of Framework Document ( PDF 48 KB ) Appliances and Commercial Equipment Standards: Energy Conservation S... http://www1.eere.energy.gov/buildings/appliance_standard s/residential/b...

1 of 2 6/4/2009 8:59 A MFramework Document Public Meeting Framework Document ( PDF 1.7 MB ) Draft Technical Report ( PDF 1.3 MB )

Contact Information Victor Petrolati Project Manager (202) 586-4549

Printable Version

Building Technologies Program Home | EERE Home | U.S. Department of Energy Webmaster | Web Site Policies | Security & Privacy | USA.gov Content Last Updated: 05/28/2009 Appliances and Commercial Equipment Standards: Energy Conservation S... http://www1.eere.energy.gov/buildings/appliance_standard s/residential/b...

2 of 2 6/4/2009 8:59 A M1 [6450-01-P]

DEPARTMENT OF ENERGY

Office of Energy Efficiency and Renewable Energy

10 CFR Part 430

(Docket No. EERE-2008-BT-STD-0005)

RIN: 1904-AB57

Energy Efficiency Program for Consumer Pro ducts: Public Meeting and Availability of

Framework Document for Battery Char gers and External Power Supplies

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION: Notice of public meeting and availability of a Framework Document.

SUMMARY: The U.S. Department of Energy (DOE) is initiating a rulemaking process to

consider establishing new energy conservation standards for batte ry chargers and amending the

energy conservation standards for Class A extern al power supplies, as directed by the Energy

Independence and Security Act of 2007 (EISA). A ccordingly, DOE will hold an informal public

meeting to discuss and receive comments on its pl anned analytical approa ch and issues it will

address in this rulemaking proceeding. DOE also welcomes written comments from the public

concerning this rulemaking. To inform interested pa rties and to facilitate this process, DOE has2 prepared two documents: a framework document, which explains the analytical approach and

identifies particular issues on which DOE is interested in receiving comment; and a draft

technical report, which details DOE ’s research and analysis on thes e products to date. Copies of

these and all other documents associated with this rulemaking are available at

www.eere.energy.gov/buildings/appliance_standa rds/residential/battery_external.html

.

DATES: DOE will hold a public meeting in Washington, D.C., beginning on July 16, 2009,

from 9 a.m. to 5 p.m.. The agenda for the public meeting will include the energy conservation

standards rulemaking on battery chargers and external power supplies. DOE must receive

requests to speak at this public meeting no la ter than 4 p.m., Thursday, July 2, 2009. DOE must

receive a signed original and an electronic copy of statements to be given at the public meeting

no later than 4 p.m., Thursday, July 9, 2009. Wr itten comments on the framework document are

welcome, especially following the public meeting, and should be submitted by [INSERT DATE

45 DAYS AFTER PUBLICATION OF THIS NOTICE]

.

ADDRESSES: The public meeting will be held at th e U.S. Department of Energy, Forrestal

Building, Room 1E-245, 1000 Independence Av enue, SW, Washington, DC 20585-0121. Please

note that foreign nationals participating in the public meeting are subject to advance security

screening procedures. If a foreign national wish es to participate in the public meeting, please

inform DOE as soon as possible by contacting Ms. Brenda Edwards at (202) 586-2945 so that

the necessary procedures can be completed.3Interested parties may submit comments, identified by docket number EERE-2008-BTSTD-0005 and/or Regulation Identifier Numb er (RIN) 1904-AB57, by any of the following

methods:

 Federal eRulemaking Portal : www.regulations.gov . Follow the instructions for

submitting comments.

 E-mail : BC&EPS_ECS@ee.doe.gov . Include docket number EERE-2008-BT-STD0005 and/or RIN 1904-AB57 in the s ubject line of the message.

 Mail : Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies

Program, Mailstop EE-2J, Framework Document for Battery Chargers and External

Power Supplies, docket number EER E-2008-BT-STD-0005 and/or RIN 1904-AB57,

1000 Independence Avenue, SW., Washi ngton, DC 20585-0121. Please submit one

signed paper original.

 Hand Delivery/Courier : Ms. Brenda Edwards, U.S. Department of Energy, Building

Technologies Program, 6 th Floor, 950 L’Enfant Plaza, SW, Washington, DC 20024.

Please submit one signed paper original.

Instructions : All submissions received must incl ude the agency name and docket number

or RIN for this rulemaking.

Docket : For access to the docket to read backgr ound documents or comments received,

go to the U.S. Department of Energy, Resour ce Room of the Building Technologies Program,

Sixth Floor, 950 L’Enfant Plaza, SW., Washi ngton, DC 20024, (202) 586-2945, between 9 a.m.4 and 4 p.m., Monday through Friday, except Federa l holidays. Please call Ms. Brenda Edwards

first at the above telephone number for additiona l information about visiting the Resource Room.

FOR FURTHER INFORMATION CONTACT: Mr. Victor Petrolati, U.S. Department of

Energy, Office of Energy Efficiency and Rene wable Energy, Building Technologies, EE-2J,

1000 Independence Avenue, SW., Washingt on, DC 20585-0121. Telephone: (202) 586-4549. Email: Victor.Petrolati@ee.doe.gov

.

Mr. Michael Kido, U.S. Department of En ergy, Office of the General Counsel, GC-72,

1000 Independence Avenue, SW., Washington, DC 20585. Telephone: (202) 586-9507. E-mail:

mailto: Michael.Kido@hq.doe.gov

.

For information on how to submit or review public comments and on how to participate

in the public meeting, contact Ms. Brenda Edwards, U.S. Department of Energy, Office of

Energy Efficiency and Renewable Energy, Bu ilding Technologies Program, EE-2J, 1000

Independence Avenue, SW., Washington, DC, 20585-0121. Telephone (202) 586-2945. E-mail:

Brenda.Edwards@ee.doe.gov

.

SUPPLEMENTARY INFORMATION:

Title III of the Energy Policy and Conserva tion Act (EPCA), as amended (42 U.S.C.

6291 et seq .), sets forth a variety of provisions designed to improve energy efficiency. Part B of

Title III (42 U.S.C. 6291–6309), subsequently renamed Part A, established the “Energy5 Conservation Program for Consumer Products Other Than Automobiles.” 1 The consumer

products subject to this program are referred to as “covered products.”

Section 135 of the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58, amended

sections 321 and 325 of EPCA, by defining batter y chargers and external power supplies and

directing the Secretary to prescribe “definitions an d test procedures for the power use of battery

chargers and external power supplies” and to “iss ue a final rule that determines whether energy

conservation standards shall be i ssued for battery chargers and external power supplies or classes

of battery chargers and external power supplies.” (42 U.S.C. 6295(u)(1)(A) and (E))

On December 8, 2006, DOE complied with the first of these requirements by publishing a

final rule that prescribed te st procedures for a variety of products. 71 FR 71340. That rule,

which is currently codified in multiple sections of the Code of Federal Regulations (CFR),

included definitions and test pro cedures for battery chargers a nd external power supplies. The

test procedures for battery chargers and exte rnal power supplies are found in 10 CFR Part 430,

Subpart B, Appendix Y (“Uniform Test Method for Measuring the Energy Consumption of

Battery Chargers”) and 10 CFR Part 430, Subpart B, Appendix Z (“Uniform Test Method for

Measuring the Energy Consumption of Ex ternal Power Supplies.”), respectively.

DOE subsequently published a notice of public meeting and availability of

documentation for public review on December 29, 2006. 71 FR 78389. This public meeting,

called a “Scoping Workshop,” discussed DOE’s plans for conducting a determination analysis

for battery chargers and extern al power supplies. The Scoping Workshop was held at DOE’s

Forrestal Building in Washington, DC, on Ja nuary 24, 2007. Information pertaining to the

1 This part was originally titled Part B but it was redesignated Part A in the United States Code for editorial reasons.6 Scoping Workshop can be found on DOE’s website at

www.eere.energy.gov/buildings/appliance_standa rds/residential/battery_external.html

.

On December 19, 2007, Congress enacted the En ergy Independence and Security Act of

2007 (EISA), Pub. L. 110-140, which amended, am ong others, sections 321, 323, and 325 of

EPCA. While EPACT 2005 amended EPCA by defini ng an external power supply as “an

external power supply circu it that is used to convert household el ectric current into DC current or

lower-voltage AC current to operate a consum er product” (42 U.S.C. 6291(36)(A)), section 301

of EISA amended this definition by creating a su bset of external power supplies called “Class A

External Power Supplies”—those external power s upplies that are “able to convert to only 1 AC

or DC output voltage at a time” and that have “nam eplate output power that is less than or equal

to 250 watts.” (42 U.S.C. 6291(36)(C)(i)) Sectio n 301 of EISA also es tablished for these

products energy conservation standards that beca me effective on July 1, 2008, and directed DOE

to conduct an energy conservation standards rule making to review those standards by July 1,

2011.

Additionally, section 309 of EISA amended section 325(u )(1)(E) of EPCA by directing

DOE to issue a final rule that prescribes ener gy conservation standards fo r battery chargers or

classes of battery chargers or to determ ine that no energy conservation standard is

technologically feasible and economically justified. DOE is bundling together this battery

charger rulemaking proceeding with the requir ement to review and consider amending the

energy conservation standards for Class A external power supplies, as both rulemakings must be

completed by July 1, 2011. The new rulemaking re quirements contained in sections 301 and 3097 of EISA effectively supersede the prior determination analysis that EPACT 2005 required DOE

to conduct.

Section 309 of EISA also instru cted DOE to “issue a final rule that determines whether

energy conservation standards shall be issued for external power supplies or classes of external

power supplies” no later than tw o years after EISA’s enactment. (42 U.S.C. 6295(u)(1)(E)(i)(I))

Because DOE cannot conduct a determination an alysis on whether it should issue energy

conservation standards for a product for which standards have already been set, DOE is

interpreting these sections jointly as a requirement to determine, in a separate rulemaking to be

completed by December 19, 2009, whether energy conservation standards shall be issued for

non-Class A external power supplies. Examples of these types of external power supplies include

those with nameplate output power greater than 250 watts, those that are able to convert to more

than one AC or DC output voltage at the same ti me, and those that are specifically excluded from

coverage under the Class A external power suppl y definition provided by EI SA by virtue of their

application ( e.g. , EPSs used with medical devices).

Finally, section 310 of EISA established de finitions for active mode, standby mode, and

off mode, and directed DOE to amend its existi ng test procedures fo r both BCs and EPSs to

measure the energy consumed in standby mode and off mode. (42 U.S.C. 6295(gg)(2)(B)(i))

DOE satisfied this requirement by publishing a fina l rule that incorporat ed standby and off mode

measurement into the DOE test procedure. 74 FR 13318 (March 27, 2009).

To initiate the bundled battery charger a nd Class A external power supply rulemaking,

DOE has prepared a Framework Document to expl ain the issues, analyses , inputs, and processes

it anticipates will arise in developing new energy conservation standards for battery chargers and8 amended energy conservation standards for Class A external power supplies. In addition, DOE

has prepared a draft technical report that presen ts DOE’s research, analysis, and methods on both

these products as part of its work on the determ ination analysis in 2007. The publication of this

draft technical report is not intended to set any new precedent for framework document

meetings. Instead, DOE believes that it may receive better comment and more precise direction

from interested parties on key issues by publishi ng its previously developed draft analyses in

conjunction with this framework document. As di scussed earlier, the work on the determination

was overtaken by the changes intr oduced by EISA, which modified both its scope and schedule.

As noted above, DOE will hold a public meeting on Thursday, July 16, 2009, in

Washington, DC, to discuss the analyses presen ted and issues identified in the Framework

Document. At the public meeting, the Department will make a number of presentations, invite

discussion on the rulemaking process as it appl ies to battery chargers and external power

supplies, and solicit comments, data, and informa tion from participants and other interested

parties. DOE will also invite comment on its preliminary analyses of battery chargers and

external power supplies, as descri bed in the draft technical report

The public meeting will be conducted in an informal, facilitated conference style. There

shall be no discussion of proprietary informati on, costs or prices, market shares, or other

commercial matters regulated by U.S. antitrust laws . A court reporter will record the proceedings

of the public meeting, which will be ente red into the docket for this rulemaking.

DOE encourages those who wish to partic ipate in the public meeting to read the

Framework Document and draft t echnical report and to be prepar ed to discuss their contents.9 Copies of both documents are available at

www.eere.energy.gov/buildings/appliance_standa rds/residential/battery_external.html

.

Public meeting participants need not limit thei r comments to the issues identified in the

Framework Document. DOE is also interested in receiving comments c oncerning other relevant

issues that participants believe would aff ect any energy conservation standards for these

products. For example, interested parties are i nvited to comment on external power supplies not

included in Class A. DOE is c onducting a separate determination analysis rulemaking for these

products, but intends to invite public comment on the scope of coverage for non-Class A external

power supplies at the end of the public meeting, if time permits.

DOE invites all interested parties, whether they participate in the public meeting, to

submit in writing by [INSERT DATE 45 DAYS AFTER DATE OF PUBLICATION IN

THE FEDERAL REGISTER]

, comments and information on matters addressed in the

Framework Document and on other matters rele vant to assessment of energy conservation

standards for battery chargers and external power supplies.

After the public meeting and the close of the comment period on the Framework

Document, DOE will begin collecting data, cond ucting the analyses as discussed in the

Framework Document and at the public m eeting, and reviewing the comments received.10 DOE considers public participation to be a ve ry important part of the process for setting

energy conservation standards. DOE encourages th e participation and interaction of the public

during the comment period in each stage of the rulemaking process. Beginning with the

Framework Document, and during each subse quent public meeting and comment period,

interactions with and among memb ers of the public provide a bala nced discussion of the issues

that assists DOE in the standa rds rulemaking process. Accordingly, anyone who would like to

participate in the public meeting, receive meeting materials, or be added to the DOE mailing list

to receive future notices and information rega rding this and related rulemakings on battery

chargers and external power supplies should c ontact Ms. Brenda Edwards at (202) 586-2945, or

via e-mail at Brenda.Edwards@ee.doe.gov

.

Issued in Washington, DC, on May 26, 2009.

_________________________________ Steven Chalk Principal Deputy Assistant Secretary Energy Efficiency and Renewable Energy

### Energy Conservation Standards Rulemaking Framework Document for Battery Chargers and External Power Supplies

U.S. Department of Energy Office of Energy Efficiency and Renewable Energy Building Technologies Program

May 2009

iFOREWORD

The U.S. Department of Energy (DOE) is publishing this framework document in conjunction with a draft techni cal report that summarizes the preliminary findings of DOE’s analysis conducted in 2006 and 2007. This analysis was part of DOE’s Determination Analysis for Battery Chargers and External Power S upplies (Docket No. EERE- 2006-DET-0136) that the Energy Policy Act of 2005 (EPACT 2005) re quired DOE to perform by August 2008. The Energy Independence and Security Act of 2007 (EISA) superseded this determination analysis, redefining the scope of the analysis and exte nding the deadline to December 2009. Among other things, EISA also established energy conservati on standards for certain t ypes of external power supplies, directed DOE to conduct rulemakings to review and consider amending the external power supply standards, and required DOE to esta blish energy conservati on standards for battery chargers. Given the similarities between these two products and the timing requirements imposed by Congress, DOE is bundling these two rulemakings into one proceeding, which together form the subject of this framework document.

While DOE chose in this instance to publish a draft technical repor t in conjunction with this framework document to provide interested pa rties an opportunity to review and comment on the draft analysis prepared in 2006 and 2007, intere sted parties should not view this action as establishing a new precedent for fr amework document public meetings. Because DOE was already examining these products and developing its analysis for the determination analysis when EISA altered EPCA, DOE believes that pub lishing this draft analys is for public review now will encourage more detailed and targeted comm ents from interested parties that will help DOE prepare its analysis for the next stage of this rulemaking.

Building Technologies Program Office of Energy Efficiency and Renewable Energy U.S. Department of Energy

iiHOW TO SUBMIT COMMENTS

DOE seeks comments from the public on this document and any supplemental data or other information about battery chargers and external power supplies. The public may submit comments, identified by Docket Number EERE-2008-BT-STD-0005 and/or Regulation Identifier Number (RIN) 1904-AB57, by any of the following methods:

 E-mail : BC&EPS_ECS@ee.doe.gov . Include EERE-2008-BT-STD-0005 and/or RIN 1904-AB57 in the subject line of the message.

 Federal eRulemaking Portal : www.regulations.gov . Follow the instructions for submitting comments.

 Mail : Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, Mailstop EE-2J, Framework Document for Battery Chargers and External Power Supplies, EERE-2008-BT-STD-0005 and/or RIN 1904-AB57, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Please submit one signed paper original.

 Hand Delivery/Courier : Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 6th Floor, 950 L’ Enfant Plaza, SW., Washington, DC 20024. Phone: 202-586-2945. Please submit one signed paper original.

For access to the docket to read background doc uments, a copy of the transcript of the public meeting, or comments received, go to the U. S. Department of Energy, Resource Room of the Building Technologies Program, 6th Floor, 950 L’Enfant Plaza, SW., Washington, DC 20024, between 9 a.m. and 4 p.m., Monday through Friday, except Federal holidays. For more information about visiting the Resource R oom, contact Ms. Brenda Edwards, 202-586-2945.

FOR FURTHER INFORMATION CONTACT:
Mr. Victor Petrolati, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies , EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-0121. Phone: 202-586-4549. E-mail: Victor.Petrolati@ee.doe.gov

. Mr. Michael Kido, U.S. Department of En ergy, Office of the General Counsel, GC-72, 1000 Independence Avenue, SW., Washi ngton, DC 20585. Phone: 202-586-9507. E-mail:
mailto: Michael.Kido@hq.doe.gov

.
For information on how to submit or review public comments and on how to participate in the public meeting, contact Ms. Brenda Edwards, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Bu ilding Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washingt on, DC 20585-0121. Phone: 202-586-2945. E-mail: Brenda.Edwards@ee.doe.gov

.

iiiTABLE OF CONTENTS

1 INTRODUCTION

.................................................................................................................. 1 1.1 The Appliance and Commercial Equipment Standards Program

....................................... 2 1.2 Overview of the Rulemaking Process

................................................................................. 4 1.2.1 Test Procedures

.......................................................................................................... 4 1.2.2 Rulemaking Process and Intere sted Party Participation

............................................ 4 1.3 Pre-Rulemaking Analyses and Other Activities

................................................................. 6 1.4 Notice of Proposed Rulemaking

......................................................................................... 8 1.5 Final Rule

..................................................................................................................... ....... 9 2 OVERVIEW OF ANALYSES FOR RULEMAKING

........................................................... 9 3 MARKET AND TECHNOLO GY ASSESSMENT

............................................................. 11 3.1 Definitions

......................................................................................................................... 11 3.1.1 Current Statutory Definitions

................................................................................... 12 3.1.2 Additional Definitions

............................................................................................. 13 3.2 Scope of this Rulemaking

................................................................................................. 15 3.2.1 Wall Adapters That Do Not Power Battery Charging Systems

............................... 16 3.2.1.1 Medical EPSs

..................................................................................................... 16 3.2.2 Battery Charging Systems Not Powered by Wall Adapters

.................................... 17 3.2.2.1 DC-Powered Battery Charging Systems

............................................................ 18 3.2.3 Battery Charging Systems Powered by Wall Adapters

........................................... 18 3.2.3.1 Wall Adapters Specifically Exclude d from Class A EPS Standards

................. 21 3.2.3.2 Key Questions

.................................................................................................... 22 3.2.3.3 Possible Approaches to Interpreting the Definitions of BCs and EPSs

............. 23 3.2.3.4 Details of Approach A

....................................................................................... 28 3.2.3.5 Details of Approach B

....................................................................................... 30 3.2.3.6 Details of Approach C

....................................................................................... 33 3.2.3.7 Details of Approach D

....................................................................................... 35 3.2.3.8 Summary of the Four Approaches

..................................................................... 37 3.2.4 Identification of Wall Adapters

............................................................................... 38 3.3 Market Assessment

........................................................................................................... 40 3.3.1 Distribution Channels

.............................................................................................. 41 3.3.2 Shipments

................................................................................................................. 42 3.3.3 Regulatory and Vol untary Programs

....................................................................... 44 3.3.4 Market Failures

........................................................................................................ 44 3.4 Technology Assessment

.................................................................................................... 44 3.4.1 Battery Charger Design

............................................................................................ 45 3.4.2 External Power Supply Design

................................................................................ 47 3.5 Measuring Efficiency

........................................................................................................ 49 3.5.1 Measuring Battery Charger Efficiency

.................................................................... 49 3.5.2 Measuring External Power Supply Efficiency

......................................................... 50 3.6 Product Classes

................................................................................................................. 51 3.6.1 Battery Charger Product Classes

............................................................................. 51 3.6.2 External Power Supply Product Classes

.................................................................. 52 3.7 Technology Options for Efficiency Improvement

............................................................ 57 3.7.1 Battery Charger Technology Options

...................................................................... 57 iv3.7.2 External Power Supply Technology Options

........................................................... 59 4 SCREENING ANALYSIS

................................................................................................... 59 5 ENGINEERING ANALYSIS

............................................................................................... 61 5.1 Engineering Analysis Overview

....................................................................................... 61 5.2 Representative Product Classes and Units

........................................................................ 63 5.2.1 Battery Charger Representative Units

..................................................................... 64 5.2.2 External Power Supply Representative Units

.......................................................... 64 5.3 Engineering Analysis Approach

....................................................................................... 65 5.4 Proprietary Designs

........................................................................................................... 67 5.5 Outside Regulatory Changes Aff ecting the Engineering Analysis

................................... 68 6 ENERGY USE AND END-USE LOAD CHARACTERIZATION

.................................... 68 6.1 Battery Charger Energy Use

............................................................................................. 69 6.2 External Power Supply Energy Use

.................................................................................. 71 6.2.1 EPS Usage Profiles

.................................................................................................. 71 6.2.1.1 EPS Modes and Application States

.................................................................... 71 6.2.2 EPS Power Consumption by Modes of Operation

................................................... 73 6.2.3 Calculating EPS Energy Use

................................................................................... 76 6.3 Off-Mode Energy Consumption

....................................................................................... 77 7 PRODUCT PRICE DETERMINATION

............................................................................. 78 8 LIFE-CYCLE COST AND PA YBACK PERIOD ANALYSES

......................................... 80 8.1 Life-Cycle Cost and Pa yback Period Methodology

.......................................................... 82 8.2 Life-Cycle Cost and Pa yback Period Inputs

..................................................................... 84 8.2.1 Electricity Prices

...................................................................................................... 85 8.2.2 Life-Cycle Cost Discount Rates

............................................................................... 86 8.2.3 BC and EPS Operational Lifetimes

......................................................................... 87 9 SHIPMENTS ANALYSIS

.................................................................................................... 89 9.1 Base Case Forecast

........................................................................................................... 89 9.2 Standards Impacts on BC and EPS Shipments

................................................................. 92 10 NATIONAL IMPACT ANALYSIS

..................................................................................... 93 10.1 Inputs to Forecasts

............................................................................................................ 93 10.2 Calculation of National Energy Savings

........................................................................... 95 10.3 Net Present Value

............................................................................................................. 96 11 LIFE-CYCLE COST SUBGROUP ANALYSIS

................................................................. 97 12 MANUFACTURER IMPA CT ANALYSIS

......................................................................... 98 12.1 Sources of Information for the Manufacturer Impact Analysis

........................................ 98 12.2 Industry Cash-Flow Analysis

............................................................................................ 99 12.3 Manufacturer Subgroup Analysis

..................................................................................... 99 12.4 Competitive Impacts Analysis

........................................................................................ 100 12.5 Cumulative Regulatory Burden

...................................................................................... 100 13 UTILITY IMPACT ANALYSIS

........................................................................................ 101 14 EMPLOYMENT IMPACT ANALYSIS

............................................................................ 102 15 ENVIRONMENTAL ASSESSMENT

............................................................................... 103 16 REGULATORY IMPACT ANALYSIS

............................................................................. 106 APPENDIX A – EPCA DIRECTIVES REGARDING BATTERY CHARGERS AND EXTERNAL POWER SUPPLIES

............................................................................................. 108

vAPPENDIX B – DEFINITIONS

................................................................................................ 114 APPENDIX C – TEST PROCEDURES

..................................................................................... 116 APPENDIX D – ENERGY INDEPENDE NCE AND SECURITY ACT OF 2007

................... 119 APPENDIX E – LIST OF ITEMS FOR COMMENT

................................................................ 126 APPENDIX F – OTHER MANDATORY AND VOLUNTARY ENERGY-EFFICIENCY STANDARDS FOR BCEPS

....................................................................................................... 131 F.1 United States – ENERGY STAR for BC and ENERGY STAR Tier I (V1.1) and Tier II (V2.0) for EPS

........................................................................................................................ 131 F.2 Australia and New Zealand – Minimum Ener gy Performance Standards (MEPS) AS/NZS 4665:2005

............................................................................................................................... 132 F.3 Canada – C381.1 for EPS and C381.2 for BC

................................................................ 134 F.4 China – China National Institute of Sta ndardization (CNIS) and China Standard Certification Center (CSC) Standards

..................................................................................... 135 F.5 European Union—Code of Conduct on Efficiency of External Power Supplies, EU Standby Initiative

.................................................................................................................... 136 F.6 European Union—Eco-design of Energy-usi ng Products (EuP) Init iative, Directive 2005/32/EC

............................................................................................................................. 138 F.7 EU (Subset of Member Countries)

 Group for Energy Efficient Appliances

............... 140 F.8 Israel – SI 4665.2 (AS/NZX 4665.2-2005)

..................................................................... 140 F.9 Korea – e-Standby Program

............................................................................................ 141

LIST OF TABLES
Table 1.1. Rulemaking Schedule for BC and EPS Energy Conservation Standards

...................... 6 Table 3.1. Treatment of Different Types of Wa ll Adapters That Power a Battery Charging

Table 3.2. Treatment of Different Types of Wa ll Adapters That Power a Battery Charging

Table 3.3. The Answers to the Key Questions Are Co mbined to Form Four Distinct Approaches

Table 3.4. Comparison of the Four Approaches to Interpreting the BC and EPS Definitions System Spending on the Answer to the First Key Question

......................................................... 2 2

System Depending on the Answer to the Second Key Question

.................................................. 2 3

to Dealing with Wall Adapters That Power Battery Charging Systems

....................................... 2 3

Against Desirable Characteristics

.............................................................................................. ... 3 7 Table 3.5. BC-Powered Applications fo r Which DOE Has Shipment Data

................................. 4 3 Table 3.6. EPS-Powered Applications for Which DOE Has Shipment Data

............................... 4 3 Table 3.7. Battery Charger Product Classes Devel oped for the Draft Determination Analysis

... 5 2 Table 3.8. EISA Efficiency St andards for Class A EPSs

............................................................. 5 3 Table 3.9. ENERGY STAR Version 2.0 Active-Mode EPS Product Classes

.............................. 5 4 Table 3.10. ENERGY STAR Version 2.0 No -Load-Mode EPS Product Classes

........................ 5 4 Table 3.11. Product Classes Used in the EPS Determination Analysis

........................................ 5 6 Table 5.1. Representative Unit Charac teristics for Battery Chargers

........................................... 6 4 Table 5.2. Representative Unit Characteristics Used for External Power Supplies

..................... 6 5 Table 6.1.Summary of EPS Modes

............................................................................................... 7 2 Table 6.2. Usage and Output Power of 40 W EPS for Inkjet Co mputer Printer

........................... 7 3 Table 7.1. BC Manufacturer-to-Consumer Markups

.................................................................... 7 9 Table 7.2. EPS Manufacturer-to-Consumer Markups

.................................................................. 8 0 Table 8.1. Draft Inputs to the Life-Cycle Cost and Payback Period Analyses

............................. 8 5 viTable 8.2. Shares and Interest or Return Rates Used for Household Debt and Equity Types

...... 8 7

Table 9.3. Base Case Distributi on of BC Shipments Across Effici ency Levels by Product Group

Table 9.4. Base Case Distributi on of EPS Shipments Across Effi ciency Levels by Product Group

Table F.1. U.S. ENERGY STAR Tier II for EPS Active-Mode Efficiency and No-Load Power:

Table F.2. U.S. ENERGY STAR Tier II for EPS Active-Mode Efficiency and No-Load Power:

Table F.4. Australia/New Zealand MEPS Levels for EPS Active-Mode Efficiency and No-Load

Table F.5. Australia/New Zealand High Efficiency Level IV for EPS Active-Mode Efficiency

Table F.6. Australia/New Zealand High Efficiency Level V for EPS Active-Mode Efficiency and

Table F.8. CSC Levels for Active-Mode Effi ciency and No-Load Power (Same as ENERGY

Table F.9. EU Code of Conduct Version 2 Standards for EPS Active-Mode Efficiency and NoTable F.10. EU Code of Conduct Version 3 Standards for EPSs Excluding Cellular Telephone

Table F.11. EU Code of Conduct Version 3 Stan dards for Cellular Telephone Adapters with

Table F.14. GEEA Levels for EPS and “Portable Personal Equipment” Active-Mode Efficiency Table 8.3. Shipment-Weighted Average Lifetimes for Battery Chargers

.................................... 8 8 Table 8.4. Shipment-Weighted Average Lifetimes for External Power Supplies

........................ 8 8 Table 9.1. Battery Charger Shipments by Product Group in 2007

............................................... 9 0 Table 9.2. External Power Supply Shipments by Product Group in 2007

.................................... 9 0

in 2007

.......................................................................................................................................... 9 0

in 2007

.......................................................................................................................................... 9 1 Table 9.5. Base Case Shipments Gr owth Rates for BCs and EPSs

.............................................. 9 2 Table 10.1. Inputs to the Na tional Impact Analysis

...................................................................... 9 5 Table 12.1 National and Internat ional Voluntary and Regulator y Programs for BCs and EPSs 1 01

Standard Models

................................................................................................................ ......... 1 31

Low-Voltage Models

............................................................................................................. ..... 1 32 Table F.3. ENERGY STAR Specifications fo r BC Maximum Nonactive Energy Ratio

........... 1 32

Power

.......................................................................................................................................... 1 33

and No-Load Power

.................................................................................................................... 1 34

No-Load Power

........................................................................................................................... 1 34 Table F.7. CNIS MEPS for Active-Mode Efficiency and No-Load Power

................................ 1 36

STAR Tier 1)

.............................................................................................................................. 1 36

Load Power

................................................................................................................................. 1 37

Adapters with Nameplate Output Power ≤ 8 Watts

.................................................................... 1 38

Nameplate Output Power ≤ 8 Watts

........................................................................................... 1 38 Table F.12. EuP Version 1 Levels for EPS Ac tive-Mode Efficiency and No-Load Power

....... 1 39 Table F.13. Version 2 Levels for EPS Activ e-Mode Efficiency and No-Load Power

............... 1 39

and No-Load Power

.................................................................................................................... 1 40 Table F.15. SI 4665.2 Levels for EPS Active- Mode Efficiency and No-Load Power

............... 1 41 Table F.16. e-Standby Program Levels for EPS Active-Mode Efficiency and No-Load Power 1 42 Table F.17. e-Standby Program Levels for Ce llular Telephone Charger No-Load Power

......... 1 42

LIST OF FIGURES
Figure 2.1. Analyses Conducted for an Ener gy Conservation Standard Rulemaking

.................. 1 0 Figure 3.1 Example of a Wall Adapter and a De sktop Adapter, Treated Together as “Wall Adapters”

...................................................................................................................................... 1 3 viiFigure 3.2 Example of a Cr adle and a Charging Base

................................................................. 1 4

Figure 3.4. Examples of the Three Categories of Products DOE is Considering for Inclusion in

Figure 3.6. Charge Control Circuitr y Required for Battery Charging Can Be Contained in (a) the

Figure 3.7. The Same Wall Adapter Can Be Used for Both BC and EPS Functions, Depending

Figure 3.8. Configurations of Po wer Conversion and Battery Char ging Functions in Consumer

Figure 3.9. Configurations of Po wer Conversion and Battery Char ging Functions in Consumer

Figure 3.10. Comparison of How Va rious Battery Charging Systems Would Be Treated Under Each of the Four Approaches. The charge cont rol function can be spli t between enclosures. Enclosures covered by the “overl ap” would be considered to be subject to both BC and EPS

Figure 3.11. EPA ENERGY STAR Di vision Between Products Qualifying Under the EPS and Figure 3.3 Examples of Batteries

............................................................................................... ... 1 4

This Rulemaking

........................................................................................................................... 1 5 Figure 3.5 Examples of USB ports.

.............................................................................................. 1 8

Cradle or Charging Base, or (b) the Wall Adapter

....................................................................... 1 9

on Which Portion of Its Current-Volta ge (I–V) Curve It Is Operating

......................................... 2 0

Products

....................................................................................................................... .................. 2 5

Products (Continued)

.................................................................................................................... 2 6

standards.

...................................................................................................................................... 2 7

BC Specifications. This division is similar to that under consideration in Approach B.

............. 3 1 Figure 3.12. BC and EPS Distribution Networks

......................................................................... 4 1 Figure 6.1. DIY Power Tool Weekly Usage Profile in Hours

...................................................... 7 1 Figure 6.2. Example Measurements fr om an EPS Test Procedure

............................................... 7 4 Figure 6.3. Relationship Between EPS Input Power and Output Power at Five Loading Points. 7 5 Figure 7.1. BC and EPS Distribution Networks

........................................................................... 7 8 Figure 8.1. Flow Diagram of Inputs for the Determination of LCC and PBP

.............................. 8 3 Figure 8.2. AEO 2007 Residential Electricity Price Trend Forecast

............................................ 8 6

viiiLIST OF ACRONYMS AND SYMBOLS

AC alternating current A ampere Ah ampere-hour AEO Annual Energy Outlook AHAM Association of Home Appliance Manufacturers BC battery charger BOM bill of materials BT Building Technologies Program CAIR Clean Air Interstate Rule CAMR Clean Air Mercury Rule CBECS Commercial Building En ergy Consumption Survey CEA Consumer Electronics Association CFR Code of Federal Regulations CO 2 carbon dioxide CSL candidate standard level DC direct current DIY do-it-yourself DOE U.S. Department of Energy DOJ U.S. Department of Justice DTR Draft Technical Report EERE Office of Energy Efficiency and Renewable Energy EIA Energy Information Administration (DOE) EISA Energy Independence and Security Act of 2007 EPA U.S. Environmental Protection Agency EPACT 2005 Energy Policy Act of 2005 EPCA Energy Policy and Conservation Act of 1975 EPS external power supply FR Federal Register GRIM Government Regulatory Impact Model Hg mercury IC Integrated Circuit ImSET Impact of Sector Energy Technologies LCC life-cycle cost MIA manufacturer impact analysis MSP manufacturer selling price NEMS National Energy Modeling System NES national energy savings NIA national impact analysis NOPR notice of proposed rulemaking NO x nitrogen oxides NPV net present value OEM original equipment manufacturer OMB U.S. Office of Management and Budget PFC Power Factor Correction

ixPTI Power Tool Institute RIA regulatory impact analysis SO 2 sulfur dioxide SWEF shipment weighted energy factor TSD technical support document TSL trial standard level UEC Unit Energy Consumption U.S.C. United States Code V volt W watt

x1 INTRODUCTION

The U.S. Department of Energy (DOE) App liance and Commercial Equipment Standards Program, within the Office of Energy Effi ciency and Renewable Energy’s Building Technologies Program (BT), develops and promul gates test procedures and energy conservation standards for consumer products and commercial equipment. As a general matter, the process for developing standards involves anal ysis, public notice, and consulta tion with interested parties. Such parties include manufacturers, consum ers, energy conservation and environmental advocates, State and Federal agenci es, and any other groups or indi viduals with an interest in these standards and test proce dures. A DOE report to Congress 1 issued on March 4, 2009, identifies the rulemakings DOE has scheduled for completion by June 2011, including standards for, battery chargers (BCs) and external power supplies (EPSs). Th e report explains many of the techniques that DOE will apply during the rulemaki ng process to meet this schedule. In February 2008, DOE submitted a report to Congress 2 on appliance energy-efficiency rulemakings that sets forth DOE’s understanding of the new requi rements under the Energy Independence and Security Act of 2007 (EISA).

This Framework Document describes the proce dural and analytical approaches that DOE anticipates using to evaluate energy conserva tion standards for BCs and EPSs. (See section 1.1 below for a discussion of the statutory authority for this rulemaking.) With this document, DOE intends to inform interested parties of the process DOE will follow for the standards rulemaking for these products, and to enc ourage and facilitate input from interested parties during the rulemaking. DOE views this document as a starting point for developing sta ndards, and not as a definitive statement about any issue to be determined in the rulemaking.

Section 1 provides an overview of DOE ’s rulemaking process and background, and context for DOE’s work on BCs and EPSs. S ections 2 through 16 discuss DOE’s proposed analyses to fulfill the statutory requirements and guidance for this particular standards rulemaking. DOE will conduct separate analyses for BCs and EPSs to determine whether new or amended energy conservation standards are technol ogically feasible and economically justified, and would result in significant energy savings . DOE will maintain information about these rulemakings on its website, www.eere.energy.gov/buildings/appliance_standard s/residential/battery_external.html.

1 U.S. Department of Energy. Energy Conservation Standards Activities; Submitted Pursuant to Section 141 of the Energy Policy Act of 2005 and to the Conference Report (109-275) to the FY 2006 Energy and Water Development Appropriations Act. Jan. 31, 2006. Available at www1.eere.energy.gov/buildings/appliance_standards/ pdfs/congressional_report_013106.pdf.
2 U.S. Department of Energy. Implementation Report: Energy Conservation Standards Activities; Submitted Pursuant to Section 141 of the Energy Policy Act of 2005 & Section 305 of the Energy Independence and Security Act of 2007 . February 2008. Available at www1.eere.energy.gov/buildings/appliance_standards/pdfs/ congressional_report_0208.pdf.

1Although DOE seeks comments on all aspects of th e material presented in this document, specific issues are highlighted in comment boxes. DOE uses these comment boxes to ask questions about its proposed approaches for c onducting the analyses required for the standards rulemaking. Requests for feedback are numbered sequen tially throughout the document and are repeated in appendix E.

1.1 The Appliance and Commercial Equipment Standards Program
Title III of the Energy Policy and Co nservation Act (EPCA) (42 U.S.C. 6291, et seq .) sets forth a variety of provisions designed to improve en ergy efficiency. Part A of Title III (42 U.S.C. 6291–6309) establishes the “Energy Conservation Program for Consumer Products Other Than Automobiles.” The consumer products subject to this program (referred to as “covered products”) include BCs and EPSs. Section 135 of the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58, amended sections 321 and 325 of EPCA by inserting definitions for battery chargers and external power supp lies and directing the Secretary of Energy to carry out three activities: (1) establis h test procedures, (2) hold a scopi ng workshop to discuss plans for developing energy conservation st andards, and (3) conduct a dete rmination analysis for energy conservation standards for BCs and EPSs. (42 U.S.C. 6295(u))

DOE complied with the first of these require ments by publishing the test procedure final rule, 71 FR 71340, on December 8, 2006. This rule included definitions and test procedures for BCs and EPSs. DOE codified a te st procedure for BCs in Titl e 10 of the Code of Federal Regulations (CFR), Part 430, Subpart B, Appendi x Y (“Uniform Test Method for Measuring the Energy Consumption of Battery Chargers”) and a test procedure for EPSs in 10 CFR Part 430, Subpart B, Appendix Z (“Uniform Test Method for Measuring the Energy Consumption of External Power Supplies”).

Complying with the second requirement, DOE then published a notice of public meeting and availability of documentation for public review on December 29, 2006. 71 FR 78389. DOE made two documents available on its website: Plans for Developing Energy Conservation Standards for Battery Charge rs and External Power Supplies and The Current and Future Market for Battery Charge rs and External Power Supplies . The public meeting, called a “Scoping Workshop,” was held at DOE’s Forrest al Building in Washington, DC, on January 24, 2007. As EPACT 2005 required, the workshop focuse d on DOE’s plans for developing energy conservation standards for BCs and EPSs. Info rmation pertaining to the Scoping Workshop is available on DOE’s website at www.eere.energy.gov/buildings/appliance_standa rds/residential/battery_external.html

. Regarding the third requirement, on December 19, 2007, EISA, Pub. L. 110-140, was enacted, amending sections 321, 323, and 325 of EPCA . These amendments required significant changes to the determination analysis DOE had been conducting. Sections 301, 309, and 310 of EISA made several changes to EPCA related to BCs and EPSs.

First, section 301 of EISA modified some of the definitions pertaining to EPSs. EPACT 2005 defined an EPS as “an external power suppl y circuit that is used to convert household

2electric current into DC current or lower-voltage AC current to operate a consumer product.” (42 U.S.C. 6291(36)(A)) Section 301 of EISA retained that definition, but created a subset of EPSs called Class A External Power Supplies. By the definition introduced by EISA, these devices are “able to convert to only 1 AC or DC output voltage at a time” a nd have “nameplate output power that is less than or equal to 250 watts.” (42 U.S.C. 6291(36)(C)(i)) Section 301 of EISA further amended EPCA by establishing standards for Clas s A EPSs, effective July 1, 2008, and directing DOE to conduct two successive rulemakings to review, and consider amending, the energy conservation standards for EPSs, the first of wh ich is required to be completed by July 1, 2011.

Second, section 309 of EISA amended section 325(u)(1)(E) of EPCA, instructing DOE to issue no later than two years afte r EISA's enactment a final rule determining whether to issue energy conservation standards for external power supplies or classes of ex ternal power supplies. (42 U.S.C. 6295(u)(1)(E)(i)(I)) However, DOE cannot conduct a determination analysis on whether it should issue conserva tion standards for a product for which standards have already been set by Congress in s ection 301(c) of EISA ( i.e. , Class A external power supplies). Furthermore, section 325(u)(1)(E) of EPCA, as amended by EISA, di rects DOE to complete this determination analysis ‘‘No later than 2 years afte r the date of enactment of this subsection.’’ (42 U.S.C. 6295(u)(1)(E)(I)) This subs ection, however, is a re sult of EPACT, wh ich was signed into law on August 8, 2005. Interpreting this subsection strictly as ame nded by EISA would place the determination analysis final rule issue date on August 8, 2007, more than four months prior to the passage of EISA.

To resolve these inconsistencies, DOE inte rprets the ‘‘date of enactment of this subsection’’ (42 U.S.C. 295(u)(1)(E)(I)) as the date of passage of EISA, namely December 19, 2007. In this context, DOE interprets sections 301 and 309 of EISA jointly as a requirement to determine, by December 19, 2009, whether energy conservation standards shall be issued for EPSs that are covered, but are not classified as Class A external power supplies. Examples of these EPSs include those with nameplate output power greater than 250 watts , those that are able to convert to more than one AC or DC output vol tage at the same time, and those excluded from coverage under Class A External Power Supplies ( e.g. , medical devices). Section 309 also required DOE to issue a final rule prescrib ing energy conservation standards for BCs, if technologically feasible and economically justified, by July 1, 2011. (42 U.S.C. 6295(u)(1)(E)(i)(II))

Finally, section 310 of EISA established defi nitions for active mode, standby mode, and off mode, and directs DOE to amend its existi ng test procedures for both BCs and EPSs to measure the energy consumed in standby mode and off mode. (42 U.S.C. 6295(gg)(2)(B)(i)) DOE satisfied this requirement by publishing a fina l rule that incorporat ed standby and off mode measurement into the DOE test procedure. 74 FR 13318 (March 27, 2009). It also amended the definitions of standby mode and off mode to be tter adapt them to how consumers use battery chargers and external power supplies.

The above discussion summarizes the pertinent legislative and regulatory history for BCs and EPSs. It sets the stage for the issues raised in the balance of this framework document, which initiates an energy conservation standards rule making for BCs and EPSs, to be completed by July 1, 2011, as required by EISA. (42 U. S.C. 6295(u)(1)(E)(i)(II) and 42 U.S.C.

36295(u)(3)(D)(i)) In this rulemaking, DOE will consider setting new standards for BCs and will consider amending existing standa rds for Class A EPSs, consiste nt with sections 309 and 301, respectively, of EISA. When setting any new standard, DOE will also consider the energy consumed in standby mode and off mode for thes e products consistent with EPCA, as amended by section 310 of EISA. See appe ndix B for the statutory definitions of BCs, EPSs, and Class A EPSs.

1.2 Overview of the Rulemaking Process

1.2.1 Test Procedures
EPACT 2005 directed DOE to establish te st procedures for BCs and EPSs. DOE complied with this requirement by publishing the test procedure fi nal rule, 71 FR 71340, on December 8, 2006, which included definitions and test procedures for BCs and EPSs.

As noted above, EISA further amended EP CA by defining active mode, standby mode, and off mode. EISA also directed DOE to amend its existing test procedures for both BCs and EPSs to measure the energy consumed in sta ndby and off modes. To comply with this requirement, DOE published a notice of pr oposed rulemaking (NOPR) on August 15, 2008, 73 FR 48054. In that NOPR, DOE also proposed a new test procedure to help with the determination analysis require d under section 325(u)(1)(E)(i)(I) of EPCA, as amended by EISA. (42 U.S.C. 6295(u)(1)(E)(i)(I)) This test proc edure would provide a method for measuring the standby mode, off mode, and average e fficiency of multiple-voltage EPSs.

Following a public meeting held on Septem ber 12, 2008, and after receiving comments from interested parties, DOE published a fina l rule on March 27, 2009. 74 FR 13318. In the final rule, DOE amended its test procedures for BCs and EPSs to include provisions for measuring standby-mode and off-mode energy consumpti on. However, due to the limited time provided by EISA and limited resources available prior to th e publication of this fi nal rule, DOE was unable to address the large number of stakeholder comments received on some of the other aspects of the NOPR and decided to defer action on these issu es and the incorporation of multiple-voltage EPSs to a later rulemaking that will address ch anges to both the BC and EPS test procedures.

1.2.2 Rulemaking Process and Interested Party Participation When DOE evaluates any new or amended energy conservation standard for “covered products,” EPCA, as amended, specifies that any standard DOE prescribes for consumer products shall be designed to “achieve the maxi mum improvement in energy efficiency . . . which the Secretary [of Energy] determines is technologically feasible and economically justified.” (42 U.S.C. 6295(o )(2)(A)) Moreover, EPCA states that the Secretary may not establish an amended standard if such standard will not result in a “significant conservation of energy,” or “is not technologica lly feasible or economically ju stified.” (42 U.S.C. 6295(o)(3)(B)) In determining whether a standa rd is economically justified, DOE considers, to the greatest extent practicable, the following seven f actors (42 U.S.C. 6295(o)(2)(B)(i)):

4(1) the economic impact of the standard on the manufacturers and on the consumers of the products subject to such standard; (2) the savings in operating costs throughout th e estimated average life of the covered products in the type (or class) compared to any increase in the price, or in the initial charges for, or maintenance expe nses of, the covered products which are likely to result from the imposition of the standard; (3) the total projected amount of energy (or, as applicable, water) savings likely to result directly from the imposition of the standard; (4) any lessening of the utility or the perfo rmance of the covere d products likely to result from the imposition of the standard; (5) the impact of any lessening of compe tition, as determined in writing by the Attorney General, that is likely to result from the imposition of the standard; (6) the need for national energy and water conservation; and (7) other factors the Secretary considers relevant.

Additional statutory requirements for prescr ibing new or amended standards are set forth in 42 U.S.C. 6295(o)(1)–(2)(A), (2 )(B)(ii)-(iii), and (3)–(5).

The process for developing new or amende d energy conservation standards involves analysis, public notice, and cons ultation with interested parties. Such parties generally include manufacturers, consumers, energy conservation and environmental advocates, State and Federal agencies, and any other groups or individuals with an interest in energy conservation standards and test procedures. DOE considers the participation of interested pa rties a very important part of the rulemaking process. The broad array of inte rested parties who rou tinely provide comments during this process promotes a balanced discus sion of critical information required to conduct the standards rulemaking. Accordingly, DOE encourag es the participation a nd interaction of all interested parties during the comment period provided at each stage of the rulemaking.

In conducting the test procedure rulemaki ngs and the energy (and water) conservation standards rulemakings, DOE involves interested parties through a variety of means, including formal public notifications ( i.e.
, Federal Register notices) and public meetings. As discussed in further detail below, the sta ndards rulemaking process involves a prelim inary publication of analyses on the Department’s website, and two major public notices, which are published in the Federal Register . The publication of the preliminary analyses as well as the NOPR will be accompanied by public meetings to solicit comment from interested parties to guide the rulemaking process.

 Preliminary publication of analyses and public meeting (section 1.3): The preliminary publication of analyses and pub lic meeting is designed to obtain public review of the models and tools that DOE w ill use in the rulemaking and to facilitate public participation before the proposed rule stage. Candidate standard levels (CSLs), which span the range of efficiencies from baseline products to the most efficient technology, are the basis for demonstrating th e functionality of the models and tools. 3

3 In the past DOE issued an Advanc e Notice of Propo sed Rulemaking (ANOPR) following publication of the framework document. The Energy Independence and Security Act of 2007 eliminated the requirement that DOE issue ANOPRs as part of the standards rulemaking proces s, see EISA, at sec. 307. DOE is now using an alternate

5 NOPR (section 1.4): The NOPR presents a discussion of comments received in response to the preliminary analyses; DOE’s analysis of the impacts of standards on consumers, manufacturers, and the nation; DOE’s weighing of those impacts; and the proposed standard levels for public comment.

 Final rule (section 1.5): The final rule presents a discussion of comments received in response to the NOPR, the revised analysis of the impacts of standards, DOE’s weighting of the impacts, and the standard levels DOE is adopting. The final rule also establishes the effective date of the standards.

DOE has prepared and intends to follow the schedule below for the BC and EPS energy conservation standards rulemaking.

Table 1.1. Rulemaking Schedule for BC and EPS Energy Conservation Standards

Rulemaking Notice Publication Date
Framework Document May 2009 Preliminary Analyses Public Meeting Notice March 2010
NOPR December 2010
Final Rule July 1, 2011 (EISA Deadline)

Any amended standards for Class A EPSs prom ulgated by the Final Rule would apply to products manufactured on or after July 1, 2013. ( 42 U.S.C. 6295(u)(3)(D)(i)) A compliance date for new BC standards has not yet been es tablished since EISA did not set one.

1.3 Pre-Rulemaking Analyses and Other Activities
DOE’s initial pre-rulemaking activity typi cally includes identif ying product technology options and determining whether they warrant detailed analysis or can be eliminated from further consideration. This process in cludes a market and technology assessment (section 3) and a screening analysis (section 4). DOE applies four criteria in the screening analysis to determine which technology options to eliminate from furt her consideration: tec hnological f easibility; practicability to manufacture, in stall, and service; adverse impacts on product utility or availability; and adverse impact s on health or safety. DOE calls technologies that pass the screening analysis “desig n options,” and considers them in th e engineering analysis as methods of improving the efficiency of the covered products.

Also in the pre-rulemaking st age of the analysis, DOE collects manufacturer cost data, historical shipment data, shipment-weighted average efficiency data, and preliminary manufacturer impact data ( e.g. , capital conversion e xpenditures, marketing costs, and research and development costs). Given these data, and th e efficiency levels achievable by the design options developed earlier, DOE estimates the impact of potential standards on individual

process to provide the same information and opportun ity for public comment as the ANOPR, but without publication of analyses in the Federal Register

.

6consumers and the Nation as a whole. These cal culations are contained within the following analyses, explained in subsequent s ections of this framework document:

 the engineering analysis (section 5);

 the consumer life-cycle cost (LCC) and pa yback period (PBP) analyses (section 8);

 the national impact analysis, which cons iders national energy savings (NES) and national consumer net present value (NPV) (section 10); and

 a preliminary manufacturer imp act analysis (section 12).

DOE will present the results of these analyses in a technical support document (TSD) to be published prior to the NOPR stage of the ru lemaking. The preliminary TSD, which will be made available on the Department’s website, will be followed by a preliminary analyses public meeting. A meeting agenda, presentation slides , and an executive su mmary highlighting the issues on which DOE seeks comment will accompany the TSD on the website. DOE will publish a notice announcing the avai lability of the materials and the meeting in the Federal Register

. Discussion of various CSLs in the prelimin ary TSD will facilitate review by interested parties of the spreadsheet models that underpin the analyses. DOE will use these comments to refine the models for the NOPR stage of th e rulemaking analyses, where DOE will propose specific efficiency levels for adoption. Based on the results, DOE selects CSLs from the energyefficiency or energy-use levels considered in the preliminary analyses. In addition to the efficiency levels corresponding to the maxi mum technologically f easible (“max-tech”) 4 design and the minimum LCC point, DOE generally select s for consideration levels or design options that span the full range of technologically achie vable efficiencies. DOE typically analyzes the following CSLs:

 the baseline CSL ( i.e. , the minimum level) is repr esented by the product with the lowest energy-efficiency level currently sold on the market for a given product class; for classes where energy-efficiency standard s already exist, the baseline efficiency level is typically defined by the ex isting energy conservation standard;

 the highest CSL or lowest energy consumpti on level that is technologically feasible ( i.e.
, the “max-tech” level);

 the level with the minimum LCC or greatest LCC savings; and

 levels that incorporate noteworthy technologi es or fill in large gaps between other CSLs considered.

In the preliminary analyses DOE uses analytical models and tools to assess the different product classes at each efficiency or energy use level analyzed. Ma ny of these analytical models and tools are in the form of spreadsheets, some of which DOE uses to conduct the LCC and PBP analyses and to determine the NES and NPV of prospective standards. Preliminary results may

4 The “max tech” represents the mos t efficient design that is commercialized or has been demonstrated in a prototype with materials or technologies available today. “Max tech” is not constraine d by economic justification, and typically is the most expensive design option considered in the engineering analysis.

7facilitate discussions among interested parties on potential joint recommendations for standard levels.

In addition to the other materials mentione d above, DOE will make the spreadsheet tools used for the preliminary analyses available on it s website for review and will consider comments after the public meeting. 5 DOE will provide a 60-day public comment period following the publication of the preliminary anal yses notice. At that point, DOE encourages interested parties to develop joint recommendations for sta ndard levels to the extent possible.

1.4 Notice of Proposed Rulemaking
In developing the NOPR, DOE will first review and consider all the comments it receives after the public meeting. This process may result in revisions or refinements to the preliminary analyses, including the engineering and LCC analyses. DOE will also conduct additional economic and environmental impact analyses at this stage of the rulemaking. These analyses generally include a consumer LCC subgroup anal ysis (section 11), a complete manufacturer impact analysis (section 12), a utility impact analysis (section 13), an employment impact analysis (section 14), an environm ental assessment (section 15), and a regulatory impact analysis (section 16).

DOE will describe the methodology used and make the results of all the analyses available on its website for review and comments. Based on comments from interested parties, DOE may further revise the analyses. This anal ytical process ends with the selection of a proposed standard level (if any) for each produc t class that DOE will pr esent in the NOPR. DOE selects the proposed standard levels from the tr ial standard levels (TSLs) analyzed during the NOPR phase of the rulemaking, equivalent to the CSLs analyzed dur ing the preliminary analyses. The NOPR, published in the Federal Register , will document the evaluation and selection of any proposed standard s levels, along with a discussion of other TSLs considered but not selected, including the r easons for not selecting them.

In selecting proposed efficien cy standards, DOE generally first identifies the max-tech efficiency level. If DOE proposes a level lower than that, it will explain sequentially the reasons for eliminating each higher level, beginning with the highest level considered. DOE will present the analytical results in the NOPR, with the deta ils of the analysis provided in an accompanying TSD.

DOE considers many factors in selecting pr oposed standards, as described above in section 1.3. These factors and the associated criteria are specified in EPCA and consider the benefits, costs, and impacts of energy conser vation standards. Additi onally, DOE encourages interested parties to develop joint recommendations for standard levels. DOE will carefully consider such recommendations in its decision process.

When DOE publishes the NOPR, it will provide the Department of Justice (DOJ) with copies of the NOPR and TSD to solicit feedback on the impact on competition that the proposed

5 All materials associated with the b attery chargers and ex ternal power supplies rulemakings are available on DOE’s website at www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external.html

.

8standard levels would have. DOJ will review thes e standard levels in light of any lessening of competition that is likely to result from the imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) Publication of the NOPR will be followed by a public meeting and a 60-day public comment period.

1.5 Final Rule
After the publication of the NOPR, DOE will consider public comments that it receives on the proposal (including TSLs) and accompanying analyses. On the basis of the public comments, DOE will review the engineering and economic impact analyses and proposed standards and consider modifications where nece ssary. Before issuing the final rule, DOE will also consider DOJ comments on the impacts of the proposed standard levels on competition to determine whether changes to these standard levels are needed.

The standards rulemaking will conclude with the publication of the final rule. DOE will select the final standard level based on the co mplete record of the standards rulemaking. The final rule will specify the final standard level an d its effective date and explain the basis for the selection. The final rule will be accompanied by a final TSD.

2 OVERVIEW OF ANALYSES FOR RULEMAKING

Analyses are conducted in support of the st andards rulemaking to ensure that DOE selects energy conservation standards that achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified, and will result in significant energy savings. Economic justificat ion includes the consideration of economic impacts on domestic manufacturers and consumer s, national benefits including environmental impacts, issues of consumer utility, and impacts from any lessening of competition. DOE expects the selection of such standards to achieve th e maximum energy savings that are economically justified without imposing an undue financ ial burden on any particular party.

Figure 2.1 summarizes the analytical component s of the standards-setting process. The analyses are presented in the cente r column. Each analysis has a se t of key inputs, which are data and information required for the analysis. The id entified approaches are the methods that DOE will use to obtain key inputs, which may vary depending on the information in question. DOE will collect other information from interested parties or experts with special knowledge and develop analyses and other information in s upport of this rulemaking. The results of each analysis are key outputs, which f eed directly into the rulemaking. Arrows indicate the flow of information among the various analyses. DOE ensu res a consistent approach to its analyses throughout the rulemaking by considering each analysis as a part of the ov erall standards-setting framework. DOE intends to conduct each of thes e analyses separately for BCs and EPSs.

9Appro ach es Ke yInputs Analy ses Ke y Outputs

Frame w ork Document ork Document

• C har acter i z e Ind u str y

• A nal y s i s of M a r k et D a t a • M a r k et Seg m ent ati o n

• No n

- Re gu la to ry P r o g ra m s • Iden ti f y Fi r m s/Pr oduc ts

• Histo rica l S h ipm e nts Market anMarket an d T e c hnol og y A s s ess men t • Pr oduct C l a sses

• T ec hnol og y Opti ons

• E f f i ci ency

- Lev el Appr o a ch

• Desig n Option Ap pr oa ch

• A ccoun ti ng Ap pr oach

• BackcastBackcast an d Forec a st

• Ma rke t S a t u ra t i on • Re ta il P r ice Co lle ction a n d A nal y s i s • A nal y s i s of En er g y U s e Da ta • A nal y s i s of Pr od uct D a ta ScreeninScreenin g A n a l y s is

Engine ering A n al y s is

Produc t Price D e t e r m in a t io n Life

- Cy cl e Co s t an d Pa y b ack Periack Peri od A n al y s es

Natio n al I m pac t An a l ys i s Energ y Us e

Shipments Shipments An a l ys i s • Pr oduct D e si g n s

• L i fe- C y c le Co sts

• Pay b ack Per i o d s

• N ati onal Ener g y Sav i ng s

• N e t Pr ese n t Val ues • Ener g y Pr i c es

• In sta lla ti o n Co s t s

• M a i n ten ance & R e pai r C o sts Desig n Options Pr oduct C l a sses

Re ta il Pr i c es De s i gn E n e r gy/ Us e • E f f i ci ency / Per f or manc e • C o m m er ci al Pr o ducts

C andi d ate Stan dar d

Lev el s T ec hnol og y Opti ons

• Desig n Options

• Ener g y Pr i c e For e cast s

• Si te

- to

- Sour ce F a ctor s • Ener g y
- E ff i c i ency Lev el s • InstallatiInstallati on Costs
• Ma in t Co s t s • Re p a i r Co sts • UE C

• Ener g y Pr i c es A nnu al E ner g y U s e ( U EC )

PreliminarPreliminar y Manuf act urer I m pac t An a l ys i s • M anu f ac t ur er Pr i c es

• A v e rag e Costs • C onv er si on C api tal Ex pen di tur e s

• D i r ect Emplect Empl oy ment Im pacts • Pr oduct Pr ot oty pes

Ener g y -Eff icie n c y Lev el s Product Desig n s

Advance Notice of Proposed Rulemaking (ANO) Publication of Preliminary Analyses

• M anu f ac t ur er I nter v i ew s

• GRIM Analy s is

• NE MS

- BT

• ImS E T • Stake hol d e r C o m m ent s

• D emog r ap hi cs

• M anu f ac t ur er Pr i c es

• A v e rag e Costs

• M anu f a c tur er Fi n anci a l D a ta

• Utility Load Factors Load Factors

• N ati onal Ener g y Sav i ng s

• N ati onal Ener g y Sav i ng s

• N a ti onal Pr od uct C o sts

• N a ti onal Oper a t i n g C o sts Revise Preliminary

Utilit y I m p act

An a l ys i s A n al y s es

Life

- Cy cl e Co s t Sub

- Grou p A n al y s is

Manuf act urer I m pac t An a l ys i s

Emplo y m e nt I m pact An a l ys i s TS L s

• Indus tr y C a sh Fl ow

• Sub

- Gr oup C a s h

- Flow

• D i r ect Emplect Empl oy ment Im pacts

• Co m p e t itiv e Imp a cts

• Cu m u lativ e Re gu la to ry B u rd en

• N ati onal Em pl oy men t I m pac t s D i r ect Emplect Empl oy men t Im p a cts

• Utility Im p a cts • L i fe- C y c le Co sts

• Pay b ack Per i o d s • T r i a l St and ar d Lev el s ( TS L s )

• NE MS

- BT • Em ission Rates

• N ati onal Ener g y Sav i ng s En v i ronmentalronmental A s s ess men t • Emi ssi on Esti mat e s

• No n

- Re gu la to ry A l t er nati v es Regul ator y I m p act An a l ys i s • N ati onal Ener g y Sav i ng s

• N e t Pr ese n t Val ues

Noti ce of Prce of Pr opose d Rul e mak i ng (NOPR) ng (NOPR)

• Stake hol d e r C o m m ent s • D epar t m en t o f Justi c e R e v i e w Re v ise A n al y se s • Re v i se d Re su lts

Fi nal Rule

Figure 2.1. Analyses Conducted for an Ener gy Conservation Standard Rulemaking

10Before the enactment of EISA, DOE was wo rking to determine whether it should set standards for BCs and EPSs, as required by EPACT 2005. In a separate draft technical report published in conjunction with this framework document, DOE presents the determination analysis that it had been developing for BCs and EPSs. DOE invites interest ed parties to review the draft technical report and pr ovide comments to DOE on all aspects of the draft analysis pertaining to the energy cons ervation standards rulemaking initiated by this framework document. All the major issues associated with th e analysis presented in the draft technical report are identified for comment by “Item” boxes thro ughout this framework document. The draft technical report provides more detail on th ese issues by characterizing DOE’s current understanding of the technology and market for BCs and EPSs, as well as the inputs and methods DOE proposes to use in its future analyses.

DOE developed the draft technical report, whic h is being made available in conjunction with this framework document, as part of the determination analysis on BCs and EPSs DOE is conducting under EPACT 2005. That determination an alysis, however, was superseded by EISA, which modified its scope and schedule and initia ted rulemakings to consider new and amended standards for BCs and EPSs, respectively. The public ation of the draft techni cal report, therefore, represents a special case, and should not be c onstrued as setting a precedent for future DOE action in conjunction with the public ation of a framework document.

Item 1 DOE invites interested parties to revi ew the draft technical report published in conjunction with this framework documen t and to provide comments on the analytical structure, inputs, and method DOE followed.

3 MARKET AND TECHNOLOGY ASSESSMENT

The market and technology assessment will provide information about BC and EPS manufacturers and specifics about the performance attributes of BCs and EPSs. This assessment is particularly important at the outset of the rulemaking for developing product classes and identifying technology options that improve the efficiency of BCs and EPSs.

3.1 Definitions
A key issue in DOE’s BC and EPS rulemakings is the necessity for clear and distinct product definitions. DOE has taken several approaches in the past, but with the current rulemakings, the need for regulatory definitions ba sed on an interpretation of the EPCA statutory language is becoming more pressing. Therefor e, before discussing any analysis, DOE will review the current statutory definitions and discuss the pos sible interpretation of these definitions, with the goal of establishing regulatory definitions that provide greater clarity for interested parties.

113.1.1 Current Statutory Definitions Title III of EPCA (42 U.S.C. 6291, et seq. ) sets forth a variety of provisions designed to improve energy efficiency. Part A of Title II I (42 U.S.C. 6291–6309) establishes the “Energy Conservation Program for Consumer Products Other Than Automobiles.” 6 Section 135 of EPACT 2005, Pub. L. 109-58, amended sections 321 and 325 of EPCA, inserting definitions for BCs and EPSs into the list of covered products . Subsequently, Section 301 of EISA created a subset of EPSs designated as Class A. The relevant portions of these acts follow:
Battery Charger The term battery charger mean s a device that charges batteries for consumer products, including battery chargers embedded in ot her consumer products. (42 U.S.C. 6291(32))
External Power Supply The term external power supply means an exte rnal power supply circuit that is used to convert household electric current into DC curre nt or lower-voltage AC current to operate a consumer product. (42 U.S.C. 6291(36)(A))
Class A External Power Supply i. IN GENERAL- The term class A external power supply means a device that— I. is designed to convert line voltage AC input into lower voltage AC or DC output; II. is able to convert to only 1 AC or DC output voltage at a time; III. is sold with, or intended to be used with, a separate end-use product that constitutes the primary load; IV. is contained in a separate physical enclosure from the end-use product; V. is connected to the end-use product via a removable or hard-wired male/female electrical connection, cable, cord, or other wiring; and VI. has nameplate output power that is less than or equal to 250 watts. ii. EXCLUSIONS- The term class A external power supply does not include any device that— I. requires Federal Food and Drug Admini stration listing and approval as a medical device in accordance with sec tion 513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c); or II. powers the charger of a detachable batte ry pack or charge s the battery of a product that is fully or primarily motor operated. (42 U.S.C. 6291(36)(C))

Consumer Product The term consumer product means any article (o ther than an automobile, as defined in section 32901 (a)(3) of title 49) of a type— A. which in operation consumes, or is designed to consume, energy or water with respect to showerheads, faucets, water closets, and urinals; and B. which, to any significant extent, is dist ributed in commerce for personal use or consumption by individuals without regard to whether such article of such type is in fact distributed in commerce for personal us e or consumption by an individual, except

6 This part was originally titled Part B but it was redesignated Part A in the United States Code for editorial reasons.

12that such term includes fluorescent lamp ba llasts, general servic e fluorescent lamps, incandescent reflector lamps, showerheads, faucets, water closets, and urinals distributed in commerce for personal or co mmercial use or consumption. (42 U.S.C. 6291(1))
Detachable Battery The term detachable battery means a battery that is— A. contained in a separate enclosure from the product; and B. intended to be removed or disconnected fr om the product for recharging. (42 U.S.C. 6291(52))

3.1.2 Additional Definitions The following additional terms are used by DOE throughout this framework document to provide clarification and further describe components of BCs and EPSs:
Wall Adapter. DOE uses the term “wall adapter” to refer to any external power adapter ( Figure 3.1 ) that connects a cons umer product to the household el ectric supply (AC mains). Wall adapters, which consist of a power conversion circ uit housed in a plastic enclosure and typically connected to a product through an output cord, provide many func tions, the most important of which is safety. All wall adapters isolate th e consumer product from mains and reduce the voltage, thereby reducin g the risk of shock. 7

In addition to performing isolation and c onversion functions, wall adapters may also provide functions such as rectif ication (AC/DC conversion), voltage regulation, and/or control of the charge current from AC mains to the batt ery for safe charging. There are no distinguishing physical features ( e.g. , size, shape, etc.) that would allow an observer to determine the internal circuitry (and the corresponding functions) of a wa ll adapter. Furthermore, some adapters can provide different functions depending on their region of operation— i.e. , the output current and voltage at a particular time.

Wall Adapter Desktop Adapter Figure 3.1 Example of a Wall Adapter and a De sktop Adapter, Treated Together as “Wall Adapters”
Cradle or Charging Base. For many rechargeable consumer products, the battery may be charged using a “cradle” or “charging base” ( Figure 3.2). Some cradles and charging bases use a wall adapter in tandem, while others perform th e same power conversion and isolation functions, rendering wall adap ters unnecessary. Similar to wall adapters, cradles and charging bases have

7 A transformer within the adapter— which also serves to reduce the voltage level from the mains voltage of 120 V AC—passes power while blocking the direct electrical path between input and output.

13no distinguishing physical features that would allo w an observer to conclusively determine their internal circuitry and function.

Handheld vacuum cleaner cradle Power tool battery charging base (shown with wall adapter) (no wall adapter) Figure 3.2 Example of a Crad le and a Charging Base

Item 2 DOE welcomes comment from interest ed parties on differentiating between wall adapters and cradles. DOE also seeks comment on the type of circuitry (or lack thereof) typically contained in cradles.

Battery. For this rulemaking, DOE considers “ba tteries” to be one or more sealed electrochemical cells that provi de power to a consumer product, allowing it to operate while disconnected from AC mains. Products may use batteries in standard-size ( e.g. , AA, AAA, etc.) packages or non-standard, product-specific packag es. Batteries may also be packaged with additional circuitry to prevent ove rcharging, or to detect faults or charge status. Examples of batteries are illustrated in Figure 3.3.

Laptop battery Power tool battery pack Standard-size batteries pack shown with sub-C cell (not to scale) Figure 3.3 Examples of Batteries

Battery charging system. The term “battery charging system” refers to all the components necessary to charge and mainta in a battery, from the AC wall plug to the battery itself, and includes the wall adapter, cradle, and—if the ba ttery is integral to the consumer product—the product itself. Which parts of a battery charging sy stem are considered the battery charger (BC), and therefore subject to this standards rulemaking, depends on the interpretation of the BC definition, just as which wall adapters are consid ered EPSs depends on th e interpretation of the EPS definition. In other words, “BC” and “EPS” are regulatory terms subject to interpretation, while “battery charging system” a nd “wall adapter” are terms that describe physical objects. In the following discussion, care has been taken to distinguish between these regulatory and physical terms.

143.2 Scope of this Rulemaking
EPCA, as amended by EISA, requires DOE to conduct this standards rulemaking on BCs and Class A EPSs. However, the statutory definitions of these two terms leave substantial room for interpretation. Comments received from inte rested parties during the public meeting on the standby and off mode test procedure NOPR on September 12, 2008, emphasized that many interested parties were unsure how to classify their products. Specifically, because wall adapters are sometimes used with battery charging system s and because the definitions of BCs and EPSs are not mutually exclusive, it is unclear which portions of the system fall under the EPS and BC definitions, respectively.

To be clear, when a wall ad apter meeting the EPS definition powers any application other than a battery charging system, DOE c onsiders that device to be an EPS. Similarly, in cases where a battery charging system meets the BC definition, and does not use a wall adapter, DOE considers the entirety of the system to be a BC. Only in cases when a wall adapter powers a battery charging system is the situation ambiguous. These three cases are illustrated in Figure 3.4

.

Category Wall adapter not powering a battery

charging system (considered an EPS)
Example (a) Computer monitor with wall adapter Battery charging not powered by a wall adapter (considered a BC) (b) Universal charger for AA batteries Unclear how DOE should consider the wall adapter and battery charging

system components (c) Cell phone with wall adapter and battery

Illustration

Figure 3.4. Examples of the Three Categorie s of Products DOE is Considering for Inclusion in This Rulemaking

How DOE interprets this term will affect both this rulemaking and the scope of other rulemakings underway for BCs and EPSs described earlier in section 1. More immediately, DOE’s interpretation of Class A EPS will also aff ect which wall adapters are subject to the EISA Class A EPS standards that became effective on July 1, 2008. The following subsections will discuss possible interpretations of the BC and EPS definitions and the impact of these interpretations on energy conservation standards. 8

8 DOE outlined an interim approach to differentiating BCs and EPSs at the Scoping Workshop Public Meeting on Developing Energy Conservation Standards for BCEPS, on January 24, 2007. At that time, DOE indicated that it might review and revise this approach as well as consider whether devices serving both BC and EPS functions should be subject to both standards. The following subsections are intended to present this revision.

153.2.1 Wall Adapters That Do Not Power Battery Charging Systems As mentioned above, DOE considers wall adapte rs that meet the EPS definition and that do not power a battery charging system to be EP Ss. Furthermore, based on the EISA definition for Class A EPS (42 U.S.C. 6291(36)(C)), DOE considers a wall adap ter that meets the following conditions to fall within the scope of this rulemaking:

(1) Able to convert to only one AC or DC output voltage at a time; (2) Has nameplate output power that is le ss than or equal to 250 watts; and (3) Does not power: i. any device that requires Federal Food and Drug Administration listing and approval as a medical device in accordance with se ction 513 of the Federal Food, Drug, and Cosmetic Act; or ii. the charger of a detachable battery pack or charges the battery of a product that is fully or primarily motor operated.

EPSs excluded from the Class-A EPS definition (42 U.S.C. 6291(36)(C)) are not within the scope of this rulemaking, and will be covered in a separate rulemaking on non-Class A EPSs, as required by EISA. (42 U.S.C. 6295(u)(1)(E)(i)(I )) That separate rulemaking will determine whether energy conservation standards shal l be issued for four types of EPSs:

(1) Multiple-Voltage EPSs : These devices are able to conve rt to more than one AC or DC output voltage at a time. (2) High-Power EPSs : These devices have a nameplate output power greater than 250 watts. (3) Medical EPSs : These devices are used to power medical devices regulated by the Food and Drug Administration. (4) EPSs for Particular Battery Charging Applications : These devices provide power to battery chargers of detachable batterie s or batteries of prod ucts that are motor operated. The devices included in this type are heavily dependent on the interpretation of the BC and EPS defini tions chosen by DOE, as discussed in section 3.2.3.1.

While the first two types of non-Class A E PSs are easily understood, the exclusions for EPSs that power medical devices and particular battery charging applications are more nuanced. The former is explained in sect ion 3.2.1.1, the latt er, in section 3.2.3.1.

3.2.1.1 Medical EPSs

The definition of Class A EPS excludes, in relevant part, “any device that (I) requires Federal Food and Drug Administration listing an d approval as a medical device in accordance with section 513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c).” (42 U.S.C. 6291(36)(C)(ii)(I)) While this language may appear clear on its face, it ra ises a number of interpretive issues.

First, it is unclear wh ether the exclusion shoul d apply only to EPSs that are themselves listed as medical devices or also to EPSs that are components of listed medical devices. A literal

16reading of EPCA would exclude from Class A only those EPSs that are themselves medical devices. A search of the Food and Drug Administ ration’s (FDA) product classification database for “power supply,” however, shows that of th e approximately 1,700 types of medical devices, only one device might be an EPS—an auxiliar y power supply (ac or dc) for an external transcutaneous cardiac pacemaker.

However, there are several other types of medical devices that may have EPSs as components, for example, nebulizers and sleep therapy devices. These medical devices are tested, listed, and approved for use with specif ic EPSs, which must meet the safety standards codified in International Electrotechnical Co mmission (IEC) Standard 60601-1. Furthermore, once the medical device has been approved for use with the EPS, the EPS is not interchangeable and can be considered an integral part of the medical device. Thus, DOE interprets EPCA to also exclude from Class A those EPSs that power medical devices.

Second, the exclusion applies to devices that are required to be listed and approved under 21 U.S.C. 360c. Section 360c create s three classes of medical devi ces (Classes I through III), all of which are subject to the listi ng requirements of FDA regulations. Similarly, each class requires some level of approval by FDA, ranging fr om the filing of forms with the agency (such as 510(k) approval filings) to premarket approvals for devices intended for human use (as occurs with Class III medical devices, which pos e a higher degree of risk to users). 9

Each device covered under S ection 513 requires regulatory oversight by the FDA because of its impact on the public health. Since these devices play a vital ro le in helping to ensure public health, DOE believes that the exclusion crea ted by Congress was designed to prevent any adverse impact on the public with respect to the safety of these regulated devices. This concern is highlighted by DOE’s obligation under EPCA to c onsider the performance of a regulated product when subjected to a new standar d, as well as other factors that the agency considers relevant— such as the health and safety of the public, which could be put at risk by imposing limits on energy usage. (42 U.S.C. 6295(o)(IV) and (VII))

Accordingly, given the language provided by C ongress with respect to this exclusion and the criteria set out under EPCA, DOE believes that under the most reasonable interpretation, this exclusion applies to all EPSs that are Class I, II, and III medical devices or that are components of such devices.

Item 3 DOE requests comment from interested parties on its interpretation of the Class A EPS exclusion of medical EPSs.

3.2.2 Battery Charging Systems Not Powered by Wall Adapters According to its statutory definition, a BC is “a device that charges batteries for consumer products, including battery chargers embedded in other consumer products.” (42 U.S.C. 6291(32)) DOE considers all components of a system that meet this definition—but not

9 “Classify Your Medical Device,” Center for Devi ces and Radiological Health, U.S. Food and Drug Administration. www.fda.gov/cdrh/devadvice/313.html

.

17necessarily the wall adapter, discussed further in section 3.2.3—to be within the scope of this rulemaking on BCs and Class A EPSs.

3.2.2.1 DC-Powered Battery Charging Systems
DOE also intends to include within this ru lemaking battery charging systems that draw power from DC sources other than wall adapte rs. These DC sources include, for example, computer universal serial bus (USB) ports and automobile cigarette lighter receptacles. DOE believes these BCs are within the scope of th e rulemaking because the BC definition—unlike the EPS definition—does not specify that the device i nput power must be AC. Furthermore, these BCs are a type of product “other than an automo bile . . . which in operation consumes, or is designed to consume, energy”— i.e. , “electricity, or fossil fuels. ” (42 U.S.C. 6291(1) and (3))

A potential complication with including DC-power ed chargers arises in the case of wall adapters with a USB output, as shown in Figure 3.5(b). A USB-powered charger embedded in a portable device can draw power from either a computer ( Figure 3.5(a)) or one of these wall adapters. However, the USB output of this ad apter could not only power a battery charger embedded in, for example, a portable music player, but also a consumer product without a battery. If the USB wall adapter is not designed fo r a specific battery char ging system, but is sold as an after-market accessory, DOE proposes to tr eat it as a wall adapter that does not power a battery charging system ( i.e. , an EPS). If, however, it is pack aged and sold together with a battery charging system, DOE proposes to treat it as a wall adapter for that system, according to one of the approaches presented in section 3.2.3.

(a) USB port on a laptop (b) USB port on a wall computer adapter Figure 3.5 Examples of USB ports.

Item 4 DOE seeks comments on including DC-powered battery chargers within the scope of the BC standards analysis.

3.2.3 Battery Charging Systems Powered by Wall Adapters The current definitions for BCs and EPSs are not mutually exclusive. This fact becomes problematic when wall adapters (which can be co nsidered EPSs) are a part of battery charging systems. While some of these wall adapters are electrically equivalent to wall adapters that power non-battery charging applications, others operate differently by providing additional functions necessary for battery charging.

18These additional functions in clude current and temperatur e sensing, timing, and current limiting, all of which are include d in battery charging systems for safety reasons. When manufacturers decide to use a wall adapter to perform the power conversion for a battery charging system, they may also sh ift some of these charge contro l functions to the wall adapter, as illustrated in Figure 3.6.

Figure 3.6. Charge Control Circuit ry Required for Battery Char ging Can Be Contained in (a) the Cradle or Charging Base, or (b) the Wall Adapter

Wall adapter constant-voltage (CV) sources perform only AC/DC conversion functions, converting mains power at 120 volts AC to low-vol tage DC power suitable for the safe operation of electronic products. Constant-vo ltage sources provide a fixed vo ltage regardless of the current drawn by the end-use product load (as long as the current remains within the specified region of operation and given some imperfections due to regulation— i.e. , the dependence of output voltage on load current).

Wall adapter constant-current (CC) sources also operate at low DC voltages; however, their output characteristics are oppos ite those of constant-voltage sources. Rather than provide a fixed voltage regardless of the current, they provide a fixed current, regardless of the load voltage. The latter characteristic is necessary in battery charging applica tions to limit charging current into the battery—as the ba ttery voltage varies from fully discharged to fully charged, the constant-current source will maintain the charge current at a safe level and prevent overheating of the battery.

Referring again to Figure 3.7, it is possible to see how th e constant-current and constantvoltage sources are combined in a typical char ger design for lithium-ion or lead-acid batteries. The wall adapter will act as a cons tant-current or constant-volta ge source depending on its region of operation. When the battery is discharged and its voltage is low (see the bottom portion of Figure 3.7 ), the charger operates as a constant-cu rrent source, limiting the charge current flowing into the battery. However, when the battery is charged and its voltage is high (see the top portion of Figure 3.7), the charger operates as a constant- voltage source, outputting a fixed voltage and maintaining full charge.

19Figure 3.7. The Same Wall Adapter Can Be Used for Both BC and EPS Functions, Depending on Which Portion of Its Current-Voltage (I–V) Curve It Is Operating

In other words, some wall adapters used in a battery charging syst em may do more than “convert household electric current into DC curren t or lower-voltage AC current”—the role of an EPS, according to the EPACT 2005 definition. (42 U.S.C. 6291(36)(A)) These additional charge control functions may add to the cost and power consumption of the wall adapter, and may even make it functionally unsuitable for use with other, non-battery char ging applications.

Once the EPS definition has been interpreted to either include or exclude wall adapters, DOE must then interpret the BC definition, which is also ambiguous . Specifically, the BC definition does not specify the input power source for the battery charger. As a result, in cases such as the one illustrated in Figure 3.6(a), where the wall ad apter only performs power conversion and no battery charging f unctions, it is unclear whether to consider the entire battery charging system ( i.e. , from AC mains to the battery) as the BC, or only the components downstream from the wall adapter ( i.e. , from the charging base to the battery).

The interpretation of the BC definition, like the EPS definition, depends on the functionality of the wall adapter. If a wall adap ter provides charge contro l, the battery charging system it powers cannot operate or be tested with out it. On the other ha nd, if the wall adapter only provides power conversion, it can be modeled as a voltage source, and the battery charging system can be tested independently of the wall ad apter. In this case, the wall adapter portion of the battery charging system could therefore be included or not include d in the eventual BC standards.

203.2.3.1 Wall Adapters Specifically Excluded from Class A EPS Standards

The above discussion concerns battery ch arging functionality, and its use as a determinant for inclusion of wall adapters within the scope of BC and EP S standards. However, though a particular wall adapter may be considered an EPS based on its lack of charge control functionality, it may still be excluded from th is rulemaking because the Class A definition presented in section 3.2.1 excludes EPSs used within specific kinds of battery charging systems.

In particular, any device that “powers the char ger of a detachable battery pack or charges the battery of a product that is fully or primar ily motor operated” is excluded. (42 U.S.C. 6291 (36)(C)(ii)(II)) EISA further defines a detachable battery as one that is “(A) contained in a separate enclosure from the pr oduct; and (B) intended to be rem oved or disconnected from the product for recharging.” (42 U.S.C. 6291(52))

The second criterion in paragra ph (36)(C)(ii)(II) is clear: any wall adap ter that falls under the definition of EPS is excluded fr om current and future Class A EPS standards if it is part of a battery charging system used with a power tool or other motor-operated rechargeable product.

The meaning of the first criterion in paragr aph (36)(C)(ii)(II) is less clear. The phrase “contained in a separate enclos ure from the product,” however, a ppears earlier in the Class A EPS definition, providing a potential interpretati on. In that case, the definition limits Class A EPSs to devices “contained in a separate physical enclosure from the end-use product,” i.e. , a separate component outside the physical boundaries of th e end-use consumer product. (42 U.S.C. 6291(36)(C)(i)(IV))

Similarly, when applied to detachable batterie s, this phrase can also be interpreted to mean “wholly outside the physical boundaries of the end-use consumer product.” This is in contrast to batteries contained in an enclosure wholly or partly inside the physical boundaries of the end-use consumer product ( e.g. , inside a battery compartment).

A further constraint on the defini tion of detachable batteries is the requirement that they be “intended to be removed or disconnected from the product for recharging.” (42 U.S.C. 6291(52)(B)) Thus, even if a battery is not contai ned inside the product, it may not be considered “detachable” unless it is also intended to be “removed or disconnected from the product.”

In particular, several popular models of ca mcorders employ wall adapters that can be used to power the camcorder and charge its battery. 10 However, even though these batteries are not contained inside the product, it is not necessary to remove them for charging. Rather, the wall adapter plugs directly into the camcorder body or into a cradle that accepts the entire camcorder. Therefore, DOE does not consider thes e batteries detachable and does not consider the wall adapters for these camcorders to be excluded from the Class A EPS definition per 42 U.S.C. 6291(36)(C)(ii)(II).

Other than camcorders, DOE has not identif ied any end-use consumer products with batteries that are not contained inside the produc t that are not also “fu lly or primarily motor operated.” Therefore, DOE considers only the wall adapters for moto r operated products ( e.g. ,

10 The Sony Handycam HDR-TG1 and the Canon Vixia HF10 are two examples.

21rechargeable power tools and household applia nces) to be excluded from the Class A EPS definition and the scope of Class A standards.

Item 5 DOE welcomes comment on any products with detachable batteries that are not motor operated, the wall adapters of whic h should also be excluded from Class A EPS standards.

Finally, it is worth noting that there are no el ectrical differences between the two battery arrangements ( i.e. , wholly outside versus wholly or pa rtly inside the end-use product). As a result, there is no explanation w hy charging one type of battery w ould require the associated EPS to be excluded from Class A, while charging an other type would not. Nonetheless, DOE believes that excluding EPSs that charge batteries wholly outsi de the physical bounda ries of the end-use consumer product is more appropriate in the context of the language in 42 U.S.C. 6291 (36)(C)(ii)(II).

Item 6 DOE requests comment on its interpretati on of the definition of “detachable battery,” and the impact on EPSs excluded from Class A.

3.2.3.2 Key Questions
The above discussion of how to treat wall ad apters when used with battery charging systems can be reduced to two key questions. The answers to these two questions will determine whether DOE will treat a particular wall adapter as an EPS, a part of a BC, both, or neither, and will determine which components of a battery charging system are subject to which test procedure (BC or EPS) and whic h standard they must meet.

Question 1: Should a wall adapter that powers a ba ttery charging system be considered an EPS? Based on the answer to this question, DOE w ill determine whether to test the wall adapter to meet the requirements of an EPS energy c onservation standard. Th ere are three possible answers to this question:

(1) A wall adapter that powers a battery charging system is always considered an EPS. (2) A wall adapter that powers a battery charging sy stem is considered an EPS only if it does not perform a charge control function. (3) A wall adapter that powers a battery chargi ng system is never considered an EPS.

Table 3.1. Treatment of Different Types of Wal l Adapters That Pow er a Battery Charging System Spending on the Answer to the First Key Question
Q1: Should the wall adapter be considered an EPS? (1) Always (2) Only if no charge control (3) Never Wall Adapter Without Charge Control Functionality Wall Adapter with Charge Control Functionality EPS EPS Not EPS

EPS Not EPS Not EPS

22Question 2: Should the wall adapter that powers a battery charging system be considered part of the BC? There are two possible answers to this question: (1) A wall adapter that powers a battery charging sy stem is always considered part of the BC. (2) A wall adapter that powers a battery chargi ng system is considered part of the BC only if it performs charge control functions.

Based on the answers to these questions, DOE will determine which components of a battery charging system will have to meet the requirements of a possible BC energy conservation standard.

Table 3.2. Treatment of Different Types of Wal l Adapters That Pow er a Battery Charging System Depending on the Answer to the Second Key Question
Q2: Should the wall adapt
(1) Always er be considered part of the BC?
(2) Only if charge control Wall Adapter Without Charge Control Functionality Wall Adapter with Charge Control Functionality BC

BC Not BC

BC

3.2.3.3 Possible Approaches to Interpreting the Definitions of BCs and EPSs The answers to each of the key questions pr esented above can be combined in several different ways to fully describe the treatment of wall adapters that power battery charging systems. These combinations of answers are su mmarized as one of four possible “Approaches,” which are presented in Table 3.3.

Table 3.3. The Answers to the Key Questions Are Combined to Form Four Distinct Approaches to Dealing with Wall Adapters That Power Battery Charging Systems
Q2: Should the wall adapter be considered part of the BC?

(1) Always (2) Only if charge control
(1) Always Approach D Approach not evaluated.* Q1: Should the wall adapter be considered an (2) Only if no charge control Approach A Approach C

EPS? (3) Never Approach B Approach not evaluated.**

* DOE will not evaluate this approach further because it would result in too many additional product classes as discussed under section 3.2.3.7, Details of Approach D. ** DOE will not evaluate this approach further because it would require granting an exclusion from Class A EPS standards that is inconsistent with EISA (see section 3.2.3.5) and would leave some wall adapters entirely outside of the scope of the BC and Class A EPS rulemakings.

23Figure 3.8 and Figure 3.9 illustrate all the mains-powered product configurations that are within the scope of the BC and Class A EPS rule makings. One of the four approaches, described abstractly in Table 3.3, will be applied to each of these configurations during this rulemaking. In particular, the key questions presented above con cern the middle configur ations (Configurations 2–10) in the two figures, which include a wall ad apter that powers a battery charging system. Configuration 1 in Figure 3.8 lacks a battery charging system , and is therefore outside the scope of this discussion, but was included for the sake of completeness. Similarly, Configurations 11– 13 in Figure 3.9 lack wall adapters, so, as described in section 3.2.2 there is no question that they would be considered BCs in their entirety.

Because the configurations are similar, with differences only in battery packaging and charger interface, it is useful to focus on the distribution of functions within the system. Figure 3.10 illustrates the four approaches as they apply to generalizations of the product configurations presented in Figure 3.8 and Figure 3.9; the details of charger, cradle, and battery have been removed while the distributions of functions between the wall adap ter and the rest of the system have been retained. The following sections detail the advantages and disadvantages of the four approaches.

24AC/DC Conversion Charge control Key Battery End-Use Load

Figure 3.8. Configurations of Power Convers ion and Battery Charging Functions in Consumer Products

25AC/DC Conversion Charge control Key Battery End-Use Load

Figure 3.9. Configurations of Power Convers ion and Battery Charging Functions in Consumer Products (Continued)

26AC/DC Conversion Charge control

Key Battery End-Use Load

EPS BC Overlap

Figure 3.10. Comparison of How Various Batt ery Charging Systems Would Be Treated Under Each of the Four Approaches. The charge control function can be split between enclosures. Enclosures covered by the “overlap” would be considered to be subject to both BC and EPS standards.

273.2.3.4 Details of Approach A Under Approach A, illustrated in Figure 3.10, DOE would:

 only consider a wall adapter that powers a ba ttery charging system to be an EPS if it does not perform a charge control function;

 always consider the wall adapte r to be part of the BC; and

 potentially establish two standards: one fo r the wall adapters that perform only power conversion and one for all components of the BC system.

The July 1, 2008, EISA standard levels we re based on efficiency levels used by ENERGY STAR and at least 9 States and the Di strict of Columbia. Their EPS efficiency programs, however, limited their scopes to wa ll adapters providing only power conversion functions, 11 so the standards these programs—and subsequently Congress—adopted were developed specifically for these types of wall ad apters. By adopting Approach A, which would harmonize with these prior programs, DOE woul d be ensuring that the current Class A EPS standards apply to all the wall adapters for which they were originally developed.

For the purposes of describing BCs, this approa ch considers the entire battery charging system—from wall plug to battery—to be a BC. A ny wall adapter that powers a battery charging system is a component of “a device that charges batteries for consumer products”— i.e. , a BC— even if it is also considered an EPS and subj ect to EPS standards. (42 U.S.C. 6291(32)) Under this approach some battery charging systems woul d be subject to two standards: a BC standard for the battery charging system as a whole—from wall plug to battery—and an EPS standard specifically for the wall adapter. EISA permits th is possibility since it pr ovides that “an energy conservation standard for external power supplies shall not constitute an energy conservation standard for the separate end-use product to whic h the external power supply is connected.” (42 U.S.C. 6295(u)(4))

Because Approach A would treat only wall adap ters without charge control as EPSs, all devices subject to the EPS standards analysis w ould provide similar utility as constant-voltage sources. As a result, all EPSs could be held to a consistent set of standards, requiring no additional product cl asses (see section 3.6.2). Likewise, DOE expects th e product-class divisions within the BC analysis to be straightforwar d because under this interpretation of the BC definition, all components of a battery charging system would be included in the standards analysis—extending from the wall plug to the ba ttery. Thus, all AC mains-powered BCs would contain the same circuit functions—whether th ey are located within the consumer product, charging cradle, or wall adapte r—and could be included within the same overarching product class before being separated by outpu t voltage as described in section 3.6.1. An additional product class would be required to analyze DC-powered BCs.

11 The ENERGY STAR and State p rograms specifically exclude wall adapters that “have batteries or battery packs that physically attach direc tly” or “have a battery chemistry or type selector switch AND an indicator light or state of charge meter.” (EPA. “ENERGY STAR Program Requirements for Single-Voltage External Ac-Dc and Ac-Ac Power Supplies: Eligibility Criteria.” Version 1.1 (emphasis in original).) These exclusions would apply to wall adapters with battery charging functions.

28However, this approach would also intr oduce some overlap between the BC and EPS definitions, which would affect DOE’s analysis . Because certain wall adapters would be considered both EPSs and components of BC syst ems, the potential for energy savings may have to be analyzed sequentially. First, an economically justified and technologically feasible standard level would have to be developed for the wall adapter during the EPS analysis. Then, given a wall adapter that meets a particular EPS sta ndard level, an economically justified and technologically feasible standard level would have to be develope d for the system as a whole.

As a result, a separate product class may have to be created to accurately analyze BCs powered by wall adapters that are also cons idered EPSs. However, based on testing and discussions with manufacturers, DOE believes that the majority of wall adapters used for battery charging applications have charge control functions, leaving only a small percentage of these wall adapters that would be considered EPSs under Approach A. 12

An added complication of the overlap between BC and EPS standards is the possibility that future EPS standards may impose a design c onstraint resulting in lower cost-justified energy savings than a single system-wide BC standard. This is because complying with future EPS standards may prevent implementing cost-justi fied energy efficiency improvements in the remainder of the BC system. (DOE would need to evaluate the likelihood of this possibility.) Furthermore, a general EPS analysis of a wa ll adapter independent of the battery charging system it powers would not fully account for the loading and usage of th e battery charger as accurately as a dedicated battery charging system analysis.

This problem could, however, be mitigated through the addition of product classes specifically for BCs powered by EPSs. By placing these products in a separate product class, DOE could exempt the wall adapters from add itional EPS standards beyond those required by EISA, resulting in only one new system-wide BC standard. DOE may decide to exempt products in this class from additional EPS requirements beyond EISA, based on consideration of the seven EPCA factors (see section 1.2.2), particularly given the potentia l for additional cost-justified EPS energy savings and an analysis of burdens on th e manufacturer. A single system-wide standard for BCs powered by EPSs could result in higher cost-justified energy savings.

Finally, Approach A would require manufacturers to qualify and certify some wall adapters as compliant with EPS standards and subs equently re-qualify the entire battery charging system powered by the wall adapter as compliant with BC standards. However, as mentioned above, DOE does not believe that a significant nu mber of battery charging systems use wall adapters that would be considered EPSs under Approach A. Futhermore, DOE does not expect the absolute duration of the qualific ation process to increase, as ma nufacturers should be able to qualify the wall adapter and the entire battery char ging system in parallel, if the wall adapter is not already qualified under EISA.

12 Furthermore, many battery chargi ng systems powered by wall adapters either have detachable batteries or are “fully or primarily motor operated” an d, therefore, are not subj ect to the EISA EPS stan dards. DOE is currently analyzing whether an energy conservation standards rulemaking should be conducted for these products.

29Nonetheless, even if qualific ation and certification are c onducted in parallel, adopting this approach could double the testing and doc umentation burden on manufacturers compared to a single system-wide BC standard ( e.g. , as under Approach B). Similarly, in cases where manufacturers outsource the desi gn and production of the BC wa ll adapter, these compliance costs would affect the final cost of the product. This burden could be reduced if DOE places BCs powered by EPSs into a separate pr oduct class, as described above.

Nonetheless, because of its consistency w ith the ENERGY STAR and State approaches, its inclusion of a large number of wall adapters under the current EISA EPS standards, and the possibility of reducing manufacturer compliance burdens, DOE believes that the benefits of Approach A outweigh the disadvantages. Acco rdingly, DOE proposes Approach A as its preferred approach.

To summarize, under this approach, DOE woul d only consider wall adapters that do not perform a charge control function to be EPSs, while it would consider all wa ll adapters to be part of the BC, even if they are also considered E PSs. The advantages of this approach are that:

 it is consistent with the ENERGY STAR a nd State interpretations of EPS definition and testing of products;

 it provides the second great est scope of coverage a nd savings for current EPS standards (equal to Approach C, second to Approach D); and

 it provides for an overall battery charging system standard (in addition to the EPS standard for some wall adapters) such that th e system is tested in a manner similar to how it is operated.

The disadvantages of this approach are that:

 it subjects BC manufacturers usi ng wall adapters without charge control to both EPS and system-wide BC standards, potentially increasing compliance burden; and

 it may result in lower cost-justified energy savings than a single system-wide BC standard (unless certain wall adapters are exempted from EPS standards beyond EISA);

3.2.3.5 Details of Approach B Under Approach B, illustrated in Figure 3.10, DOE would:

 never consider a wall adapte r that powers a battery charging system to be an EPS;

 always consider the wall adapte r to be part of the BC; and

 potentially establish separate BC standard s for the battery charging system and EPS standards for wall adapters that do no t power battery charging systems.

This approach is based in part on the EPA ENERGY STAR “heat , light, and motion” approach 13 used to differentiate between EPSs and BCs that DOE initially considered adopting wholecloth. Under this ENERGY STAR approach, a pr oduct is classified as either a BC or EPS,

13 EPA. “ENERGY STAR Program Requirements for Products with Battery Charging Systems: Eligibility Criteria.”

30but not both. 14 Qualifying devices under the BC categor y are further limited to (1) chargers packaged with “products whose principal output is mechanical motion, light, the movement of air, or the production of heat,” and (2) stand-alone chargers for removable and standard-size alkaline-battery replacement batteries. Th e ENERGY STAR approach is illustrated in Figure 3.11

.

Source: U.S. EPA, 2009. Figure 3.11. EPA ENERGY STAR Division Between Products Qualifying Under the EPS and BC Specifications. This di vision is similar to that und er consideration in Approach B.

The ENERGY STAR approach eliminates ove rlap between the BC and EPS categories and would potentially reduce the compliance burden on manufactur ers while resulting in higher economically justified energy savings. The ENERGY STAR BC and E PS divisions, however, conflict with the statutory BC definition, which is not limited to chargers used for heat, light, and motion products or stand-alone chargers. Consequently, when c onsidering the scope set out in the statutory definition of a BC, DOE has determined that the ENERGY STAR Program approach is too narrow and would not permit DOE to satisfy its legal obligations under the statutory framework laid out by Congress.

To address these shortcomings, DOE developed Approach B, which is similar in structure to the ENERGY STAR approach, but attempts to address the coverage issues presented by the statutory BC definition. Like th e ENERGY STAR approach, Approach B results in no overlap between BC and EPS standards. But in contrast to ENERGY STAR, all components of the battery charging systems for every application ar e considered BCs, not just chargers for heat, light, and motion applications.

14 EPA defines EPSs in terms simila r to those used in s ection 301 of EISA to define Class A EPSs. (42 U.S.C. 6291(36)(C)(i))

31Under this broader reading of the BC defin ition, the scope of the BC standard would include battery chargers embedded in products su ch as cellular telephones and laptop computers. The wall adapters of these products have been considered to be EPSs by the ENERGY STAR program and the ten States that have adopted EPS definitions and standards based on ENERGY STAR. 15

However, to prevent an overlap between BC and EPS standards, these wall adapters would not be considered EPSs under Approach B. Instead, DOE would interpret the phrase “consumer product” in the EPS definition to excl ude devices already regulated separately under the BC standard. Although this interpretation wo uld clarify the ambiguities in the BC and EPS definitions and resolve the issues with overlap ping regulation raised by Approach A, it would result in a smaller scope of coverage for the cu rrent Class A EPS standards than Approaches A, B, and C, and may not be consistent with some additional requirements contained in EISA.

Specifically, DOE cannot limit the scope of the EPS definition by adding another exclusion to those already crea ted by Congress. Section 301 of EISA amended section 321 of EPCA by inserting a definition for Class A EPSs. In addition to defining a Class A EPS, EISA also created two specific exclus ions for products that would ot herwise be considered Class A EPSs. EISA excludes “any device that . . . powers the charger of a detachable battery pack or charges the battery of a produc t that is fully or primarily motor operated.” (42 U.S.C. 6291(36)(C)(ii)) This exclusion limits its scope to those devices that (1) power the charger of a detachable battery pack or (2) charge the battery of a product that is fully or primarily motor operated. Congress did not authorize DOE to add to these exclusions.

Given these specific statutory exclusions, and the absence of any statutory authority to add to these exclusions, DOE cannot create add itional exclusions for Class A EPSs beyond those that Congress already created. Nonetheless, DOE has included this approach in the discussion because of its similarity to the accepted EN ERGY STAR approach and potential for lower compliance burdens on manufacturers.

Item 7 DOE welcomes comment on ways of amending Approach B to make it consistent with the statutory language in EISA, or proposals of alternate approaches based on the clear BC and EPS divisions of the ENERGY STAR program.

In this context, it is worth emphasizing the po ssibility of creating a separate product class for wall adapters that power battery charging systems but that provide no charge control functions (and would therefore be consider ed EPSs under Approach A). See section 3.2.3.4, above. By placing these types of wall adapters in to a product class separate from wall adapters

15 To date, none of the states have adopted standards for BCs, and only one—California— has adopted a test procedure. Furthermore, none of the states have issued guidelines on delineating BCs and EPSs.

32for other applications, these wa ll adapters could be subject on ly to future BC standards as components of a BC system.

Treating wall adapters in this manner, Appr oach A becomes similar to Approach B and the ENERGY STAR approach, by removing overla p between future BC and EPS standards since only wall adapters for non-battery charging appli cations would be potentially subject to amended EPS standards. Similarly, wall adapters that are part of a battery chargi ng system—together with any other enclosures that incl ude the charge-control circuitr y—would only be subject to a system-wide BC standard. Therefore, there woul d be no overlap between the scope of the two standards.

The benefits of this elaborati on to Approach A, as opposed to Approach B, are that it is consistent with the statute and would result in a larger number of wall adapters currently subject to the Class A EISA EPS standards, and greater immediate energy savings.

Despite the advantages of Approach B, DOE will be unable to adopt this and similar approaches due to their exclusion of wall adap ters that power batter y charging systems from current EPS standards. Were it pos sible to implement it, the advant ages of Approach B would be that:

 it eliminates overlap between the scope s of EPS and BC standards, limiting manufacturer burden of complying with one standard for both manufacturers of individual components and the entire BC-EPS system; and

 it provides broadest scope for system-wide BC standard (all components of battery charging systems), resulting in maximu m economically justified energy savings.

The disadvantages of Approach B would be that:

 it is inconsistent with the EISA definition of Class A EPSs;

 it excludes wall adapters for applications such as laptops and cell phones from EPS standards, contrary to ENERGY STAR and State precedent; and

 it provides the smallest scope of coverage and savings for current EPS standards, by interpreting the EPS definition to exclude any wall adapter that powers a battery charger, including applications such as laptops and cell phones.

3.2.3.6 Details of Approach C Under Approach C, illustrated in Figure 3.10, DOE would:

 consider a wall adapter that powers a battery charging system to be an EPS only if it does not perform charge control functions;

 consider the wall adapter to be part of the BC only if it performs charge control functions; and

 establish separate EPS standards for some wall adapters and BC standards for the remainder of the components of the battery charging system.

33Approach C is similar to Approach A in its interpretation of the EPS definition; however, its interpretation of the BC definition is differe nt. Under Approach C, DOE would interpret the EPS definition to include all wall adapters that perform no charge control functions. However, the Department would interpret the definition of a BC to apply only to battery charging system components intended exclusively for battery ch arging. This interpretation would therefore consider a wall adapter that powers a battery ch arging system to be part of the BC only if it performs charge control functions.

Like Approach A, Approach C would apply EPS standards only to wall adapters that perform no charge control functions, which woul d harmonize this approach with the ENERGY STAR and State approaches. Approach C would, however, eliminate overlap between BC and EPS standards because a wall adapter that does no t perform charge control function would not be considered as part of the BC. As a result, com ponents of the same battery charging system could be subject to two separate, but disjointed, standards: an EPS st andard for wall adapters with no charge control functions, and a BC standard for the remaining components of the BC system. Like Approach A, Approach C would subject all wall adapters currently within the scope of the ENERGY STAR program to the current Class A EISA standards, providing the second greatest scope of coverage for current standards.

Even though there is no overlap between the EPS and BC standards under Approach C, applying separate standards to components of a system may still result in higher manufacturer burden and lower economically justified energy sa vings than a single, system-wide standard. Manufacturers of a single product would have to comply with two efficiency standards on different components of the pr oduct, while an analysis condu cted under approach C would ignore any technology options that rely on the interaction betw een two components considered BCs and EPSs, respectively, to produce energy savings. Furthermore, by including the wall adapter within the scope of the general EPS standa rds analysis, it is not possible to account fully for the particular load presented by the batter y charging system, since the application of the generic EPS loading conditions and usage profiles may not be completely representative of BC loads.

Finally, unlike Approach A, there is no way to mitigate these concerns since Approach C’s definition of BC does not include the wall adapter, DOE cannot exclude wall adapters for BCs from possible future EPS standards, wh ile subjecting them only to system-wide BC standards.

Approach C also requires additional product classes. Unlike Approaches A and B, where the interpretation of EPS and BC definitions placed similar types of products within the scope of EPS and BC standards, under Approach C, the BC standard would include two distinct types of battery chargers. The first class of BCs, using an internal power suppl y or wall adapter with charge control circuitry for power conversion, w ould be tested with the power supply, and its presence would be reflected in the efficiency test results. In cont rast, the second class, utilizing a voltage-source wall adapter su bject to EPS standards, would be te sted without the wall adapter to prevent overlap between the st andards, which means that the power supply would not be included in the test results. Accordingly, the energy consumption of the two classes would not be directly comparable, requiring th e use of separate standards.

34To conclude, Approach C is similar to Appr oach A in that the definition of EPS is interpreted to include only wall ad apters without charge control. It differs in its interpretation of the BC definition, which includes the wall adapter if it contains charge co ntrol functionality. The advantages of this approach are that:

 it is consistent with the ENERGY STAR and State interpretation of the EPS definition and testi ng of products; and

 it provides the second great est scope of coverage a nd savings for current EPS standards (equal to Approach A, second to Approach D).

The disadvantages of this approach are that:

 like Approach A, it subjects components of battery charging system powered by a wall adapter without charge control to EPS and BC standards, potentially increasing compliance burden for manufacturers of the entire BC-EPS system; and

 like Approach A, it will result in future equal or lesser cost-justified energy savings than a single-system-wide BC standard for BCs powered by EPSs.

3.2.3.7 Details of Approach D

Under Approach D, illustrated in Figure 3.10, DOE would:

 always consider a wall adapter that powers a battery charging system to be an EPS;

 always consider the wall adapte r to be part of the BC; and

 potentially establish two standards: one fo r wall adapters and one for the BC system as a whole.

Unlike the previous approaches, which consid ered the circuit function when determining whether a component of a battery charging system should be subject to the EPS or potential BC standard, Approach D takes into account only the physical characte ristics of the device. An EPS “converts household electric current into DC curr ent or lower-voltage AC current,” and in the discussion of Approaches A and C, DOE indicated th at this clause can be interpreted to exclude wall adapters that perform charge control functi ons and are intended solely to charge batteries (sections 3.2.3.4 and 3.2.3.6). However, one could also view wall adapters as providing charge control functions in addition to converting household current into lower voltage DC current and should therefore be considered EPSs.

Further, while the EISA definition of a Class A power supply is modeled on the ENERGY STAR EPS definition, it contains a significant diffe rence. Whereas the ENERGY STAR EPS definition excludes devices that “have batteries or battery packs that physically attach directly . . . to the power supply unit,” 16 the EISA Class A definition does not. Because the EISA definition omits this exclusion, wall adap ters that “physically at tach directly” to the

16 EPA. “ENERGY STAR Program Requirements for Single- Voltage External Ac-Dc and Ac-Ac Power Supplies: Eligibility Criteria.” Version 1.1 (emphasis added).

35battery may now be considered as Class A E PSs. These wall adapters, however, are equipped with charge control, which is ne cessary when the wall adapter is connected directly to the battery to limit the charge current a nd prevent overheating. Therefore, the removal of the above exclusion from the EISA Class A EPS definition seems to imply that EPSs with charge control functionality could be included under the definition of Class A EPSs and therefore EPSs in general. This would expand the scope of coverage of current Class A EISA standards to all wall adapters, not just those that have be en considered EPSs under ENERGY STAR.

Under Approach D, all components of a batte ry charging system would be considered within the scope of the BC definition, similar to Approach A. This interpretation would likewise cause overlap between BC and EPS standards, wi th wall adapters that power battery charging systems considered both EPSs and components of BCs. Similarly as under Approaches A and C, this overlap may result in a higher compliance bu rden and lower cost-justified energy savings than achievable under single, system-wide BC standards.

Also, because wall adapters with and without charge control would be considered EPSs, these two types of devices would need to be grouped into sepa rate overarching product classes and be subject to two different standard levels. This would be necessary because wall adapters with charge control provide addi tional utility and may not be able to meet the same standard levels as wall adapters without charge control.

Thus, although Approach D would facilitate the differentiation between BCs and EPSs by allowing quick visual inspection, differentiating wall adapters ba sed on charge control function cannot be eliminated entirely and would comp licate the downstream analysis and potential EPS standards. 17

By modifying Approach D to exclude wall ad apters without charge control function from the scope of the BC definition, DOE could decr ease the number of wall adapters potentially subject to both BC and EPS standards. Under this alternate approach, all wall adapters would be considered EPSs, but wall adapters without charge control would not be subject to BC standards. DOE did not consider this altern ate approach because it would fu rther add to the product classes required under Approach D, as separate standa rds for wall adapters with and without charge control would be needed as we ll as separate standards for BCs powered by wall adapters with and without charge control.

However, the complications may go beyond separate product classes and standard levels—some wall adapters with charge cont rol may not be testab le under the EPS test procedure. As presented in Figure 3.7, some wall adapters for battery charging applications provide a constant current, rather than a constant voltage. This c onstant current varies from unit to unit due to manufacturing toleranc es, such that a particular unit may not be able to deliver its nameplate current. Under these conditions, a manufact urer may not be able to test a wall adapter with charge control under the EPS test procedure, which requires loading the unit to 100 percent of its nameplate current, further complicating th e implementation of Approach D and any similar approaches.

17 Differentiating wall adapters base d on charge control function would require testing of output current and voltage under load, as described in section 3.2.4.

36Item 8 DOE seeks comment on the prevalence of wall adapters for battery charging applications that may not be testabl e under the EPS test procedure.

To summarize, under Approach D, all wall ad apters would be considered EPSs, while all components of a battery charging system, includi ng those wall adapters that are considered EPSs, would be considered BCs. There would be significant overlap between the two definitions and scopes of potential standards. The a dvantages of this approach are that:

 it simplifies identification of EPSs by relying solely on phys ical characteristics; and

 it provides the greatest scope of coverage and savings for current EPS standards, because it considers all wall adap ters (even those with charge control) to be EPSs and therefore subject to the current EISA standards.

The disadvantages of this approach are that:

 it subjects wall adapters without charge control that power battery charging systems to both EPS and system-wide BC standard s, potentially increasing the compliance burden for manufacturers of individual co mponents as well as the entire BC-EPS system;

 it may result in lower cost-justified energy savings than a single, system-wide BC standard (unless certain wall adapters are exempted from EPS standards beyond EISA);

 it may lead to complications associated with testing wall adapters that perform charge control according to the EPS test procedure;

 it would result in additional product cla sses and potential standard levels; and

 it is inconsistent with ENERGY STAR and St ate interpretation of EPS definition and product testing.

3.2.3.8 Summary of the Four Approaches

DOE evaluated the above four approaches based on the desirable criteria presented in Table 3.4 , assigning a “+” (advantage), “0” (neutr al), or “–” (disadvantage), depending on how well the approach met each criterion.

Table 3.4. Comparison of the Four Approaches to Interpreting the BC and EPS Definitions Against Desirable Characteristics

Criterion Approach A Approach B Approach C Approach D Is consistent with the EISA Class A EPS definition + – + + Provides a broader scope of coverage for current EPS standards 0 – 0 + Results in higher cost-justified energy savings 0 + – 0 Subjects manufacturers to lower compliance burdens – + – – Results in fewer potential product classes + + 0 – Is consistent with ENERGY an d State EPS efficiency + 0 + 0

37Criterion Approach A Approach B Approach C Approach D
programs Provides a BC definition that encompasses entire battery charging system + + 0 +

Item 9 DOE seeks comments on the four approac hes to interpreting the BC and EPS definitions to resolve ambiguities in the scope of the analyses. DOE is also interested in determining whether Approach B could be modified to permit its use in a manner consistent with the statutory framework created by Congress.

Item 10 DOE welcomes comment on additional f unctionality provided by some wall adapters for battery chargers that may impede their ability to meet the same standards as comparable wall adapters for ot her applications. DOE asks that commenters provide specific examples and suggest ways in wh ich DOE can address any potential barriers that may arise.

Item 11 DOE welcomes comment on the manufacturer burden of compliance with current EISA Class A EPS standards under each of the four approaches and seeks information on how DOE can minimize this burden while ensuring that the standards are being met consistently by the industry.

Item 12 DOE also welcomes comment on the likely manufacturer burden of compliance with possible future EPS and BC standards under each of the four approaches. To this end, DOE also seeks information from the industry regarding how the monitoring of compliance with these standards can be accomplished.

3.2.4 Identification of Wall Adapters The above approaches depend on identifying whether wall adapters that power battery charging systems also perform charge control functi ons, a task that is not always straightforward. To aid in this process, DOE is considering the ad option of three possible criteria to help identify those wall adapters that perf orm charge control functions:

(1) Short-circuit operation : How the wall adapter performs when a short-circuit load is applied. (2) Voltage regulation : How the output voltage of the wa ll adapter varies at different active mode loading conditions relativ e to the nameplate output voltage. (3) No-load voltage : How the output voltage of the wall adapter varies at no load relative to the nameplate output voltage.

Short-circuit operation is important to battery charging because a fully discharged battery connected to a battery charging sy stem approximates a short circuit. The battery charger must be

38designed to operate in this conditi on. It cannot cut off current to the battery completely, but must provide sufficient current for the battery to ch arge safely. For wall ad apters without charge control that do not connect directly to batteries, a short circuit is an abnormal fault condition. In that case, the wall adapter may cut off all current to the output through a fu se or other protective element.

In addition to short-circuit operation, DOE is considering vol tage regulation and no-load voltage as possible criteria for determining the presence of charge control functions and the placement of a particular wall ad apter within the scopes of the BC and EPS definitions under the four approaches. A wall adapter for non-battery ch arging applications is a voltage source that ideally provides constant output voltage with variable output current. In contrast, battery charging requires a current source that provides constant current with variable output voltage.

However, some line-frequency wall adapters that are not used in battery charging applications tend to have poor voltage regulation, 18 which limits the usefulness of this criterion because their voltage regulation and no-load voltag e might be similar to that of a wall adapter that performs charge control.

Item 13 DOE is seeking input on these and any addi tional criteria it should consider in determining the presence of wa ll adapter charge control functions.

DOE is also considering requiring identifica tion labels to easily differentiate between wall adapters that perform charge control functi ons and those that do not, as identified using criteria such as those listed a bove. Manufacturers could be required to label a wall adapter based on whether it performs charge control functions . Under Approaches A and C, this label would determine whether the wall adapter should be subject to an EPS sta ndard or should be considered as part of the entire battery charging system, and therefore su bject to a BC standard. Under Approach D, this label would determine which EPS product class a wall adapter belongs to, and therefore, which standard it may be required to meet. In any case, the la bel would serve only to expedite standards enforcement; because labeling is vulnerable to manipulation, DOE would also need to check whether the correct label has been applied through the more extensive tests noted above.

Item 14 DOE welcomes comment on external c haracteristics (either physical or electrical) that can be used to identify a wall adapter performing charge control for determining compliance with the appropriate standard under Approaches A, C, and D, as well as the use of labeling to permit easy iden tification. How likely would it be that those requirements would be subject to poten tial manipulation by manufacturers? If manipulation is possible, what form, and in w hat context, would th ese activities likely occur?

18 “Regulation” refers to the dependence of output voltage on output current. Ideal voltage sources have excellent voltage regulation, meaning the voltage does not vary significantly with output current.

393.3 Market Assessment
DOE will qualitatively and quantitatively char acterize the structure of the markets for BCs and EPSs. In the market assessment, DOE will identify and characterize the manufacturers of this equipment, estimate market shares and trends, address regul atory and non-regulatory initiatives intended to improve the efficiency or reduce the energy consumption of BCs and EPSs, and explore the potential for technological improvements in the design and manufacturing of these products.

This market assessment will establish the cont ext for the rulemaking, and it will serve as a resource to guide the analyses that follow. Fo r example, DOE may use historical shipments and prices as an indicator of futu re shipments and prices. Similarl y, DOE may use market structure data for the manufacturer impact analysis, as thos e data could be particular ly useful for assessing competitive impacts.

DOE recognizes that there may be limited public information on national shipments, manufacturing costs, distributi on channels, and manufacturers’ ma rket shares of BCs and EPSs. These types of data are importa nt inputs to analyses that determine if energy conservation standards are economically justified and will re sult in significant energy savings. Therefore, DOE encourages interested parties to submit data pertaining to thes e areas of interest that would improve DOE’s understanding of the BC and EPS markets. These data may be provided under a confidentiality agreemen t with DOE’s contractors responsible for this part of the rulemaking analysis, namely Navigant Consulting, Inc. (NCI) and/or D&R International, Ltd. As with other DOE rulemakings, DOE’s contractors will aggreg ate data provided by manufacturers and other organizations when preparing results for DOE’s analyses. These aggregated results do not divulge the sensitive raw data from each interested party, but enable other parties to review and comment on the aggregated dataset.

Alternatively, interested parties may subm it confidential data to DOE, indicating in writing which data should remain confidential. To prevent public disclosure of the data as a result of third-party actions, in terested parties providing confidential information to DOE must submit that data according to 10 CFR 1004.11. Under 10 CFR 1004.11, any person submitting information that he or she believes to be conf idential and exempt by law from public disclosure should submit two copies. One copy of the document shall include all the information believed to be confidential, and the other copy of the docum ent shall have the information believed to be confidential deleted. DOE will determine whether the information is confidential and treat it accordingly. 19

19 Factors of particular interest to D OE when evaluatin g requests to treat submitted information as confidential include the following: (1) a description of the items; (2) whether and why such items are customarily treated as confidential within the industry; (3) whether the informatio n 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 th e competitive injury to the submitting person which would result from public disclosure; (6) a date upon which such information might lo se its confidential nature due to the passage of time; and (7) why disclosure of the information would be contrary to the public interest.

40The following discussion reviews some asp ects of DOE’s market assessment developed during its 2006–2007 determination an alysis, and presents approaches that DOE may use in the forthcoming preliminary analyses.

3.3.1 Distribution Channels Figure 3.12 characterizes the phys ical distribution networks for BCs and EPSs that DOE examined during its initial work for the determ ination analysis. A component manufacturer sends components to a BC manufacturer, who assembles the BC. The BC manufacturer often ships the assembled device to a separate original equipm ent manufacturer (OEM). The OEM incorporates the BC into a consumer product and ships the entire package to a retailer, who sells it to the consumer. Alternatively, a single company coul d manufacture both a consumer product and the BC that charges it.

Component Manufacturers

BC Manufacturers

Consumer Product Retailers

Consumers OEMs Component Manufacturers

EPS Manufacturers

Consumer Product Retailers

Consumers OEMs EPS Distributors Battery Charger Distribution External Power Supply Distribution

Sources: Calwell and Reeder, Manufactur er Incentives for Energy Efficien t Power Supplies, 2002; Calwell and Reeder, Power Tools: A Hidden Opportunity for Energy Savings, 2002; Collon Lee, Astec Power, Personal Communication, 2006; Michael O’Connor and Michael Mueller, Phihong USA, Personal Communication, 2006; Power Tool Institute and Association of Home Applia nce Manufacturers, DOE Scop ing Workshop Transcript, January 24, 2007. Figure 3.12. BC and EPS Distribution Networks

Item 15 DOE welcomes comment on the possible di fferences in distribution channels between wall adapters used for battery c harging applications that do and do not have charge control functions.

41Like BCs, EPS distribution also begins w ith component manufacturers. Unlike BCs, nearly all EPSs are built by EPS manufacturers. The EPS manufacturer will build either custom EPSs for an OEM or stock EPS models designed to work with a variety of consumer products. Stock products are manufactured according to popular designs that do not differ based on the application and then sold directly to OEMs or to EPS distributors. EPS distributors will then sell to retailers or OEMs. OEMs will bundle the EPS with a consumer product, and then sell to retailers or directly to consumer s. One example of the latter is the direct-to-consumer sale of laptop computers.

3.3.2 Shipments In section 2.2.1 of the associated draft technical report, DOE identifies four major trends that can affect shipments of BCs and EPSs ove r time. These trends are all related to the consumer products powered by BCs and EPSs.

 Demand for Consumer Product Applications refers to the changes in preferences, level of affluence, and population size that affect the demand for existing consumer product applications that use BCs or EPSs.

 Convergence means the application that uses an EPS is made redundant by another application. For example, m obile telephones increasingly in corporate the features of personal digital assistants (PDAs). As a result of convergence, some consumers may now have fewer devices than in the past, thus reducing the demand for BCs or EPSs.

 Emergence refers to the creation of new cons umer product application categories—a critical factor, given the rapid pace of ch ange in the consumer electronics market.

 Substitution means a shift between methods for supplying power to consumer products—internal power supplies, extern al power supplies, primary batteries, rechargeable batteries, Universal Seri al Bus (USB) systems, and others.

Item 16 DOE seeks comments on whether these and/or other factors influence the shipments of BCs and EPSs, and the extent to which each trend is likely to affect shipments.

Although some data on the shipments of BCs and EPSs exist, DOE is also examining shipment information for applications that use BCs or EPSs. Application-level data are important in determining the growth rate of BC and EPS sh ipments (discussed in sect ion 9) as well as the usage characteristics of these products (discussed in section 6). The following are the sources of shipment information DOE has identified to da te. DOE will update these as newer information becomes available.

 Appliance Magazine

. 30th Annual Portrait of the U.S. Appliance Industry . September 2007.

 Appliance Magazine

. 54th Annual Report: A Ten-Year Review 1997–2006 of the U.S. Appliance Industry. May 2007.

42 Consumer Electronics Association. US Consumer Sales and Forecasts, 2003–2008

. July 2007. CEA: Arlington, VA.

 Darnell Group. External AC-DC Power Supplies: Global Market Forecasts and Competitive Environment. Second Edition. 2005. Darnell Group: Corona, CA.

 Information Technology Industry Council. ITI PC Committee Projects Shipment Growth for 2007-2009. September 2007. Information Technology Industry Council: Washington, DC.

 TIAX LLC. Assessment of Analyses Performed fo r the California Energy Efficiency Regulations for Consumer Electronics Products . February 2006. TIAX LLC: Cambridge, MA.

 Unpublished information provided by trade associations.

Tables 3.1 and 3.2 list the applications for which DOE was able to obtain shipment information. DOE intends to use the shipment data it has already collected for BCs and EPSs, as well as relevant new data. DOE invites submission of shipment data and specifically seeks data on applications not listed below. For a complete list of consumer product applications that use a BC or EPS and are considered in this rulemaking, pl ease refer to section 2.3 of the draft technical report.

Table 3.5. BC-Powered Applications for Which DOE Has Shipment Data

Camcorders Kitchen products Digital cameras Personal care products Do-it-yourself (DIY) power tools Professional power tools Floor care products Universal battery chargers

Table 3.6. EPS-Powered Applications for Which DOE Has Shipment Data

Camcorders Notebook computers Cordless telephones Portable audio players Digital cameras Portable gaming devices Flat panel monitors Portable video players

Flatbed scanners Small liquid crystal display (LCD) TVs Ink-jet computer printers Telephone answering devices Local area network (LAN) equi pment Wi-Fi access points

Medical devices Wireless telephones

Modems/fax modems

Item 17 DOE seeks input on shipment data for BCs and EPSs and the applications that use them, including applications that use non-Class A EPSs (section 3.6.2). DOE also seeks input on the percentage of applicatio ns that are shipped with either a BC or an EPS.

433.3.3 Regulatory and Voluntary Programs DOE has also identified several voluntary and regulatory programs within the United States and abroad that address the energy c onsumption of BCs and EPSs. Because the BC and EPS markets are global, these programs may affect the efficiency of BCs and EPSs sold in the United States, even in the absence of a simila r Federal standard. For an overview of these programs, please refer to Appendix F of this document.

Item 18 DOE invites interested parties to review and comment on domestic and foreign efficiency programs relating to BCs and EPSs.

3.3.4 Market Failures To prepare for its review under Execu tive Order 12866, “Regulatory Planning and Review,” DOE will study market failures or ot her specific problems that may warrant agency action. DOE will assess the significance of any pr oblem to determine whether a new regulation of BCs and EPSs is warranted. In its initial revi ew of the market, DOE believes that there may be asymmetric information (one party to a trans action has better information than the other) regarding energy-efficiency oppor tunities in the BC and EPS ma rkets. Battery chargers and external power supplies are generally bundled w ith the consumer product applications they power. Consumer purchasing decisions are based pr imarily on the merits of the end-use product and not the BC or EPS packaged with the product.

In most cases, the party responsible for deciding which BC or EPS to use with a particular application is not the consumer who pays the cost of operating it, but rather the OEM, who does not pay the cost of operation. OEMs ma y decide which BC or EPS to package with their product based on the manufacturing cost, not the efficiency of the unit. Because BCs and EPSs are often custom-designed for the applica tion, the end user has li ttle ability to choose a more efficient power source.

There may be certain external benefits resu lting from the improved efficiency of BCs and EPSs that are not captured by users of these devices. These include both environmental and energy security-related effects that are not already reflected in energy prices, such as reduced emissions of greenhouse gases and reduced use of natural gas and oil for electricity generation. DOE seeks comments on the weight DOE should gi ve to these factors when considering the maximum efficiency at which the total benefits ar e likely to exceed the total costs resulting from a new standard level.

Item 19 DOE seeks comments and data from inte rested parties on these and other potential market failures that may apply to BCs and EPSs.

3.4 Technology Assessment
The technology assessment focuses on unders tanding how the product uses energy and how efficiency measures can reduce the energy co nsumption of the BC or EPS. Measures that

44improve the energy efficiency of the product ar e called technology options. These are based on commercially available technologies as well as prototype designs and concepts. In consultation with interested parties, DOE will develop a list of technology options for consideration in this rulemaking. Following research into this list of technology options, DOE will consider each option against four screening criteria: technological feasibility; practicab ility to manufacture, install, and service; adverse impacts on product utility or avai lability; and adverse impacts on health or safety. (See section 4 for a discussion of these screening crite ria.) Technology options that pass the four screening criteria are called design options and will be considered as appropriate ways of improving the efficiency of the product in the engineering analysis.

Unlike other products regulated under the DOE Appliances and Commercial Equipment Standards Program, BCs and EPSs do not provide an end-user function, but rather serve to provide power to consumer products. EPSs convert household AC power to lower-voltage AC or DC power required by electronic ci rcuits. BCs perform a similar f unction, using a battery as an intermediary. The BC first stores energy in the battery, which then powers the consumer product, allowing it to operate without a power cord. The power systems of certain products may include both BCs and EPSs.

DOE is studying technology options that coul d improve the efficiency of the BCs and EPSs covered in this rulemaking. Accordingly, DOE is reviewing manufact urer catalogs, recent trade publications, technical jour nals, and patent filings. To ga ther more information, DOE is conducting manufacturer interviews and consulting with technical experts who have worked on BCs or EPSs.

BC and EPS designs vary according to the maximum output power of the devices, the output voltage, and their intende d application. Because the technology options for efficiency improvement will still need to meet the design requirements of a particular BC or EPS, a discussion of designs and product classes pr ecedes a listing of technology options.

3.4.1 Battery Charger Design Methods of improving BC efficiency depend on whether the BC is a slow charger or a fast charger. The distinction be tween the two types of BCs is based on the charge rate (also referred to as C-rate), often defined as the av erage charging current flowing into the battery, divided by the nominal battery charge capacity. For current expressed in amperes and battery capacity expressed in ampere-hours , the resulting quantity is expre ssed in units of 1/hours or C. For example, a BC with a 0.1 ampere (A) output current charging a 1 ampere-hour (Ah) battery would result in a charge rate of 0.1 C. Charging time is approximately the inverse of the charge rate, adjusted for the efficiency of the battery it self, which varies with chemistry. In the previous example, the battery would take slig htly longer than 10 hours to charge.

DOE considers BCs with charge rates less th an 0.2 C (typically around 0.1 C) to be slow chargers. At this low charge ra te, nickel-based batteries can be charged continuously without concern for excessive battery overheating or safet y. Slow chargers do not typically include cutoff or monitoring circuitry. However, as the battery nears full charge and its voltage increases, the difference between the BC output and battery voltages decreases and the charge-control resistance used in a slow charger will cause the charging current to decrease. This reduces power

45consumption and lessens battery heating due to overcharge (thereby extending battery life). Slow chargers are not typically used in combination wi th lithium-based batteries, because of the safety concerns associated with overcharging these batteries.

Slow chargers are typically composed of a line-frequency transformer followed by a rectifier and charge-control elem ent. The function of the charge-control element is to limit charging current into the battery, which can be accomplished by either a discrete resistor or the parasitic internal resistance of the transformer windings. The power conversion losses in a slow charger are mostly due to magnetization losses in the transformer core steel, resistive losses in the charge-control element, and voltage drops across the rectifier diodes.

In addition, slow chargers typical ly continue to deliver current to the battery even after it is fully charged, usually at a rate much higher than that necessary to maintain the charge lost due to battery self-discharge. The excess power is dissipated as heat in the battery. The power conversion losses identified earlier continue to have an impact in this maintenance mode, further increasing power consumption. Even in no-battery mode, when the battery is disconnected from the charger, the slow charger continues to c onsume significant power du e to the transformer magnetization losses. For a detailed discussion of slow-charger power consumption in all modes, please see sections 3.3 and 3.5 of the draft technical report.

A battery charger that contains monitoring, cu toff, or limiting circuitry can safely charge lithium-based batteries and fast-charge nickel-based batteries. DOE considers BCs with charge rates greater than 0.2 C (typically between 0.6 C and 1 C) to be fast chargers. Because the charge rate of fast chargers is much greater than that of slow chargers, the maximum rated output power of a fast charger can be 5 to 20 times greater th an that of slow chargers, even when charging a battery of the same voltage and capacity. For th is reason, fast chargers typically use switchedmode power supplies (section 3.4.2), which are smaller and light er than line-frequency power supplies. Fast chargers also employ monitoring and cutoff circuitry, as the high currents used during charging may overheat the batt ery and lead to a safety hazar d if not reduced at the proper time. Because of these design differences, fast ch argers are composed of more complex circuits and are susceptible to different loss mechanisms than slow chargers.

The high-frequency switched-mode power suppl y (whether internal or external) that typically performs the energy conversion in a fast ch arger is usually more efficient than the linefrequency transformer and rectifier discussed pr eviously. High-frequency power supplies can use transformer cores made of ferrite that are smaller and more efficient than the steel cores typically found in line-frequency designs. However, there are still conversion losses associated with switching and rectificat ion, as well as fixed overhead losse s associated with powering the integrated circuit (IC) switching controller and any safety circu itry. Also, although fast chargers terminate ( i.e. , limit charging current once th e battery has reached full charge), most chargers continue to supply a small amount of maintena nce current. As with slow chargers, this maintenance current and the associated convers ion losses contribute heavily to maintenancemode power consumption. Finally, even with th e battery removed, the charger can continue consuming significant power due to the overhead of powering the control and safety circuitry mentioned above. For a more detailed discussion of fast-charger power consumption, please see sections 3.3 and 3.5 of the draft technical report.

46Further, manufacturers may, and often do, choose to substitute a fast charger for a slow one as a means of improving portability and ener gy efficiency. Because both types of chargers can often be used with the same battery powerin g the same consumer product, they provide the same utility to the consumer, which sometimes means the fast charger can be considered an option for the baseline slow charger.

Finally, because changes in ba ttery temperature and voltage happen more slowly at lower charge rates, monitoring circuitry that depends on these changes to stop the charging process is typically not sensitive enough to be used atrates below 0.3 C. Therefore, although DOE differentiates between BCs with charge rates greater than or less th an 0.2 C, DOE does not expect to find many BCs with charge rates between 0.15 C and 0.3 C.

Item 20 DOE seeks comments on whether the 0.2 C charge-rate division between slow and fast chargers is appropriate and seeks detailed information regarding the typical charge rates for both categories of BCs.

3.4.2 External Power Supply Design To power a consumer product, EPSs must meet numerous specifications; of these, output power and output voltage have the largest impact on EPS efficiency. Together, the output power and voltage determine the current, which ha s the greatest impact on conduction losses and associated power dissipation in the EPS. 20 EPSs are generally designe d to provide power at a fixed output voltage with variable current to a consumer product.

The consumer product powered determines the EPS design criteria, including output power, output voltage, and the tolerance of the output voltage. EPSs designed for consumer products that require precise voltages ( e.g. , computers) will incorporat e output voltage regulation to minimize voltage fluctuations caused by load or power source variations. Other applications that can tolerate some voltage fluctuation may use simpler EPSs, with no regulation of the output voltage.

In these unregulated line-frequency EPSs , the two main sources of loss are the transformer and the rectifying diodes. A transformer consists of two wires wrapped around a metal core. As current passes th rough the primary wire, power is transferred to the secondary wire (usually at a lower voltage) th rough magnetic induction in the core. 21 The quality of the metal core, the intensity of magnetic induction, and the gauge of the wires determine transformer losses. The transformer secondary current then pa sses through rectifier diodes that have voltage drops that also cause losses. Typically, diodes have a drop of 0.6 volts; this fixed voltage drop constitutes a larger share of the losses at lower voltages.

20 The draft technical report discuss es conduction losses in more detail.
21 Magnetic induction is is the coupling of the magnetic fields surrounding the primary and secondary windings, allowing the transfer of power from one to the other without a galvanic ( i.e. , conductive) connection between the
two.

47To achieve voltage regulation, one can add a second stage, such as a linear regulator, to the line-frequency power conversion stage desc ribed above, or redesign the power conversion stage entirely, using a switched-mode design or topology. Because the AC/DC conversion stage of a regulated line-frequency EPS is essentially the same as that of an unregulated EPS, it has the same loss mechanisms. The linear voltage regula tion stage adds to thes e losses by passing power from the AC/DC converter to the consumer pr oduct through a power-dissipating element. This regulation stage senses the output voltage and adjusts the curren t flowing through it to keep the output voltage proportional to a fixed reference. Loss in a regulated line-frequency EPS is caused by the conversion stage delivering current at a higher voltage than needed by the consumer product, and dropping the excess voltage across the regulator to achieve the (lower) regulated output voltage. The power lost in the regulator is the product of the voltage drop and the load current and is dissipated as heat.

A switching regulator can also follow the line-frequency AC/DC power-conversion stage, in place of the linear regulator described above. These tend to be much more efficient than linear regulators because they do not dissipate excess po wer through a linear control element. Rather, they switch the output at high frequency, adju sting the proportion of “on” time during each switching cycle ( i.e. , the duty ratio) to maintain the regul ated output voltage proportional to a fixed reference. Due to their higher costs, these switching regulators are not as common as linear regulators.

The unregulated and two-stage regulated EPSs discussed above are called line-frequency EPSs because the frequency of the current passing through their transformers is the same as that of the AC mains current (nominally 60 Hz in the United States). Switched-mode power supplies (SMPS) convert power differently than line-freq uency EPSs. SMPSs first rectify the AC mains current to high-voltage DC, conve rting it back to AC by switchi ng the current on and off at high frequencies. The high-voltage, high-frequency AC current th en passes through the primary winding of a transformer while the output from the secondary winding of the transformer is rectified, resulting in a low-voltage DC output. B ecause of the high frequency of the AC current passing through the transformer, the transformer can be made smaller, resulting in lower losses, weight, and material costs, all of wh ich decrease with transformer volume.

Although DOE is aware of unregulated switche d-mode power supplies used for specific applications, most switched-mode EPSs are regulated. In these E PSs, the output voltage signal is used to control the primary-side switching elem ent, taking power from mains to match the needs of the consumer product load and main taining a constant output voltage.

The critical elements in a switched-mode EPS are the transistor, output rectifier, transformer, and controller. A transistor acts as a switch that constrains the flow of power into the transformer, through the out put rectifier and, ultimately, to the consumer product. A controller, typically an IC, sens es the output voltage of the E PS and switches the transistor on and off at frequencies in the kilohertz range. By adjusting the duty ratio, th e IC controls both the average current through the primary winding of th e transformer and the output voltage of the EPS.

48Further, the IC can greatly increase efficiency by reducing power consumption in no-load mode, the condition when the EPS has been disconn ected from the load, resulting in zero output current. The IC can also limit power dissipation in active mode by switching the transistor during the lowest portions of its current or voltage wavevorms. As before, the power lost in the transistor is proportional to the product of current and voltage, so performing the transistor state transition when either quantity is zero significantly decreases losses.

After passing through the transformer, the curre nt is rectified and f iltered before reaching the consumer product. Principal sources of lo ss in a switched-mode EPS are the transistor switching transients, transistor magnetizati on and resistive losses, controller IC power consumption, and rectifier losses. Although the numb er of different source s of loss is higher in switched-mode EPSs than in line-frequency EPSs , the total power lost in switched-mode EPSs tends to be lower. (See section 3.7.2 for more discussion on the efficiency of switched-mode EPSs.)

3.5 Measuring Efficiency

An evaluation of the effectiveness of technol ogy options for efficiency improvement and the tradeoffs between them depends heavily on the measures used to quantify the efficiency of BCs and EPSs. DOE has already adopted test pr ocedures for measuring the energy consumption of both BCs and EPSs. This section presents a br ief discussion of the test procedures and any issues related to the test procedures that may affect the energy conservation standards rulemaking.

Within this document, the term “energy consum ption” is used loosely to refer to power dissipation or power consumption of BCs and EPSs in one of th eir several modes. Likewise, “efficiency” can mean EPS active-mode efficien cy or BC energy ratio, both discussed in the following sections. More generall y, “efficiency” can also refer to the energy consumption of a BC or EPS against that of comparable devices in any of their modes.

3.5.1 Measuring Battery Charger Efficiency On December 8, 2006, DOE adopted a test met hod to measure the efficiency of battery chargers (section 1.2.1). 71 FR 71340. This test method, based on the U.S. Environmental Protection Agency’s (EPA) ENERGY STAR “T est Methodology for Determining the Energy Performance of Battery Charging Systems,” integrates the power consumed by BCs in maintenance and no-battery modes over fixed periods of time. This “nonactive energy” is divided by the battery energy, measur ed at a discharge rate of 0.2 C, resulting in an energy ratio. Normalizing by battery energy is meant to accoun t for proportionally higher losses in chargers intended for higher-energy batteries. A higher energy ratio represents higher BC nonactive energy consumption.

However, in the December 8, 2006, Test Procedure Final Rule, DOE stated that it intended to study further BC active mode energy cons umption and reserved a section in the test procedure (section 4(b) of appendix Y to subpart B of 10 CFR Part 430) to cover active mode energy consumption. 71 FR 71340, 71360. DOE is currently developing an approach for measuring BC active— i.e. charging—mode energy consumpti on and is considering adopting a

49test procedure that would return multiple metr ics that would correspond to energy consumption in each of the modes of operation of a BC.

Under this approach, these separate metrics would then be weighted during the energy use and end-use load characterization (section 6) to reflect the typical usage of BCs in each product class. The potential energy conservation standards for each class would likewise be written in terms of a single metric even though th e test procedure would measure consumption in each of the modes separately. Ma nufacturers would then be free to trade power consumption in one mode for another as long as they meet the mode-weighted power consumption required by the standard.

Also, in a separate rulemaking, DOE amended the BC test procedure, adding measurement of power consumption during off m ode and standby mode for BCs. As presented in the test procedure final rule, standby mode is de fined as the condition where the BC is connected to mains, the battery or product with an integr al battery is disconnected from the charger, and any on-off switches are turned on. Off mode is defi ned to be applicable only to BCs with on-off switches, and is the same condi tion as standby mode, with the cav eat that all on-off switches are off. Because both off mode and standby mode are nonactive modes, this standby and off mode final rule did not expand the test procedure to measure energy consump tion in active mode. 74 FR 13334.

Item 21 Although DOE intends to revisit this issue in the future, its test procedure does not currently measure active-mode energy consumption. Nonetheless, DOE seeks comments on how it can best account for energy consumed during active mode.

Item 22 DOE seeks comments on how DOE could, in a future rulemaking, amend its BC test procedure to measure en ergy consumption in active mode.

3.5.2 Measuring External Power Supply Efficiency On December 8, 2006, DOE codified a test procedure final rule for EPSs in appendix Z to subpart B of 10 CFR Part 430 (“Uniform Test Method for Measuring the Energy Consumption of External Power Supplies”). 71 FR 71340. DO E’s test procedure, based on the ENERGY STAR EPS test procedure, measures active-m ode efficiency and no-load-mode (standby-mode) power consumption. In the standby and off mode test procedure NOPR for BCs and EPSs, 73 FR 48054 (August 15, 2008), DOE proposed to amend the EPS test procedure to add a measurement of power consumption in off mode, where, if th e EPS has an on-off switch, the EPS is connected only to mains and the switch is turned off. These amendments were included in the final rule, published March 27, 2009. 74 FR 13335.

Active mode conversion efficiency is the ratio of output power to input power. DOE averages the efficiency at four loadin g conditions—25, 50, 75, and 100 percent of maximum rated output current—to assess th e performance of an EPS when powering diverse loads. DOE also measures the power consumption of the EPS when disconnected from the consumer product, which is termed no-load power consumption. DOE combines both of the above metrics into

50“matched pairs” that describe the CLSs used in setting potential energy conservation standards, discussed further in section 5.1.

3.6 Product Classes
When necessary, DOE divides covered products into classes by the type of energy used, the capacity of the product, and any other perfor mance-related feature th at justifies different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE then conducts its analysis and consid ers establishing or amending standards to provide separate standard levels for each product class. In th is section, DOE summarizes the various product classes used by EISA, ENERGY STAR, and the draft analysis prepared by DOE for the determination in 2007. (See section 3.6 of the draf t technical report for details on these product classes.)

3.6.1 Battery Charger Product Classes There are several capacity- and performance-related features of a BC that could be used for classification, including th e charging method it uses (conti nuous charging or terminating charging), the charge rate, the vol tage or capacity of the battery or batteries char ged, and/or the battery chemistry.

For example, ENERGY STAR uses product cl asses for battery charging systems based on the voltage of the batteries or battery pack s they charge. The ENERGY STAR specification contains 20 product classes, from 1.2 volts to greater than 24 volts, in 1.2 volt increments. ENERGY STAR does not distinguish among batt ery charging systems by charging method, charge rate, battery capacity, or battery chemistry. There are no State or international standards for BCs.

In conducting the determination analysis mandated by EPACT and superseded by EISA, DOE divided battery chargers in to product classes based on battery voltage. This characteristic, more than any other, impacts the performance and utility of the battery ch arger. Battery voltage has a large impact on attainable battery charge r efficiency as well as the opportunities for efficiency improvement. Furthermore, a BC desi gned for one battery voltage cannot be replaced with one designed for another, as it is the consumer product app lication that se ts the battery voltage.

Although one cannot easily exchange a fast ch arger for a slow one without significantly affecting consumer utility, the same cannot be said of the converse. In fact, exchanging a slow charger that uses a line-frequency power supply for a fast charger with a switched-mode power supply was a technology option fo r improving efficiency (section 3.7) that manufacturers identified during interv iews held in 2007.

Additionally, class divisions based on battery voltage permitted DOE to analyze the different technological paths to energy-efficiency improvement in the major categories of BCs for consumer products. For example, most chargers for personal-care applications ( e.g. , shavers, beard trimmers, etc.) have an out put voltage less than 3 V, while those for power tools have an

51output greater than 9 V. Using pr oduct class divisions based on voltage would, therefore, allow DOE to account for the varied usage of chargers for diverse consumer product applications by differentially weighting their energy consum ption in each mode based on the usage. Table 3.7 shows the product classes used in the determin ation analysis, while se ction 3.6.2 of the draft technical report describes them in detail.

Table 3.7. Battery Charger Product Classes Developed for the Draft Determination Analysis

Battery Voltage Product Class 0 V through 3 V A >3 V through 9 V B >9 V through 48 V C

Item 23 DOE seeks comments on BC product class divisions, including whether battery voltage is the appropriate product classification criteri on, and/or whether DOE should take into account other factors, such as charge rate, battery capacity, or battery chemistry.

3.6.2 External Power Supply Product Classes Output power and output voltage have the la rgest impact on achievable EPS efficiency (section 3.5.2); consequently, DOE is considering one or both of these criter ia in developing EPS product classes for its preliminary analyses. DOE is reviewing EPS product classes created by EISA, ENERGY STAR, and manufact urers to determine what ro le output power and voltage play in their definitions. EISA defines Class A EPSs and sets efficiency standards by EPS output power. Version 1.1 of the ENERGY STAR specification only cons idered EPS output power but Version 2.0 considers output pow er, input power, conversion type (AC/DC versus AC/AC), and output voltage.

In a previous analysis pres ented in section 3.6.1 of the draft technical report, DOE developed product classes by output power and out put voltage based on ma nufacturer input. In this section, DOE summarizes these methods for establishing product classes and seeks comments from interested parties in developing product classes for its preliminary analyses.

As mentioned in section 1.1, EISA amended EPCA, esta blishing energy conservation standards for Class A External Power Supplies that became effective on July 1, 2008. These energy conservation standards divide Class A E PSs into three product classes based on rated nameplate output power (in watts): less than 1 watt, 1–51 watts, inclusive; and greater than 51
watts. Table 3.8 shows the classes and energy cons ervation standards established by EISA.

52Table 3.8. EISA Efficiency Standards for Class A EPSs

Nameplate Output Active-Mode Required Efficiency (decimal equivalent of a percentage)

<1 watt 0.5 times the nameplate output
1 to 51 watts The sum of 0.09 times the natural logarithm of the nameplate output and 0.5
>51 watts 0.85

Nameplate Output Maximum No-L oad-Mode Power Consumption

No more than 250 watts 0.5 watts

Section 321 of EPCA, as amended by secti on 301 of EISA, defines a Class A External Power Supply as a device that (1 ) is designed to convert line volta ge AC input into lower voltage AC or DC output; (2) is able to convert to only one AC or DC output voltage at a time; (3) is sold with, or intended to be used with a sepa rate end-use product that constitutes the primary load; (4) is contained in a separa te physical enclosure from the end-use product; (5) is connected to the end-use product through a removable or hardwired male-female electrical connection, cable cord, or other wiring; and (6) has nameplate output power that is less than or equal to 250
watts.

As such, the product classes listed in Table 3.8 do not apply to EPSs with output power greater than 250 watts or with multiple simu ltaneous output voltages. The statute further excludes any device that: (I) requ ires Federal Food and Drug Ad ministration listing and approval as a medical device in accordan ce with section 513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c); or (II) powers the charger of a detachable batte ry pack or charges the battery of a product that is fully or pr imarily motor operated.” All pro ducts that are excluded or not covered under the definition of “Class A External Power Supply” will be evaluated under the determination analysis for non-Class A EPSs required by EPCA, as amended by EISA. See 42 U.S.C. 6295(u)(1)(E).

This topic is discussed further in section 3.2.1. In the context of this section, DOE seeks comment on how to extend the product-class divisi ons for Class A EPSs, introduced by EISA, to non-Class A EPSs, or how to create novel pr oduct-class divisions for non-Class A EPSs.

Item 24 DOE seeks comments on creating potential product class divisions for EPSs excluded from the EISA definition of Class A.

The ENERGY STAR program for EPSs, led by EPA, created the first EPS specification in 2004 (Version 1.1), and the produc t classes set forth by ENERGY STAR have affected other programs since. On April 23, 2008, EPA issued its ENERGY STAR specification Version 2.0 for EPSs, where it presented two product class structures ( Table 3.9 and Table 3.10) based on

53output power and output voltage as well as output current, input power, power factor, and conversion type (AC/AC or AC/DC). 22

Table 3.9. ENERGY STAR Version 2.0 Ac tive-Mode EPS Product Classes

Model Type Nameplate Output Power
≤ 1 Watt 1–49 Watts >49 Watts Low-Voltage Models* A B C
Standard Models D E F *Low-voltage models have output voltage of less than 6 volts and an output current greater than or equal to 550 milliamps.

Table 3.10. ENERGY STAR Version 2.0 No -Load-Mode EPS Product Classes

Conversion Type Nameplate Output Power
<50 Watts ≥ 50 Watts

AC/AC Converters W X
AC/DC Converters Y Z

These product classes are based on the Version 1.1 product classes, which divide EPSs at a no-load-mode consumption of 10 watts and output power of 1 and 49 watts. Version 2.0 retained these product-class divi sions based on feedback from interested parties. Based on additional feedback, ENERGY STAR also cr eated separate product classes for AC/AC converters, low-voltage units , and high-input-power units. 23

Input from interested parties also prompted ENERGY STAR to create a separate no-load power consumption specification for AC/AC EPSs because those converters are typically limited to line-frequency architectures and cannot meet the same no-load power consumption levels as switched-mode AC/DC EPSs. Additionally, the proposed ENERGY STAR Version 2.0 Program Requirements set a less stringent specification for low-voltage units with an “output voltage less than 6 volts and an output current greater than or equal to 550 milliamps.” 24 Interested parties sought a separate product class for low-voltage EPSs because, for the same power, lower output voltages result in higher currents and associat ed conduction losses. Lower voltage EPSs are further affected by proportionally greater losses du e to voltage drops in the output rectifier.

Finally, interested parties prompted ENER GY STAR to include minimum power factor and efficiency requirements for high-power E PSs with input power of 100 watts or greater, where the power factor is the ratio of real power to total power drawn by the EPS. Due to

22 “ENERGY STAR® Program Req uirements for Single Voltage External Ac-Dc and Ac-Ac Power Supplies Eligibility Criteria (Version 2.0) Revise d Final Draft.” April 2008. Available at www.energystar.gov/ia/partners/prod_development/revisions/downloads/Spec.pdf

. 23 “Cover Letter to Accompany Final Dr aft of EPS Specification Version 2.0. ” February 19, 2008. Available at www.energystar.gov/ia/partners/prod_development/revisions/downloads/CoverLetterV2.pdf

. 24 “ENERGY STAR Program Requirements for Single Voltage External Ac-Dc and Ac-Ac Power Supplies Eligibility Criteria (Version 2.0) Revise d Final Draft.” April 2008. Available at www.energystar.gov/ia/partners/prod_development/revisions/downloads/Spec.pdf

.

54nonlinear and energy-storage circ uit elements such as diode s and inductors, respectively, electrical products often draw currents that are not proportional to the line voltage. These currents are either distorted or out of phase in relation to the line voltage, resulting in no real power drawn by the EPS or transmitted to the lo ad. However, although the EPS itself consumes no real power, these currents are real and cause power dissipation from conduction losses in the transmission and distribution wiring. For a gi ven nameplate output pow er and efficiency, products with a lower power factor cause greater power dissipation in the wiring, an effect that also becomes more pronounced at higher input powers. Therefore, in light of these concerns, ENERGY STAR, through Version 2.0, limits the power factor of EPSs with an input power of 100 watts or greater, effectively creating an additional product class division based on input power.
Taking into consideration the ENER GY STAR Version 1.1 specification and manufacturer suggestions, DOE developed pr oduct classes based on output power for its determination analysis, presented in section 3.6.1 of the draft technical report. DOE divided the EPSs into low-, medium-, and high-power units, with the boundaries at 4 and 60 watts nameplate output power. Based on manu facturer inputs, DOE expected EPSs in each product class to share design characteristics that woul d affect the cost of increasi ng active-mode efficiency and decreasing no-load power consumption. For exam ple, DOE did not expe ct low-power switchedmode EPSs with output power of less than 4 watts to contain a controller IC , due to the high cost of an IC in relation to the total cost of the E PS. Because an IC is necessary for reducing power consumption at light and no load through such strategies as cycle-ski pping, the high proportional cost of an IC would lead to an increased co st of improving no-load power consumption for lowpower EPSs.

Similarly, DOE expected EPSs with output pow er greater than 60 watts to exhibit a twostage circuit architecture with active power factor correction (PFC), which is necessary for meeting power-factor requirements under the Eur opean Union Code of Conduct, a voluntary agreement of EPS manufacturers described later in Appendix F Due to the global nature of the EPS market, these requirements would affect the design of and cost-efficiency relationship for high-power EPSs in the United States.

However, after analyzing 32 EPSs with outpu t power less than 6 watts and 18 EPSs with output power greater than 50 watts, DOE was un able to find support for power level product class divisions. There were no clear thresholds at which manufacturers would begin to use controller ICs or PFC circuitry. Therefore, although DOE recognizes the important role of ICs and PFC in EPS design and anticipates further an alysis of these criteria, it is not currently considering EPS product classes related to these criteria.

In interviews held in 2007, manufacturers also suggested that DOE differentiate the EPS product classes by output voltage in addition to output power. This is because when comparing EPSs with the same output power, EPSs with lower output voltages have higher conduction and diode-drop losses that pose addi tional challenges to achieving high efficiency. To address this situation, manufacturers suggested that DOE further subdivide its product classes by output voltage, with a division at 12 volts, which is the point where the appr oximately 0.6-volt diode drop results in losses equal to 5 percent of the output voltage Table 3.11 presents the product

55classes that DOE used in its determination analys is and described in detail in section 3.6.1 of the draft technical report.

Table 3.11. Product Classes Used in the EPS Determination Analysis

Nameplate Output Voltage Nameplate Output Power
<4 Watts 4–60 Watts >60 Watts

<12 volts A B C

≥ 12 volts D E F

Item 25 DOE seeks comments on whether to consider the presence of ICs or PFC circuitry in developing product classes for EPSs.

Item 26 DOE seeks comments on how to cons ider output voltage in developing product classes, and how the low-voltage divi sion should vary with EPS output power.

Class A EPSs represent the vast majority of EPSs manufactured and sold. This group encompasses a broad range of products with ma ny different designs and end-use utilities and applications. DOE is considering a few possibl e approaches concerning EPS product classes. Two options include: (1) subdivi ding the EISA Class A standa rd product classes, which are based on output power, into even narrower product classes that take in to account unit output voltage; or (2) establishing new product classes based on output power divi sions different from what the Class A EISA standard uses. Based on co mments from interested parties, DOE may use one of these two approaches, modify one approa ch, or use an entirely different Class A EPS product class structure for the preliminary analyses.

Item 27 DOE seeks comments on the possible approaches discussed concerning EPS product classes, and invites interested par ties to propose alter native approaches and/or other factors DOE should consider in devel oping product classes for the preliminary analyses.

As discussed earlier, EPCA, as amended by EISA, also requires DOE to conduct a determination analysis that considers EPSs other than Class A. While conducting the determination analysis, DOE may define addition al classes of EPSs, for example, EPSs with nameplate output power greater than 250 watts and EPSs that are ab le to convert to more than one AC or DC output voltage simultaneously. If the determination is positive, standards for certain additional classes of EPSs may be considered under the sc ope of this energy conservation standards rulemaking.

56Item 28 DOE seeks comments on how the product classes it is considering for Class A EPSs may apply to non-Class A EPSs and whether there are particular issues DOE needs to take into account.

Item 29 DOE seeks comments on all aspects of the product classes it is considering for BCs and EPSs, as well as any other met hods for establishing product classes in accordance with the requirem ents of 42 U.S.C. 6295(q).

3.7 Technology Options for Efficiency Improvement

3.7.1 Battery Charger Technology Options The following list, organized by charger ty pe, provides preliminary technology options that DOE intends to evaluate during the prelim inary analyses. A detailed discussion of the specific technology options can be found in sec tion 3.8.2 of the draft te chnical report. Although many of these technology options could be used in both fast and slow chargers, doing so may be impractical due to the cost and benefits of each option for the tw o types of chargers. Therefore, in the list below, the options are grouped with the charger type where they would be most practical.

Slow charger technol ogy options include:

 Improved Cores : The efficiency of line-frequency transformers, which are a component of the power conversion circ uitry of many slow chargers, can be improved by replacing their cores with ones made of lower-loss steel.

 Termination : Substantially decreasing the charge current to the battery after it has reached full charge, either by using a tim er or sensor, can significantly decrease maintenance-mode power consumption. Because most slow chargers have a charge rate of approximately 0.1 C, and maintena nce-mode current below 0.05 C is typically sufficient to keep a battery fully charged, a slow charger that employs termination can roughly halve its maintenance-mode power consumption.

 Elimination/Limitation of Maintenance Current : Constant maintenance current is not required to keep a battery fully charged. In stead, the BC can provide current pulses to "top off" the battery as needed. Elimination or limitation of maintenance can decrease maintenance-mode power consumption even further and has the added benefit of extending the battery lifetime by reduc ing heating due to overcharge.

 Elimination of No-Battery Current : A mechanical AC line switch inside the battery charger "cup" automatically disconnects the BC from the mains supply when the battery is removed from th e charger. Although manual ( i.e. , user-controlled) switches are also possible, this method guarantees that the BC ceases to consume power once the battery is removed from the battery charger.

57 Switched-Mode Power Supply : To increase efficiency, line-frequency power supplies can be replaced with switched-mode EPSs, which greatly reduce the biggest sources of loss in a line-frequency EPS: the tr ansformer. Because a switched-mode EPS operates at high frequency (gre ater than 20 kHz), its transf ormer can be smaller, and because transformer losses are a function of volume, a smaller transformer is usually more efficient. It is worth noting that this technology option is not often found in practice, because the inclusion of a sw itched-mode power supply within the BC design allows the higher pow er levels necessary for fast charging. The universal consumer preference for shorter charging times limits the occurrence of slow chargers with high-frequency switched-mode power supplies.

Fast charger technology options include:

 Low-Power Integrated Circuits : The efficiency of the BC's switched-mode power supply can be further improved by substituti ng low-power IC controllers, which can switch more efficiently in active mode and reduce power consumption in no-load mode. To increase efficiency in active mode , the IC controller can decrease switching transients through zero-voltage or zero-cu rrent switching. Furthermore, the IC can turn off its start-up current (sourced from the primary side of the power supply) once the output voltage is stable. In addition, when in no-load mode, the IC can turn off the switching transistor for extended periods of time (termed "cycle-skipping").

 Elimination/Limitation of Maintenance Current : See above.

 Schottky Diodes and Sync hronous Rectification : Both line-frequency and switchedmode EPSs use diodes to rectify output voltage. Schottky diodes and synchronous rectification can replace standard diodes to reduce rectification losses, which are increasingly significant at low voltage. Schottky diodes ar e rectifiers constructed from a metal-silicon junction rather than a p-n silicon junction and have a voltage drop of 0.3–0.4 volts, compared to approximately 0.6 volts for standard p-n junction diodes. Synchronous rectification (which is typically used only in switched-mode EPSs) further reduces losses by substituti ng field-effect transistors (FETs) for the diodes. The voltage drop across the drain-to -source resistance of the FET is much lower than that of a Schottky diode, leadi ng to lower losses in the output rectifier.

 Elimination of No-Battery Current : See above.

 Phase Control to Limit Input Power : Even when a typical BC is not delivering its maximum output current to the battery, its power conversion circ uitry continues to draw significant power. A phase control circu it, like the one present in most common light dimmers, can be added to the primar y side of the BC power supply circuitry to limit input current in lower-power modes.

584 3.7.2 External Power Supply Technology Options The technology options under consideration that may improve the efficiency of EPSs, as discussed in section 3.4.2, are listed below. Because many of the technology options are the same as those for BCs, please refer to the discussion in section 3.7.1 for additional details.

 Switched-Mode Power Supply : Unlike battery chargers (see above), line-frequency EPSs often use linear regulators to maintain a constant output voltage. By using a switched-mode circuit architecture, a desi gner can limit both losses associated with the transformer and the regulator.

 Low-Power Integrated Circuits : See Battery Charger Technology discussion above.

 Schottky Diodes and Sync hronous Rectification : See Battery Charger Technology discussion above.

 Low-Loss Transistors : The switching transistor dissipa tes energy due to its drain-tosource resistance ( R DS_ON ) when the current flows th rough the transistor to the transformer. Using transistors with low R DS_ON can reduce this loss.

 Resonant ("Lossless") Snubbers : In switched-mode EPSs, a common snubber protects the switching transistor from the high voltage spike that occurs after the transistor turns off by dissipating that power as heat . A resonant or lossless snubber recycles that energy rather than dissipating it.

Item 30 DOE seeks comments on the preliminary t echnology options identified in this section and whether there are other technol ogy options it should consider. In commenting on design options, please disc uss their impacts, if any, on safety, performance, and consumer utility.

SCREENING ANALYSIS

The purpose of the screening analysis is to screen out technology options that DOE will not consider in the rulemaking for BCs and EPSs . DOE uses the following process to perform this screening.

DOE starts by developing a list of tec hnology options, developed through its own research and in consultation with interested partie s, for consideration in the engineering analysis (section 5). The identified candidate technology options or best available technologies will encompass all those technologies that may be technologically feasible. DOE then reviews each technology option or best available technology in li ght of the following four criteria, as provided

59in sections 4(a)(4) and 5(b) of the Process Rule. 25 These criteria have been tailored to the current rulemaking:

(1) Technological feasibility : DOE will not consider technologies that are not incorporated in commercially availa ble products or wo rking prototypes.

(2) Practicability to manufactu re, install, and service : If DOE determines that mass production of a technology in commercial products and reliable installation and servicing of that technology could not be achieved on the scale necessary to serve the relevant market by the time of the eff ective date of the standard, it will not consider that technology further.

(3) Adverse impacts on product or eq uipment utility or availability : If DOE determines that a technology has a significan t adverse impact on the utility of the product to significant subgroups of consumers, or results in th e unavailability of any covered product type with performance characteristics (including reliability), features, size, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not consider that 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 that technology further.

DOE will document its reasons for eliminating any technology option during the screening analysis, and will provide this docum entation for review and comment by interested parties as part of the preliminary TSD. DOE will call those technology options that are not screened out by the above four criteria “design options” and will consider these options in the development of cost-efficiency curv es in the engineering analysis.

Item 31 DOE seeks comments on how the four sc reening criteria might apply to the technology options di scussed in section 3.7, as well as any additional technology option(s) that an interested party recommends to DOE.

As previously discussed, DOE is consider ing replacing line-frequency EPSs with switched-mode EPSs as a technology opti on. However, DOE acknowledges that the two technologies may not have equiva lent utility for certain appl ications. Although switched-mode EPSs attempt to filter the electrical nois e from their high-frequency switching, some highfrequency currents may still be present on their input or output lines, where they may interfere with nearby electronic equipment, including the load connected to the EPS. DOE has learned that certain medical, radio, and media player app lications could suffer from electromagnetic interference when supplied by a switched-mode E PS instead of a line-frequency EPS. Because

25 10 CFR Part 430, Subpart C, App endix A.

60switched-mode EPSs typically include more prot ections against short circuit and overcurrent conditions, some manufacturers have also report ed difficulties when using a switched-mode EPS in place of a line-frequency EPS in high-current applications.

Item 32 DOE seeks comments on any consumer product applications which require use of a line-frequency EPS, and which coul d not accommodate use of a switched-mode EPS.

5 ENGINEERING ANALYSIS

After conducting the screening analysis described above, DOE will perform an engineering analysis based on the remaining de sign options for efficiency improvement. The engineering analysis consists of estimating th e energy consumption and cost of products at various levels of increa sed efficiency. Section 5.1 provides an overview of the engineering analysis. Section 5.2 discusses the representative units selected for BCs and EPSs. Section 5.3 describes DOE’s proposed approach to the en gineering analysis fo r both products. Section 5.4 addresses proprietary designs, and section 5.5 discusses cumulative regulatory burdens that might affect the engineering analysis.

5.1 Engineering Analysis Overview
The purpose of the engineering analysis is to determine the relationship between BC and EPS efficiency and manu facturer selling price. 26 This relationship serves as the basis for the underlying costs and benefits to individual consumers (section 8, LCC analysis) and the Nation (section 10, national impact analysis (NIA)). The output of the engi neering analysis provides the manufacturer selling price at sele cted, discrete candidate standard levels (C SLs) of efficiency. CSLs are generally based on (1) design options asso ciated with the specific units being analyzed; (2) other voluntary specifications or mandatory standards that cause manufacturers to develop products at particular efficien cy levels; and (3) the maximum technologically feasible level. 27 For example, DOE often considers th e ENERGY STAR level as one CSL.

DOE begins the engineering analysis by id entifying the representative product classes and selecting one representative unit for analysis from each of the representative product classes. DOE presumes that findings relating to the represen tative unit are applicable to all the units in its product class. Later, the NIA scales the analytic al findings for each representative unit to other units in the same representative product class, and from the representative product class to other product classes that DOE did not explicitly analyze.

The analysis of the representa tive unit begins with the ba seline CSL, which models the most common, least-efficient devices in a product class. Once DOE selects the representative units and establishes baseline CSLs, it may choose one or more possible appro aches to arrive at a

26 This price, which is what manufa cturers charge distributors and retailers, forms the basis for the price consumers eventually pay.
27 The “max tech” represents the most efficient design that is commercialized or has been demonstrated in a prototype with materials or technologies available today. “Max tech” is not constraine d by economic justification, and typically is the most expensive design option considered in the engineering analysis.

61manufacturer selling price for re-designed device s that match the performa nce characteristics of the representative unit at the baseline CSL, but which have a higher efficiency. DOE has used the following four approaches in prior rulemakings:

(1) Examination of published pr ices and efficiency results : For certain products, prices can be obtained from manufacture r or distributor cat alogs. For prices obtained from catalogs, DOE would apply appropriate di scounting to account for distributor markup, and catalog prices are typically prov ided at volumes several orders of magnitude lower than those used in typical production. Using these data, DOE will estimate the manufacturer selling price. Similarly, the results of efficiency tests can often be obtained from manufacturer or di stributor literature or from the test databases of other regul atory agencies. This approach examines only commercially available products and may not provide information about the most efficient designs.

(2) Testing and teardowns : DOE can purchase commercia lly available products and conduct its own efficiency tests followed by teardowns ( i.e. , disassembly of the product to obtain a bill of materials (BOM) and valuati on of components). In this approach, sometimes called “reverse engineering,” DOE estimates the manufacturer selling price from the re sulting BOM and estimated manufacturer markups. DOE examines only commercially available products; therefore, this approach may not provide information about the most efficient designs.

(3) Efficiency level approach : DOE interviews product manufacturers, requesting estimates of the manufacturer selling pri ce for commercially available as well as theoretical units at several CSLs. When providing these data, usually under a nondisclosure agreement, manufacturers ch aracterize their least-cost-path to efficiency at each CSL for which DOE requests data. Manufacturers also generally provide some information on the design options used.

(4) Design option modeling : In this approach to the engineering analysis, DOE develops or subcontracts pr oduct design software that simulates the efficiency of incorporating various combina tions of design options into the representative unit. In this approach, the manufacturer selling price at a particular CSL is based on the component costs ( i.e. , BOM) of the design options necessary to achieve it. DOE obtains component costs from public a nd private sources and confirms the information during the manufacturer interviews.

Although DOE may use information about design op tions to help select a particular CSL, the CSLs themselves are not technologically pr escriptive and manufacturers are free to use any combination of design options to achieve the efficiency of a given CSL.

Another important consideration in developi ng CSLs for EPSs is the use of “matched pairs” of active-mode efficiency and no-load -mode power consumption. CSLs based on matched pairs consist of simultaneous requirements of minimum active-mode efficiency and maximum no-load power consumption, instead of a single re quirement based on some integrated efficiency metric. Matched pairs allow DOE to base CSLs on existing EPS specifications or standards, such

62as those developed by ENERGY STAR. As these CSL “matched pairs” progress from least to most efficient, either one or both metrics ( i.e. , active-mode efficiency and no-load mode power consumption) increase in stringency. By preventing a decrease in the stringency of these metrics, DOE makes a tacit assumption that there is no trade-off between EPS performance in the two modes, and increasing the energy savings in one mode does not necessarily cause a decrease in energy savings in the other.

Item 33 DOE seeks recommendations on possibl e candidate standard levels to use when analyzing EPSs and BCs.

5.2 Representative Product Classes and Units

Once DOE establishes its product classes for BCs and EPSs, it needs to determine which to study in the engineering analysis, i.e. , whether to analyze all the product classes, or select a few representative product classe s to study and then scale the fi ndings from those product classes to the remainder. Representative product classe s are typically chosen to encompass those types of devices that have the highest market share or some performance characteristic that deserves special consideration.

Within each of the representative product cla sses, DOE then selects a representative unit, which is the theoretical BC or EPS that DOE will study in the engineering analysis. The representative unit is a theoretical unit specified by characteristics such as battery voltage, charge rate and battery capacity for BCs , or output power and output volta ge(s) for EPSs, among others. These characteristics determine the usability of the BC or EPS with a particular end-use product application. As long as they are constant betw een two BCs or EPSs, these power converters are assumed to be interchangeable, providing consumers with the same utility. Characteristics such as costs and efficiency are variable, allowi ng DOE to calculate the relationship between improvements in efficiency and material costs, while maintaining constant utility. In other words, these units serve as reference points ag ainst which DOE can measure changes resulting from potential energy conservation standards.

DOE develops a separate engineering analysis for each representative unit. Selection of the representative unit is a critical aspect of DOE ’s analytical process, because this unit is meant to represent the characteristics of common or typical products sold in a given product class. Following selection, DOE evaluates the cost of the representative unit at a baseline efficiency level and any changes in cost necessary for the unit to meet the higher CSLs. The baseline representative unit is of ten selected to just meet the curren t energy conservation standard, as is the case for Class A EPSs. However, there are no standards in place for BCs. Therefore, DOE will select representative units typical of the most common or l east efficient products offered for sale in the market as the baseline for its analysis.

Once DOE has completed its engineering and su bsequent life-cycle cost analyses on the representative units, the results wi ll be scaled from the representa tive units to the representative product classes, and from those pr oduct classes to othe r product classes DOE did not analyze.

63Item 34 DOE invites comments on the identifica tion and selection of representative product classes and on models that may serve as good representative units within each product class. DOE also seeks comments on appropriate scaling relationships among product classes for both BCs and EPSs.

5.2.1 Battery Charger Representative Units

DOE decided to analyze all thr ee BC product classes presented in Table 3.7, as part of its determination analysis presented in the draft te chnical report. Each class was represented by a unit that served as the focus of the analysis, except for product class C, which was represented by two units, one a slow charger a nd the other a fast charger. Al though most low-voltage batteryoperated applications (product clas ses A and B) used slow charge rs, this was not the case with many high-voltage applications, such as professiona l power tools, which typi cally ship with fast chargers.

The characteristics of the repres entative units can be seen in Table 5.1. DOE chose these units because they represent high-volume BCs wi thin each of the produc t classes discussed in section 3.4.1. Following the engineering analysis, each of the representative units underwent lifecycle cost and payback period analyses. DOE app lied the cost-efficiency curves developed for each unit to all the products in its product class during the calculation of national energy savings and national net present value.

Table 5.1. Representative Unit Characteristics for Battery Chargers

Product Class Battery Voltage Ba ttery Capacity Charge Rate Typical Application

A 1.2 V 1.2 Ah 0.1 C Shaver

B 4.8 V 1.2 Ah 0.1 C Vacuum
C 18 V 1.5 Ah 0.15 C DIY tool
C 18 V 2.4 Ah 1 C Pro tool

5.2.2 External Power Supply Representative Units

Following further discussion with manufacturer s, DOE narrowed its focus within the list of the six product classes it had developed for the determination analysis to three representative product classes. While the original six product classes, presented in Table 3.11, were based on output power and voltage, the three repres entative product classes, presented in Table 5.2, were based solely on output power. DOE chose these representative product cl asses and criteria for division because manufacturers design “families” of EPSs with the same output power, but different output voltages. Therefore, for a gi ven output power, low-vol tage and high-voltage EPSs share the same design, often differing only in the choice of component values. Because of this similarity of design, there is a functional relationship between the efficiency achievable by units of different output voltage . Therefore, no differential analysis of separate voltage-based representative product classes is necessary.

64For each of the three representative EPS product classes analyzed in 2007 (section 3.6), DOE identified a representative unit for evaluation in the engineering analysis. These three units were chosen to represent EPSs that ship with hi gh-volume applications, such as laptop computers and cellular telephones. For additi onal discussion, please see sect ion 5.2.3 of the draft technical report.
Table 5.2. Representative Unit Characterist ics Used for External Power Supplies

Product Class Output Power (W) Output Voltage (V) Typical Application

A 2.75 W 5 V Cellular Telephone

B 18 W 12 V Modem

F 90 W 19 V Laptop Computer

DOE chose the representative unit for Product Cl ass A to represent a typical charger for a cellular telephone, the consumer product associated with the highest volume of EPS sales. DOE chose Product Class B’s representa tive unit to be characteristic of mid-power applications such as a modem or wireless router. Finally, DOE chos e the representative unit for Product Class F to represent a high-power application such as a laptop computer or video game console.

DOE invites interested parties to comment on these three representative units and on whether DOE should analyze these or other representative units dur ing the preliminary analyses. Note that DOE is publishing some of the result s from the tear-down analysis conducted in 2007 in section 5.5.5 of the draft technical report published in co njunction with this framework document.

Item 35 DOE seeks comments on representative product classes and selection of representative units from those representative product classes.

Item 36 DOE seeks comments on the scaling of findings from representative product classes to other product classes that DOE may not explicitly analyze.

5.3 Engineering Analysis Approach

This section discusses the A pproach DOE intends to follow to estimate the manufacturer selling price for each representative unit (section 5.2) at successively more stringent CSLs.

DOE is considering using three of the four approaches described in section 5.1 to gather data on and validate the relations hip between manufacturer selling price and efficiency: (1) an efficiency level approach, (2) testing and teardo wns, and (3) examination of published prices and efficiency results. DOE intends to use the manufact urer interviews as one of its data sources, structuring the collection of thes e data around an interview guide si milar to the one presented in appendices 5.A and 5.B of the draft technical report. DOE will perform its own testing and teardowns. DOE will also consult publicly av ailable data to validate the information manufacturers provide.

65Item 37 DOE invites manufacturers to work with DOE in the interviews to help develop aggregated curves of manufacturer sellin g price versus efficiency for the various representative units.

In interviews, manufacturers may provide data for products similar to the representative units, rather than the precise representative units . In those cases, DOE will scale the data to be consistent with the representative unit. For example, during the inte rviews conducted in 2007, manufacturers provided data on EPSs that were similar to the representative units in terms of capacity, functionality, and desi gn, but had slightly different output power or output voltage. DOE then used typical relationshi ps between power and efficiency or voltage and efficiency to adjust the efficiency data so that it w ould pertain to the representative unit.

For example, EPSs with higher output power tend to be more efficient, so the efficiency of a lower-power unit would be increased when the data were scaled to a higher-power representative unit. This normali zation maintained the unit’s rela tive standing within the market in terms of cost and efficiency and accounted for any differences in output power, output voltage, volume, and other characteristics and perm itted aggregation of cost-efficiency data from the maximum number of manufacturers. The norm alization method is presented in sections 5.4.5, 5.4.9, 5.4.10, and 5.4.11 of the draft technical report.

Item 38 DOE seeks comments on methods for nor malizing cost and efficiency data provided by manufacturers for EPSs with out put power and output voltage that differ from those of the representative units.

Item 39 DOE seeks comments on the shipment volumes to use for the representative units.

To validate the manufacturer-p rovided engineering data, DOE plans to develop a range of possible costs of production, from the bottom up, a pplying markups to arrive at a manufacturer selling price. The process of evaluating the cost of a BC or EPS starts w ith DOE conducting teardowns of commercially available BCs and E PSs, counting parts, and preparing BOMs. Typically, DOE first obtains low-volume BOM costs by summing individual component prices, obtained from electronic distribut or catalogs using the largest possible retail volume, typically 500 to 1,000 pieces.

Because manufacturer selling prices calculated from 1000-piece parts costs are too high to meaningfully represent manufacturers’ produc tion costs, in the 2007 determination analysis, DOE scaled these low-volume parts costs to refl ect what the components would cost in more typical (much larger) volumes. In developing this more typical volume, DOE used a highvolume quote obtained from a distributor to perform the scaling, a proces s that consisted of calculating scaling ratios of low- and high-volume parts cost s for several types of parts, and applying them to all parts of that type in each low-volume BOM. The high-volume parts costs were quoted at a volume of 500,000 pieces, which DOE considers to be a typical yearly volume of a single EPS design for a mid-size manufacturer.

66After deciding on an appropriate volume, DOE then applied manufacturer markups to the resultant high-volume BOM cost to account for a dditional manufacturer cost s not included in the BOM. These markups included (1) a production markup, (2) an add-on for packaging and mechanical components, and (3) a non-producti on markup. The production markup included all direct and indirect labor, indi rect materials, local taxes, a nd factory operating expenses. In addition to the electronics, BCs or EPSs also co nsist of a plastic enclos ure, cords, and other mechanical components such as heat sinks or printed circuit boards. DOE expected the mechanical costs to remain constant at all CS Ls and added these costs to the marked-up BOM, rather than applying a second markup. At this point, DOE applied an additional non-production markup to take into account shipping, handling, import duty, and corporate overheads. The result of this markup chain was the manufacturer selling price, which could serve as an input for further analyses. The exact markups DOE used in its determination analysis are described in depth in sections 5.4.6 and 5.4.12 of the draft te chnical report for BCs and EPSs, respectively.

Even given small manufacturer markups, DOE recognizes that the manufacturer selling prices obtained using the above method are at best an upper bound on the true cost of production. Actual EPS prices are lower becau se EPS manufacturers typically bypass the distributor used to obtain the high-volume quote. They also often de al at higher volumes. In its preliminary analyses, DOE plans to incorporate additional data on high-volume parts cost s, obtained directly from component manufacturers or electronics -industry analysts. DOE welcomes input on factory-direct parts costs at 500,000 pieces per year and 2,000,000 pieces per year, which DOE considers to be typical yearly volumes for singl e EPS and BC designs. Ob taining parts costs at two different volumes allows DOE to obtain a mo re accurate cost estimate at additional volumes through interpolation.

Item 40 DOE seeks comments on this and other possible methods of determining and validating manufacturing costs. DOE is parti cularly interested in obtaining high-volume component costs and typical manufacturer mark ups applied to the bill-of-materials cost.

Finally, DOE realizes that by testing and pr icing commercially available EPSs and BCs according to the method described above, it will be able to validate manufacturer-supplied data only along the efficiency range fr om baseline to best-in-market . DOE cannot purchase and test devices to validate manufacturer estimates at the max-tech CSL, because by definition no products exist in the market beyond the best-i n-market CSL. DOE is, however, exploring methods of simulating the performance and evalua ting the cost of EPSs and BCs that can meet CSLs beyond best-in-market.

Item 41 DOE welcomes comment on methods for simulating the performance of highly-efficient EPSs and BCs as a means of validating data provided by manufacturers.

5.4 Proprietary Designs
DOE will consider in its engineering and ec onomic analyses all design options that are commercially available or present in a working prototype, including proprietary designs, that

676 meet the screening criteria discussed in sec tion 4. However, DOE will consider a proprietary design in the subsequent analyses only if it does not repr esent a unique path to a given efficiency level. If the proprietary design is the only approach available to ach ieve a given efficiency level, DOE will reject the efficiency level from furthe r analysis, because the analytical results would appear to favor one manufacturer over others . If, on the other hand, a given energy-efficiency level can be achieved by a number of design a pproaches, including a pr oprietary design, DOE may examine the given efficiency level based on that design. DOE is sensitive to manufacturer concerns about proprietary designs and will take appropriate steps to maintain the confidentiality of any proprietary data manuf acturers provide. These data will provide input to the competitive impacts assessment and other economic analyses.

Item 42 Are there proprietary designs of which DOE should be aware for any of the BCs and EPSs under consideration in this rulemaking? If so, how should DOE acquire the cost data necessary for evaluating these designs?

5.5 Outside Regulatory Changes Affe cting the Engineering Analysis
In conducting an engineering analysis, DOE considers the effects of regulatory burdens outside DOE’s statutory energy c onservation standards rulemaking process that can affect the manufacturers of the covered equipment. Outsid e regulatory requirements can also affect the energy efficiency or energy consumption of the BCs and EPSs covered under this rulemaking. DOE will attempt to identify all such outside re gulatory requirements that could affect the engineering analysis. The consider ation of these requirements is cl osely related to the cumulative regulatory burden assessment that DOE will carry out as part of the manufacturer impact analysis. DOE will consider the comments received on the engineering analysis described in the preliminary TSD and make any necessary changes. The updated analysis will be presented in the NOPR TSD.

Item 43 DOE seeks comments on regulatory burdens or changes that should be considered in the engineeri ng analysis of BCs and EPSs.

Item 44 DOE seeks comments on any other issues that could affect the engineering analysis.

ENERGY USE AND END-US E LOAD CHARACTERIZATION

The purpose of the energy-use and end-use load characterization is to identify how consumers use products and equipment, and there by determine the energy-savings potential of energy-efficiency improvements. For BCs and EPSs, DOE’s analysis will focus on how end users operate BCs and EPSs with th e consumer products they power.

The energy-use and end-use load characterizat ion, which is an input to the LCC and national impact analyses, will represent the typica l energy consumption in the field. End-use load characterization for BCs and EPSs is comprised of usage profiles, which estimate the time a

68device spends in each mode in one year. Because of the nature of BCs and EPSs, the usage profile of the device will be re lated to the usage profile of th e associated application. It is difficult to predict changes in usage, so DOE also assumes that usage profiles will not change over the analysis period.

Sections 6.2.1 and 6.3.1 of the dr aft technical report provide a detailed list of usage profiles for BC and EPS applications.

Item 45 DOE seeks comments on the consumer usage profiles presented in sections 6.2.1 and 6.3.1 of the draft technical report. DOE seeks alternate sources, databases, or methodologies for developing usage profiles. DOE also seeks comments on its assumption that the usage profiles do not vary over the analysis period.

For most electrical appliances, energy c onsumption is determined by measuring the energy an application draws from mains while performing its intended function(s). However, BCs and EPSs are power conversio n devices, and their intended f unction is to deliver a portion of the energy drawn from mains into another application. Therefore, th e traditional method of calculating energy consumption is not appropriate for measuri ng BC or EPS energy consumption rates, which are more accurately described us ing the amount of energy dissipated by these devices.

6.1 Battery Charger Energy Use
For the purposes of calculating energy consump tion, DOE considers a BC to always be in one of the following four states:

 Active Mode : The existing DOE test procedure for BCs defines active mode as the condition in which the battery charger is connected to mains power; a battery is attached to the charger; a nd the battery is receiving the main charge, equalizing cells, 28 and performing other one-time or lim ited-time functions necessary for bringing the battery to the fully charged state. (See appendix C);

 Maintenance Mode : The existing DOE test procedure for BCs defines maintenance mode as the condition in which the battery charger is connected to mains power and the battery is fully charged, but is still connected to the charger. (See appendix C);

 Standby Mode or No-Battery Mode : The existing DOE test procedure for BCs defines no-battery mode as the conditi on in which the battery charger is connected to mains power and no battery is attached to the char ger. As EISA requires, DOE is revising its BC test procedure to address standby mode . In a separate rulemaking, DOE defined standby mode as equivalent to no-batte ry mode for BCs. (See 74 FR 13318); and

28 Equalization is a strategy implem ented by some chargers wh ereby the states of charge of all the cells in a battery are brought to the same level to prevent the voltage ac ross any cells from inverting—and thereby damaging the cell—during deep discharge.

69 Unplugged Mode : Unplugged mode represents the state in which the battery charger is disconnected from mains power. No energy is consumed in this mode.

Unit energy consumption represents the annual consumption of a BC attaining a particular CSL. DOE calculates unit energy consum ption at each CSL for each representative unit by combining the usage profile with the energy consumption characteristics for each energyconsuming mode. For BCs, unit en ergy consumption is the sum of:

(1) Charge Energy Consumption : The product of the number of 24-hour charge cycles per year and the 24-hour ch arge cycle energy consumption;

(2) Maintenance Mode Energy Consumption : The product of the time spent in maintenance mode and the power dr awn during maintenance mode; and

(3) Standby Mode Energy Consumption : The product of the time spent in standby mode and the power drawn during standby mode.

Based on comments from interested parties a bout the variability of charge time among different battery chargers and charging behavior among end-users, DOE is considering using 24­ hour cycles to uniformly account for energy c onsumption during battery-charging sessions. A 24-hour cycle models the behavior of a user who allows 24 hours for a battery to recharge. The cycle encompasses time spent in active mode, and once the battery reaches full charge, any remaining time spent in maintenance mode. The users of certain products, such as handheld vacuums, may keep the battery connected to the charger for ex tended periods of time following a 24-hour charge cycle. In these cases, the usage profile would account for a dditional time spent in maintenance mode, in addition to the time spent in maintenance mode as part of the 24-hour charge cycle.

Item 46 DOE requests comments on the use of 24-hour charge cycles for estimating energy consumption for BCs in active mode.

Figure 6.1 shows an example of an estimated usage profile for do-it -yourself (DIY) power tools that DOE created for its determination analysis. A manufacturer trade organization suggested this usage pattern as being typical for this product a pplication. As the figure shows, over the course of a week, a DIY power tool wi ll go through approximately three 24-hour charge cycles, for a total of 72 hours. Time in mainte nance mode is also 72 hours, and DOE estimates that the DIY power tool will spend 24 hours in standby mode per week and no time in unplugged mode. This weekly usage profile was then extended over a year to give an annual usage profile. DOE seeks comments on the usage profiles of BC applications. To view the annual usage profiles of all BC applications DOE has analyzed to date, please see section 6.2 of the draft technical report.

70Figure 6.1. DIY Power Tool Weekly Usage Profile in Hours

Item 47 DOE requests comments on the methodology presented for calculating unit energy consumption. DOE also requests comme nts on the usage profiles detailed in section 6.2 of the dra ft technical report.

6.2 External Power Supply Energy Use
Unit energy consumption represents the a nnual consumption of an EPS attaining a particular CSL. DOE calculates unit energy consumption at each CSL by combining usage profiles, which describe the time a device spe nds in each mode in one year, and the energy consumed by the EPS in each mode of operation.

6.2.1 EPS Usage Profiles For many applications, usage depends strongly on the individual user. To account for the variety of users and their associated usage profiles, DOE will develop multiple usage profiles where appropriate. DOE will then calculate a weighted-average usage profile based on an estimated distribution of user types.

6.2.1.1 EPS Modes and Application States Normally, when evaluating usage and energy co nsumption for a device, it is sufficient to observe only the energy-consuming modes of that device. Because the function of EPSs is to power consumer product applications, however, ev aluating the usage and energy consumption of the EPS also requires evaluating the usage and energy consumption of th e application itself.

To avoid confusion, when describing usage and energy consumption from the perspective of the application, DOE uses the term “application state.” In contrast, when describing usage and energy consumption from the perspective of the EPS, DOE uses the term “EPS mode.”

71By definition all energy-consuming application states are part of active mode from the perspective of the EPS. That is, since any energy-consuming application state requires the application to be connected to the EPS, any en ergy-consuming application state is part of EPS active mode. These states vary by the type of application.

An EPS can be in active mode, no- load mode, off mode, or unplugged. Table 6.1.gives a summary of these modes. Table 6.1.Summary of EPS Modes

EPS Mode Status of EPS Connection to Mains Status of EPS Connection to

Application EPS On/Off Switch Selection (If Switch is Present)
Active Connected Connected On
No Load Connected Disconnected On
Off Connected Disconnected Off Unplugged Disconnected — —

 Active Mode : EISA generally defines active mode as “the condition in which an energy-using product (I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main functions .” EISA further defines active mode for EPSs as “the mode of operation when an external power supply is connected to the main electricity supply and the output is c onnected to a load.”(42 U.S.C.6291(36)(B))

 Standby Mode or No-Load Mode : EISA describes no-load mode for EPSs as “the mode of operation when an external power s upply is connected to the main electricity supply and the output is not connected to a load.”(42 U.S.C. 6291(36)(D)) Accordingly, DOE revised its EPS test procedure to address standby mode. In a separate rulemaking proceeding published in the Federal Register on March 27, 2009, (74 FR 13318), DOE defined standby mode as equivalent to no-load mode for EPSs.

 Off Mode: Off mode is a mode applicable only to an EPS with an on/off switch in which the EPS is connected to mains, is disconnected from the load, and the on/off switch is set to “off.” Off Mode is discussed further in section 6.3.

 Unplugged Mode : Unplugged mode is the state when the EPS is disconnected from mains power. No energy is consumed in this state.

Consider a usage profile for an inkjet co mputer printer. DOE identified the following application states for multifuncti on devices. In each of these app lication states the EPS is in active mode:

 Printing: Where the inkjet printer is on and pe rforming one of its primary functions.

 Idle: Where the printer is on but not performing any printing tasks.

72 Off: Where the printer is off (whether by automatic shutdown or by a user-controlled on/off switch).

As illustrated in Table 6.2, in each application state, the power demands of the inkjet printer differ, so the EPS must supply a different amount of power for each state the application is in. Table 6.2. Usage and Output Power of 40W EPS for Inkjet Computer Printer

EPS Mode Application State Annual Usage (hours/year) Reasoning EPS Output Power (W)

Active Printing 52 Device in operation for 1 hour per week, or roughly 10-15 minutes a day (5-7 tasks) each day of a 5-day work week. 32*

Idle 1,606 Device left idle for ~30 hours per work week, or 6 hours per day for 5 days a week. 9.1

Off 7,102 Device turned off when not in

use. 6.2

No Load Disconnected from EPS 0 The EPS is never disconnected from the load but left connected to mains. 0

Unplugged Disconnected from EPS 0 EPS is never disconnected from mains. 0

* DOE estimated EPS output power for printing to be 80 percent of nameplate output power. Usage profile derived from TIAX LLC, "U.S. Residential Information Technology Energy Consumption in 2005 and 2010." Prepared for U.S. Department of Energy March 2006.

Item 48 DOE requests comments on the usage prof iles for EPS applications detailed in section 6.3 of the draft technical report.

6.2.2 EPS Power Consumption by Modes of Operation EPS power consumption is a function of three factors: the nameplate output power of the EPS, the efficiency of the EPS, and the consumption of the EPS when in no load mode.

No-load mode power (P NL ) is the measured power drawn by the EPS from mains while in no-load mode. Because the EPS is disconnected from the application, all of the power drawn from mains is consumed by the EPS. For each candi date standard level, an associated no-load mode power is given.

EPS power consumption during active mode vari es as the power requi rements of its load vary. Nameplate output power is the highest output power that an EPS is capable of delivering.

73X

4 X

3 X

2 X DOE intends to use two different approaches to calculating EPS power consumption in active mode—one for application states requirin g 25 percent or more of the EPS’s nameplate output power and another for application states requiring less than 25 percent.

The approach for application states requiring 25 percent or more of the EPS’s nameplate output power is straightforward. The EPS test procedure measures the active mode efficiency ( η ) of the EPS at 25, 50, 75, and 100 percent of namepl ate output power or cu rrent. The active mode efficiency of the EPS is then defined as the av erage of these 4 values (points 2, 3, 4, and 5 in Figure 6.2 .) As such, power consumption is

P Con = P In – P Out where P Out = P In x η

or P In = P Ou t x (1/ η )

Therefore, P Con = P Out x (1/ η – 1)

For example, an EPS delivering an output power of 10 watts at 75 percent efficiency would consume: P Con = 10 W x (1/0.75 – 1) = 3.33 W

5Input Power

1 (0W, P NL ) X

0% 25% 50% 75% 100%

Output Power (Percent of Nameplate)

Figure 6.2. Example Measurements from an EPS Test Procedure

74X

4 X

3 X

2 X

(25% x P Nameplate , 25% x [P Nameplate / η ]) The approach for application states requiring less than 25 percent of the EPS’s nameplate output power blends measures of the EPS’s ac tive-mode efficiency and no-load mode power consumption. Most applications have some appli cation states that require an output power below 25 percent of nameplate. Additi onally, many applications spend a significant portion of time in these states. However, at these low power levels, the efficiency of an EPS is relatively low. Because of this situation, DOE does not intend to use the active-mode efficiency metric alone.

Instead, DOE will calculate energy consumption in this region by interpolating between two known points: (1) the no load power consump tion and (2) the active mode consumption at 25 percent of nameplate output pow er. These are points 1 and 2 in Figure 6.3. At an output power of 25 percent, the ener gy consumed by the EPS is: P Consumed = P Out x (1/ η – 1). At an output power of 0 percent (no load mode ), the energy consumed by the EPS is: P Consumed = P NL . Given these two known values, DOE assumed that the energy consumed by an EPS at an output power between 0 and 25 percent of nameplate output power must fall on a curve between these two points.

5Input Power

1 (0W, P NL ) X

0% 25% 50% 75% 100%

Output Power (Percent of Nameplate)

Figure 6.3. Relationship Between EPS Input Po wer and Output Power at Five Loading Points DOE approximated this curve with a straight line between points 1 and 2, which can be described by the following equation re lating input power to output power:

P In = m x P Out + B

Where B is the y-axis intercept, or P NL , and m is the slope, or:

75m = ∆ y/ ∆ x m = [(25% x [P Nameplate / η ]) – P NL ] / [(25% x P Nameplate ) – 0]

Thus, for output power levels below 25 per cent nameplate output power, the input power of the EPS is:

P In = {[(25% x [P Nameplate / η ]) – P NL ] / [25% x P Nameplate ]} x POut + P NL

Since P Consumed = P In – P Out

Then P Consumed = {[(25% x [P Nameplate / η ]) – P NL ] / [25% x P Nameplate ]} x P Out + P NL – P Out Or P Consumed = ({[(25% x [P Nameplate / η ]) – P NL ] / [25% x P Nameplate ]}-1) x P Out + P NL
DOE seeks comment on its proposed methodolog y for calculating energy consumption at output power levels below 25 per cent of nameplate output power.

6.2.3 Calculating EPS Energy Use Unlike most other consumer products using electricity, the energy consumption of an EPS cannot always be measured as the energy draw n from mains, since the function of an EPS is to deliver power for the operation of other end- use applications. DOE in tends to calculate the energy consumption of an EPS (E CON ) as the difference between energy drawn from mains (E IN ) and the energy supplied to the end-use application (E OUT ), or:

E CON = E IN - E OUT
Since energy measures power (P) multiplie d by a duration of time (T), the following equation is used: P CON * T = (P IN – P OUT ) * T

Factoring in the different EPS modes:

P CON * T TOTAL = P CON-Active * T Active + P CON-No-Load * T No-Load
Further factoring in application states:

P CON * T TOTAL = P CON-Active1 * T Active1 + P CON-Active2 * T Active2 + P CON-Active3 * T Active3 +

... P CON-No-Load * T No-Load

76Thus, to calculate the energy consumption of an EPS, DOE will combine the time values (from usage profiles) with power consumption values.

In its determination analysis, DOE did not differentiate between energy consumption of the EPS power levels above and below 25% of nameplate output power. Instead, DOE estimated a capacity factor, which is a si ngle value expressed as the time- averaged ratio of actual output power during active mode divided by the nameplate output power. Capacity factor is described in detail in section 6.3.2. 3 of the draft technical report. DOE does not intend to use capacity factor in this rulemaking. Rather, DOE believe s the methodology described in this framework document will more accurately model EPS energy consumption. DOE invites stakeholder comment on this matter.

Section 6.3 of the draft techni cal report lists usage profile s and unit energy consumption estimates for the following EPS-powered applications:

Camcorders Laptop computers Cordless telephones Portable audio players Digital cameras Portable gaming devices Flat panel monitors Portable video players

Flatbed scanners Small liquid crystal display (LCD) TVs Ink-jet computer printers Telephone answering devices Local area network (LAN) equi pment Wi-Fi access points

Medical devices Wireless telephones

Modems/fax modems

Item 49 DOE requests comment on its proposed me thodology for calculating energy consumption at each applicati on state under EPS active mode.

Item 50 DOE requests comments on its proposed me thodology for calculating energy consumption at output levels below 25 pe rcent of nameplate output power.

6.3 Off-Mode Energy Consumption

EISA directs DOE to consider off mode ener gy consumption and defines this mode as the state when a device is connected to a main power source and not pr oviding any standby or active mode function. In a separate rulemaking, DOE esta blished that off mode only applies to those BCs and EPSs that have manual on-off switche s (see 74 FR 13318). For BCs, off mode is the condition in which the charger is connected to ma ins power, the charger is not connected to the battery, and all switches on the de vice are in the off position. For EPSs, off mode is the condition in which the EPS is connected to mains power, the EPS is not attached to a load, and all switches on the device are in the off position.

Because the inclusion of on-off switches on BCs and EPSs is uncommon and the frequency with which these switches are us ed is unknown, DOE assumes that the energy

777 consumption of the device would be zero while in off mode. That is, DOE assumes that the onoff switch controls the power input to the devi ce, and thus switching it off would completely disconnect the device from mains. Therefore, as a simplification, DOE is proposing to include any time the device spends in off mode as part of the time the device spends in unplugged mode.

Item 51 DOE requests comments on its propos al to associate off mode with unplugged mode for the purposes of calculati ng energy consumption. DOE also requests comments on time spent in off m ode, as well as power consumption while in off mode.

PRODUCT PRICE DETERMINATION

As stated in section 5, the purpose of the engineeri ng analysis and product price determination is to understand the relationship be tween end-user price and efficiency for BCs and EPSs. Because DOE needs a retail (consumer) price for each efficiency level used in the LCC and PBP analysis and the national impact analysis, DOE will start with manufacturer selling price (MSP) estimates and study the dist ribution value chain for BCs and EPSs moving from manufacturer to end-user. From that anal ysis, which includes volume estimates and typical markups applied by interested parties in the distribution ch ain, DOE will then calculate a manufacturer-to-retail markup to convert MSP estim ates to retail price estimates. DOE will also develop a sales tax estimate and apply it to the re tail price estimates to a rrive at end-user product prices.

Component Manufacturers

BC Manufacturers

Consumer Product Retailers

Consumers OEMs Component Manufacturers

EPS Manufacturers

Consumer Product Retailers

Consumers OEMs EPS Distributors Battery Charger Distribution External Power Supply Distribution

Figure 7.1. BC and EPS Di stribution Networks

78Figure 7.1 shows the paths that BCs and E PSs typically take to market. Section 3.3.1 discusses this distribution netw ork in more detail. DOE estimat es MSPs in its engineering analysis. For EPSs, OEM markups ar e then applied to the MSPs to arrive at the price to the retailer. To estimate the OEM markups, DOE will use publicly available data on the gross margins of major manufacturers. For BCs, DOE does not intend to derive separate OEM markups, because a single company will typica lly manufacture both a BC and the end-use application it powers.

DOE will estimate retailer markups using public ly available data on the gross margins of major retailers of electronic and electrical produc ts. When applying the reta iler markups to arrive at pre-tax consumer prices, DOE will consider th at some fraction of BCs and EPSs are not sold through a retailer but sold directly from the OEM to consumers.

The sales tax represents state and local sale s taxes and is a multiplicative factor that increases the end-user product price. DOE will obtain information on state and local sales tax from the Sales Tax Clearinghouse. 29 These data will be compiled to calculate a national, population-weighted average sales tax as well as a population-weighted average tax for each Census division. The national-level sales tax fi gures will be used in the LCC, PBP (both discussed in section 8), and NP V (section 10) analyses, while the Census division-level tax figures may be used in life-cycle cost subgroup analyses (section 11).

DOE has created initial estimates of manu facturer-to-consumer markups for BCs and EPSs. These estimates, shown in Table 7.1 and Table 7.2, are based on assumptions about how BCs and EPSs are sold ( i.e. , product grouping and dist ribution channels). Ch apter 7 of the draft technical report explains these underlying assumptions in detail.

DOE has grouped BCs and EPSs as the ta bles show merely for convenience of presentation. DOE is not proposi ng product classes at this time. If DOE adopts different product classes in the preliminary analyses, it will de velop new estimates of the distribution chain markups for those classes. Section 3.6 discusses product classes, a nd comments from interested parties on this issue are welcome.

Table 7.1. BC Manufacturer-to-Consumer Markups
Battery Voltage

0 to ≤ 3 V >3 to ≤ 9 V > 9 V Slow Charging >9 V Fast Charging OEM Markup 1.00 1.00 1.00 1.00 Retailer Markup 1.37 1.45 1.51 1.51 Sales Tax 1.069 1.069 1.069 1.069 Total Markup 1.46 1.55 1.61 1.61 Note: Total markup equals the product of the three markups. Multiplying the manufacturer selling price by the total markup yields the consumer purchase price. Column groupings represent past analysis and are provided as examples; products may be grouped differently in future analyses.

29 The Sales Tax Clearinghouse, Inc ., was established in Augu st 1999 to facilitate the calculation of sales and use taxes administered by the Nation’s 7,000 taxing authorities at the State, county, and city levels. Information on the Sales Tax Clearinghouse can be found at www.thestc.com.

798 Table 7.2. EPS Manufacturer-to-Consumer Markups
Nameplate Output Power 0 to < 4 W ≥ 4 to ≤ 60 W > 60 W OEM Markup 1.43 1.43 1.36 Retailer Markup 1.31 1.31 1.31 Sales Tax 1.069 1.069 1.069 Total Markup 2.00 2.00 1.90 Note: Total markup equals the product of the three markups. Multiplying the manufacturer selling price by the total markup yields the consumer purchase price. Column groupings represent past analysis and are provided as examples; products may be grouped differently in future analyses.

Take, for example, low-voltage BCs, whose ba ttery voltage is less than or equal to 3 volts. The manufacturer selling prices DOE used as inputs in its preliminary analysis for BCs represent the prices at which BCs are sold to retailers. Because ther e is no separate OEM markup, it appears as 1.00 in Table 7.1. DOE found that the principa l retailers of products that incorporate low-voltage BCs have an averag e markup of 37 percent or 1.37. The Sales Tax Clearinghouse reported a national average sales tax of 6.9 percent or 1.069. Multiplying these markups gives a total markup of 46 percent, or 1.46, for low-voltage BCs. DOE used the same process to arrive at manufactur er-to-consumer markups for other BCs and for EPSs. Chapter 7 of the draft technical report provides additional deta il, including the data from which DOE derived the preliminary markups.

Item 52 DOE seeks comments on all aspects of the product price determination for BCs and EPSs, including assumptions about th e percent of shipments passing through each distribution channel and the markups associated with each channel.

LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES

This section describes the Department of Energy (DOE)’s methodology for analyzing the economic impacts of possible energy efficiency sta ndards on individual cons umers. The effect of standards on individual consum ers includes a change in operati ng expense (usually decreased) and a change in purchase price (usually increa sed). This section describes three metrics DOE uses in the consumer analysis to determine th e effect of standards on individual consumers:

 Life-cycle cost (LCC) is the total consumer expens e over the life of a product, including purchase expense and operati ng costs (including en ergy expenditures). DOE discounts future operating costs to the time of purchase, and sums them over the lifetime of the equipment;

 Payback period (PBP) measures the amount of time it takes customers to recover the assumed higher purchase price of more energy-efficient equipment through lower operating costs; and

80 Rebuttable payback period is built on a rebuttable presumption that an energy conservation standard is considered economica lly justified if “the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three tim es 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))

DOE’s LCC and PBP analyses generate valu es that calculate the payback period for consumers of potential energy conservation standa rds, which include, but are not limited to, the three-year payback period contemplated unde r the rebuttable presumption noted above. However, DOE routinely conducts a full economic analysis that considers the full range of impacts, including those 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 justif ication for a potential standard level.

Because the test procedures codified in 10 CFR Part 430, Subpart B, Appendices Y and Z measure the energy efficiency of BCs and EPSs , and not actual energy consumption, DOE must analyze the effect on consumers of BCs and EP Ss by calculating the LCC and PBP using data from the engineering analysis (section 5), th e energy-use and end-use load characterization (section 6), and the product pri ce determination (section 7).

When calculating the LCC, DOE discounts futu re operating costs to the time of purchase and sums them over the lifetime of the equi pment, as shown in the following equation:

N OC t LCC  IC  

## 

t t  1 

##  1  r 

## 
where:

LCC = life-cycle cost in dollars, IC = total installed cost in dollars, ∑ = sum over the lifetime, from year 1 to year N, N

= lifetime of product in years, OC = operating cost in dollars,

r

= discount rate, and
t = year for which operating cost is being determined.

For BCs and EPSs, DOE conducted some prelim inary work on the LCC as part of its determination analysis directed by EPACT 2005. The text that follows discusses some of these inputs and methodologies that DOE was develo ping when the determination analysis was rescheduled. One of the initial decisions DOE made for the LCC wa s to focus the analysis on the use of BCs and EPSs in the residential sector, ra ther than the commercial or industrial sectors. The scope of coverage for these rulemakings en compasses BCs and EPSs designed for consumer products, such as cellular telephone s, laptop computers, portable music players, digital cameras, power tools, hand-held vacuum cleaners, and so on. While DOE recognizes that commercial and industrial entities use these products , and the BCs and EPSs that pow er them, it believes that the

81residential sector uses a consid erable majority of th e products in service today. For this reason, DOE is considering focusing its preliminary LCC analysis on the residential sector.

Item 53 DOE seeks comments on its intention to focus its preliminary LCC analysis on the residential sector, and not the commercial or industrial sectors.

8.1 Life-Cycle Cost and Payback Period Methodology
For the draft determination analysis, DOE developed an LCC methodology based on the approach followed in other rulemakings, tailored for some unique aspects of BCs and EPSs. For example, while the equation above mentions “total installed co st” in its list of LCC input variables, DOE considers installation costs to be zero because they would typically entail a consumer simply unpacking the BC or EPS from the box it was sold in and connecting the device to mains power and its associated product or battery. Because the cost of this “installation” (which may be considered tem porary, as intermittently used devices might be unplugged for storage) is not quantif iable in dollar terms, DOE cons iders the installation cost to be zero. Therefore, the total inst alled cost would be the retail price of the product paid by the

consumer.
Similarly, DOE considers repair and maintena nce costs (which are typically associated with larger products and applia nces) to be zero. In making th is decision, DOE recognizes the reality of the marketplace, where the service life of a BC or EPS typically exceeds that of the consumer product with which it is designed to op erate. A consumer would not incur repair or maintenance costs for a BC or EPS. Also, if a BC or EPS did fail, cons umers would typically discard the device and purchase a replacement BC or EPS.

In Figure 8.1, DOE presents its flow diagram for the draft determination analysis LCC developed in 2007. The figure depicts, from left to right, LCC inputs in yellow boxes, interim calculated values in green boxe s, and final output values ( i.e. , LCC and PBP) in blue boxes.

82Figure 8.1. Flow Diagram of Inputs for the Determination of LCC and PBP

Under 42 U.S.C. 6295(o)(2)(B)(iii), the statute establishes a rebuttable presumption that a standard is economically justified “[i]f the Secr etary finds that the additional cost to the consumer of purchasing a product complying with an energy conser vation standard level will be less than three times the value of the energy . . . savings during the first ye ar that the consumer will receive as a result of the st andard, as calculated under the app licable test procedure. . . .” DOE’s LCC and PBP analyses generate values that indicate the cost-effectiveness of products meeting potential energy conservation standards. These values include, but are not limited to, the 3-year payback period contemplated under the rebuttable presumption test discussed above. However, DOE routinely conducts a full economic analysis that considers the full range of impacts, including those to the consumer, manufacturer, Nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this full analysis serve as the basis for DOE to definitively determine the economic justifica tion for a potential standard level (thereby supporting or rebutting the results of any prelimin ary determination of economic justification).

DOE intends to conduct the preliminary LCC a nd PBP analyses using typical values for equipment retail price, operating life, electric ity costs, electricity consumption, and discount

83rates. If DOE determines that there is significant variability in any of these inputs, it will conduct sensitivity analyses to determine how the LCC and PBP are affected by high and low estimates of each input. For any sensitivity analyses th at it conducts, DOE will acc ount for correlations that may exist between inputs ( e.g. , electricity usage may be correla ted to electricity prices). The detailed impact calculation, which DOE will conduct during the NOPR stage of the rulemaking, may include an assessment of impacts on subgroups of consumers, as described in section 11 of this framework document.

For the NOPR, DOE will carefully review all the comments it receives on the preliminary LCC analysis, make any necessary revisions, and evaluate additional parameters not included in the preliminary analysis if necessary.

8.2 Life-Cycle Cost and Payback Period Inputs
As discussed above, DOE conducted some pre liminary work in developing its LCC for the determination analysis. The LCC methodology described above and the inputs presented in Table 8.1 are based on approaches that DOE deve loped for other energy conservation standards rulemakings. The draft inputs are presented here for review and comment by interested parties.

In its LCC analysis, DOE noted that BCs and EPSs are most commonly sold as components of consumer products. That is, the BC or EPS works as an enabling part of a system, converting mains electricity to ch arge a battery or operate a produc t. Thus, the retail price of a BC or EPS is bundled with the reta il price of the consumer product ( e.g. , cellular telephone, laptop computer, digital camera). To determine a ppropriate retail prices for BCs and EPSs, DOE reviewed distributor catalogs and interviewed manufacturers familiar with the supply chain. As section 7 discusses, DOE used product price determination and supply chain markups to calculate product price inputs. These product pric es (detailed in section 8.3.1 of the draft technical report) varied signifi cantly depending on the cap acity of the device and its efficiency.

Table 8.1 presents the draft inputs that DOE developed in 2007 for the determination analysis. Section 8.3 of the draft technical report provides further de tail on the derivation of and sources for these inputs.

84Table 8.1. Draft Inputs to the Life-Cycle Cost and Payback Period Analyses

Input Description Average or Typical Value Sources

Product Price The retail price before tax ( i.e.
, bundled with a consumer product). Based on a manufacturer selling price marked up through the distribution chain. Varies Distributor catalogs, high-volume price estimates, manufacturer interviews.

Sales Tax Used to convert the product price to a final consumer retail price including sales tax. 6.9% Weighted average of sales tax in 13 geographic regions and large states.

Unit Energy Consumption The annual on-site electricity consumption associated with a BC or EPS. Varies Developed in section 6, Energy-use and End-use Load Characterization.
Electricity Prices The national residential sector average price per kilowatt-hour ( i.e.
, $/kWh). $0.097/kWh in 2005 Energy Information Administration (EIA).

Electricity Price Trends Projects changes in the price of electricity over the analysis period. Includes a high and low scenario. Varies The Annual En ergy Outlook from the EIA.

Product Lifetime The total years in use after which the consumer retires the BC or EPS from service. The BC or EPS may be retired before the end of its useful life if the consumer product it operates is retired from service. 3 - 5 years Discussed in section 8.2.3.

Discount Rate The rate DOE estimates to be representative of BC and EPS consumers, used to discount future expenditures and establish their present value. 5.6% Weighted average of residential financing methods, discussed in section 8.2.2.

Analysis Period The time period over which DOE calculates the LCC. Product lifetime Discussed in section 1.5.

8.2.1 Electricity Prices For residential consumers of BCs and EPSs, DOE plans to use projections of national average electricity prices from Ener gy Information Administration's (EIA) Annual Energy Outlook (AEO) for the most recent year available. In other rulemakings, DOE has calculated a shipment-weighted average electr icity price, based on inventorie s of products developed through the EIA’s Residential Energy Consumption Surv ey. However, the survey did not include questions on inventories of BCs and EPSs, and therefore, DOE is unable to create a national installed-base-weighted average electricity pr ice. Instead, DOE proposes to use the national average electricity price, as published by EIA.

To ascertain the sensitivity of the LCC to futu re electricity price trends, in addition to the reference case, DOE will evaluate the LCC usi ng both the low and high economic growth cases.

85Together, these three cases reflec t the uncertainty in electricity prices over the analysis period. Figure 8.2 presents the residen tial electricity price trends (in constant 2007$), based on AEO 2007 projections.Cents/kWh (2007$) 10.8

10.7

10.6

10.5

10.4

10.3

10.2

10.1

10.0

9.9 High

Low

Ref

9.8

2006 2008 2010 2012 2014 2016 2018 2020 2022

Figure 8.2. AEO 2007 Residential Electricity Price Trend Forecast

Item 54 DOE seeks comments on the use of the EIA national average electricity price and the AEO forecast of electricit y prices over the analysis period.

8.2.2 Life-Cycle Cost Discount Rates Discounting reflects the current value of money spent or saved in the future. As discussed previously, calculation of consum er LCC requires DOE to use a di scount rate to determine the present value of the money the consumer would spend to operate the BCs and EPSs over the products’ lifetime. Because consumers can use a variety of financial means to purchase a BC or EPS, the discount rate should e qual the average cost of capital to the consumer. DOE assumes these financial means, listed in Table 8.2, to be similar to the ones consumers use when purchasing and financing replacem ent appliances for the home.

For the draft determination analysis, DOE acknowledged the similarity between households financing replacement appliances and purchasing BCs and EPSs, and therefore adapted the LCC discount rate derivation from the home appliances rulemaking to its draft analysis. DOE’s approach involved identifying all possible debt or asset classes that consumers

86might use to purchase replacement equipment, incl uding household assets that might be affected indirectly.

DOE estimated the shares of the various de bt and equity classes in the typical U.S. household portfolio using the Federal Reserve’s Survey of Consumer Finances ( SCF ) data for 1989, 1992, 1995, 1998, 2001, and 2004. DOE also used SCF data to determine rates of return for each class. DOE then calculated an average rate weighted by the share of each class of debt or equity, equal to 5.6 percent, to represent a household discount ra te. For more detail on the data sources, methodology, and calculation of the reside ntial discount rate, pl ease see section 8.3.4 of the draft technical report.

Table 8.2. Shares and Interest or Return Rates Used for Household Debt and Equity Types

Type Average Share of Household Debt Plus Equity (%)* Mean Real Effective Discount Rate (%)** Home equity loans
Credit cards
Other installment loans
Other residential loans
Other line of credit Checking accounts Savings and money market accounts Certificates of Deposit Savings bonds
Bonds
Stocks 3.6
2.0
1.7
4.9
0.5
4.5
15.7

9.0
1.5
10.0
29.1 4.0
11.0

6.0
4.6
8.7
0.0
2.3
2.4
3.5
4.2
8.8
Mutual funds 17.5 7.0 Total/weighted-average discount rate 100.0 5.6.0
* Not including primary mortgage or retirement accounts. ** Adjusted for inflation and, for home equity loans, loan interest tax deduction.

Item 55 DOE seeks comments on the methodology to be used for calculating residential discount rate us ed in the LCC analysis.

8.2.3 BC and EPS Operational Lifetimes
DOE intends to use information from manufact urer product catalogs, various literature sources such as technical reports and conferen ce proceedings, and input from manufacturers and other interested parties to es tablish BC and EPS lifetimes for use in the LCC and subsequent analyses.

87As discussed earlier in this section, because BCs and EPSs are often made specifically for use with particular consumer pr oducts, their lifetimes relate dire ctly to the lifetimes of those products. DOE assumes that once the consumer produc t has reached the end of its useful life, the user typically discards the associated BC or E PS. Therefore, for each group of BCs and EPSs, DOE has gathered lifetime values for consumer product applications and combined them with shipment estimates to derive a shipment-weigh ted average lifetime representative of the group. Table 8.3 and Table 8.4 display the shipment-weighted average lifetimes that DOE derived during its preliminary work. These results are from DOE’s initial analysis and may change depending on the product classes used in the preliminary analysis.

Table 8.3. Shipment-Weighted Average Lifetimes for Battery Chargers
Battery Voltage

0 to ≤ 3 V > 3 to ≤ 9 V > 9 V Slow Charging > 9 V Fast Charging Lifetime 3 years 5 years 5 years 5 years

Table 8.4. Shipment-Weighted Average Li fetimes for External Power Supplies

Nameplate Output Power
0 to < 4 W ≥ 4 to ≤ 60 W > 60 W
Lifetime 4 years 5 years 4 years

To see the lifetimes of specific consumer product applications, pl ease refer to section 8.3.5 of the draft technical report. Based on consid eration of the comments received on this framework document, DOE will make necessary ch anges to the analysis. These changes will be reflected in the preliminary TSD.

Item 56 DOE seeks comments on appropriate life times for the BCs and EPSs covered in this rulemaking.

The following is a list of the sources of BC and EPS lifetime data DOE has identified to date:

 “30th Annual Portrait of the U.S. Appliance Industry.” Appliance Magazine

. September 2007.

 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy. “FY2005 Preliminary Priority-Setting Summary Report and Actions Proposed. Appendix A: FY2005 Technical Support Document. Table A9-1: Background Data on Battery Chargers and Power Supp lies.” (Last accessed March 3, 2006.) www.eere.energy.gov/buildings/appliance_st andards/pdfs/fy05_priority_setting_app

_ a.pdf.

 TIAX LLC. “Assessment of Analyses Performe d for the California Energy Efficiency Regulations for Consumer Electronic s Products.” February 2006. TIAX LLC: Cambridge, MA.

88Item 57 DOE seeks input on additional sources for the lifetimes of BCs and EPSs and comments on the application lifetimes provided in section 8.3.5 of the draft technical report.

9 SHIPMENTS ANALYSIS

DOE develops shipment forecasts of produc ts to calculate the national impacts of standards on energy consumption, NPV, and future manufacturer cash flows. DOE plans to develop shipments forecasts based on an analys is of key market drivers for BCs and EPSs. Principal among these drivers is demand for th e consumer products that use BCs and EPSs.

9.1 Base Case Forecast

To evaluate the various impacts of standa rds, DOE develops a base case shipments forecast against which it compares standards case shipments forecasts at higher CSLs. DOE will design the base case forecast to depict what it anticipates would happen to energy consumption and energy costs over time if energy conservatio n standards for the units covered under this rulemaking are not adopted. In determining the ba se case forecast, DOE will consider historical shipments, the mix of BC and EPS efficiencies currently sold, and how that mix might change over time if new standards are not adopted. For these purposes, DOE needs data on historical equipment shipments and the market shares of th e different efficiency levels offered in each product class.

In its work on the determination, DOE estimated that in 2007, 69,562,200 battery chargers and 397,200,000 external power supplies were sold in the United States. Using its data on total shipments of applications, DOE divided these shipments into groups according to voltage for BCs and nameplate output power for EPSs. To divide BC shipments into product groups, DOE used input from the Association of Home Appliance Manufacturers (AHAM) and the Power Tool Institute (PTI). DOE estimated distributions for EPSs based on the work of TIAX 30 and the Darnell Group. 31 Table 9.1 and Table 9.2 show the distribution of shipments by product grouping for BCs and EPSs. For a more detailed description of how DOE estimated shipments of BCs and EPSs, see chapte r 9 of the draft technical report.

30 TIAX LLC. Assessment of Analyses Performed for the Californ ia Energy Efficiency Regulations for Consumer Electronics Products . TIAX LLC: Cambridge, MA. February 2006.

31 Darnell Group. External AC-DC Power Supplies: Global Market Forecasts and Competitive Environment. Second Edition. Darnell Group: Corona, CA. 2005.

89Table 9.1. Battery Charger Shipments by Product Group in 2007

Battery Voltage

0 to ≤ 3 V > 3 to ≤ 9 V > 9 V Slow Charging > 9 V Fast Charging Shipments (millions) 5.14 41.71 11.36 11.36

Table 9.2. External Power Supply Shi pments by Product Group in 2007
Nameplate Output Power 0 to < 4 W ≥ 4 to ≤ 60 W > 60 W Shipments (millions) 112.2 249.5 35.5

Item 58 DOE seeks recommendations on sources of data on shipments of BCs and EPSs by product group.

DOE also hopes to understand the breakdown of efficiency levels within each group of BCs or EPSs on which analyses are performed ( i.e. , data on the distribution of shipments by efficiency). DOE is considering using the effi ciency distributions shown in Table 9.3 for BCs and Table 9.4 for EPSs. Because very little info rmation is available about the distribution of shipments by efficiency for BCs and EPSs, DOE reports these distributions with some uncertainty and encourages commen ts on alternative distributions.

To estimate the distribution of BCs by efficien cy, DOE based its analysis on a subset of a large dataset published by the Ca lifornia Energy Commission (CEC). 32

Table 9.3. Base Case Distribution of BC Shipm ents Across Efficiency Levels by Product Group in 2007

Percentage of Market at Efficiency Level* Battery Voltage

0 to ≤ 3 V > 3 to ≤ 9 V > 9 V Slow Charging > 9 V Fast Charging Baseline Slightly Improved CEC Tier 1/ENERGY STAR Beyond Standard Best-in-Market 60 20 13

0 7 45 65 13 10 26 10 10 15

6 0 65 10 10 15

0 All Levels 100 100 100 100 *Efficiency levels are discussed in section 5.2.
To estimate the current year’s efficiency distribution of EPSs for its determination analysis, DOE used a Pacific Gas and Elect ric study. The study estimated that in 2004, 40

32 Blosser, J., H. Kameth, et al. Batt ery Charger Laboratory Test Data File . California Energy Commission Public Interest Energy Research Funding. 2006.

90percent of EPSs met CEC Tier 1 standards and 25 percent met CEC Tier 2 standards. 33 DOE used these estimates and the EPA ENERGY STAR Qualified Products List to arrive at a distribution of EPS shipments across e fficiency levels for each product group, 34 discussed in depth in section 9.1.2 of the draft technical report. DOE recognizes that this information may be outdated and may change dramati cally with the standards imposed by EISA. DOE seeks input on sources of current data on this subject.

Table 9.4. Base Case Distribution of EPS Shipments Across Efficiency Levels by Product Group in 2007

Percentage of Market at Efficiency Level* Nameplate Output Power

0 to < 4 W ≥ 4 to ≤ 60 W > 60 W

Baseline Linear Baseline Switched-Mode EPS CEC 1/ENERGY STAR CEC 2 > CEC 2 Market Best Max Tech 35 25 15 12 10

3 0 16 44 15

6 18

1 0 0 60 15

9 5 11

0 All Levels 100 100 100 *Efficiency levels are discussed in section 5.2.
DOE intends to use two approaches to charac terize changes in effici ency of both BCs and EPSs over time in the absence of new standard s. In the static approach, the efficiency distribution does not change over time in th e absence of a new st andard. In the dynamic approach, efficiency improves progressively over time, even after a new standard takes effect. DOE uses these two approaches to provide an upper and lower bound, respectively, for calculated energy savings from improvements in energy efficiency. These improvements may be spurred by changes in technology, voluntary pr ograms such as the ENERGY STAR program, consumer preferences, and other market forces. S ee section 9.2 of the draf t technical report for a more detailed discussion of DOE’s proposed ap proaches to forecasting changes in efficiency over time.

Item 59 DOE seeks recommendations on sources of data that would provide accurate and up-to-date information on BC and EPS efficiency distributions within product groups. DOE also seeks comments on how it migh t characterize long-term trends in the efficiency of BCs and EPSs for its base case shipments forecasts.

33 Fenstrom, Gary . “ Codes and Standards Enhancement Initiative for PY2004: Title 20 Standards Development Analysis of Standards Options for Single-Voltage Exte rnal AC to DC Power Supplies.” Prepared by Ecos Consulting, Davis Energy Group, and Energy Solutions for Pacific Gas and Electric. May 2004.

34 Environmental Protection Agency. “Qualified Product (Q P) List for ENERGY STAR® Ac-Dc Qualified External Power Supplies.” www.energystar.gov/ia/products/ prod_lists/eps_ac_dc_prod_list.pdf . Accessed December 17, 2007.

91DOE intends to prepare shipment forecasts fo r the base case. The model will keep track of the aging and replacement of BCs a nd EPSs given product lifetimes (section 8.2.3) and a projection of future BC and EPS sales growth. Th e shipments growth rate for many applications using BCs and EPSs is quite high. This is especi ally true for higher-powered EPS applications. DOE is considering using the c onstant annual growth rates in Table 9.5 as reference values. However, as the market for these goods becomes more saturated, growth rates may slow. DOE seeks comments on whether growth rates that dec line over time would be more appropriate and what those growth rates should be for purposes of DOE’s analysis.

Table 9.5. Base Case Shipments Growth Rates for BCs and EPSs

All BCs EPSs by Nameplate Output Power 0 to < 4 W ≥ 4 and ≤ 60 W > 60 W Compound Annual Growth Rate (%) 4 2 3 4

Note: DOE may use separate growth rates for each BC product group.

Item 60 DOE seeks comments on appropriate shipment growth rates.

9.2 Standards Impacts on BC and EPS Shipments
DOE will develop a set of shipment forecasts for each set of efficiency standards analyzed. These standards case forecasts will help DOE evaluate the impacts of standards on BC and EPS shipments and therefore on the energy consumption of BCs and EPSs. DOE derives standards case forecasts using the same data sets it used for the base case forecasts. However, because the standards case forecasts account for the increase in purchase price and the decrease in operating costs caused by standards, forecaste d shipments typically deviate from the base case. The magnitude of the difference between the standards case and base case shipment forecasts depends on the calculated purchase price increase, as well as the operating cost savings from the standard. Because the pur chase price tends to have a larg er impact than operating cost on equipment purchase decisions, standards case forecasts typically show elasticity of demand, manifested as a drop in shipments relative to th e base case. However, in the case of BCs and EPSs, the demand may be inelastic if the cost of BCs and EPSs does not increase much relative to the cost of the application.

Another market response to the presence of a st andard for BCs or EPSs is to substitute a different power source for the BC or EPS. Possible substitute sources may include internal power supplies, external power supplies (for BCs), primar y batteries, rechargeable batteries (for EPSs), and USB systems, among others. The extent to which manufacturers ch oose substitute power sources may be limited by design constraints. Fo r example, in some cases, using an internal power supply makes an application less portabl e. Another substitute, USB power, is limited because USB ports are much less common than traditional wall outlets. In its preliminary analysis, DOE assumed that the demand for BCs and EPSs is inelastic; that is, price increases in

92the standards case lead to no decrease in demand for the product. DOE seeks comments on the price elasticity of demand for BCs and EPSs.

Item 61 DOE seeks input on the sensitivity of BC and EPS demand to changes in price.

In addition to quantifying the projected imp act of standards on total shipments, DOE must also quantify the change in the mix of product efficienci es due to standards. DOE is considering two market reactions : shift and rollup. In the shif t scenario, all products become more efficient in response to a standard, even thos e that were more efficien t than the standard. In the rollup scenario, those products that do not meet the standard become just efficient enough to meet the standard but not exceed it, while the produc ts that were already more efficient than the standard remain unaffected. These two standards case scenarios will be used in combination with the static and dynamic base case scenarios discu ssed above in section 9.1. See section 9.3 of the draft technical report for a more detailed disc ussion of DOE’s proposed approach to forecasting the effects of standards on shipments.

Market-pull programs such as the ENER GY STAR program and consumer rebate programs that encourage the purchase of more effi cient BCs and EPSs also affect standards case forecasts. When such programs exist, DOE will consider their impacts on shipments.

Item 62 DOE seeks comments on how any new energy conservation standard for BCs and EPSs might affect shipments of these products. DOE specifically seeks comments on its rollup and shift scenarios, as discussed in section 9.3 of the draft technical report.

10 NATIONAL IMPACT ANALYSIS

The national impact analysis reflects DOE’s assessment of the aggregate impacts of potential efficiency standards at the national le vel. Measures of impact that DOE will report include future NES from CSLs ( i.e. , the combined incremental energy savings from a new or increased energy conservation standard relative to a base case of no change in the energy conservation national standard over a specified forecast period) and the NPV from CSLs ( i.e. , the combined incremental LCC from a new or increa sed energy conservation st ate relative to the base case over a specified forecast period).

10.1 Inputs to Forecasts
Analyzing impacts of Federal energy conser vation standards for BCs and EPSs requires comparing projected energy consumption in th e United States with and without new energy conservation standards. The forecasts contain pr ojections of unit energy consumption of BCs and EPSs, annual shipments, the price of purchas ed units, and base case and standards case efficiencies. Section 6 discusses approaches to determine unit energy consumption while section 7 discusses approaches to determine reta il prices for equipment. Section 9 discusses the derivations of the base case shipments forecasts.

93Although improving the energy effi ciency of a product would generally lead to lower energy consumption, DOE recognizes other fact ors that may impact energy consumption:

 Rebound Effect: Consumers who encounter lower ope rating costs associated with a more energy-efficient product frequently use that product more often than a less efficient product. This phenomenon is called the rebound effect. For BCs and EPSs, DOE expects the rebound effect to be negligible because consumers are unlikely to notice the decrease in operating costs that would result from new standards for these products.

 Associated Application Effect: BCs and EPSs are distinct from other consumer products regulated by DOE in that their en ergy consumption is directly tied to the usage of another end-use consumer product. Therefore changes in energy consumption, energy efficiency, or usage of that consumer product may affect the energy consumption of the BC or EPS. Because of the wide range of consumer products included and the absence of a ny known trend in how consumer product designers respond to more efficient power c onverters, DOE assumes this effect to be negligible.

 Consumer Awareness Effect: Increased awareness of the energy consumption of a BC or EPS in non-active modes may lead to consumers unplugging these devices when not in use. Conversely, decreased heating of the devices due to increased efficiency, may lead to lower perceived energy consumption and less consumer willingness to unplug devices when in standby mode. Because of the wide range of possible consumer reactions and no apparent tr end in how consumers respond to more efficient power converters, DOE assumes the effects of individual consumer reactions would effectively cancel each othe r, leaving a negligible effect.

Item 63 DOE seeks comments on the impact of the rebound effect, the associated application effect, and the cons umer awareness effect on en ergy consumption of BCs and EPSs. To the extent that commenters can offer reasons and data supporting the adoption of a particular quantitative value fo r each of these effects, DOE is also interested in this information.

Table 10.1 describes some of the major inputs DOE is anticipating it will develop for the national impact analysis.

94Table 10.1. Inputs to the National Impact Analysis

Input Data Description of Data Sources Shipments Annual shipments developed in section 9.
Stock of BCs and EPSs This stock is calcul ated from the service life of BCs and EPSs developed in section 8 and annual sh ipments developed in section 9.
Effective Date of Standard 2013 for Class A EPSs; TBD for BCs. Analysis Period 2013 to 2043 (30 years) for Class A EPSs; TBD for BCs. Base Case Forecasted Efficiency Distribution of ba se case shipments by efficiency level over time developed in section 9. Standards Case Forecasted Efficiency Distribution of shipments by efficiency le vel for each standards case over time developed in section 5.2. Unit Energy Consumption (kWh/yr) The average energy consumption of a BC or EPS established in the energy-use and end-use load characterization, section 6.
Total Installed Cost Established in the Product Price Determination, section 7, and the LCC analysis, section 8. Electricity Price Forecast Established in th e Life-Cycle Cost Analysis, section 8. Electricity Site-to-Source Conversion Conversion varies yearly and is generated by EIA Annual Energy Outlook forecasts of electricity genera tion and electricity-related losses.
Discount Rate The discount rate is the rate at which DOE discounts future expenditures to establish their present value. To comply with OMB requirements, DOE will use 3 and 7 percent discount rates.
Present Year Future costs and savings will be discounted to the year the analysis is performed.
Rebound Effect The difference between the projected and actual savings due to increased efficiency.

10.2 Calculation of National Energy Savings
DOE intends to calculate NES for each year be ginning with the expected effective date of the standards. DOE will calculate these savings as the difference in national electricity consumption between the base case and each CS L analyzed. DOE will perform this calculation using a spreadsheet model that effectively multiplies unit energy savings by the stock of equipment affected by standards. The National I nventory catalogs this stock of equipment.

DOE determines unit energy savings by:

 calculating the weighted-average unit ener gy consumption (UEC) for a device in the base case, obtained by multiplying the UECs at each efficiency level by the base case forecasted efficiency;

 calculating the weighted-average UEC for a device in the standard s case, obtained by multiplying the UECs at each efficiency level by the standards case forecasted efficiency; and

 calculating the difference between the UEC of the base case to the UEC of the standards case, with the difference representing th e weighted-average UEC for a device in that year.

95The National Inventory represents the rolling stock of EPSs and BCs through the analysis period. It is obtained by adding ne w shipments each year and removing units after their lifetime has passed. Because the efficiency of new units pu t in service each year can change over time, the inventory keeps track of the sales year (or vintage) of ever y unit. The savings generated by the BCs and EPSs of a given vintage accrue over several years. The national energy savings in a given year are actually the sum of the savings from multiple vintages of units.

10.3 Net Present Value
DOE determines the national NPV of energy conservation standards in conjunction with the NES. DOE calculates annual energy expend itures from annual energy consumption by incorporating forecasted energy prices using the shipment and average energy-efficiency forecasts described in section 9. DOE calcula tes annual equipment expenditures by multiplying the price per unit by the number of units in forecasted shipments. The difference between a base case and a standards case scenario gives the national energy bill savings and increased equipment expenditure in dollars. For the BCs and EPSs rule makings, this differential will likely result in a NES offset against increased expenditures on BCs and EPSs. The difference each year between energy bill savings and increased equipment expend itures is the net savings (if positive) or net cost (if negative).

DOE will discount these annual values to the present and sum them to provide an NPV. Since the national cost of capital may differ from the consumer cost of cap ital, the discount rate in the NIA can be different from the rate used in the LCC. Consistent with U.S. Office of Management and Budget (OMB) guidance, DOE will conduct two NPV calculations, one using a real discount rate of 3 percen t and another using a real disc ount rate of 7 percent (OMB, Circular A-4: Regulatory Analysis , September 17, 2003). DOE considers th e 7-percent and 3-percent real discount rates to be representative of the present value of costs and benefits associated with two types of investments facing an average degree of ri sk. Specifically, the 7-pe rcent real value is an estimate of the average before-tax rate of retu rn to private capital in the U.S. economy. The 3­ percent real value represents the “societal rate of time preference,” the rate at which society discounts future consumption flows to their present value.

In calculating national NPV, DOE intends to us e the same energy price forecasts it uses in the LCC. However, there is an important difference between the two analyses: in the LCC analysis, residential and commercial consumers ar e considered separately ; however, estimates of national NPV must consider all consumers at once. Thus, DOE calculates national NPV using a weighted-average energy price forecast that considers the proportion of energy savings that accrue to each type of consumer.

Item 64 DOE requests comments on the percen t distribution of residential and commercial energy use for calculation of the weighted-average energy price.

In response to comments by interested parties who asked for a simple, transparent model, DOE developed NES/NPV spreadsheet models fo r its standards rulemakings in 1996. These models project energy savings and demonstrat e how to account for efficiency growth over

96time. 35 Although these models are specif ic to each product, their gene ral framework is applicable to the BC and EPS markets. DOE expect s that the NES/NPV spreadsheet models

 one for BCs and one for EPSs

 will provide stand-alone forecasts of NES and NPV. Based on the comments DOE receives on this framework document and the preliminary TSD, DOE will make any necessary changes to the analysis and incorpor ate those changes in the documentation for the NOPR.

Item 65 DOE seeks comments on the NES/NPV spreadsheet models that DOE plans to use for estimating national impacts of ener gy conservation standards for BCs and EPSs. See chapter 10 of the draft technical re port for a descripti on of these models.

11 LIFE-CYCLE COST SU BGROUP ANALYSIS

At the NOPR stage of this rulemaking, DOE will conduct a life-cycle cost subgroup analysis. In this analysis, DOE analyzes cons umer impacts by dividing consumers into subgroups and accounting for variations in key inputs to the LCC analysis. A consumer subgroup comprises a subset of the population that is likely, for a vari ety of reasons, to be affected disproportionately by new or revised energy conservation standards ( e.g. , small businesses, ethnic minorities, lowincome or elderly consumers, etc.). 36 The purpose of a subgroup analysis is to determine the extent of any such disproportional impact. DOE w ill work with interested parties early in the rulemaking process to identify any subgroups for this consideration. However, as noted above, DOE will not analyze the consumer subgroups until the NOPR stage of the analysis.

In comparing potential impacts on the differe nt consumer subgroups, DOE will evaluate variations in regional elec tricity prices, usage profiles, and inst allation costs that might affect the NPV of an energy conservation standard to cert ain consumer subgroups. To the extent possible, DOE will obtain estimates of the vari ability in each input factor a nd consider this variability in its calculation of consumer impacts. DOE will disc uss with interested parties the variability in each input factor and likely sources of information.

Item 66 DOE seeks comments on which consumer subgroups, if any, DOE should consider when developing standards for BCs and EPSs.

35 Several examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at www.eere.energy.gov/buildings/appliance_standards

. 36 For example, consumer subgroups with lower electricity prices than the average consumer will experience lower operating cost savings in the face of a standa rd, resulting in lower life-cycle cost savings. As another example, lowincome consumers may be disproportionately affected by standards that eliminate lower-cost products from the market.

9712 MANUFACTURER IMPACT ANALYSIS

As required by section 141 of EPAC T 2005, DOE announced changes to the manufacturer impact analysis (MIA) approach in a report issued to Congress on January 31, 2006, titled “Energy Conservati on Standards Activities” 37 . Under this new approach, DOE will collect, evaluate, and report pre liminary information and data on manufacturer impacts in the preliminary TSD. (See “Energy Conservation Standards Activities,” page 48.) Such preliminary information includes the anticipat ed conversion capital expenditure s by efficiency level and the corresponding anticipated impacts on employment. DOE will seek further input on these issues during its manufacturer interviews for the preliminary analyses.

The MIA is designed to assess the potential impacts of energy conservation standards on manufacturers of BCs and EPSs. In addition to fi nancial impacts, a wide range of quantitative and qualitative effects may occur following adopti on of a standard that may require changes to the manufacturing practices for these units. DOE will identify these effects through interviews with manufacturers and other experts.

For the NOPR, DOE will supplement the resu lts of the preliminary MIA conducted as part of the preliminary analyses wi th more detailed analyses (sections 12.1 through 12.5). Specifically, DOE will conduct an industry-wide cash-flow analysis using the Government Regulatory Impact Model (GRIM) , identify and analyze subgr oups of manufacturers whose business varies significantly from the industr y as a whole, perform a competitive impacts assessment, and review the cumulativ e regulatory burden for the industry.

12.1 Sources of Information for the Manufacturer Impact Analysis
Many of the analyses described earlier provide important information that DOE will use as inputs for the manufacturer impact analysis. Such information includes financial parameters developed in the market assessment (section 3.1), retail price forecasts (section 7), and shipments forecasts (section 9). DOE will supplement this information with information gathered during manufacturer interviews.

DOE will conduct detailed interviews with manuf acturers to gain insight into the range of potential impacts from standards. The intervie w process plays a key role in the manufacturer impact analysis, because it provides an opportunity for directly affected pa rties to express their views on important issues. During the intervie ws, DOE will solicit information on the possible impacts on manufacturing costs, equipment prices, sales, direct employment, capital assets, and industry competitiveness. Both qualitative and qu antitative information are valuable for this analysis. DOE will schedule interviews well in advance to provide every opportunity for key individuals to be available to participate. In addition, DOE will provide manufacturers with questionnaires before the interviews to fac ilitate information gathering. Although a written response to the questionnaire is acceptable, DOE prefer s an interactiv e interview process, which helps clarify responses and provides the oppor tunity to identify additional issues.

37 This report, titled “Energy Conser vation Standards Activ ities” (Standards Activities), is available on the DOE website at www1.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html.

98DOE will ask interview participants to identif y all confidential information provided in writing or orally. DOE also will determine whet her the information submitted is entitled to confidential treatment. DOE will co nsider the information gathered, as appropriate, in the energy conservation standard decision-making process. DOE will also ask participants to identify any information that they wish to include in the pub lic record, but that they do not want to have associated with their interview (thereby identi fying that particular manufacturer). DOE will incorporate this information into the public record, but will report it without attribution.

DOE will collate the interview results and prepare a summary of the major issues and outcomes. This summary will become part of the technical support document for this rulemaking.

12.2 Industry Cash-Flow Analysis
The industry cash-flow analysis will rely pr imarily on the GRIM. DOE uses the GRIM to analyze the financial impacts of new or more stringent energy conservation standards on the industry that produces the equipment covered by the standard.

The GRIM analysis uses several factors—a nnual expected revenues; manufacturer costs such as costs of goods sold; se lling, general, and administrativ e costs; taxes; and capital expenditures (both ordinary capita l expenditures and those relate d to standards)—to determine annual cash flows associated with a new standard, beginning from the announcement of the standard and continuing for several years afte r its implementation. DOE compares the results against base case projections that involve no new standards. The financial impact of new standards is the difference be tween the two sets of discount ed annual cash flows. Other performance measures, such as return on invest ed capital, are also available from the GRIM.

DOE will gather the inputs needed for the GRIM from two primary sources: the analyses conducted to this point, and interviews with manufacturers and other interested parties. Information gathered from previous analyses will include financial parameters, manufacturing costs, price forecasts, and shipments forecasts. Interviews with manufacturers and other interested parties will be essentia l in supplementing this information.

12.3 Manufacturer Subgroup Analysis
Using average industry cost values may not adequately assess differential impacts among subgroups of BC or EPS manufacturers. DOE recognizes that smaller, more specialized, or other manufacturers exhibiting a cost structure that differs significan tly from the industry average may be affected differently by the imposition of stan dards. Ideally, DOE would consider the impact on every firm individually. In high ly concentrated industries, this may be possible. In industries having numerous participants, however, DOE uses the results of the market and technology assessment to group manufacturers into subgroups, as appropriate. For BCs and EPSs, DOE does not intend to assess the impacts on every manufacture r individually, and theref ore is interested in feedback from interested pa rties about pot ential subgroups.

99The detailed manufacturer subgroup impact anal ysis will entail calculating cash flows separately for each defined class of manufacturer.

Item 67 DOE seeks comments on which potential subgroups of BC and EPS manufacturers should consider in its manufacturer subgroup analysis.

12.4 Competitive Impacts Analysis
EPCA directs DOE to consider any lessening of competition likely to result from an imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i )(V)) It further directs the Attorney General to determine in writing the impacts, if any, of any lessening of competition. (42 U.S.C. 6295(o)(2)(B)(ii))

DOE will make a determined effort to gather firm-specific financial information and impacts, and it will then report the aggregated impact of the standard on manufacturers. The competitive impacts analysis will focus on assessing the impacts on smaller, yet significant, manufacturers. DOE will base the assessment on manufacturing cost data and on information collected from manufacturer interv iews. The interviews will focus on gathering information that would help in assessing asymmetrical cost incr eases to some manufacturers, increased proportion of fixed costs potentially increasing business ri sks, and potential barriers to market entry ( e.g. , proprietary technologies). DOE w ill provide the Attorney Genera l with a copy of the NOPR for consideration in evaluating the potential comp etitive impact that standards would have.

12.5 Cumulative Regulatory Burden

Other regulations may apply to the BCs and EPSs covered under th is rulemaking, and to other equipment produced by the same manufactu rers. Multiple regulations may result in a significant, cumulative regulatory burden on these manufacturers. DOE will analyze and consider the impact on BC and EPS manufactur ers of multiple, equipment-specific regulatory actions.

Other regulations that could impact the industry affected by this rulemaking include:

 energy conservation standards for Cla ss A EPSs established by the Energy Independence and Security Act of 2007 (EISA, Public Law 110-140);

 existing and/or proposed State standards for BCs and EPSs; and

 international standards, including upco ming regulation of EPSs and proposed regulation of BCs by Canada, Aust ralia, and the European Union.

Table 12.1 lists the national and international voluntary and regulatory programs for BCs and EPSs, including the voluntary ENERGY STAR specification in the United States and eight regulatory efforts internationally. Most of the regulatory programs are for EPSs only and follow

100a structure similar to the ENERGY STAR EP S Version 1.1 specification. ENERGY STAR and Canada also address BCs. Appendi x F provides a more complete discussion of these programs.

Table 12.1 National and International Volunt ary and Regulatory Programs for BCs and EPSs
Country/Region Program/Institution BC EPS United States ENERGY STAR for BC and ENERGY STAR Tier I (V1.1) and Tier II (V2.0) for EPS X X

Australia and New Zealand Minimum Energy Performance Standards (MEPS) AS/NZS 4665:2005 X

Canada C381.1 for EPS and C381.2 for BC X X China China National Institute of Standardization (CNIS) and China Standard Certification Center (CSC) Standards X

European Union Code of Conduct on Efficiency of External Power Supplies, EU Standby Initiative X

European Union Eco-design of Energy-using Products (EuP) Initiative, Directive 2005/32/EC X

European Union (Subset of Member Countries) Group for Energy Efficient Appliances X

Israel SI 4665.2 (AS/NZX 4665.2-2005) X Korea e-Standby Program X

Item 68 DOE seeks comments on other existing and pending regulations it should consider in its examination of cumulative regulatory burden.

13 UTILITY IMPACT ANALYSIS

Like the life-cycle cost subgroup analysis, DOE completes the utility impact analysis during the NOPR stage of this rulemaking. In th e utility impact analysis, DOE estimates the effects of energy conservation standards for BCs and EPSs on electricity sales for the electric utility industry. To quantify this impact, DOE plans to use a variant of EIA’s NEMS, called NEMS-BT. 38 NEMS is a large, multi-sectoral, partia l-equilibrium model of the U.S. energy sector used primarily to prepare the AEO. NEMS-BT is a customized version of NEMS appropriate for the rulemaking analyses conduc ted by DOE’s Office of Building Technologies. NEMS-BT provides the reference case forecas t for the United States through 2030 and is available to the public.

The utility impact analysis compares the NE MS-BT model results fo r the base case and standards cases. Outputs of the u tility impact analysis usually para llel results that appear in the latest AEO, with some additions. Typical out puts include forecasts of electricity generation,

38 For more information on NEMS, please refer to th e U.S. Department of Energy, Energy Information Administration documentation. A useful summary is National Energy Modeling System: An Overview 2000

, DOE/EIA-0581 (March 2000). EIA approves the use of the name NEMS to describe only an official version of the model without any modification to code or data. Because this analysis entails some minor code modifications and the model is run under various policy scenarios that are variations on EIA assumptions, DOE refers to the model by the name NEMS-BT. (“BT” refers to DOE’s Building Technologies Program, under whose aegis this work has been performed.)

101sales, price, and avoided capacit y. DOE plans to conduct the utility impact analysis as a scenario departing from the latest AEO reference case. In other words, DOE will model the energy savings impacts from energy conservation stan dards for BCs and EPSs using NEMS-BT to generate forecasts that deviat e from the AEO reference case. 39

Item 69 DOE seeks input on its plans to use NE MS-BT to conduct the utility impact analysis.

14 EMPLOYMENT IMPACT ANALYSIS

DOE includes employment impacts among the f actors it considers in selecting a proposed efficiency standard. DOE also considers the impact of CSLs on both direct and indirect employment. There is a general presumption 40 against any CSL that would directly cause plant closures or significant loss of domestic empl oyment unless specifically identified expected benefits of the standard would outweigh such adverse effects. (See the Process Rule, 10 CFR Part 430, Subpart C, Appendix A, sections 4(d)(7)(ii) and (vi) , and 5(e)(3)(i)(B).)

During the NOPR stage of the BC and EPS rulemakings, DOE will estimate the impacts of standards on employment for equipment manufacturers, releva nt service industries, energy suppliers, and the economy in general. DOE’s analysis will cover both direct and indirect employment impacts. Direct empl oyment impacts would result if st andards led to a change in the number of employees at manuf acturing plants and related supp ly and service firms. Direct impact estimates are covered in th e manufacturer impact analysis.

Indirect employment impacts are impacts on the national economy other than in the manufacturing sector being re gulated. Indirect impacts may result both from expenditures shifting among goods (the substitution effect) and ch anges in income that lead to a change in overall expenditure levels (the income effect). DOE defines indirect em ployment impacts from standards as net jobs eliminated or created in the general economy as a result of increased spending, driven by the increased equipmen t prices and reduced spending on energy.

DOE will investigate the combined direct and indirect employment impacts in the employment impact analysis using the “Impact of Sector Energy Technologies” (ImSET) model that Pacific Northwest Nationa l Laboratory (PNNL) developed for DOE’s Office of Planning, Budget, and Analysis. The model estimates the em ployment and income effects of energy-saving technologies in buildings, indus try, and transportation. In comp arison with simple economic

39 Several NEMS-BT models from p revious rulemakings can be found on the DOE’s Web site at www1.eere.energy.gov/buildings/appliance_standards.

40 “(B) If the Department determines that a candidate standard level would be the direct cause of plant closures, significant losses in domestic manufacturer employment, or significant losses of capital investment by domestic manufacturers, that standard level will be presumed not to be economically justified unless the Department determines that specifically identified expected benefits of the standard would outweigh this and any other expected adverse effects.” (Emphasis added, 10 CFR Part 430, Subpart C, Appendix A, section 5(e)(3)(i)(B)).

102multiplier approaches, ImSET allows for more co mplete and automated analysis of the economic impacts of energy-efficiency investments. Alt hough DOE intends to use ImSET for its analysis of employment impacts, it seeks input on other tools and factors it might consider.

Item 70 DOE seeks feedback on its planned approac h for assessing direct and indirect national employment impacts.

15 ENVIRONMENTAL ASSESSMENT

DOE will prepare its draft environmental a ssessment (EA) pursuant to the National Environmental Policy Act and the require ments under 42 U.S.C. 6295(o)(2)(B)(i)(VI) and 6316(a), to determine the environmental impacts of the amended standards. The intent of the environmental assessment is to provide emissions results estimates and to fulfill requirements to properly quantify and consider the environmental effects of all new Federal rules.

The environmental assessment will focus on the impact of possible energy conservation standards on the significant pollutants and emissions of el ectricity-generating power plants. Specifically, the environmental assessment for this rulemaking will consider three types of energy-related emissions — oxides of nitrogen (NO x ), mercury (Hg), and carbon dioxide (CO 2 ). An additional emission, sulfur dioxide (SO 2 ), was previously considered. However, DOE has determined that due to the presence of national caps on SO 2 emissions as addressed below, any such reduction resulting from an energy conservation standard woul d not affect the overall level of SO 2 emissions in the United States.

DOE will estimate the reduction in tota l emissions of carbon dioxide (CO 2 ) using the NEMS-BT computer model. DOE will calculat e a range of estimates for reduction in NO x emissions and Hg emissions using current power sector emission rates. DOE will conduct each portion of the environmental impact analysis pe rformed under this rulemaking as an incremental policy impact ( i.e. , an energy conservation standard for BCs and EPSs) of EIA’s AEO forecast, applying the same basic set of assu mptions used in the latest vers ion of AEO available for use in this analysis. Also, forecasts conducted with NEMS-BT consider the supply-side and demandside effects on the electric utili ty industry. Thus, DOE’s analys is will account for any factors affecting the type of electricity generation and, in turn, the amount of airborne emissions the utility industry generates.

The NEMS-BT is run similarly to the AEO 2008 NEMS, except the energy use is reduced by the amount of energy saved due to the CSLs . DOE obtains the inputs of national energy savings from the NIA spreadsheet model. For th e Environmental Assessment, the output is the forecasted physical emissions. The net benefit of the standard is the difference between emissions estimated by NEMS-BT and the AEO2008 Reference Case. The NEMS-BT tracks CO 2 emissions using a detailed module that provides results with a broad coverage of all sectors and inclusion of interactive effects.

103Item 71 DOE seeks input on its plans to use NEMS-BT to conduct the environmental impact analysis on the equipmen t covered by this rulema king. DOE is particularly interested in whether there are any other appr oaches to the environm ental assessment that it should consider and the advantages and disa dvantages for each of those approaches.

The Clean Air Act Amendments of 1990 set an emissions cap on SO 2 for all power generation. The attainment of this target, however, is flexible am ong generators and is enforced through the use of emissions allowan ces and tradable permits. Because SO 2 emissions allowances have value, they will almost certain ly be used by generators , although not necessarily immediately or in the same year regardless of whet her a standard is in place. In other words, with or without a standard, total cumulative SO 2 emissions will always be at or near the ceiling, while there may be some timing differences among yearly forecasts. Thus, it is unlikely that there will be an SO 2 environmental benefit from standards as l ong as there is enforcem ent of the emissions ceilings. Although there may not be an actual reduction in SO 2 emissions from electricity savings, there still may be an economic benefit from reduced demand for SO 2 emission allowances. Electricity savings decrease the generation of SO 2 emissions from power production, which can decrease the need to purchase or generate SO 2 emissions allowance credits, and decrease the costs of complying with regulatory caps on emissions.

NO x emissions are currently subject to emissi ons caps under the Clean Air Interstate Rule (CAIR) published in the Federal Register on May 12, 2005. 70 FR 25162 (May 12, 2005). The CAIR caps emissions in 28 eastern States and the District of Columbia (D .C.). As with the SO 2 emissions cap, energy conservation standards are not likely to have a physical effect on NO x emissions in those States. However, the standa rds created by a final rule that may result from this framework document might produce an envi ronmentally related economic impact in the form of lower prices for emissions allowance credits if they were large enough. DOE believes that such standards would not produce such an impact because the estimated reduction in NO x emissions or the corresponding increase in availa ble allowance credits in States covered by the CAIR cap would be too small to affect allowance prices for NO x. In contrast, new or amended energy conservation standa rds would reduce NO x emissions in those 22 States that are not affected by the CAIR, and these emissions could be estimated from NEMS-BT. As a result, DOE will use NEMS-B T to forecast emission reductions from any standards that DOE ultimately proposes in a NO PR for the products covered by this framework document.

Though currently in effect, CAIR has been th e subject of signifi cant litigation. CAIR was vacated by the U.S. Court of Appeals for the Di strict of Columbia Circ uit (D.C. Circuit) in its July 11, 2008, decision in North Carolina v. Environmental Protection Agency

. 41 However, on December 23, 2008, the D.C. Circuit decided to allow the CAIR to remain in effect until it is replaced by a rule consistent with the court's earlier opinion. 42

41 531 F.3d 896 (D.C. Cir. 2008)
42 North Carolina v. EPA , 550 F.3d 1176 (D.C. Cir. 2008) (remand of vacatur).

104Similar to SO 2 and NO x , future emissions of Hg would have been subject to emission caps under the Clean Air Mercury Rule (CAMR). The CAMR would have permanently capped emissions of Hg for new and existing coal-fired plants in all States by 2010, but was vacated by the D.C. Circuit in its Fe bruary 8, 2008, decision in New Jersey v. Environmental Protection Agency

. 43 DOE typically uses the NEMS-BT model to calculate emissions from the electrical generation sector; however, the 2008 NEMS-BT model is not suitable for assessing mercury emissions in the absence of a CAMR cap. Thus, DOE plans to use a range of Hg emissions rates (in metric tons of Hg per energy terawatt hour (TWh) produced) based on the AEO2008. To estimate the reduction in mercury emissions, DOE will then multiply the emission rate by the reduction in coal-generated electricity associated with standards considered.

Item 72 Because court actions have vacated the CAIR, DOE seeks input on how it should address NO x emissions in this rulemaking.

Item 73 Because court actions have vacated the CAMR, DOE seeks input on how it should address Hg emissions in this rulemaking.

DOE will calculate the possible monetary benefit of CO 2 , NO x , and Hg reductions. Cumulative monetary benefits will be determined using discount rates of 3 and 7 percent. DOE will monetize reductions in CO 2 emissions due to the potential standards based on a range of monetary values drawn from studies that attempt to estimate the present value of the marginal economic benefits (based on the avoide d marginal social costs of carbon) likely to result from reducing greenhouse gas emissions. The marginal so cial cost of carbon is an estimate of the monetary value to society of the environmental damages of CO 2 emissions. This concept will be used rather than compliance costs because CO 2 is not regulated.

SO 2 emissions have markets for emissions a llowances. The market clearing price of SO 2 emissions is roughly the marginal cost of meeting the regulatory cap, not the marginal value of the cap itself. Further, because SO 2 (for the nation) is regulated by a cap and trade system, the effect of the need to meet these caps is alrea dy included in the price of energy or energy savings. With a cap on SO 2 , the value of energy savings al ready includes the value of SO 2 control for those consumers experiencing energy savings. Th e economic cost savings associated with SO 2 emissions caps is approximately equal to the chan ge in the price of traded allowances resulting from energy savings multiplied by the number of allowances that would be issued each year. That calculation is uncertain be cause the energy savings for BCs and EPSs would most likely be so small relative to the entire electricity generati on market that the resulting emissions savings would have almost no impact on price formation in the allowances market and likely would be outweighed by uncertainties in the margin al costs of compliance with the SO 2 emissions caps.

43 New Jersey v. EPA , 517 F.3d 574 (D.C. Cir. 2008).

105Item 74 DOE invites comments on how to estimate such monetary values associated with emissions reductions or on any widely ac cepted values which might be used in DOE’s analyses.

Item 75 DOE seeks input on other environmenta l factors to consider in this rulemaking.

16 REGULATORY IMPACT ANALYSIS

In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis. This analysis will address the potential for non- regulatory approaches to supplant or augment energy conservation standards to improve the efficiency of BCs and EPSs in the market.

The regulatory impact analysis will consid er the likely eff ects of non-regulatory initiatives on BC and EPS energy use, consumer utility, and life-cycle costs. DOE will account for the actual impacts of any existing initiatives to date, and consider hist orical information that may reasonably estimate the impacts of any such initiative in the future. DOE will use the NES spreadsheet model (section 10.2, “Calculation of National Energy Savings”) to calculate the NES and NPV for the alternatives to the potent ial conservation standa rds under consideration.

As part of the regulatory impact an alysis, and as discussed in section 12, “Manufacturer Impact Analysis,” DOE will identify and s eek to mitigate the overlapping effects on manufacturers of new or revised DOE standards and other regulatory actions affecting the same products. This will include the collection of da ta on potential small manufacturer impacts or competitive disruptions that may result from a ny regulation. Furthermore, DOE will consider small business impacts on consumers in the life-cycle cost subgroup analysis, section 11.

If DOE proposes energy conservation standa rds for BCs and EPSs and if the proposed rule constitutes a significant regulatory action, DOE will submit to OMB an assessment of costs and benefits required under section 6(a)(3) of Executive Order 12866, “Regulatory Planning and Review,” 58 FR 51735 (October 4, 1993). The Executiv e Order requires agencies to identify the specific market failure or other specific problem they intend to address that warrant new agency action, and also to assess the significance of that problem to help determine whether new regulation is warranted. (Execu tive Order 12866, section 1(b)(1)) Without a market failure, a regulation cannot result in net benefits. DOE s eeks comments on the potential market failures discussed in section 3.1 of this framework document.

Of course, there are likely to be external benefits resulting from the improved efficiency of BCs and EPSs that are not cap tured by the users of such equipment. These benefits include both environmental and energy security-related eff ects that are not alrea dy reflected in energy prices such as reduced emissions of greenhouse gases and reduced use of natural gas and oil for electricity generation. DOE seeks comments on the wei ght that it should give to these factors in

106determining the maximum efficiency level at whic h the total benefits are likely to exceed the total burdens resulting from a DOE standard.

107APPENDIX A – EPCA DIRECTIVES RE GARDING BATTERY CHARGERS AND EXTERNAL POWER SUPPLIES

This appendix lists the relevant statutor y requirements under 42 U.S.C. 6291, 42 U.S.C. 6293, and 42 U.S.C. 6295 that apply to BCs and EPSs. These requirements are drawn from sections 321, 323, and 325 of EPCA, as amende d by section 135 of EPACT 2005 and sections 301, 309, and 310 of EISA.

EPCA 321 (42 U.S.C. 6291)

(32) The term “battery charger” means a device that charges batteries for consumer products, including battery chargers embe dded in other consumer products.

[ * * * * *]

(36) EXTERNAL POWER SUPPLY- (A) IN GENERAL- The term “external power supply” mean s an external power supply circuit that is used to convert household electric current into DC current or lower-voltage AC current to operate a consumer product. (B) ACTIVE MODE- The term “`active mode”' means the mode of operation when an external power supply is connected to the main electricity supply and the output is connected to a load. (C) CLASS A EXTERNAL POWER SUPPLY- (i) IN GENERAL- The term “`class A ex ternal power supply”' means a device that-- (I) is designed to convert line voltage AC input into lower voltage AC or DC output; (II) is able to convert to only 1 AC or DC output voltage at a time; (III) is sold with, or intended to be used with, a separate end-use product that constitutes the primary load; (IV) is contained in a separate phys ical enclosure from the end-use product; (V) is connected to the end-use prod uct via a removabl e or hard-wired male/female electrical connection, cable, cord, or other wiring; and (VI) has nameplate output power that is less than or equal to 250 watts. (ii) EXCLUSIONS- The term “`class A ex ternal power supply”' does not include any device that-- (I) requires Federal Food and Drug Ad ministration listing and approval as a medical device in accordance with section 513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c); or (II) powers the charger of a detachable battery pack or charges the battery of a product that is fully or primarily motor operated.

108(D) NO-LOAD MODE- The term ““no-load mode”” means the mode of operation when an external power supply is connected to the main electricity supply and the output is not connected to a load.

[ * * * * *]

(52) DETACHABLE BATTERY- The term “`detachab le battery”' means a battery that is-- (A) contained in a separate enclosure from the product; and (B) intended to be removed or disconn ected from the produc t for recharging.

EPCA 323(b) (42 U.S.C. 6293(b))

(17) CLASS A EXTERNAL POWER SUPPLIES- Test procedures for class A external power supplies shall be based on the “Test Method for Calculating th e Energy Efficiency of SingleVoltage External AC-DC and AC-AC Power Supplies” published by the Environmental Protection Agency on August 11, 2004, except that the test voltage specified in section 4(d) of that test method shall be only 115 volts, 60 Hz.

EPCA 325 (42 U.S.C. 6295)

(u) Battery charger and external power supply electric energy consumption (1)(A) Not later than 18 months after August 8, 2005, the Secret ary shall, after providing notice and an opportunity for comment, prescribe, by rule, definitions and test procedures for the power use of battery charge rs and external power supplies. (B) In establishing the test procedures unde r subparagraph (A), the Secretary shall - (i) consider existing definitions and test procedures used for measuring energy consumption in standby mo de and other modes; and (ii) assess the current and projected fu ture market for battery chargers and external power supplies. (C) The assessment under subparagr aph (B)(ii) shall include – (i) estimates of the significance of po tential energy savings from technical improvements to battery chargers and external power supplies; and (ii) suggested product classes fo r energy conservation standards. (D) Not later than 18 months after Augus t 8, 2005, the Secretary shall hold a scoping workshop to discuss and receive comments on plans for developing energy conservation standards for energy use for battery chargers and external power supplies. (E) EXTERNAL POWER SUPPLI ES AND BATTERY CHARGERS- 44 (i) ENERGY CONSERVATION STANDARDS- (I) EXTERNAL POWER SUPPLIES- Not later than 2 years after the date of enactment of this s ubsection, the Secret ary shall issue a final rule that determines whether energy conservation standards

44 The determination required under 49 U.S.C. 6295(u)(1 )(E) is due December 19, 2009, which is two years after the enactment of this provision.

109shall be issued for external power supplies or classes of external power supplies. (II) BATTERY CHARGERS- Not later than July 1, 2011, the Secretary shall issue a final rule that prescribes energy conservation standards for battery chargers or classes of battery chargers or determine that no en ergy conservatio n standard is technically feasible a nd economically justified. (ii) For each product class, any en ergy conservation standards issued under clause (i) shall be set at the lowest level of energy use that – (I) meets the criteria and procedures of subsections (o), (p), (q), (r), (s), and (t) of this section; and (II) would result in significant overall annual energy savings, considering standby mode a nd other operating modes. (2) The Secretary and the Administrator shall collaborate an d develop programs (including programs under section 6294a of this title and other voluntary industry agreements or codes of conduct) that are designed to reduce standby mode energy use. (3) EFFICIENCY STANDARDS FOR CL ASS A EXTERNAL POWER SUPPLIES­ (A) IN GENERAL- Subject to subparagra phs (B) through (D), a class A external power supply manufactured on or after the later of July 1, 2008, or the date of enactment of this paragraph shall meet the following standards:

Active Mode Nameplate Output Required Efficiency (decimal equivalent of a percent-age) Less than 1 watt 0.5 times the Nameplate Output

From 1 watt to not more than 51 watts The sum of 0.09 times the Natural Logarithm of the Nameplate Output and 0.5 Greater than 51 watts 0.85 No-Load Mode Nameplate Output Maximum Consumption No more than 250 watts 0.5 watts

(B) NONCOVERED SUPPLIES- A class A ex ternal power supply shall not be subject to subparagraph (A) if the cl ass A external power supply is-- (i) manufactured during the period be ginning on July 1, 2008, and ending on June 30, 2015; and (ii) made available by the manufacturer as a service part or a spare part for an end-use product-- (I) that constitutes the primary load; and (II) was manufactured before July 1, 2008. (C) MARKING- Any class A external power supply manufactured on or after the later of July 1, 2008 or the da te of enactment of this paragraph shall be clearly and permanently marked in accordance with the External Power Supply International Efficiency Marking Protocol, as refe renced in the ‘“Energy Star Program

110Requirements for Single Voltage Extern al AC-DC and AC-AC Power Supplies, version 1.1’” published by the Environmental Protection Agency. (D) AMENDMENT OF STANDARDS- (i) FINAL RULE BY JULY 1, 2011- (I) IN GENERAL- Not later than July 1, 2011, the Secretary shall publish a final rule to determine whether the standards established under subparagraph (A) should be amended. (II) ADMINISTRATION- The final rule shall-- (aa) contain any ame nded standards; and (bb) apply to products manuf actured on or after July 1, 2013. (ii) FINAL RULE BY JULY 1, 2015- (I) IN GENERAL- Not later than July 1, 2015 the Secretary shall publish a final rule to determine whether the standards then in effect should be amended. (II) ADMINISTRATION- The final rule shall-- (aa) contain any ame nded standards; and (bb) apply to products manuf actured on or after July 1, 2017. (4) END-USE PRODUCTS- An energy conser vation standard for external power supplies shall not constitute an energy cons ervation standard for the separate end-use product to which the external pow er supplies is [sic] connected.

[ * * * * *]

(gg) Standby Mode Energy Use- (1) DEFINITIONS- (A) IN GENERAL- Unless the Secretar y determines otherwise pursuant to subparagraph (B), in this subsection: (i) ACTIVE MODE- The term '“active mode'” means the condition in which an energy-using product-- (I) is connected to a main power source; (II) has been activated; and (III) provides 1 or more main functions. (ii) OFF MODE- The term '“off mode '” means the condition in which an energy-using product-- (I) is connected to a main power source; and (II) is not providing any standby or active mode function. (iii) STANDBY MODE- The term '“st andby mode'” means the condition in which an energy-using product-- (I) is connected to a main power source; and (II) offers 1 or more of the follo wing user-oriented or protective functions: (aa) To facilitate the activa tion or deactivation of other functions (including active mode) by remote switch (including remote control), in ternal sensor, or timer.

111(bb) Continuous functions, including information or status displays (including clocks) or sensor-based functions. (B) AMENDED DEFINITIONS- The Secretary may, by rule, amend the definitions under subparagraph (A), taking into consideration the most current versions of Standards 62301 and 62087 of the International Electrotechnical Commission. (2) TEST PROCEDURES- (A) IN GENERAL- Test procedures for all covered products shall be amended pursuant to section 323 to include standby mode and off mode energy consumption, taking into consideration th e most current versions of Standards 62301 and 62087 of the International Elect rotechnical Commission, with such energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product, unless the Secretary determines that-- (i) the current test procedures for a covered product already fully account for and incorporate the standby mode and off mode energy consumption of the covered product; or (ii) such an integrated test procedure is technically infeasible for a particular covered product, in which case the Secretary shall prescribe a separate standby mode and off mode energy use test procedure for the covered product, if technically feasible. (B) DEADLINES- The test procedure amen dments required by subparagraph (A) shall be prescribed in a final rule no later than the following dates: (i) December 31, 2008, for battery charge rs and external power supplies. (ii) March 31, 2009, for clothes dr yers, room air conditioners, and fluorescent lamp ballasts. (iii) June 30, 2009, for resi dential clothes washers. (iv) September 30, 2009, for resi dential furnaces and boilers. (v) March 31, 2010, for residential water heaters, direct heating equipment, and pool heaters. (vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and dehumidifiers. (C) PRIOR PRODUCT STANDARDS- The te st procedure amendments adopted pursuant to subparagraph (B ) shall not be used to determine compliance with product standards established prior to the adoption of the amended test procedures. (3) INCORPORATION INTO STANDARD- (A) IN GENERAL- Subject to subparagra ph (B), based on the test procedures required under paragraph (2), any final rule establishing or revising a standard for a covered product, adopted after July 1, 2010, shall incorporate standby mode and off mode energy use into a single am ended or new standard, pursuant to subsection (o), if feasible. (B) SEPARATE STANDARDS- If not feasible, the Secretary shall prescribe within the final rule a separate standa rd for standby mode and off mode energy consumption, if justifie d under subsection (o).

112(ii) APPLICATION DATE.—Secti on 327 [42 U.S.C. 6297] applies— (1) to products for which energy conservation standards are to be established under subsection (l), (u), or (v) of this section beginning on the da te on which a final rule is issued by the Secretary, except that any State or local standard prescribed or enacted for the product before the date on which the final rule is issued shall not be preempted until the energy conservation standard established under subsection (l), (u), or (v) of this section for the product takes effect; and (2) to products for which energy conservation standards are established under subsections (w) through (hh) on August 8, 2005, ex cept that any State or local standard prescribed or enacted before the date of enactment of August 8, 2005 shall not be preempted until the energy conservation standards es tablished under subsections (w ) through (gg) take effect.

113APPENDIX B – DEFINITIONS

This appendix provides statutory defi nitions relevant to BCs and EPSs.

“Battery Charger”

42 U.S.C. 6291(32)

(32) The term "battery charger" means a de vice that charges batteries for consumer products, including battery chargers embedded in other consumer products.

“External Power Supply”

42 U.S.C. 6291(36)(A)

(A) IN GENERAL- The term “external power supply” mean s an external power supply circuit that is used to convert household electric current into DC current or lower-voltage AC current to operate a consumer product.

“Class A External Power Supply”

42 U.S.C. 6291(36)(C)

(i) IN GENERAL- The term “`class A exte rnal power supply'” means a device that-- (I) is designed to convert line voltage AC input into lower voltage AC or DC output; (II) is able to convert to only 1 AC or DC output voltage at a time; (III) is sold with, or intended to be us ed with, a separate end-use product that constitutes the primary load; (IV) is contained in a separate physical enclosure from the end-use product; (V) is connected to the end-use prod uct via a removabl e or hard-wired male/female electrical connection, cable, cord, or other wiring; and (VI) has nameplate output power that is less than or equal to 250 watts. (ii) EXCLUSIONS- The term “`class A exte rnal power supply'” does not include any device that-- (I) requires Federal Food and Drug Admi nistration listing and approval as a medical device in accordance with sec tion 513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c); or (II) powers the charger of a detachable ba ttery pack or charges the battery of a product that is fully or primarily motor operated.

“Detachable Battery”

42 U.S.C. 6291(52)

114The term “`detachable battery'” means a battery that is-- (A) contained in a separate enclosure from the product; and (B) intended to be removed or disconn ected from the produc t for recharging.

“Consumer Product”

42 U.S.C. 6291(1)

The term “consumer product” means any article (other than an automobile, as defined in section 32901(a)(3) of title 49) of a type—

(A) which in operation consumes, or is designed to consume, energy or, with respect to showerheads, faucets, water closets, and urinals, water; and (B) which, to any significant extent, is di stributed in commerce for personal use or consumption by individuals;

without regard to whether such article of such type is in fa ct distributed in commerce for personal use or consumption by an individual, except that such term includes fluorescent lamp ballasts, general serv ice fluorescent lamps, incandescent reflector lamps, showerheads, faucets, water closets, and ur inals distributed in commerce for personal or commercial use or consumption.

115APPENDIX C – TEST PROCEDURES

This appendix provides the DOE test proce dures for measuring the energy consumption of BCs and EPSs, as contained in 10 CFR 430, Subpart B, Appendices Y and Z, respectively. These test procedures were published in the Federal Register on December 8, 2006 and amended by the standby and off mode final rule on March 27, 2009.

Battery Chargers

1. Scope: This appendix covers the te st requirements used to measure battery charger energy consumption.

2. Definitions: The following definitions are for the purposes of understanding terminology associated with the test method for meas uring battery charger energy consumption. 45

Accumulated nonactive energy is the sum of the energy, in watt -hours, consumed by the battery charger in battery-maintenance mode and standb y mode over time periods defined in the test procedure.

Active mode is the condition in which the battery is re ceiving the main charge, equalizing cells, and performing other one-time or limited-time func tions necessary for bringing the battery to the fully charged state.

Battery or battery pack is an assembly of one or more r echargeable cells intended to provide electrical energy to a consumer product, and may be in one of the following forms: (a) detachable battery: a battery that is contained in a separate en closure from the consumer product and is intended to be removed or disconnected from the consumer product for recharging; or (b) integral battery: a battery that is contained within the consumer product and is not removed from the consumer product for charging purposes.

Battery energy is the energy, in watt-hours, delivered by the battery under the specified discharge conditions in the test procedure.

Battery maintenance mode or maintenance mode is the mode of operation when the battery charger is connected to the main electricity supply and the battery is fully charged, but is still connected to the charger.

Energy ratio or nonactive energy ratio means the ratio of the accumulated nonactive energy divided by the battery energy.

Multi-port charger means a battery charger that is capable of simultaneously charging two or more batteries. These chargers also may have multi-voltage ca pability, allowing two or more batteries of different voltage s to charge simultaneously.

45 For clarity on any other terminolo gy used in the test method, please refer to IEEE Standard 1515– 2000.

116Multi-voltage a la carte charger means a separate battery charger that is individually packaged without batteries, and is able to charge a variety of batteries of different nominal voltages. Standby mode or no-load mode means the mode of operation wh en the battery charger is connected to the main electricity supply and th e battery is not connected to the charger.

3. Test Apparatus and General Instructions: The test apparatus, standa rd testing conditions, and instructions for testing battery chargers shall co nform to the requirements specified in section 4, ‘‘Standard Testing Conditions,’’ of the EPA’s ‘‘Test Methodology for Determining the Energy Performance of Battery Charging Systems,’’ D ecember 2005 Incorporated by reference, see § 430.22). The test voltage specified in section 4.1.1, ‘‘Voltage,’’ shall be 115 volts, 60 Hz. The battery charger should be tested using the full test methodology, which has a test duration of 48 hours. In section 4.3.1, ‘‘Precision Requirements,’’ a ppend this sentence to the end: ‘‘The test equipment must be capable of accounting for crest factor and frequency spectrum in its measurement of the UUT input current.’’

4. Test Measurement: (a) Inactive Mode Energy Consumption Measurement. The measurement of the battery charger energy ra tio shall conform to the require ments specified in section 5, ‘‘Determining BCS Energy Ratio,’’ of the EP A’s ‘‘Test Methodology for Determining the Energy Performance of Battery Charging Systems, December 2005’’ (Incorporated by reference, see § 430.22).

(b) Active Mode Energy Consump tion Measurement. [RESERVED]

External Power Supplies

1. Scope: This appendix covers the test requirements used to measure the active mode efficiency and the no-load energy consumption of external power supplies.

2. Definitions: The following definitions are for the purposes of understanding terminology associated with the test method for measur ing external power supply energy consumption. 1

Active mode is the mode of operation when the external power supply is connected to the main electricity supply and the output is connected to a load.

Active mode efficiency is the ratio, expressed as a percentage, of the total real output power produced by a power supply to the real input power required to produce it.

No load mode means the mode of operation when the ex ternal power supply is connected to the main electricity supply and the out put is not connect ed to a load.

Single voltage external AC–AC power supply means an external power s upply that is designed to convert line voltage AC input into lower voltage AC output and is able to convert to only one AC output voltage at a time.

117Single voltage external AC–DC power supply means an external power s upply that is designed to convert line voltage AC input into lower voltage DC output and is able to convert to only one DC output voltage at a time.

Total harmonic distortion, expressed as a percent, is the RM S value of an AC signal after the fundamental component is removed and interh armonic components are ignored, divided by the RMS value of the fundamental component.

True power factor is the ratio of the active (also referred to as real) power consumed in watts to the apparent power, drawn in volt-amperes.

3. Test Apparatus and General Instructions: The test apparatus, standa rd testing conditions, and instructions for testing external power supplies shall conform to the requirements specified in section 4, ‘‘General Conditions for Measurement, ’’ of the CEC’s ‘‘Test Method for Calculating the Energy Efficiency of Single-Voltage Ex ternal AC–DC and AC–AC Power Supplies,’’ August 11, 2004. The test voltage specified in se ction 4.d, ‘‘Test Voltage,’’ shall only be 115 volts, 60 Hz.

4. Test Measurement: The measurement of the external power supply active mode efficiency and no-load energy consumption shall conform to the requireme nts specified in section 5, ‘‘Measurement Approach,’’ of the CEC’s ‘‘Test Method for Calculating the Energy Efficiency of Single-Voltage External AD–DC a nd AC–AC Power Supplies,’’ August 11, 2004 (Incorporated by reference, see § 430.22).

118APPENDIX D – ENERGY INDEPENDEN CE AND SECURITY ACT OF 2007

On December 19, 2007, the President signed into law the Energy Independence and Security Act of 2007 (EISA 2007) (P.L. 110-140). Th is legislation amended certain aspects of EPCA, including, in particular, the potential amen dment of existing testing requirements for BCs and EPSs (section 310 of EISA) and addition of mandatory efficiency standards for external power supplies (section 301 of EISA).

SEC. 301. EXTERNAL POWER SUPPL Y EFFICIENCY STANDARDS.

(a) Definitions- Section 321 of the Energy Policy and Conserva tion Act (42 U.S.C. 6291) is amended-- (1) in paragraph (36)--

(A) by striking ”(36) The” and inserting the following:

“(36) EXTERNAL POWER SUPPLY-

“(A) IN GENERAL- The”; and (B) by adding at the end the following:

“(B) ACTIVE MODE- The term `active mode' means the mode of operation when an external power supply is connected to the main electricity supply and the output is connected to a load.

“(C) CLASS A EXTERNAL POWER SUPPLY-

“(i) IN GENERAL- The term `c lass A external power supply' means a device that--

“(I) is designed to convert line voltage AC input into lower voltage AC or DC output;

”(II) is able to convert to only 1 AC or DC output voltage at a time;

”(III) is sold with, or intended to be used with, a separate end-use product that constitutes the primary load;

”(IV) is contained in a separa te physical enclosure from the end-use product;

119”(V) is connected to the end- use product via a removable or hard-wired male/female electr ical connection, cable, cord, or other wiring; and

”(VI) has nameplate output power that is less than or equal to 250 watts.

“(ii) EXCLUSIONS- The term `class A external power supply' does not include any device that--

“(I) requires Federal Food and Drug Administration listing and approval as a medical device in accordance with section 513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c); or

“(II) powers the charger of a detachable battery pack or charges the battery of a product that is fully or primarily motor operated.

“(D) NO-LOAD MODE- The term `no-load mode' means the mode of operation when an external power supply is connected to the main electricity supply and the output is not connected to a load.”; and (2) by adding at the end the following:

”(52) DETACHABLE BATTERY- The term `d etachable battery' means a battery that is-­

”(A) contained in a separate enclosure from the product; and

”(B) intended to be removed or di sconnected from the product for recharging.”.

(b) Test Procedures- Section 323(b) of the Energy Policy and Conservation Act (42 U.S.C. 6293(b)) is amended by adding at the end the following:

”(17) CLASS A EXTERNAL POWER SUPPLIES- Test procedures for class A external power supplies shall be based on the `Test Me thod for Calculating the Energy Efficiency of Single-Voltage External AC-DC and AC-AC Power Supplies' published by the Environmental Protection Agency on Augus t 11, 2004, except that the test voltage specified in section 4(d) of that test method shall be only 115 volts, 60 Hz.”.

(c) Efficiency Standards for Class A External Power Supplies- Section 325(u) of the Energy Policy and Conservation Act (42 U.S.C. 6295(u)) is amended by adding at the end the following: ”(6) EFFICIENCY STA NDARDS FOR CLASS A EXTERNAL POWER SUPPLIES120”(A) IN GENERAL- Subject to subparagraphs (B) through (D), a class A external power supply manufactured on or after the later of July 1, 2008, or the date of enactment of this paragraph shall meet the following standards:

“Active Mode “Nameplate Output Required Efficiency (decimal equivalent of a percent-age) Less than 1 watt 0.5 times the Nameplate Output

From 1 watt to not more than 51 watts The sum of 0.09 times the Natural Logarithm of the Nameplate Output and 0.5 Greater than 51 watts 0.85 “No-Load Mode “Nameplate Output Maximum Consumption No more than 250 watts 0.5 watts

”(B) NONCOVERED SUPPLIES- A class A ex ternal power supply shall not be subject to subparagraph (A) if the cl ass A external power supply is--

”(i) manufactured during the period beginning on July 1, 2008, and ending on June 30, 2015; and

”(ii) made available by the manufacturer as a service part or a spare part for an end-use product-- ”(I) that constitutes the primary load; and “(II) was manufactured before July 1, 2008. ”(C) MARKING- Any class A external power supply manufactured on or after the later of July 1, 2008 or the date of enact ment of this paragraph shall be clearly and permanently marked in accordance with the External Power Supply International Efficiency Marking Protocol , as referenced in the `Energy Star Program Requirements for Single Voltage External AC-DC and AC-AC Power Supplies, version 1.1' published by the Environmental Protection Agency.

”(D) AMENDMENT OF STANDARDS-

”(i) FINAL RULE BY JULY 1, 2011-

”(I) IN GENERAL- Not later than July 1, 2011, the Secretary shall publish a final rule to determine whether the standards established under subparagraph (A) should be amended.

”(II) ADMINISTRATION- The final rule shall--

”(aa) contain any amended standards; and

121”(bb) apply to products manuf actured on or after July 1, 2013.

”(ii) FINAL RULE BY JULY 1, 2015-

”(I) IN GENERAL- Not later than July 1, 2015 the Secretary shall publish a final rule to determine whether the standards then in effect should be amended.

”(II) ADMINISTRATION- The final rule shall--

”(aa) contain any amended standards; and

”(bb) apply to products manuf actured on or after July 1, 2017.

”(7) END-USE PRODUCTS- An energy cons ervation standard for external power supplies shall not constitute an energy cons ervation standard for the separate end-use product to which the external power supplies is connected.”.

SEC. 309. BATTERY CHARGERS.

Section 325(u)(1)(E) of the Energy Policy and Conservation Act (42 U.S.C. 6295(u)(1)(E)) is amended--

(1) by striking ”(E)(i) Not” a nd inserting the following:

”(E) EXTERNAL POWER SUPPLIES AND BATTERY CHARGERS-

”(i) ENERGY CONSERVATION STANDARDS-

”(I) EXTERNAL POWER SUPPLIES- Not”;

(2) by striking ”3 years” and inserting ”2 years”;

(3) by striking ”battery chargers and” each place it appears; and

(4) by adding at the end the following:

”(II) BATTERY CHARGERS- No t later than July 1, 2011, the Secretary shall issue a final rule that prescribes en ergy conservation standards for battery chargers or classes of battery chargers or determine that no energy conservation standard is technically feasib le and economically justified.”.

SEC. 310. STANDBY MODE.

122Section 325 of the Energy Policy and Conser vation Act (42 U.S.C. 6295) is amended—

(1) in subsection (u)—

(A) by striking paragraphs (2), (3), and (4); and

(B) by redesignating paragraphs (5) a nd (6) as paragraphs (2) and (3), respectively;

(2) by redesignating subsection (gg) as subsection (hh);

(3) by inserting after subsection (ff) the following:

”(gg) Standby Mode Energy Use-

”(1) DEFINITIONS-

”(A) IN GENERAL- Unless the Secretary determines otherwise pursuant to subparagraph (B), in this subsection:

”(i) ACTIVE MODE- The term `active mode' means the condition in which an energy-using product—

”(I) is connected to a main power source;

”(II) has been activated; and

”(III) provides 1 or more main functions.

”(ii) OFF MODE- The term `off mode' means the condition in which an energy-using product—

”(I) is connected to a main power source; and

”(II) is not providing any st andby or active mode function.

”(iii) STANDBY MODE- The term `standby mode' means the condition in which an energy-using product—

”(I) is connected to a main power source; and

”(II) offers 1 or more of the fo llowing user-oriented or protective functions:

123”(aa) To facilitate the activa tion or deactivation of other functions (including active mode) by remote switch (including remote control), in ternal sensor, or timer.

”(bb) Continuous functions, incl uding information or status displays (including clocks) or sensor-based functions.

”(B) AMENDED DEFINITIONS- The Secretary may, by rule, amend the definitions under subparagraph (A), taking into consideration the most current versions of Standards 62301 and 62087 of the International Electrotechnical Commission.

”(2) TEST PROCEDURES-

”(A) IN GENERAL- Test procedures fo r all covered products shall be amended pursuant to section 323 to include standby mode and off mode energy consumption, taking into consideration th e most current versions of Standards 62301 and 62087 of the International Elect rotechnical Commission, with such energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor for each covered product, unless the Secretary determines that—

”(i) the current test procedures for a covered product already fully account for and incorporate the standby mode and off mode energy consumption of the covered product; or

”(ii) such an integrated test proce dure is technically infeasible for a particular covered product, in which case the Secretary shall prescribe a separate standby mode and off mode energy use test procedure for the covered product, if technically feasible.

”(B) DEADLINES- The test procedure amendments required by subparagraph (A) shall be prescribed in a final ru le no later than the following dates:

”(i) December 31, 2008, for battery charge rs and external power supplies.

”(ii) March 31, 2009, for cl othes dryers, room air conditioners, and fluorescent lamp ballasts.

”(iii) June 30, 2009, for resi dential clothes washers.

”(iv) September 30, 2009, for residential furnaces and boilers.

”(v) March 31, 2010, for residential water heaters, direct heating equipment, and pool heaters.

124”(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and dehumidifiers.

”(C) PRIOR PRODUCT STANDARDS- The te st procedure amendments adopted pursuant to subparagraph (B ) shall not be used to determine compliance with product standards established prior to the adoption of the amended test procedures.

”(3) INCORPORATION INTO STANDARD-

”(A) IN GENERAL- Subject to subparag raph (B), based on the test procedures required under paragraph (2), any final rule establishing or revising a standard for a covered product, adopted after July 1, 2010, shall incorporate standby mode and off mode energy use into a single am ended or new standard, pursuant to subsection (o), if feasible.

”(B) SEPARATE STANDARDS- If not feas ible, the Secretary shall prescribe within the final rule a separate standa rd for standby mode and off mode energy consumption, if justified under subsection (o).”; and

(4) in paragraph (2) of subsection (hh) (as redesignated by paragraph (2)), by striking ”(ff)” each place it a ppears and inserting ”(gg)”.

125APPENDIX E – LIST OF ITEMS FOR COMMENT

This appendix lists all the items for commen ts contained in this framework document and the page numbers on which those items can be found.

Item 1 DOE invites interested parties to review the draft technical report published in conjunction with this framework document and to provide comments on the analytical structure, inputs, and method DOE followed...

............................................................................................. 11 Item 2 DOE welcomes comment from interested parties on differentiating between wall adapters and cradles. DOE also seeks comment on the type of circuitry (or lack thereof) typically contained in cradles... .................................................................................................................... 14 Item 3 DOE requests comment from interested parties on its interpretation of the Class A EPS exclusion of medical EPSs...

............................................................................................... .. 17 Item 4 DOE seeks comments on including DC-powered battery chargers within the scope of the BC standards analysis. ............................................................................................................ 18 Item 5 DOE welcomes comment on any products with detachable batteri es that are not motor operated, the wall adapters of which shoul d also be excluded from Class A EPS standards. 2 2 Item 6 DOE requests comment on its interpretation of the definition of “d etachable battery,” and the impact on EPSs excluded from Class A...

........................................................................ 22 Item 7 DOE welcomes comment on ways of amendi ng Approach B to make it consistent with the statutory language in EISA, or proposal s of alternate approach es based on the clear BC and EPS divisions of the ENERGY STAR program. ................................................................... 32 Item 8 DOE seeks comment on the prevalence of wall adapters for battery charging applications that may not be test able under the EPS test procedure...

.......................................... 37 Item 9 DOE seeks comments on the four appro aches to interpreting the BC and EPS definitions to resolve ambiguities in the scope of the analyses. DOE is also interested in determining whether Approach B could be modified to permit its use in a manner consistent with the statutory framework created by Congress... ............................................................................ 38 Item 10 DOE welcomes comment on additional functio nality provided by so me wall adapters for battery chargers that may impe de their ability to meet the same standards as comparable wall adapters for other applications . DOE asks that commenters provide specific examples and suggest ways in which DOE can address any potential barriers that may arise. .......................... 38 Item 11 DOE welcomes comment on the manufacturer burden of compliance with current EISA Class A EPS standards under each of the four approaches and seeks information on how DOE can minimize this burden while ensuring that the standards are bein g met consistently by the industry...

................................................................................................................ ................. 38 Item 12 DOE also welcomes comment on the likely ma nufacturer burden of compliance with possible future EPS and BC standards under each of the four approaches. To this end, DOE also seeks information from the industry regarding how the monitoring of compliance with these standards can be accomplished. ................................................................................................. ... 38 Item 13 DOE is seeking input on these and any addi tional criteria it should consider in determining the presence of wall ad apter charge control functions. ............................................ 39

126Item 14 DOE welcomes comment on external charact eristics (either physic al or electrical) that can be used to identify a wall adapter pe rforming charge control fo r determining compliance with the appropriate standard unde r Approaches A, C, and D, as well as the use of labeling to permit easy identification. How likely would it be that those requirements would be subject to potential manipulation by manufact urers? If manipulation is possi ble, what form, and in what context, would these activities likely occur?

................................................................................ 3 9 Item 15 DOE welcomes comment on the possible di fferences in distribution channels between wall adapters used for battery charging applications that do and do not have charge

Item 16 DOE seeks comments on whether these and/or other factors influence the shipments

Item 17 DOE seeks input on shipment data for BCs and EPSs and the applications that use them, including applications that use non-Class A EPSs (section 3.6.2). DOE also seeks input on

Item 18 DOE invites interested parties to revi ew and comment on domestic and foreign

Item 19 DOE seeks comments and data from interest ed parties on these and other potential

Item 20 DOE seeks comments on whether the 0.2 C ch arge-rate division between slow and fast chargers is appropriate and seeks detailed information regard ing the typical charge rates for

Item 21 Although DOE intends to revisit this issue in the future, its test procedure does not currently measure active-mode energy consumption. Nonetheless, DOE seeks comments on how

Item 22 DOE seeks comments on how DOE could, in a future rulemaking, amend its BC test

Item 23 DOE seeks comments on BC product class di visions, including whether battery voltage is the appropriate produc t classification criterion, and/or whether DOE should take into

Item 24 DOE seeks comments on creating potential pr oduct class divisions for EPSs excluded

Item 25 DOE seeks comments on whether to consider th e presence of ICs or PFC circuitry in

Item 26 DOE seeks comments on how to consider output voltage in developing product

Item 27 DOE seeks comments on the possible appro aches discussed concerning EPS product classes, and invites interested parties to propose altern ative approaches and/or other factors DOE

Item 28 DOE seeks comments on how the product classe s it is considering for Class A EPSs may apply to non-Class A EPSs and whether there ar e particular issues DOE needs to take into

Item 29 DOE seeks comments on all aspects of the pr oduct classes it is considering for BCs and EPSs, as well as any other methods for establishing product classes in accordance with the control functions.

............................................................................................................. ............. 4 1

of BCs and EPSs, and the extent to which each trend is likely to affect shipments

..................... 4 2

the percentage of applications that ar e shipped with either a BC or an EPS

................................ 4 3

efficiency programs relating to BCs and EPSs

............................................................................. 4 4

market failures that may apply to BCs and EPSs.

........................................................................ 4 4

both categories of BCs

.................................................................................................................. 4 7

it

can best account for energy consumed during active mode.

..................................................... 5 0

procedure to measure energy c onsumption in active mode

.......................................................... 5 0

account other factors, such as charge rate , battery capacity, or battery chemistry.

...................... 5 2

from the EISA definition of Class A

............................................................................................ . 5 3

developing product classes for EPSs.

........................................................................................... 5 6

classes, and how the low-voltage divisi on should vary with EPS output power

.......................... 5 6

should consider in developing product cl asses for the preliminary analyses.

.............................. 5 6

account. 5 7

requirements of 42 U.S.C. 6295(q)

.............................................................................................. . 5 7

127Item 30 DOE seeks comments on the preliminary technol ogy options identified in this section and whether there are other technology options it should consider. In commenting on design options, please discuss their impacts, if any, on safety, performance, and consumer utility

........ 5 9 Item 31 DOE seeks comments on how the four scre ening criteria might apply to the technology options discussed in section 3.7, as we ll as any additional technology option(s) that

Item 32 DOE seeks comments on any consumer product applications which require use of a

Item 33 DOE seeks recommendations on possible candi date standard levels to use when

Item 34 DOE invites comments on the identification and selection of representative product classes and on models that may serve as good re presentative units with in each product class. DOE also seeks comments on appropriate scali ng relationships among product classes for both

Item 35 DOE seeks comments on representative product classes and selection of

Item 36 DOE seeks comments on the scaling of findings from representative product classes

Item 37 DOE invites manufacturers to work with DOE in the interviews to help develop aggregated curves of manufacturer selling price versus efficiency for the various representative

Item 38 DOE seeks comments on methods for normalizi ng cost and efficiency data provided by manufacturers for EPSs with output power and output voltage that differ from those of the

Item 40 DOE seeks comments on this and other possible methods of determining and validating manufacturing costs. DOE is partic ularly interested in obtaining high-volume

Item 41 DOE welcomes comment on methods for simulating the performance of highlyItem 42 Are there proprietary designs of which DOE should be aware for any of the BCs and EPSs under consideration in this rulemaking? If so, how should DOE acquire the cost data

Item 43 DOE seeks comments on regulatory burdens or changes that should be considered in

Item 44 DOE seeks comments on any other issues that could affect the e ngineering analysis. an interested party recommends to DOE.

..................................................................................... 6 0

line-frequency EPS, and which could not accommodate use of a switched-mode EPS

............... 6 1

analyzing EPSs and BCs

............................................................................................................... 6 3

BCs and EPSs.

.............................................................................................................................. 6 4

representative units from thos e representative product classes.

................................................... 6 5

to other product classes that DOE may not explicitly analyze.

.................................................... 6 5

units. 6 6

representative units.

.......................................................................................................... ............ 6 6 Item 39 DOE seeks comments on the shipment volumes to use for the representative units

.. 6 6

component costs and typical manufacturer markups applied to the bill-of-materials cost

........... 6 7

efficient EPSs and BCs as a means of va lidating data provided by manufacturers

...................... 6 7

necessary for evaluating these designs?

........................................................................................ 6 8

the engineering analysis of BCs and EPSs.

.................................................................................. 6 8

6 8 Item 45 DOE seeks comments on the consumer usage profiles presented in sections 6.2.1 and 6.3.1 of the draft technical report. DOE seeks alternate sources, databases, or methodologies for developing usage profiles. DOE also seeks comm ents on its assumption that the usage profiles do not vary over the analysis period.

.......................................................................................... .. 6 9 Item 46 DOE requests comments on the use of 24-hour charge cycles for estimating energy

Item 47 DOE requests comments on the methodology presented for calculating unit energy consumption for BCs in active mode

............................................................................................ 7 0

consumption. DOE also requests comments on the us age profiles detailed in section 6.2 of the draft technical report

......................................................................................................... ............ 7 1

128Item 48 DOE requests comments on the usage profile s for EPS applications detailed in section 6.3 of the draf t technical report.

..................................................................................... .. 7 3 Item 49 DOE requests comment on its proposed methodology for calculating energy

Item 50 DOE requests comments on its proposed methodology for calculating energy

Item 51 DOE requests comments on its proposal to associate off mode with unplugged mode for the purposes of calculating energy consumption. DOE also requests comments on time spent

Item 52 DOE seeks comments on all aspects of the product price determination for BCs and EPSs, including assumptions about the percent of shipments passing through each distribution

Item 53 DOE seeks comments on its intention to focus its preliminary LCC analysis on the

Item 54 DOE seeks comments on the use of the EIA na tional average electricity price and the

Item 55 DOE seeks comments on the methodology to be used for calculating residential

Item 56 DOE seeks comments on appropriate lifetimes for the BCs and EPSs covered in this

Item 57 DOE seeks input on additional sources for the lifetimes of BCs and EPSs and

Item 58 DOE seeks recommendations on sources of data on shipments of BCs and EPSs by

Item 59 DOE seeks recommendations on sources of data that would provide accurate and upto-date information on BC and EPS efficiency distributions within pr oduct groups. DOE also seeks comments on how it might characterize long-ter m trends in the efficiency of BCs and EPSs

Item 62 DOE seeks comments on how any new ener gy conservation standard for BCs and EPSs might affect shipments of these products . DOE specifically seeks comments on its rollup

Item 63 DOE seeks comments on the impact of the re bound effect, the associated application effect, and the consumer awareness effect on energy consumption of BCs and EPSs. To the extent that commenters can o ffer reasons and data supporting the adoption of a particular

Item 64 DOE requests comments on the percent dist ribution of residential and commercial

Item 65 DOE seeks comments on the NES/NPV spreadsheet models that DOE plans to use for estimating national impacts of energy conservation standards for BCs and EPSs. See chapter

Item 66 DOE seeks comments on which consumer subgroups, if any, DOE should consider

Item 67 DOE seeks comments on which potential subgroups of BC and EPS manufacturers consumption at each application state under EPS active mode.

................................................... 7 7

consumption at output levels below 25 percent of nameplate output power

................................ 7 7

in off mode, as well as power consumption while in off mode.

................................................... 7 8

channel and the markups associated with each channel.

.............................................................. 8 0

residential sector, and not the co mmercial or industrial sectors.

.................................................. 8 2

AEO forecast of electricity pri ces over the analysis period

.......................................................... 8 6

discount rate used in the LCC analysis

......................................................................................... 8 7

rulemaking.

.................................................................................................................... ............... 8 8

comments on the application lifetimes provided in section 8.3.5 of the draft technical report

.... 8 9

product group

................................................................................................................................ 9 0

for its base case shipments forecasts

.......................................................................................... ... 9 1 Item 60 DOE seeks comments on appropriate shipment growth rates.

................................... 9 2 Item 61 DOE seeks input on the sensitivity of BC and EPS demand to changes in price

....... 9 3

and shift scenarios, as discussed in s ection 9.3 of the draft technical report

................................ 9 3

quantitative value for each of th ese effects, DOE is also inte rested in this information.

............. 9 4

energy use for calculation of the weighted-average energy price

................................................. 9 6

10 of the draft technical report for a description of these models.

............................................... 9 7

when developing standards for BCs and EPSs.

............................................................................ 9 7

should consider in its manuf acturer subgroup analysis.

............................................................. 1 00

129Item 68 DOE seeks comments on other existing and pend ing regulations it s hould consider in its examination of cumulative regulatory burden. ...................................................................... 101 Item 69 DOE seeks input on its plans to use NEMS-B T to conduct the utility impact analysis. 1 02 Item 70 DOE seeks feedback on its planned appro ach for assessing direct and indirect national employment impacts. ................................................................................................... . 103 Item 71 DOE seeks input on its plans to use NEMS -BT to conduct the environmental impact analysis on the equipment covered by this rulema king. DOE is particularly interested in whether there are any other approaches to the environmen tal assessment that it should consider and the advantages and disadvantages fo r each of those approaches...

................................................... 104 Item 72 Because court actions have vacated the CAIR, DOE seeks input on how it should address NO x emissions in this rulemaking.................................................................................. 105 Item 73 Because court actions have vacated th e CAMR, DOE seeks input on how it should address Hg emissions in this rulemaking...

................................................................................. 105 Item 74 DOE invites comments on how to estimate su ch monetary values associated with emissions reductions or on any widely accepted valu es which might be used in DOE’s analyses. 1 06 Item 75 DOE seeks input on other environmental fact ors to consider in this rulemaking. ... 106

130APPENDIX F – OTHER MANDATORY AN D VOLUNTARY ENERGY-EFFICIENCY STANDARDS FOR BCEPS

F.1 United States – ENERGY STAR for BC and ENERGY STAR Tier I (V1.1) and Tier II (V2.0) for EPS

Revised U.S. ENERGY STAR levels becam e effective on November 1, 2008. These voluntary levels are stricter than V1.1 levels, an d provide separate levels for standard vs. lowvoltage models and for AC/AC versus AC/DC models.

Power converters covered under this standard include all single-v oltage EPSs with nameplate output power up to 250 watts, and battery chargers for heat, light, and motion products with a 42-V limit and a 2-watt to 300-watt input limit. Notable ex clusions to V1.1 are devices with detachable batte ries, motor-operated devices, and medical devices. Notable exclusions to V2.0 are devices with batteries that attach directly. Exclusions to battery charger standards are inductive chargers a nd systems with additional functions.

F.1.1 Current Standards

 Version: Tier II v2.0 for EPS

 Compliance: Voluntary

 Effective: November 1, 2008

Table F.1. U.S. ENERGY STAR Tier II for EP S Active-Mode Efficiency and No-Load Power: Standard Models

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.480 * Nameplate Output + 0.140

1 < W ≤ 49 0.0626 * Ln(Nameplate Output) + 0.622

49 < W 0.870

Nameplate Output Power Maximum No-Load Power Consumption AC/AC Maximum No-Load Power Consumption AC/DC

0 < W < 50 ≤ 0.50 W ≤ 0.30 W

50 ≤ W ≤ 250 ≤ 0.50 W

131Table F.2. U.S. ENERGY STAR Tier II for EP S Active-Mode Efficiency and No-Load Power: Low-Voltage Models

Nameplate Output Power Minimum Efficiency in Active Mode (Less than 6 Volts)

0 < W ≤ 1 0.497 * Nameplate Output + 0.067

1 < W ≤ 49 0.0750 * Ln(Nameplate Output) + 0.561

49 < W 0.86

Nameplate Output Power Maximum NoLoad Power Consumption AC/AC Maximum NoLoad Power Consumption AC/DC

0 < W < 50 ≤ 0.50 W ≤ 0.30 W

50 ≤ W ≤ 250 ≤ 0.50 W

 Version: ENERGY STAR for BC

 Compliance: Voluntary

 Effective: January 1, 2006

Table F.3. ENERGY STAR Specifications fo r BC Maximum Nonactive Energy Ratio

Nominal Battery Voltage 1.2 2.4 3.6 4.8 6.0 7.2 8.4 9.6 10.8 12.0
Maximum Nonactive Energy Ratio 20.0 16.9 13.7 11.6 9.6 7.5 7.0 6.5 6.1 5.6

Nominal Battery Voltage 13.2 14.4 15.6 16.8 18.0 19.2 20.4 21.6 22.8 ≥ 24

Maximum Nonactive Energy Ratio 5.1 4.5 4.3 4.2 3.8 3.6 3.5 3.3 3.2 3.0

*Energy Ratio is a function of maintenance mode power and no-load power.

F.2 Australia and New Zealand – Minimum Energy Performance Standards (MEPS) AS/NZS 4665:2005

Administered by the Australian Greenhouse Office (AGO) through the National Appliance and Equipment Energy Efficiency Committee (NAEEEC), the Australian MEPS are mandatory. Voluntary higher efficiency levels exist, which will become the new MEPS in the future.

132Power converters covered under this standard include all single-v oltage EPSs with nameplate output power up to 250 watts . Notable exclusions are devices with batteries that attach directly, replacements, and medical devices. No -load power requirement s only apply to AC/DC power supplies.

The MEPS program does not yet deal with battery chargers, but if future standards were introduced, they would likely use the ENERGY STAR test method and MEPS, applying at 230 Vac only. If specific MEPS are not introduced for battery chargers, the 1-watt standby proposal will apply.

F.2.1 Current Standards

 Version: MEPS for EPS

 Compliance: Mandatory MEPS (Mark III), Vo luntary High Efficiency (Mark IV and Mark V)

 Effective: Australia - Decembe r 1, 2008, New Zealand – April 1, 2009

Table F.4. Australia/New Zealand MEPS Levels for EPS Active-Mode Efficiency and NoLoad Power

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.49 * Nameplate Output

1 < W ≤ 49 0.09 * Ln(Nameplate Output) + 0.49

49 < W ≤ 250 0.84

Nameplate Output Power Maximum No-Load Power Consumption

0 < W < 10 ≤ 0.50 W

10 ≤ W ≤ 250 ≤ 0.75 W

133Table F.5. Australia/New Zealand High Effi ciency Level IV for EPS Active-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.5 * Nameplate Output

1 < W ≤ 51 0.09 * Ln(Nameplate Output) + 0.5

51 < W ≤ 250 0.85

Nameplate Output Power Maximum No-Load Power Consumption

0 < W ≤ 250 ≤ 0.50 W

Table F.6. Australia/New Zealand High Efficien cy Level V for EPS Active-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode – Less than 6 Volts Minimum Efficiency in Active Mode – Greater than 6 Volts

0 < W ≤ 1 0.497 * Nameplate Output + 0.067 0.480 * Nameplate Output + 0.140

1 < W ≤ 51 0.0750 * Ln(Nameplate Output) + 0.561 0.0626 * Ln(N ameplate Output) + 0.622

51 < W ≤ 250 0.86 0.87

Nameplate Output Power Maximum NoLoad Power Consumption AC/AC Maximum No-Load Power Consumption AC/DC – Less than 6 Volts Maximum NoLoad Power Consumption AC/DC – Greater than 6 Volts

0 < W ≤ 51 ≤ 0.50 W ≤ 0.30 W ≤ 0.30 W

51 < W ≤ 250 ≤ 0.50 W No Maximum

F.3 Canada – C381.1 for EPS and C381.2 for BC

The Canadian Standards Association (CSA) is developing standards for external power supplies and battery chargers that are expect ed to become mandatory, which will require approval from Natural Resources Canada af ter the CSA has finalized the standards.

134The proposed specifications for EPSs follow EISA levels, and scope. The specifications for BCs will likely follow CEC test procedures, levels, and scope.

F.3.1 Current Standards

 Version: Minimum Energy Performance Standards for EPSs

 Compliance: Mandatory

 Effective: Proposed September 1, 20 09 for EPSs; awaiting comment from stakeholders. 2010 for BCs.

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.5 * Nameplate Output

1 < W ≤ 51 0.09 * Ln(Nameplate Output) + 0.5

51 < W ≤ 250 0.85

Nameplate Output Power Maximum No-Load Power Consumption

0 < W ≤ 250 ≤ 0.50 W

F.4 China – China National Institute of Sta ndardization (CNIS) and China Standard Certification Center (CSC) Standards

Designed and administered by the China Nationa l Institute of Standa rdization (CNIS) and the China Standard Certification Center (CSC), Chinese standards for external power supplies include both mandatory minimum efficiency levels and voluntary high-efficiency levels.

Power converters covered under this standard include all single-v oltage EPSs with nameplate output power up to 250 watts. Notable ex clusions to the CSC standards are devices with batteries that attach direc tly. Battery charger sta ndards do not exist but plans to draft them are in place, with considerati on of modes beyond no-load mode.

F.4.1 Current Standards

 Version: CNIS levels

 Compliance: Mandatory

 Effective: Possibly 2009

135Table F.7. CNIS MEPS for Active-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.39 * Nameplate Output

1 < W ≤ 49 0.107 * Ln(Nameplate Output) + 0.39

49 < W ≤ 250 0.82

Nameplate Output Power Maximum No-Load Power Consumption

0 < W < 10 ≤ 0.75 W

10 ≤ W ≤ 250 ≤ 1 W

 Version: CSC levels

 Compliance: Voluntary

 Effective: May 2005

Table F.8. CSC Levels for Active-Mode Efficiency and No-Load Power (Same as ENERGY STAR Tier 1)

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W < 1 0.49 * Nameplate Output

1 ≤ W ≤ 49 0.09 * Ln(Nameplate Output) + 0.49

49 < W ≤ 250 0.84

Nameplate Output Power Maximum No-Load Power Consumption

0 < W < 10 ≤ 0.50 W

10 ≤ W ≤ 250 ≤ 0.75 W

F.5 European Union—Code of Conduct on Effi ciency of External Power Supplies, EU Standby Initiative

Developed and administered by the European Commission Joint Research Centre, the EU Code of Conduct is a voluntary agreement. Signato ries to the Code of Conduct, which include major manufacturers of external power supplies, agree to meetactive-mode efficiency and noload power consumption targets for at least 90 percent of their product lines.

Power converters covered under this standard in clude all single-voltage EPSs and battery charger wall adapters with nameplate output power in the range 0.3 watts to 150 watts. The scope of the standard will be expanded in 2009 to include external power supplies with

136nameplate output power up to 250 watts. Version 3 of the Code of Conduct includes a separate product class for cellular telephone EPSs, whic h is subject to different standards.

F.5.1 Current Standards

 Version: 2

 Compliance: Voluntary

 Effective: January 1, 2007

Table F.9. EU Code of Conduct Version 2 Standards for EPS Active-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode*

0 to < 1 W 0.49 * Nameplate Output

≥ 1 and ≤ 49 W 0.09 * Ln(Nameplate Output) + 0.49

> 49 W to 150 W 0.84

Nameplate Output Power Maximum No-Load Power Consumption

≥ 0.3 W and < 60 W 0.30 W

≥ 60 W and < 150 W 0.50 W

* Power supplies that have a power factor co rrection (PFC) to comply with EN61000-3-2 (above 75 W input power) have a 0.04 (4-percent) allowa nce. Therefore, the minimum on mode-load efficiency (100 percent or averaged ) is relaxed to 0.80 (80 percent).

F.5.2 Future Standards

 Version: 3

 Compliance: Voluntary

 Effective: January 1, 2009

137Table F.10. EU Code of Conduct Version 3 Standards for EPSs Excluding Cellular Telephone Adapters with Nameplate Output Power ≤ 8 Watts

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.44 * Pno + 0.145

1 < W ≤ 36 [0.08 * ln(Pno)] + 0.585

36 < W ≤ 250 0.870

Nameplate Output Power Maximum No-Load Power Consumption

> 0.3 W and < 50 W 0.30 W

> 50 W and < 250 W 0.50 W

Table F.11. EU Code of Conduct Version 3 Standards for Cellular Telephone Adapters with Nameplate Output Power ≤ 8 Watts

Nameplate Output Power Minimum Efficiency in Active Mode

> 0 W and < 1 W 0.50*Pno+0.029

> 1 W and < 8 W [0.095*ln(Pno)]+0.529

Nameplate Output Power Maximum No-Load Power Consumption

> 0.3 W and < 8.0 W 0.25 W from 1.1.2009 to 31.12.2010

> 0.3 W and < 8.0 W 0.15 W from 1.1.2011

F.6 European Union—Eco-design of Energy-usin g Products (EuP) Initiative, Directive 2005/32/EC

Developed and administered by the Eur opean Commission, the Eco-design of EuP Initiative is a mandatory directive. When comp lete, the directive will pr ovide EU-wide rules for eco-design so that differences in national regulati ons do not present barriers to intra-EU trade. Minimum energy-efficiency requirements are among the product characterist ics being addressed, including MEPS for external power supplies.

Power converters covered under this standard include all single-v oltage EPSs with nameplate output power up to 250 watts. Though ba ttery chargers are not addressed, there are tentative plans for BC standards of 1 watt in off mode, enforced in 2009, dropping to 0.5 watt by 2011.

138F.6.1 Current Standards

 Version: 1

 Compliance: Mandatory

 Effective: April 26, 2010

Table F.12. EuP Version 1 Levels for EPS Ac tive-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W < 1 0.5 * Nameplate Output

1 < W ≤ 51 0.09 * Ln(Nameplate Output) + 0.50

51 < W ≤ 250 0.85

Nameplate Output Power Maximum No-Load Power Consumption

0 < W < 250 0.50 W

F.6.2 Future Standards

 Version: 2 for EPS

 Compliance: Mandatory

 Effective: April 26, 2011
Table F.13. Version 2 Levels for EPS Acti ve-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode – Less than 6 Volts Minimum Efficiency in Active Mode – Greater than 6 Volts

0 < W ≤ 1 0.497 * Nameplate Output + 0.067 0.480 * Nameplate Output + 0.140

1 < W ≤ 51 0.0750 * Ln(Nameplate Output) + 0.561 0.0626 * Ln(N ameplate Output) + 0.622

51 < W ≤ 250 0.86 0.87

Nameplate Output Power Maximum NoLoad Power Consumption AC/AC Maximum No-Load Power Consumption AC/DC – Less than 6 Volts Maximum NoLoad Power Consumption AC/DC – Greater than 6 Volts

0 < W ≤ 51 ≤ 0.50 W ≤ 0.30 W ≤ 0.30 W

51 < W ≤ 250 ≤ 0.50 W No Maximum

139F.7 EU (Subset of Member Countries)

 Group for Energy Efficient Appliances

Developed by the Group for Energy Efficien t Appliances, which includes government agencies and institutions from Denmark, the Netherlands, Sweden, Switzerland, Germany, France, and Austria, the GEEA standards are voluntary. The purpose of the GEEA, organized in 1996, is to harmonize national regulations pertaining to electronics and home office equipment. Minimum energy-efficiency requirements are among the product characteristics GEEA addresses, including MEPS for external power supplies and battery chargers.

Power converters covered under this standard include all single-v oltage EPSs with nameplate output power up to 150 wa tts. In addition to EPS and BC, this standard applies to portable personal equipment, which is defined as “equipment that is sold as part of a product with non-removable rechargeable batteries and is sold with th e aim of recharging batteries.”

F.7.1 Current Standards

 Version: N/A

 Compliance: Voluntary

 Effective: 2007

Table F.14. GEEA Levels for EPS and “Por table Personal Equipment” Active-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.49 * Nameplate Output

1 < W ≤ 49 0.09 * Ln(Nameplate Output) + 0.50

49 < W ≤ 150 0.84

Nameplate Output Power Maximum No-Load Power Consumption*

0 < W < 150 0.30 W

* Includes Battery Chargers

F.8 Israel – SI 4665.2 (AS/NZX 4665.2-2005)

Administered by the Standards Institution of Israel (SII), the SI 4665.2 standards are a Hebrew translation of the AS/NZX 4665.2-2005 standards deve loped by Australia. These voluntary standards apply to ex ternal power supplies only.

Power converters covered under this standard include all single-v oltage EPSs with nameplate output power up to 250 watts . Notable exclusions are devices with batteries that attach

140directly, replacements, and medical devices. The scope and test proc edures are identical to those in the Australian standards ( i.e. , EPA EPS).

F.8.1 Current Standards

 Version: SI 4665.2

 Compliance: Voluntary

 Effective: December 2007

Table F.15. SI 4665.2 Levels for EPS Active-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.49 * Nameplate Output

1 < W ≤ 49 0.09 * Ln(Nameplate Output) + 0.49

49 < W ≤ 250 0.84

Nameplate Output Power Maximum No-Load Power Consumption

0 < W < 10 ≤ 0.50 W

10 ≤ W ≤ 250 ≤ 0.75 W

F.9 Korea – e-Standby Program

The e-Standby standards, developed and im plemented by the Ministry of Commerce, Industry, and Energy (MOCIE) and Korea Energy Management Corporation (KEMCO), are voluntary. However, a presidentia l directive with mandatory st andby power limits, similar to President George W. Bush's Executive Orde r 13221, is likely to be implemented by 2010.

Power converters covered under this standard include all single-v oltage EPSs with nameplate output power up to 150 wa tts and cellular telephone char gers. Notable exclusions are EPSs with charge circuitry.

F.9.1 Current Standards

 Version: N/A

 Compliance: Voluntary

 Effective: January 1, 2007 for EPS, January 1, 2006 for BC

141Table F.16. e-Standby Program Levels for EPS Active-Mode Efficiency and No-Load Power

Nameplate Output Power Minimum Efficiency in Active Mode

0 < W ≤ 1 0.49 * Nameplate Output

1 < W ≤ 49 0.09 * Ln(Nameplate Output) + 0.49

49 < W ≤ 150 0.84

Nameplate Output Power Maximum No-Load Power Consumption

0 < W ≤ 10 ≤ 0.50 W

10 < W ≤ 150 ≤ 0.75 W

Table F.17. e-Standby Program Levels for Cellular Telephone Charger No-Load Power

Maximum No-Load Power Consumption

≤ 0.50 W

142

# DRAFT TECHNICAL REPORT

ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS:

Battery Chargers and External Power Supplies

May 2009

U.S. Department of Energy Assistant Secretary Office of Energy Efficien cy and Renewable Energy Building Technologies Program Appliances and Commercia l Equipment Standards Washington, DC 20585DRAFT TECHNICAL REPORT FRAMEWORK DOCUMENT

BUILDING TECHNOLOGIES PROGRAM APPLIANCES AND COMMERCIAL EQUIPMENT STANDARDS

BATTERY CHARGERS AND EX TERNAL POWER SUPPLIES

CHAPTERS

CHAPTER 1 INTRODUCTION CHAPTER 2 MARKET ASSESSMENT CHAPTER 3 TECHNOLOGY ASSESSMENT CHAPTER 4 SCREENING ANALYSIS CHAPTER 5 ENGINEERING ANALYSIS CHAPTER 6 ENERGY USE AND END-USE LOAD CHARACTERIZATION CHAPTER 7 PRODUCT PRICE DETERMINATION CHAPTER 8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES CHAPTER 9 SHIPMENTS ANALYSIS CHAPTER 10 NATIONAL IMPACT ANALYSISCHAPTER 1. INTRODUCTION

1.1 Introduction

...................................................................................................... 1-2 1.2 Regulatory and Legisl ative History

................................................................. 1-2 1.3 Overview of the Determination Analysis

........................................................ 1-3 1.3.1 Components of a Determinati on Analysis Rulemaking

........................... 1-3 1.3.2 Overview of Determination Analysis Content

......................................... 1-4

LIST OF FIGURES Figure 1.1. Flow Diagram of the Component s of a Determination Analysis

.................. 1-4

1-11.1 Introduction The U.S. Department of Energy (DOE) Draft Technical Report presents the preliminary findings of DOE’s Determination Analysis for Battery Chargers (BCs) and External Power Supplies (EPSs), Docket No. EERE-2006-DET-0136. The purpose of the determination analysis, mandated by the Energy Policy and Conservation Act (EPCA), as amended by the Energy Policy Act of 2005 (E PACT 2005), was to determine whether energy conservation standards should be se t for BCs and EPSs. DOE’s analysis was interrupted by passage of the Energy Inde pendence and Security Act of 2007 (EISA 2007). This report provides details of the work undertaken for the determination analysis until that point, and includes inputs, met hods, and some draft outputs of the analysis.

This report is published in conjunction with the “Energy Conservation Standards Rulemaking Framework Document for Battery Chargers and External Power Supplies,” which outlines the analytical process DOE will follow for the BC and EPS standards rulemaking over the next two years as a re sult of EISA 2007. This rulemaking may result in updated standards for EPSs and new st andards for BCs by July 1, 2011. Unlike the framework document, this report pres ents a retrospectiv e view of work already completed , and should not be construed as set ting a precedent for future DOE action. Rather, DOE invites stakeholders to revi ew the report and provide comments on all aspects of the draft analysis that are pe rtinent to the energy conservation standards rulemaking being initiated.

This chapter describes the regulator y and legislative background for the determination analysis, explains the analytic process, and introduces the work described in detail in the body of the report.

1.2 Regulatory and Legislative History DOE’s Appliances and Commercial Equi pment Standards Program, within the Office of Energy Efficiency and Renewabl e Energy’s Building T echnologies Program, develops and promulgates test procedur es and energy conservation standards for consumer appliances and commercial equipment.

Title III of EPCA (42 U.S.C. 6291 et seq. ) sets forth a vari ety of provisions designed to improve energy efficiency. Pa rt A of title III (42 U.S.C. 6291–6309) establishes the “Energy Conservation Pr ogram for Consumer Products Other Than Automobiles.” On August 8, 2005, the En ergy Policy Act of 2005 (Pub. L. 109-58; EPACT 2005) amended sections 321 and 325 of EPCA, inserting definitions for BCs and EPSs and directing the Secretary of Energy to (1) establish test procedures, (2) hold a scoping workshop to discuss plans for developi ng energy conservation standards, and (3) conduct a determination analysis of energy c onservation standards for BCs and EPSs. (42 U.S.C. 6295(u))

DOE complied with the first of thes e requirements by publishing the test procedure final rule, 71 FR 71340, on Decembe r 8, 2006, which included definitions and test procedures for BCs and EPSs. DOE codifi ed a test procedure for BCs in title 10 of

1-2the Code of Federal Regulations (CFR), part 430, subpart B, appendix Y (“Uniform Test Method for Measuring the Energy Consumpti on of Battery Chargers”) and a test procedure for EPSs in 10 CFR part 430, subpa rt B, appendix Z (“Un iform Test Method for Measuring the Energy Consumption of External Power Supplies”).

Complying with the second requirement, DOE then published a notice of public meeting and availability of documentati on for public review on December 29, 2006. 71 FR at 78389. DOE made two documen ts available on its website: Plans for Developing Energy Conservation Standards for Batte ry Chargers and External Power Supplies and The Current and Future Market for Batte ry Chargers and External Power Supplies . The public meeting was called a “Scoping Workshop” and was held on January 24, 2007. As required by EPACT 2005, the workshop focuse d on DOE’s plans for developing energy conservation standards for BCs and EPSs. 1

Complying with the third requirement, DOE initiated a determination analysis of energy conservation standards for BCs and EPSs in 2007, scheduled for completion in August 2008. However, on December 19, 2007, EISA 2007 (Docket No. EERE-2006

- DET-0136; Pub. L. 110-140) was enacted, amending sections 321, 323, and 325 of EPCA. These amendments required significan t changes to the determination analysis DOE had been conducting on BCs and EPSs. As a result, work on the determination analysis was suspended. The details of the anal ytical process up to that point are detailed in this report.

1.3 Overview of the Determination Analysis The purpose of the determination analysis rulemaking was to provide sufficient information to determine whether energy conservation standards should be set for BCs and EPSs. DOE’s determination and the possi ble establishment of energy conservation standards are two separate ac tions; however, the supporting an alyses are similar. A full description of the analyses conducted as part of an energy conservation standards rulemaking can be found in the “Energy Conservation Standards Rulemaking Framework Document for Battery Chargers and External Power Supplies.”

1.3.1 Components of a Determination Analysis Rulemaking

Figure 1.1 summarizes the determination analysis process and presents the analytical components discu ssed in this report. Each component (represented by the boxes with dark numbers) had a set of “key inputs,” which represent the information required for the analysis. The numbers corre spond to the chapter numbers where these analyses are found. The “approaches” column lists the methods used to obtain these inputs. For example, some key inputs existed in public databases, while others were collected from stakeholders or subject-ma tter experts. DOE developed the remaining inputs on its own. The “key outputs” column lists the results of each analysis, which feed

1 Information pertaining to the Scoping Workshop is available at www.eere.energy.gov/buildings/appliance_sta ndards/residential/battery_external.html

.

1-3directly into the rulemaking. The arrows indicate the flow of information between the various analyses.

Approaches Key Inputs* A nalyses* Key Outputs

Market and Technology A ssessment

Screening Analysis

Engineering Analysis

Markups fo r Equipment Price

Determination Energy Use and End

- Use Load Characterization

Shipments A nalysis Life

- Cycle Cost and Payback Period A nalysis

National Impact A nalysis • Product Classes • Market Structure

• Design Options

• Cost-Efficiency Relationship

• Life- Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Value • Characterize Industry

• A nalysis of Market Data • Market Segmentation

• Non -Regulatory Programs Determination Analysis

• Efficiency Level Approach

• Design Option Approach • Product Prototypes

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• A ccounting Approach:

Backcas t and Forecast; Market Saturation • Identify Firms/Products

• Define Distribution Channels

• Economic Census Data

A nalysis

• Retail Price Collection and

A nalysis Design Options

Retail Prices Design Energy 4

5

6

7

8

9

10 • Efficiency/Performance • Manufacturing Cost

• UEC

• Energy Prices • A nalysis of Energ y Use Data

• Energy Efficiency Levels • Historical Shipments

Technology Options Product Classes

Energy Efficiency Levels A nnual Energy Use • A nalysis of Product Data

• Candidate Standard Levels • Installation Costs

• Maintenance Costs

• Repair Costs

• Energy Price Forecasts

• Site-to- Source Factors 2, 3

* Dark boxes indicate Determination Analysis chapters.

Figure 1.1. Flow Diagram of the Compon ents of a Determination Analysis

1.3.2 Overview of Determination Analysis Content The BC and EPS determination analysis included a market and technology assessment, screening analysis, engineeri ng analysis, energy-use and end-use load characterization, markups for equipment price determination, life-cycle cost (LCC) and payback period analysis, shipments analysis, and national impact analysis (NIA). As described in the framework document, DOE may use the work conducted during the determination analysis as a basis for th e analyses it conducts during the energy conservation standards rulemaking process.

Chapters 2 and 3 present the market and technology assessments, respectively, for BCs and EPSs. These chapters outline the typi cal consumer-product applications of these power converters, as well as the product cla sses for analysis and t echnologies for energy efficiency improvement. Chapter 4 describes th e screening analysis, which eliminates for technical or economic reasons technology op tions that DOE will not consider in the

1-4rulemaking. Chapter 5 describes the engineering analysis, whic h involved the selection of representative units for analysis and the calculation of the costs associated with increasing the efficiency of these units.

Chapters 6 and 7 describe approaches DOE used to determine the impacts of the cost-efficiency relationship developed in ch apter 5 on end users of products powered by BCs and EPSs. Chapter 8 is an analysis of LCC and payback period, while chapter 9 describes methods for deriving base and sta ndards case shipment forecasts. Chapter 10 describes a national impact analysis, which includes a methodology to calculate national energy savings and the net present value of those savings. DOE will use the methodology described in chapter 10 to measure the imp act of Federal energy conservation standards by (1) comparing projected U.S. energy c onsumption with and without new energy conservation standards, and (2) weighing the cost savings associat ed with decreased energy consumption against the increased end-user cost of more energy efficient products discounted over the 30-year analysis period.

A determination analysis is typically less rigorous than an energy conservation standards rulemaking, which DOE is initiati ng with the publicati on of its framework document. The analyses above focused on findi ng just one candidate standard level the Secretary could use to decide whether to proceed with setti ng energy conservation standards. An energy conservation standards rulemaking considers several standards levels. Additionally, the analyses at each standard level are more detailed in a standards rulemaking compared with the determination, which evaluates average or typical cases and does not include sensitivity or subgroup an alyses. Nonetheless, many of the inputs and methods used for the determination can be applied to the st andards rulemaking, and the Department welcomes stakeholder comment on all aspects of the determination analysis presented in this report.

1-5CHAPTER 2. MARKET ASSESSMENT

2.1 Introduction

.............................................................................................. 2-2 2.2 The Importance of Applications

.............................................................. 2-2 2.2.1 Market Trends

.......................................................................................... 2-2 2.2.2 Consumer Products: Impact of Design on the Market for Battery Chargers and External Power Supplies

................................................................... 2-3 2.3 Applications That Use Battery Charge rs and External Power Supplies

.. 2-5

LIST OF TABLES Table 2.1. Battery Charger Applications for Which DOE Has Shipment Data

............... 2-5 Table 2.2. External Power Supply Applications for Which DOE Has Shipment Data

... 2-6

2-12.1 Introduction This section of the Draft Technical Report summarizes the key points, data, and methods used in DOE’s work during the determ ination analysis to assess the current and future market for BCs and EPSs.

2.2 The Importance of Applications To characterize the market for BCs and EPSs, DOE gathered information on the applications that use them. This method was chosen for two reasons. First, the demand for consumer electronics applications driv es the demand for BCs and EPSs. Nearly all BCs and most EPSs are custom-designed fo r use with the app lication they power, therefore they are bundled w ith the application. Second, because BCs and EPSs are not stand-alone products, their usag e profiles, energy consumption, and power requirements are all determined by the associ ated application. To develop re liable estimates of the realworld unit energy consumption of a BC or EPS, it is necessary to examine the application.

Sales volume is the primary driver of demand for BCs and EPSs, but trends in consumer product design also affect de mand. For example, increased demand for portability in the consumer electronics i ndustry has driven demand for battery-powered products. This has increased demand for BCs and EPSs, which are used to charge batteries in consumer electronics. In terms of volume, the main consumer products that drive demand for BCs are digital cameras a nd power tools. For EPSs, the drivers are mobile phones, flat panel monitors, co rdless phones, and notebook computers.

2.2.1 Market Trends The major trends that affect the market for BCs and EPSs are related to the consumer products that are powered by th ese products. During its work on the determination analysis, DOE noted examples of particular importance to the BC and EPS markets.

2.2.1.1 Demand for Consumer Product Applications Sales of consumer electronics and handheld appliances that use a BC or EPS have increased significantly in recent years. In the BC market, the sales drivers in terms of shipments are power tools and digital cameras. The rechargeable power tool market is growing strongly, partly due to improved batt eries and chargers that offer more power and shorter charge times.

For EPSs, DOE’s initial analysis shows that market drivers in terms of shipments are wireless phones, flat panel monitors , cordless phones, and notebook computers. Wireless phones account for the largest number of EPS sales. The Consumer Electronics Association estimated that 138.2 milli on wireless phones were sold in 2007. 1

Despite the recent rapid growth, EPS sales in this segment are expected to level off as wireless phones become ubiquitous in the United States. Notebook computer sales are the main driver behind shipments of high-power EPSs, and an emerging trend of

2-2purchasing notebooks instead of desktops ha s pushed the nameplate output power of these EPSs upward, sometimes over 100 watts.

2.2.1.2 Convergence Some applications using BCs and EPSs are in decline as their functions are incorporated into other applic ations. For example, personal di gital assistants (PDAs) have become rare because their functions are incr easingly incorporated into wireless phones. Sales of digital cameras are also slowing. Th is may be due largely to market saturation, but convergence is a factor as well as the cameras built into wireless phones improve in quality. Multi-function devices, some of wh ich use EPSs, combine the features of a printer, copier, scanner, and fax machine into one product, and make the stand-alone, single-function products redundant. The converg ence of applications could decrease demand for BCs and EPSs as consum ers do more with fewer products.

2.2.1.3 Emergence The consumer electronics market is quick to adopt new technology and experiment with new consumer products. As battery and charger technology advances, products that are now stationary may become portable in the future. Some of the products that DOE analyzed for its determination did not exist 10 years ago. New BC and EPS applications are likely to emerge during the period of analysis.

2.2.1.4 Substitution Applications use a number of methods to obtain power, includ ing internal power supplies, external power supplies, primary batteries, rechargeable batteries, and USB ports. Market forces and changing design choices may cause shifts between these methods. For example, a portable digital audio player can receive power from an EPS, a BC, or a USB port. One brand of portable audio player that ha s dominated this market is typically charged through a USB port. Howeve r, users can purchase an EPS to charge their player through a traditional wall outlet. Small LCD televisions may use an EPS, but as they grow larger, power requirements dictat e that an internal power supply (IPS) is a better option.

The presence of a standard may cause a shift away from BCs or EPSs toward other power sources. The magnit ude of this effect depends on the design considerations ( e.g. , the need to dissipate heat in high-power applications), and the demands of the consumer ( e.g. , the desire for portability may exclude the use of an IPS). In its work on the determination, DOE assumed that a sta ndard would cause no substitution effects.

2.2.2 Consumer Products: Impact of Design on the Market for Battery Chargers and External Power Supplies Manufacturer product design and consumer choice both affect the size and growth of the BC and EPS market. In some consumer product categories, nearly all models are powered the same way. For example, most handheld vacuums are powered by BCs while most Wi-Fi access points are powered by EPSs. In other consumer product categories, the power conversion device can vary by manufactur er or model. For example, designers of

2-3digital cameras have a variety of choices when deciding how to power their products, including using a mains-powered BC or EPS, a universal serial bus (USB)-powered BC, or Power over Ethernet. These differences in the source of power re late to the intended use of a product, consumer preferences, a nd industry norms. Designers choose BCs to power handheld vacuums because users de sire portability. Wi-Fi access points are stationary, so designers choose an EPS. If the designer expects a digital camera to be used by professional photographe rs, a BC or EPS might be a good choice. If the designer expects the camera to be used in close c onjunction with a comput er, power through USB might be a good option.

An increasing number of portable devices, such as portable digital music players, can be recharged through a connection to a US B computer port. It is also possible to charge a portable digital music player by us ing an EPS purchased separately from the music player, but because most consumers us e a computer’s USB port to load music onto the device, most charging also occurs through the US B port. The market trend toward consumer products that are USB-powered could affect the number of products that are shipped with stand-alone power conversion de vices considered to be BCs and/or EPSs.

Both technical issues and consumer preferences can influence manufacturer design choices. Technical considerations may relate to the method the device uses to consume power ( e.g. , short bursts of high current as in a power tool or low levels of consumption as in a portable music player). Consumer preferences can also influence the design choice, such as having longer time be tween recharge, being able to operate the device from the mains power, and not having to wait for a battery to recharge. Variations in power system designs occur as manufactur ers develop different design solutions to these problems.

This variance in design affects the mark et. The shipments of a given type of consumer product in a given year do not necessarily correspond one-to-one with the number of BCs and/or EPSs that ship with those products. Technical issues and consumer preferences will influence manufacturer desi gn choices, and sales of BCs and/or EPSs could decrease even as total sales of consumer electronics increase.

2-42.3 Applications That Use Battery Chargers and External Power Supplies Table 2.1 and Table 2.2 list the applications for which DOE has gathered shipment data.

Table 2.1. Battery Charger Applications for Which DOE Has Shipment Data
Product Application Notes/Definition
Personal care products Includes rechargeable shavers, beard trimmers, massagers, toothbrushes, etc.

Floor care products Includes rechargeable stick vacuums, handheld vacuums, robotic vacuums, etc.
Kitchen products Includes rechargeable hand-held mixers, blenders, knives, etc.

Universal battery chargers Used to charge rechargeable batteries.
Digital cameras Digital cameras that are powered by proprietary batteries.

Camcorders Camcorders and digital camcorders that are powered by proprietary batteries.
Do-it-yourself (DIY) power tools Generally less powerful tools aimed at the occasional user; includes drills, saws, grinders, and others. Professional power tools Generally more powerful tools aimed at the professional user; includes drills, saws, grinders, and others. Typically use a fast-charging BC.

2-5Table 2.2. External Power Supply Applications for Which DOE Has Shipment Data
Product Application Notes/Definition Camcorders Portable consumer video recorders.*
Cordless phones Phones lacking a cord between the base station and headset for use in the public switched telephone network, e.g. , a traditional land line. Digital cameras Includes digital cameras that use an EPS.
Flatbed scanners Desktop scanning devices.* Flat panel monitors Also known as a LCD monitor, to be used with a computer

Ink-jet computer printers Only ink-jet computer printers are included in this analysis because laser printers, the other dominant technology type, use an internal power supply. LAN equipment Local Area Network equipment. This segment includes routers, hubs, and switches.

Modems/fax modems Broadband modems used for digital subscriber lines (DSL), cable, or broadband over power line (BPL).*
Notebook computers Desktop computers use an internal power supply and therefore only notebooks are considered for the analysis.
Portable audio players Includes personal MP3 players, CD and mini disc players, and portable radios powered by EPSs. Portable gaming devices Portable gaming devices such as PlayStation Portable and Nokia Ngage.* Portable video players Includes portable DVD and multimedia players.

Small LCD TVs Note: Large LCD TVs (23” screen size or greater) and plasma TVs use an internal power supply..
Telephone answering devices Stand-alone telephone answering mach ines and telephones with built-in answering machines.
Wi-Fi access points IEEE 802.11a/b/g/n access points.* Ha rdware used as a connecting hub for a wireless network.
Wireless telephones Also known as mobile or cellular ph ones. This category includes “smart phones” and personal dig ital assistants (PDAs). * Darnell Group. External AC-DC Power Supplies: Global Market Forecasts and Competitive Environment . 2 nd Edition. 2005. Darnell Group: Corona, California.

DOE identified other products that use a BC or EPS but did not include them in the determination analysis because complete data was unavailable. These applications are listed below. For these products, DOE lacks shipment data, splits between voltage or output power, usage information, or all of the above.

Battery charger applications fo r which DOE lacks data include:

• Electric carts

• Electric outdoor appliances

• Electric ride on toys

• Golf cars

• Mobility chairs

• Rechargeable light devices

• Toys

• Uninterruptible power supplies

2-6External power supply applications for which DOE lacks data include:

• Alarm clocks

• Amplifiers

• Aquarium pumps/lights

• Baby monitoring devices

• Bluetooth headsets

• Caller ID devices

• Computer speakers

• Distribution amplifiers

• Electronic musical instruments

• External computer drives

• Fluorescent desk lamps

• Guitar effects

• Hair dryers

• Handheld computers

• Handheld image scanners

• Indoor fountain pumps/lights

• MP3 player speaker systems

• MP3 player docking stations

• Multifunction printing/scanning/faxing devices

• Non-portable gaming devices

• Set-top boxes

• Water filters

• Water softeners

References

1 Consumer Electroni cs Association. U.S. Consumer Sales & Forecasts, 2004–2009. July 2008. CEA: Arlington, VA.

2-7CHAPTER 3. TECHNOLOGY ASSESSMENT

3.1 Introduction

............................................................................................................... .... 3-3 3.1.1 The Role of Power Converters

............................................................................. 3-3 3.1.2 Different Modes of Operation

.............................................................................. 3-4 3.1.3 EPS Design Parameters

........................................................................................ 3-5 3.1.4 BC Design Parameters

......................................................................................... 3-5 3.1.5 Product Classes

.................................................................................................... 3-5 3.1.6 Efficiency Metrics

................................................................................................ 3-6 3.1.7 Technology Options for Efficiency Improvement

............................................... 3-6

3.2 External Power Supply Modes of Operation

................................................................ 3-6 3.2.1 EPS Active Mode

................................................................................................. 3-6 3.2.2 EPS No-Load Mode

............................................................................................. 3-7

3.3 Battery Charger Modes of Operation

............................................................................ 3-7 3.3.1 BC Active Mode

.................................................................................................. 3-7 3.3.2 BC Maintenance Mode

........................................................................................ 3-8 3.3.3 BC No-Load Mode

............................................................................................. 3-8

3.4 External Power Supply Design

..................................................................................... 3-9 3.4.1 General Design of an External Power Supply

..................................................... 3-9 3.4.2 AC/AC External Power Supplies

......................................................................... 3-9 3.4.3 Unregulated Line-Frequency AC/D C External Power Supplies

....................... 3-10 3.4.4 Linear-Regulated Line-Frequency AC/DC External Power Supplies

............... 3-11 3.4.5 Switching-Regulated Line-Frequency AC /DC External Power Supplies

......... 3-13 3.4.6 Switched-Mode AC/DC External Power Supplies

............................................ 3-14

3.5 BC Design

.................................................................................................................. . 3-16

3.6 Product Classes

........................................................................................................... 3 -18 3.6.1 EPS Product Classes

.......................................................................................... 3-18 3.6.2 BC Product Classes

............................................................................................ 3-19

3.7 Energy Efficiency Metrics

.......................................................................................... 3-20 3.7.1 Using Energy Efficiency Metrics

....................................................................... 3-20 3.7.2 Energy Efficiency Metrics for External Power Supplies

................................... 3-20 3.7.3 Energy Efficiency Metrics for Battery Chargers

............................................... 3-21

3.8 Technology Options for Efficiency Improvement

...................................................... 3-21 3.8.1 EPS Technology Options

................................................................................... 3-21 3.8.2 BC Technology Options

.................................................................................... 3-22 3.8.3 Transformers

...................................................................................................... 3-23 3.8.4 Diode Losses and Synchronous Rectification

.................................................... 3-24

3-1LIST OF FIGURES

Figure 3.1 Block diagram of power flowing through an external power supply

......................... 3-3 Figure 3.2 Block diagram of power flowing through a battery charger.

..................................... 3-4 Figure 3.3 Example of an Efficiency Curve of an EPS in Active Mode

..................................... 3-7 Figure 3.4 Circuit Diagram for an AC /AC External Power Supply

.......................................... 3-10 Figure 3.5 Circuit Diagram of a Line-Frequency Raw Supply

.................................................. 3-10 Figure 3.6 Block Diagram of a Linear Regulator

...................................................................... 3-11 Figure 3.7 Simplified Circuit Diagra m of a Linear Regulator

................................................... 3-12 Figure 3.8 Block Diagram of a Switching-Regulated Line-Frequency AC/DC EPS

................ 3-13 Figure 3.9 Block Diagram of a Switched-Mode Power Supply

................................................ 3-14 Figure 3.10 Simplified Circuit Diagram of a Flyback Switching Regulator

............................. 3-15 Figure 3.11 Circuit Diagram of a BC

......................................................................................... 3-1 6

LIST OF TABLES

Table 3.1. Product Classes Used in the EPS Draft Determination Analysis.

............................ 3-19 Table 3.2 BC Product Classes Developed for the Draft Determination Analysis

..................... 3-20 Table 3.3 Quality of Core Steel a nd Level of Magnetic Induction

........................................... 3-23

3-23.1 Introduction

This technology assessment examines BC and EPS technology, with a focus on the factors most affecting their efficiency. The asse ssment begins by explaining the purpose of EPSs and BCs, their legal definitions, and their differe nt modes of operation. Next, it presents the parameters that govern power converter de sign and, based on those parameters, how DOE considered grouping them into product cla sses. Last, the technology assessment reviews efficiency metrics as well as methods for improving efficiency. This introduction briefly examines each of these points. In other chapters of this document, discussion begins with BCs; for the purposes of the technology assessment, it is more natural to examine EPSs first.

The assessment presents DOE’s current unde rstanding as well as previous unpublished work. In December 2006, DOE published a draft technology assessment in “The Current and Projected Future Market for Battery Ch argers and External Power Supplies.” a DOE then continued to research BCs and EPSs in prepara tion for a determination analysis it intended to publish in August 2008. This tec hnology assessment presents DOE ’s understanding of BC and EPS technology as it was developed for the determ ination analysis until EISA suspended DOE’s examination in 2007. The purpose of this t echnology assessment is to present DOE’s understanding of the factors DOE reviewed in the scre ening analysis and then used in the engineering analysis to establish the re lationship between cost and efficiency.

3.1.1 The Role of Power Converters

EPSs and BCs are power converters that support consumer products; hence, their operation and design is primarily governed by th e consumer products they support (Figure 3.1 and Figure 3.2). Generally, external power supplie s provide power at a constant output voltage and are interchangeable among consumer pr oducts with similar power requirements. Alternatively, battery chargers deliver power while controlling the output current, the output voltage is determined by the battery. Battery chargers tend to be custom-designed for the charging and safety requirements of specific battery packs.

Figure 3.1 Block diagram of power flowin g through an external power supply.

a This document is available at www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/market_analysis.pdf

.

3-3Figure 3.2 Block diagram of power fl owing through a battery charger.

To specify, DOE is developing energy cons ervation standards for battery chargers and external power supplies defined by EPCA, as amended by EPACT. EPCA defines a battery charger as “a device that charges batteries fo r consumer products, including battery chargers embedded in other consumer products.” (42 U. S.C. 6291(32)) The definition for external power supply is “an external power supply circuit that is used to convert household electric current into DC current or lower-voltage AC current to operate a consumer product” (42 U.S.C. 6291(36)(A)) but Section 301 of EISA further ame nded this definition by creating a subset of external power supplies called Cl ass A External Power Supplies b . EISA defined this subset as those external power supplies th at, in addition to meeting seve ral other requirements common to all external power supplie s, are “able to convert to only 1 AC or DC output voltage at a time” and that have “nameplate output power that is less than or equal to 250 watts.” (42 U.S.C. 6291(36)(C)(i)) EPCA excludes from Class A an EPS if it “requires Federal Food and Drug Administration listing and approval as a medical device” or if it “powers the charger of a detachable battery pack or charges the battery of a product that is fully or primarily motor operated.” (42 U.S.C. 6291(36)(C)(ii)) This framework document only considers battery chargers and Class A external power supplies. Separately, DOE is conducting a determination analysis for non-Class A external power supplies.

3.1.2 Different Modes of Operation

BC and EPS design choices are driven by the anticipated power requirements and time spent in their modes of operat ion, including active mode, maintena nce mode (for BCs only), and no-load mode. Of these modes, active mode has the largest effect on the power converter’s size and efficiency because the maximum amount of power passes through in active mode. In the other operational modes, power converters provide less power; how ever, their power consumption is typically larger in proportion to the output power.

b The full EISA definition of a Class A external power supp ly includes a device that "(I) is designed to convert line voltage AC input into lower voltage AC or DC output; (II) is able to convert to only 1 AC or DC output voltage at a time; (III) is sold with, or intended to be used with, a separate end-use product that constitutes the primary load; (IV) is contained in a separate physical enclosure from the en d-use product; (V) is connected to the end-use product via a removable or hard-wired male/female electrical connection, cable , cord, or other wiring; and (VI) has nameplate output power that is less than or equal to 250 watts.” (42 U.S.C. 6291(36)(C)(i)) The EISA definition also excludes from Class A “ any device that-- (I) requires Federal Food and Drug Administration listing and approval as a medical device in accordance with section 513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c); or (II) powers the charger of a detachable battery pack or charges the battery of a product that is fully or primarily motor operated.” (42 U.S.C. 6291(36)(C)(ii))

3-4Although both BCs and EPSs are power convert ers with similar modes of operation, there are important differences between them. An EPS can be in active mode for an indefinite amount of time while providing power to a load. Typical ly, EPSs spend most of their time in active mode. On the other hand, while in active mode, a BC refills a battery with energy. Therefore, the BC is in active mode only until the battery is fi lled. After that point, the BC is in maintenance mode, when the BC maintains the battery at full charge.

These differences in operation lead to differences in design. For instance, BCs are designed around the charge type in active mode

 fast or slow charging. The power requirements of the EPS load in active mode are the primary criteria affecting the EPS’s design.

3.1.3 EPS Design Parameters EPSs are designed to take power from main s and convert it to a form useful to a consumer product. Thus, it is the consumer produc t that dictates the output power and output voltage of the EPS, the two design parameters with the biggest effect on EPS efficiency. The voltage requirements of the consumer product also define the tolerance of the EPS output voltage and whether it requires voltage regulation. These and other design parameters help determine whether the EPS is line frequenc y or high-frequency switched mode , and unregulated or voltage regulated. In turn, those design choices constrain which the tec hnology options that the EPS can use and its consequent efficiency.

3.1.4 BC Design Parameters BCs are designed to take power from mains and convert that power over time to energy stored in a battery; later, th e battery delivers the energy to a consumer product. Thus, the consumer product determines the choice of battery, which also determines the characteristics of the battery charger. The most im portant design parameters of a BC are the voltage of the battery it will charge and the charge type, either fast or slow. The charge type—a measure of how quickly the BC refills its battery with energy—determines maximum output power. A BC defines the output current, while the battery c ontrols the BC’s output voltage. Like an EPS, output power and battery voltage have the larges t effect on BC design a nd efficiency. In turn, those design choices constrai n which the technology options that the BC can use and its consequent efficiency.

3.1.5 Product Classes The Department of Energy groups products into “product classes” for different energyefficiency standards when a product’s characte ristics constrain its energy efficiency. As necessary, DOE divides covered pro ducts into classes by the type of energy used, the capacity of the product, and any other performa nce-related feature that justif ies different standard levels, such as features affecting cons umer utility. (42 U.S.C. 6295(q)) For example, when compared with a standard device, a device with additional functionality that provides extra utility to the consumer would be grouped in a separate product cl ass, if the additional f unctionality inherently limits its efficiency. DOE then conducts its an alysis and considers es tablishing or amending standards to provide separate standard levels for each product class. For the determination analysis, DOE considered EPS product classe s primarily based on output power and output voltage. For BCs, DOE considered ch arge type and battery voltage.

3-53.1.6 Efficiency Metrics Any evaluation of efficiency depends heavily on the measures used to quantify it. This document considers conversion efficiency in ac tive mode for EPSs and power consumption in other modes for both BCs and EPSs. DOE used previ ously adopted test pro cedures codified in 10 CFR part 430 appendices Y and Z as the basis fo r evaluating efficiency for the determination analysis.

3.1.7 Technology Options for Efficiency Improvement The largest gains in efficiency in EPSs a nd BCs come from convert ing power with lower loss components and using more energy-efficient controls in th e power converter. DOE analyzed the components in the power conve rter that consume significant pow er, such as transformers, or influence power consumption of other components, such as integrated circuits. By identifying sources of power loss and possible methods for improvement, DOE developed technology options that would allow a manufacturer to design a power converter with similar design characteristics but improved efficiency.

3.2 External Power Supply Modes of Operation

3.2.1 EPS Active Mode

When the external power supply takes power fr om mains and converts it to a form usable by the consumer product or load it is considered to be in “active mode.” For the determination analysis, DOE used the definition of active mode codified in 10 CFR part 430 subpart B appendix Z: “Active mode is the mode of operati on when the external power supply is connected to the main electricity supply and the output is connected to a load.”

In this mode, EPS efficiency is the conversion efficiency when the load draws some or all of the maximum rated output power of the EPS. To provide that output power, the EPS also consumes power due to internal losses as we ll as overhead circuitry. The amount of power the EPS consumes varies with the power demands of the load; together, those two parameters define the EPS’s efficiency at a particular loading point: P

out P out η EPS = = Eq. 3.1 P P + P

In out EPS

_ consumption where η EPS is the EPS efficiency, P EPS_consumptiont is the power consumed by the external power supply itself, P in is the power from mains into the external power supply, and P out is the power out of the external power supply to the consumer product.

EPS efficiency varies with the amount of output power as shown in Figure 3.3. Typically, EPS are inefficient at low load (0 percent to 20 percent of maximum rated output power of the EPS) when the consumer product demands little power. However, EPS are more efficient at larger loads (between 20 a nd 100 percent of maximum rated output power) as when the consumer product is fully functional and demandi ng more power. The lower efficiency at lower output current is due to the proportionally larger power consumption of internal EPS components, relative to output power. At higher power, EPS losses increase slightly, but have less of an effect on EPS efficiency. The EPS te st procedure evaluates active mode conversion

3-6efficiency at four loading poi nts: 25 percent, 50 percent, 75 percent, and 100 percent of maximum rated output power, which captures a ge neral picture of EPS efficiency. Figure 3.3 shows an example of a typical efficiency curve for an EPS in active mode.

Figure 3.3 Example of an Efficiency Curve of an EPS in Active Mode

3.2.2 EPS No-Load Mode For the determination analysis, DOE used the definition of no-load mode codified in 10 CFR part 430 subpart B appendix Z: “No load mode means the mode of operation when the external power supply is connected to the main electricity supply and the output is not connected to a load.”

EPS efficiency in no-load m ode is characterized by EPS pow er consumption, rather than conversion efficiency, because the EPS does not deliver power to the load in this mode. However, the EPS might provide functionality. For example, certain consumer products may require the EPS to deliver outpu t power within moments of bei ng connected. Thus, the EPS may consume power to provide the useful function of reduced start-up time. Nonetheless, EPS power consumption can be low (less than 1 watt) in no-load mode for Class A EPSs.

3.3 Battery Charger Modes of Operation

3.3.1 BC Active Mode DOE codified the definition of active mode for battery chargers in th e test procedure final rule published in December 2006 (10 CFR part 430 subpart B appendix Y): “Active mode is the condition in which the battery is receiving the main charge, eq ualizing cells, and performing other onetime or limited-time functions necessary for bringing the battery to the fully charged

3-7state.” For the determination analysis, DOE st udied BC active mode for its effect on BC design and performance. However, DOE used the non-activ e energy ratio to evaluate efficiency, which does not include active mode.

The output current of a BC in active mode is most critical at two poi nts: when the battery is fully charged and when the battery is empt y. When the battery is fully charged, the BC may need to immediately stop sending current to the ba ttery, as in the case of lithium-based batteries. When a battery is empty of charge its voltage be comes very low. In that state, the BC needs to limit its output current because it could damage the battery and pose a safety hazard from heat generation. Therefore, the BC must limit the charging current until the battery voltage increases.

Battery charger efficiency in active m ode is governed by BC component losses and overhead circuitry. BCs share with EPSs similar options for reducing component losses in active mode. However, some BCs have safety circuitr y to monitor the batter y during charging, which EPSs typically do not include. Safe ty circuits are often present in BCs that are fast chargers; safety concerns also affect de sign of slow-charging BCs. Thus, if a BC were compared to an EPS with similar power ratings, it might appear to have lower co nversion efficiency due to the additional power consumption of its safety circuitry.

3.3.2 BC Maintenance Mode DOE codified the definition of maintenance mode for battery chargers in the test procedure final rule published in December 2006 (10 CFR part 430 s ubpart B appendix Y): “Battery maintenance mode or maintenance mode is the mode of operation when the battery charger is connected to the main electricity supply and the battery is fully charged, but is still connected to the charger.”

Once the battery reaches a fully charged state, the BC and battery are considered to be in maintenance mode. In this mode, the BC controls the output current to prevent the battery from being damaged due to excess heat generati on or unwanted electro-chemical reactions. Specifically, the battery has di fferent requirements depending on its chemistry. Lithium-ion (LiIon) batteries do not significantly self-disch arge but do pose a serious safety hazard if overcharged. Consequently, Li-Ion BCs stop char ging once the battery is full and require no maintenance current. Conversely, nickel-based ba tteries, such as nickel -cadmium (NiCd) and nickel-metal-hydride (NiMH), si gnificantly self-discharge but are tolerant of overcharging. Hence, their BCs continue to provide maintena nce current to keep the battery fully charged. Efficiency can be improved by reducing the charge current to the minimum. For BCs that do not provide charge current in maintenance mode, efficiency can be improved by turning off circuits that are not in use.

3.3.3 BC No-Load Mode For the determination analysis, DOE used the definition of no-load mode codified in 10 CFR part 430 subpart B appendix Y: “Standby m ode or no-load mode means the mode of operation when the battery charger is connected to the main electricity supply and the battery is not connected to the charger.”

3-8Similar to the EPS that is disconnected from the load, a BC in no-load mode does not deliver power to a battery. Improved efficiency in these modes stems from reducing BC power consumption. Many of the technology options for reducing no-load mode power consumption in EPSs are also valid for BCs. Some BCs also us e a cradle to hold th e battery during charging, which offers an additional ener gy saving technology. A BC could have a switch in the cradle that senses the battery’s presence and electrically di sconnects the BC from mains when the battery is removed.

3.4 External Power Supply Design

3.4.1 General Design of an External Power Supply EPS’s must meet several specifications in order to power a consumer product; EPSs are generally designed to provide power at a fixed output voltage with variable current to a consumer product. The consumer product is what determines the EPS design criteria, including output power, output voltage and the toleran ce of the output voltage. EPSs designed for consumer products that require precise voltages ( e.g. , computers) will also incorporate output voltage regulation to minimize voltage fluctuatio ns caused by load or power source variations. Other applications that can tole rate some voltage fluctuation ma y use simpler EPSs that do not regulate the output voltage. Also, EPSs might have other specifi cations, such as total harmonic distortion or power factor.

Of all these specifications, output power and output voltage have the largest impact on EPS efficiency, because together they determ ine the output current, which directly affects conduction losses and associated power dissipation in the EPS.

Line-frequency EPSs have that name because the frequency of the current passing through their transformers is the same as that of the AC mains current (nominally 60 Hz in the United States). Switched-mode power supplies (SMPS) convert power differently than linefrequency EPSs. SMPSs first rectify the AC main s voltage to DC, converting it back to AC by switching the current on and off at high fre quency. The high-frequency AC current passes through the primary winding of a transformer while the output from the secondary winding of the transformer is rectified, resulting in a low-voltage DC output. Because the AC current passing through the transformer is at high frequency, the transformer is smaller, resulting in lower weight, material costs, and losses in the transformer, all of which decrease with transformer volume.

3.4.2 AC/AC External Power Supplies An AC/AC external power supply is the simple st type of EPS, typically consisting only of a transformer. A transformer contains tw o wires wrapped around a metal core; as current passes through the primary wire, pow er is transferred to the sec ondary wire at a lower voltage through magnetic induction in the core. The size of the wires and core depend on the output power of the transformer. The output voltage de pends on the relative number of turns between the primary and the secondary wires. The windi ngs of the transformer are wound so that the voltage generated in the secondary wire is at the design voltage for the consumer product when mains voltage is applied to the primary wire. Because the primary and secondary windings are two separate wires, the transf ormer also provides a safety f unction, electrically isolating the

3-9consumer product from the mains. The key factor s that determine transformer losses are core size, core material, number of windings, and wire gauge.

+

V

Out

- Transformer

+

V

Mains

- Primary Secondary

Figure 3.4 Circuit Diagram for an AC/AC External Power Supply

3.4.3 Unregulated Line-Frequency AC/DC External Power Supplies An unregulated line-frequency EPS is refe rred to as a “raw s upply,” which has three distinct stages (Figure 3.5): a transformer to is olate and step down mains voltage, a rectifier to convert AC voltage to DC volta ge, and a filter capacitor to smooth the output voltage. The two main sources of loss are the transformer and the rectifying diodes. After passing through the transformer, current passes thr ough rectifier diodes, whic h have voltage drops that also dissipate power. Typically, diodes have a drop of 0.6 volts, which constitutes a proportionally larger share of the losses at lower output voltages. For AC -DC EPS that have a low output voltage, below approximately 12 V, the power consumed by the di odes also becomes signifi cant in that it is more than 10% of losses, if the rectifier is a bridge with two diodes.

Figure 3.5 Circuit Diagram of a Line-Frequency Raw Supply

The raw supply is directly responsive to the load: A change in the mains power or the resistance of the load directly affects the output voltage of the ra w supply. If required, a regulator circuit follows the raw supply circu it, housed either in the EPS or in the device before the load.

3-103.4.4 Linear-Regulated Line-Frequenc y AC/DC External Power Supplies

To achieve voltage regulation, manufacturers can add a second stage, such as a linear regulator, to the line-frequency power conversion stage described above, or redesign the power conversion stage entirely using a switched-mode topology. Of the two re gulator technologies, linear regulators are simpler, bulkier, cheaper, an d generally less efficient at higher power levels than switching regulators. Switching regulators, although more complicated and costly, provide a good alternative when portability is a concern, such as when an EPS is used with a mobile phone.

The AC-DC conversion stage of a regulated line-frequency EPS is essentially the same as that of an unregulated EPS, with the same sources of power consumption. The linear voltage regulation stage adds to these losses by pa ssing power from the AC-DC converter to the consumer product through a power-dissipating elem ent. This regulation stage senses the output voltage and adjusts the voltage across the power-d issipating element to keep the output voltage fixed. Loss in a regulated line-frequency EPS is caused by the conversion stage delivering current at a higher voltage th an needed by the consumer pr oduct, and dropping the excess voltage across the regulator to achieve the lower regulated output voltage. Dissipated as heat, the power lost in the regulator is the product of the voltage drop and the load current.

Linear regulators have two key elements: a sensor and a pass device, which work together to produce a fixed output voltage (Fi gure 3.6). To determine those adjustments, the sensor element continuously compares the output voltage to a reference voltage. Whenever there is a difference between the two volta ges, the sensor directs the pass device to adjust the output in order to reduce that difference. This continuous adjustment allows the regulator to yield a constant output voltage as the lo ad resistance or mains voltage va ries. The output voltage of the linear regulator circuit is what the user sees as the output voltage of the EPS.

Raw Supply Stage Mains Power Pass Device

Sensor Linear Regulator Stage

Figure 3.6 Block Diagram of a Linear Regulator V Out

3-11Figure 3.7 shows a circuit diagra m of a “low-dropout” linear regulator, one of the more common types of linear regulators. To determin e the voltage drop across the pass device, an operational amplifier (commonly referred to as an “op-amp”) acts as a sensor that compares the output voltage against a refere nce voltage. Based on those two signals, the op-amp controls a transistor, which is the pass devi ce. The voltage drop across the transistor determines the output voltage but also dissipates energy. The energy di ssipated by the pass device is the main source of energy consumption in the linear regulator, and he nce the main source of inefficiency and heat generation. Together, the sensor and the pass device adjust the out put of the regulator to produce a stable output voltage, which is what the load receives as the output voltage of the EPS.

Figure 3.7 Simplified Circuit Di agram of a Linear Regulator
The efficiency of the linear regulator, η LinReg , is:

P V I

LinReg

_ out LinReg

_ out LinReg

_ out η LinReg = = Eq. 3.2 P V I

LinReg

_ in LinReg

_ in LinReg

_ in

where I LinReg_in is the current into the linear regulator, I

LinReg_out is the current out of the linear regulator, P

LinReg_in is the power into the linear regulator, P

LinReg_out is the power out of the linear regulator, V

LinReg_in is the voltage into the linear regulator, and V

LinReg_out is the voltage out of the linear regulator.

3-12Because the linear regu lator directly attaches to the raw supply, V LinReg_in is equal to V

RawSupp_out , the output voltage of the raw supply.

Because the input current flows directly to the output through the pass device, with other currents being negligible, I LinReg

_ out ≈ I LinReg

_ in . Therefore, the efficiency of the linear regulator alone is approximately:

V

LinReg

_ out η

LinReg ≈ Eq. 3.3 V

LinReg

_ in
The total efficiency of an EPS with a linear regulator depends on the efficiency of both the linear regulator stage a nd the raw supply stage. Depe nding on the load conditions, η LinReg generally ranges from 0.6 to 0.8, meaning the linear regulator is about 60 to 80 percent efficient. The efficiency of raw supply, η RawSup , also varies with load, generally from 0.7 to 0.9. The raw supply and linear regulator each are most efficient at differe nt load conditions. Multiplied, η LinReg and η RawSupp yield the total efficiency of an EPS with a linear regulator, η Lin_EPS , which is generally about 50 percent, but is lower for EPSs with outpu t power below 10 W:

η Lin

_ EPS = η RawSupp * η LinReg Eq. 3.4

3.4.5 Switching-Regulated Line-Frequency AC/DC External Power Supplies An alternate to a linear regulator is a switc hing regulator that can also follow the raw supply (Figure 3.8). Switching regulators tend to be much more efficien t than linear regulators because they do not dissipate excess power. Rath er, to regulate output they take power as necessary to maintain constant output volta ge. Due to their higher costs, these switching regulators tend not to be as comm on as linear regulators, since it is typically more cost-effective to use a switched-mode power supply design.

Raw Supply Stage Mains Power Chopper

Control V Out Switching R egulator Stage

Energy Transfer

Feedback

Isolation

Figure 3.8 Block Diagram of a Switchin g-Regulated Line-Frequency AC/DC EPS

3-133.4.6 Switched-Mode AC/DC External Power Supplies A switched-mode power supply consists of fi ve stages: an AC-DC conversion stage, a chopper stage, an energy transfer stage, a control stage, and a f eedback isolation stage (Figure 3.9). First, the current is rect ified and passed to the chopper, wh ich converts the DC voltage back to AC, but at high frequency. The energy transf er stage then takes energy from the chopper, briefly stores it, and then passe s it to the rectifier to be output to the consumer product. The energy transfer stage also serves to isolate the user from the mains. The level of the output voltage is fed back through a f eedback isolation stage to the co ntroller, which tracks the output voltage and adjusts the chopper to make the desired voltage.

Figure 3.9 Block Diagram of a Switched-Mode Power Supply

The critical elements in a switched-mode E PS are the transistor, output rectifier, bulk capacitor, transformer, and contro ller. A transistor acts as a switch that constrains the flow of power rectified from mains into the transformer (or choke), thr ough the output rectifier, and, ultimately, to the consumer product. A controller , typically an integrated circuit (IC), switches the transistor on and off based on the output voltage. By adjusting th e duty ratio, the IC controls the rectified mains current into the primary wi nding of the transformer and thereby the output voltage of the EPS. The IC can also limit power dissipation in active mode by reducing switching at low current or low voltage. Further, the IC can gr eatly increase efficiency by reducing power consumption in no-load mode , the condition when the EPS has been disconnected from the load, resulting in zer o output current. Af ter passing through the transformer, the current is rect ified and filtered before reaching the consumer product. Principal sources of loss in a switched-mode EPS are the tr ansistor switching transients, magnetization and resistive losses as a result of transformer current , controller IC power cons umption, and rectifier losses. Although there are more sources of loss for switched-mode EPSs than line-frequency EPSs, in total, losses in switched-mode EPSs tend to be lower.
The switching regulator usually c onsists of an integrated circ uit controller and discrete components. The circuit diagram in Figure 3.10 depi cts a “flyback” switchi ng regulator, the most common type for EPSs used with consumer electronics; however, many other switching regulator designs also exist. The AC/DC conversi on stage consists of a diode bridge and filter capacitor, similar to a raw supply. In this case, current flows directly fr om mains to the diode bridge, rather than through a transformer.
The chopper stage uses a tran sistor, which switches on and off at high frequency to convert the DC current from the AC/DC converter back to an AC current for the energy transfer stage. A control stage drives the transistor; the duty cycle of the transist or determines how much

3-14energy is transferred through th e energy transfer stage. The switching frequency is in the kilohertz range, with lower frequencies havi ng lower switching losses. Typically, the minimum frequency is 20 kHz, above the au dible range of human hearing.



### AC/DC Conversion

PWM Optocoupler Chopper

Control Isolation 

### Energy Transfer

+

V

Out



### - +

V

Mains



### -

Figure 3.10 Simplified Circuit Diagram of a Flyback Switching Regulator
The energy transfer stage consists of a choke, a capacitor, and a diode. The choke is similar to a transformer and has the same symbol in the circuit diagram. One difference is that a transformer in a line-frequency EPS is designed to pass energy from one winding to another with minimal energy storage, while a choke in a swit ched-mode EPS is designe d to store and release energy. Also, the phasing of the windings is not important in the line-frequency transformer, but it is critically important in the flyback switching regulator. This is represented in Figure 3.10 by dots on the choke.
When the chopper switch is closed, the prim ary winding of the choke takes energy from the chopper and stores the energy in the choke. When the chopper switch opens, the secondary winding transfers that energy thr ough the diode to the capacitor and provides the output for the switching regulator, electrically isol ating the load from the mains. Because the choke operates at a high frequency, it benefits from the associ ated decreases in size and weight. The energy transfer scheme of the switching regulator is mo re efficient than a linear regulator, in part because the choke stores and returns energy with relatively low losses.
The feedback isolation stage typically uses an optocoupler that cons ists of a light source and a photosensitive detector. By converting the electrical feedback signal to an optical one, the optocoupler maintains the load elect rically isolated from the mains. The detector converts the optical signal back to an electr ical signal for the controller.
Generally, the controller is an integrated circuit that drives the chopper with a highfrequency pulse-width- modulated (PWM) waveform. The cont roller monitors the EPS output

3-15voltage and adjusts the pulse widt h to increase or decrease th e amount of energy transferred by the chopper. If the output voltage dips, the contro ller will increase the duty cycle, thus increasing the energy passed by the energy transfer stage an d increasing the output vo ltage. Conversely, if the output voltage rises, the controller will decreas e the duty cycle or possibly skip cycles. This cycle-skipping feature is especially useful at low- load or when there is no load attached, because the EPS will only take from the mains the small am ount of power it needs to keep itself running.

As an alternative to an IC controller, a switched-mode EPS ca n also use discrete components, as in the case of a ringing choke conv erter. In that topology, discrete transistors control the chopper and the resulting energy transf er. EPSs without ICs te nd to be more common at lower output powers. However, by not havi ng an IC, the EPS may consume less overhead power, but offers less functionali ty, such as cycle-skipping at low load, which can limit EPS efficiency.
Both linear-regulated and switc hing-regulated EPS use regula ting circuits to achieve a stable output voltage. However, voltage is not th e only output variable th at can be regulated. Current regulation, as discussed in the following section, is a fundamental consideration in BC design.

3.5 BC Design BCs are power converters that support consum er products and their associated batteries. The circuit model for the battery is a device with certain electro- chemical characteristics, as shown in Figure 3.11.

Figure 3.11 Circuit Diagram of a BC
Technology options for improvi ng BC efficiency depend on wh ether the BC is a slow charger or a fast charger. The di stinction is based on the charge ra te (also referred to as C-rate), often defined as the average charging current in to the battery, divided by the nominal battery charge capacity. For current expressed in ampe res and battery capacity expressed in amperehours, the resulting quantity is expressed in units of 1/hours or C. For example, a BC with a 100 milliamp (mA) output current charging a 1,0 00 milliamp-hour (mAh) battery would result in

3-16a charge rate of 0.1 C. Chargi ng time is roughly the inverse of th e charge rate, adjusted for the efficiency of the battery itself, which varies with chemistry. In the previous example, charging a battery at 0.1 C would take sli ghtly longer than 10 hours to charge . Slow chargers are sometimes referred to as “continuous chargers” because th ey continuously charge the battery with no distinction between active mode and maintenance mode. Fast char gers are typically considered “terminating chargers” because they charge at high current during active mode, which terminates in maintenance mode when the battery is fully charged.
Slow, continuous-charging BCs are more co mmonly found in consumer products that operate infrequently and spend most of their life in maintenance mode. An example is a cordless hand-vacuum, which spends most of its life in a charging-base awaiting use. Continuous BCs provide current to the ba ttery using the same circuit regardless of battery state and usually only monitor the battery for safety purposes, not the state of the charge. DOE considers BCs with charge rates less than 0.2 C (typica lly around 0.1 C) to be slow char gers. At this low charge rate, nickel-based batteries can be charged conti nuously without concern for excessive battery overheating or safety. Slow char gers do not typically include cu toff or monitoring circuitry. However, as the battery nears full charge and its voltage increases, the charge-control impedance used in a slow charger will cause the chargi ng current to decrease. This reduces power consumption and lessens battery heating due to overcharging, thereby extending battery life. Slow chargers are not typically used in combination with lithium-based batteries, because of the safety concerns associated with overcharging these batteries.
Slow chargers are typically composed of a line-frequency transformer followed by a rectifier. The charger can use eith er a discrete resistor or the resistance or reactance of the transformer windings to control the battery charging current. Th e conversion losses in a slow charger are mostly the result of magnetization lo sses in the transformer co re, resistive losses in the transformer windings or other charge-control element, and diode drops in the rectifier. In addition, slow chargers typically continue to deliver current to th e battery even after it is fully charged, usually at a rate much higher than that necessary to maintain the charge lost due to battery self-discharge. The excess power is di ssipated as heat in the battery. The power conversion losses identified earlier continue to have an impact in this maintenance mode, further increasing power consumption. Even in no-battery mode, when the battery is disconnected from the charger, the slow charger continues to c onsume power due to the transformer magnetization losses.

Fast-terminating BCs recharge a battery more quickly than continuous BCs because they provide a high-current charge while the battery can safely accept it (during active mode). For example, a cordless power drill with a rapid-char ge BC uses a high current to quickly charge the battery, often in an hour. Once the battery is fully char ged, the BC maintains the battery at full charge with a lower current. To determine when to charge at high current, terminating BCs monitor inputs such as battery voltage, rate of change of battery voltage, battery temperature, rate of change of battery temperature, charging time, and charging current. These inputs direct a charging regulator in the BC to adjust output current.

Thus, a battery charger that c ontains monitoring, cutoff, or limiting circuitry can safely charge lithium-based batteries or fast-charge nickel-based batteries. DOE considers BCs with charge rates greater than 0.2 C (typically between 0.6 C and 1 C) and containing safety circuits

3-17that monitor the battery to be fast chargers. Be cause of their faster charge rate, their maximum rated output power is 5 to 20 tim es greater than that of slow chargers, even when charging a battery of the same voltage and capacity. For this reason, fast chargers typically use switchedmode power supplies, which are smaller and li ghter than line-frequency power supplies often used with slow chargers. This design differe nce means that the designs are susceptible to different loss mechanisms.
The two primary sources of energy consumption (and opportunities for energy savings) in fast-terminating BCs are transforme rs and battery monitoring circu its. First, there are conversion losses associated with switching and rectificat ion and fixed losses due to overhead power consumption associated with the integrated circuit switching contro ller and the safety monitoring circuitry in a BC with a switched-mode power supply. Also, although fast chargers terminate ( i.e. , limit charging current once the ba ttery has reached full charge), most chargers continue to supply a small amount of maintenance current. As with slow chargers, this maintenance current and the associated conversi on losses contribute heavily to maintenance-mode power consumption. Even with the battery removed, the charger continues to consume significant power due to overhead losses.

3.6 Product Classes DOE divides covered products into classes by th e type of energy used, the capacity of the product, and any other performance-related feature th at justifies different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE then conducts its analysis and considers establishing or amending standards to pr ovide separate standard levels for each product class. In this section, DOE summarizes the various produc t classes used by EISA 2007, ENERGY STAR, and the draft analysis prepar ed by DOE for the determination in 2007.

3.6.1 EPS Product Classes Because output power and output voltage ha ve the largest impact on achievable EPS efficiency, DOE considered both criteria when developi ng EPS product classes for its determination analysis. DOE reviewed EPS product classes developed by ENERGY STAR and those proposed by manufacturers. Version 1 of the ENERGY STAR specification only considered EPS output power; howev er, in interviews, manufacturers prompted DOE to consider output voltage as well.

DOE divided the EPSs under analysis into lo w-, medium-, and high- power units, with the boundaries at 4 and 60 watts na meplate output power. Based on manufacturer input, DOE expected EPSs in each product class to share design characteristics that would affect the cost of increasing active-mode efficiency and decrea sing no-load mode power consumption. For example, DOE expected low-power switched-mode EPSs with output power of less than 4 watts not to contain a controller IC, due to the high cost of an IC in relati on to the total cost of the EPS. The high proportional cost of an IC in this cas e would increase the co st of improving no-load power consumption.

Similarly, DOE expected EPSs with output power greater than 60 watts to be switchedmode EPSs with a two-stage circ uit architecture and active power factor correction (PFC). This is because many EPSs are sold in both US and Eu ropean markets, where there is a standard for

3-18power factor. Power factor co rrection is necessary for meetin g power-factor requirements under the European Union Code of Conduct, a voluntary agreement of EPS manuf acturers. Due to the global nature of the EPS market, these require ments affect the design and cost-efficiency relationship of high-power E PSs in the United States.

However, after analyzing 32 EPSs with outpu t power less than 6 watts and 18 EPSs with output power greater than 50 wa tts, DOE was unable to find s upport for the above product class divisions (discussed furthe r in chapter 5, Engineering Analysis). There did not appear to be clear thresholds at which manufacturer s would begin to use controller IC s or PFC circuitry. Therefore, DOE did not consider EPS product classes related to these criteria, alt hough DOE recognizes the important role of ICs and PFC in EPS design and anticipates further analys is of these criteria.

In interviews held in 2007, manufacturers al so suggested that DOE differentiate the EPS product classes by output voltage in addition to output power. When comparing EPSs with the same output power, EPSs with lower output vol tages have higher conduction and diode-drop losses that pose additional challenges to achie ving high efficiency. Manufacturers therefore suggested that DOE further subdi vide its product classes by output voltage, with a division at 12 volts, the point where the approximately 0.6- volt diode drop results in losses equal to 5 percent of the output voltage (for a switched-mode EPS with one output rectification diode), and corresponding efficiency losses. Table 3.1 presents the product classes that DOE used in its determination analysis. Again, although there is overlap between the terms, “product class A” from the DOE draft determination analysis is no t related to “Class A” EPSs set forth in EISA 2007.

Table 3.1. Product Classes Used in th e EPS Draft Determination Analysis.

Nameplate Output Nameplate Output Power Voltage <4 watts 4–60 watts >60 watts
<12 volts A B C
>12 volts D E F

3.6.2 BC Product Classes There are several capacity- and performance-related features of a BC that could be used for classification, including th e charging method it uses (continuous charging versus terminating charging), the charge rate, the vol tage or capacity of the battery or batteries charge d, and/or the battery chemistry. When conductin g the determination analysis, DOE divided battery chargers into product classes based on batte ry voltage. This parameter, more than any other, affects the performance and utility of the battery charger. Battery voltage has a large impact on attainable battery charger efficiency as well as the opportunities for efficiency improvement.

ENERGY STAR also created product classes for battery charging sy stems based on the voltage of the batteries or battery packs th at they charge. The EN ERGY STAR specification contains 20 product classes, divided into increments of 1.2 vo lts, starting at 1.2 volts to greater

3-19than 24 volts. ENERGY STAR does not disti nguish between battery charging systems by charging method, charge rate, battery capacity, or battery chemistry.

Although manufacturers cannot easi ly exchange a fast charge r for a slow one without significantly affecting consumer utility (i.e., slower charge time provides less utility), the same cannot be said of exchanging a sl ow charger for a fast one. In fact, exchanging a slow charger that uses a line-frequency power supply for a fa st charger with a switched-mode power supply was a technology option manufacturer s identified duri ng interviews.

Additionally, class divisions based on battery voltage permitted DOE to analyze the different technological paths to energy efficiency improvement in the major categories of BCs for consumer products. Table 3. 2 shows these product classes.

Table 3.2 BC Product Classes Developed for the Draft Determination Analysis

0 V through 3 V A >3 V through 9 V B >9 V through 48 V C

3.7 Energy Efficiency Metrics

3.7.1 Using Energy Efficiency Metrics An evaluation of the effectiveness of technol ogy options for efficiency improvement and the tradeoffs among them depends heavily on the m easures used for quantification. This section presents a brief discussion of the test procedures DOE used to measure the energy consumption of BCs and EPSs, and any issues related to th e test procedures that may affect the energy conservation standards rulemaking.

Within this document, the term “energy consum ption” is used loosel y to refer to power dissipation or power consumption by BCs and EP Ss in one of several modes. Likewise, “efficiency” can mean EPS active-mode efficien cy or BC energy ratio, both discussed in the following sections. More generally, “efficiency” can also refer to the en ergy consumption of a BC or EPS against that of comparable devices in any of their modes.

3.7.2 Energy Efficiency Metrics for External Power Supplies On December 8, 2006, DOE codifi ed a test procedure final rule for EPSs in appendix Z to subpart B of 10 CFR part 430 (“Uniform Test Me thod for Measuring the Energy Consumption of External Power Supplies.”) DOE’s test proced ure, based on the U.S. Environmental Protection Agency’s (EPA) ENERGY STAR EPS test procedur e, measures active-mode efficiency and noload-mode (standby-mode) power consumption.

Active mode conversion efficiency is the ratio of output power to input po wer. DOE averages the efficiency at four loading conditions—25, 50, 75, and 100 percent of maximum rated output current—to assess the performance of an EPS when powering diverse loads. DOE also measures

3-20the power consumption of the EPS when discon nected from the consumer product, which is termed no-load power consumption. DOE combines both of the above metrics into “matched pairs” that describe the candida te standard levels (CSLs) used in setting potential energy conservation standards. This “matched pairs” comb ination affected the analysis and is discussed further in chapter 5, Engineering Analysis.

3.7.3 Energy Efficiency Metrics for Battery Chargers On December 8, 2006, DOE adopted a test me thod to measure the efficiency of battery chargers. 71 FR at 71340. This test met hod, based on the EPA ENERGY STAR “Test Methodology for Determining the Energy Performan ce of Battery Charging Systems,” integrates the power consumed by BCs in maintenance and no-battery modes over fixed periods of time. This “nonactive energy” is divided by the battery energy, measured at a discharge rate of 0.2 C, resulting in an energy ratio. Normalizing by batte ry energy is meant to account for proportionally higher losses in chargers intended for higher en ergy batteries. A higher en ergy ratio represents higher nonactive power dissipati on in the BC – i.e., a less e fficient battery charger.

3.8 Technology Options for Efficiency Improvement

3.8.1 EPS Technology Options

DOE considered seven technology options fo r the determination analysis that may improve the efficiency of EPSs:

• Improved Transformers. In line-frequency EPSs, the tran sformer has the largest effect on efficiency. Transformer efficiency can be improved by replacing their cores and windings with ones made of lower-loss mate rial or adding extr a material. Section 3.8.3 elaborates on transformers further.

• Switched-Mode Power Supply . Line-frequency EPSs often use linear regulators to maintain a constant output voltage. By using a switched-m ode circuit architecture, a designer can limit both losses a ssociated with the transfor mer and the regulator. The differences between the two EPS types are discussed in section 3.4.4 and section 3.4.5.

• Low-Power Integrated Circuits. The efficiency of the E PS can be further improved by substituting low-power IC controllers to drive the switching transistor, which can switch more efficiently in active mode and reduce power consumption in no-load mode. For instance, the IC can turn off its start-up current (sourced from the primary side of the power supply) once the output vol tage is stable. This increases conversion efficiency and decreases no-load power cons umption. In addition, when in no-load mode, the IC can turn off the switching transistor for extended periods of time (termed "cycle-skipping").

• Schottky Diodes and Sync hronous Rectification . Both line-frequency and switchedmode EPSs use diodes to rectify output voltage. Schottky diod es and synchronous rectification can replace standard diodes to reduce rectification losses, which are

3-21increasingly significant at lo w output voltage. Section 3.8.4 elaborates on rectification further.

• Low-Loss Transistors . The switching transistor dissipa tes energy due to its drain-to

source resistance (R DS_ON ) when the current flows th rough the transistor to the transformer. Using transistors with low R DS_ON can reduce this loss.

• Resonant Switching. In addition to reducing the R DS_ON of the transistor, power consumption can be lowered further by th e IC controller decreasing switching transients through zero-voltage or zero-cu rrent switching. The power consumption of the transistor is influenced by the voltage across the R DS_ON and the current flowing through it. An IC can control the switchi ng to minimize that voltage or current, although some components in addition to the IC may also be needed.

• Resonant ("Lossless") Snubbers . In switched-mode EPSs, a common snubber protects the switching transistor from the high voltage spike that occurs after the transistor turns off by dissipating that power as heat . A resonant or lossl ess snubber recycles that energy rather than dissipating it.

3.8.2 BC Technology Options These EPS technology options can also bene fit BCs. Following is a list of four preliminary technology options that DOE studied for the determina tion analysis that apply to BCs in particular.

• Termination . Substantially decreasing the charge current to the battery after it has reached full charge, either by using a tim er or sensor, can significantly decrease maintenance-mode power consumption. Most fast chargers use this technology option, but many slow chargers do not. Because most slow chargers have a charge rate of approximately 0.1 C and maintenanc e-mode current below 0.05 C is typically sufficient to keep a battery fully charged, a slow charger that em ploys termination can roughly halve its maintenance-mode power consumption.

• Elimination/Limitation of Maintenance Current . Constant maintena nce current is not required to keep a battery fully charged. Instead, the BC can provi de current pulses to "top off" the battery as needed. Elimination or limitation of maintenance can decrease maintenance-mode power consumption even further and has the added benefit of extending the battery lifetime by reducing overcharge.

• Elimination of No-Load Current . A mechanical AC line switch inside the battery charger "cup" automatically disconnects the BC from the mains supply when the battery is remove d from the charger. Although manual ( i.e. , user-controlled) switches are also possible, this method guarantees that the BC ceases to consume power once the battery is removed from the battery charger.

• Phase Control to Limit Input Power . Even when a typical BC is not delivering its maximum output current to the battery, its power conversion circ uitry continues to draw significant power. A phase control circuit, like the on e present in most common

3-22light dimmers, can be added to the primar y side of the BC powe r supply circuitry to limit input current in lower- power modes. This technol ogy option is particularly applicable to fast chargers that have high maximu m output current.

3.8.3 Transformers
For line-frequency BCs and EPSs, the largest loss es are in the transformer, particularly at light loads. The most effective means to reduce tran sformer power loss at light loads is to select a transformer with higher quality core material and a lower level of magnetic induction. At line frequency, the transformer core material typically is thinly laminated steel alloyed with silicon. The amount of silicon affects the core power lo ss and the cost of the transformer. Core performance is enhanced by magneti cally orienting the grain struct ure in the metal. The industry standard for common non-oriented grain-structure core material ra tings range from M19 to M45, with the lower number having fewer el ectrical losses. M6 co re steel is used in an energy efficient EPS transformer because it is a high-quality grain-or iented core steel that has very low electrical losses.
The second important factor cont ributing to core loss is the level of magnetic induction. Core losses are measured in watts per pound (W/lb) , and induction is give n in kilogauss (kG). Induction levels in these devi ces typically range between 10 kG and 15 kG. Reducing the induction level will reduce the core losses, but increase the winding losses. Reducing the induction requires more wire turns and therefore a larger core for a gi ven power rating. The trade-off of these improvements is the increas ed size and weight of the transformer, and ultimately the EPS. Table 3.3 shows the effects of material type and induction on core loss. Power loss in the transformer core can be redu ced by an order of magn itude by increasing the quality of the core steel and re ducing the level of magnetic inductio n: 0.28 W/lb versus 3.1 W/lb.

Table 3.3 Quality of Core Steel a nd Level of Magnetic Induction

Steel Core Losses at Various Levels of Magnetic Induction

10 kG 12 kG 15 kG

M6 0.28 W/lb 0.40 W/lb 0.60 W/lb

M19 0.85 W/lb 1.2 W/lb 2.0 W/lb

M45 1.4 W/lb 1.9 W/lb 3.1 W/lb

Additionally, some primary tran sformer windings have high resi stance to prevent failure in the case of overload conditions. Using a separa te fuse or thermal cutout to prevent failure would allow the transformer to have a lower wind ing resistance, thus reducing electrical losses.
A large potential source of energy loss in a high-frequency EPS is the flyback choke, similar to the transformer in line-frequency E PSs. Methods of improving the energy efficiency of

3-23chokes are similar to those for improving transformers, that is, improving the core material and increasing the amount of coppe r to reduce copper losses.
Particularly, for EPSs with output power greater than 10 W, a switched-mode power supply is generally a more effici ent alternative to a line-frequency. At lower wattages, however, neither regulation technology has a clear efficiency advantage. This is partly because the switching regulator circ uit components themselves consume some energy, regardless of the output power of the device. At lower wattages, this fixed energy c onsumption is a more significant proportion of tota l EPS energy consumption.

3.8.4 Diode Losses and Synchronous Rectification

Diodes are another source of loss for DC lin e-frequency EPSs. These losses increase as the output voltage decreases, and become par ticularly significant below 12 V. The power consumed by a diode is the product of the current flowing through the diode multiplied by the voltage drop across it. When a line-frequency E PS is designed for low-output voltage, that drop becomes a significant portion of the overall losses in the EPS. Using Schottky diodes c reduces the voltage drop across the diode s, thus improving efficiency . Conventional diodes have a voltage drop of about 0.6 V, which can be re duced to about 0.3 V to 0.4 V by using Schottky diodes.
Synchronous rectification offers even lower losses by replacing diodes with transistors. In this situation, the transistor mimics the rectific ation effect of the diode . However, the loss across the source-to-drain resistance of the transistor is much lower than that of a diode. Typically,synchronous rectification replaces diodes on the secondary side of the transformer in switchedmode EPSs because that is where it offers the most energy savings.

c A Schottky diode is a metal-semiconductor diode with a sm aller voltage drop than a conventional diode, therefore consumes less power.

3-24CHAPTER 4. SCREENING ANALYSIS

4.1 Introduction

............................................................................................................... ... 4-2 4.2 Technology Options for Improvi ng BC and EPS Efficiency

....................................... 4-2 4.3 Design Options Not Screened Out of the Analysis

...................................................... 4-3 4.3.1 Improved Transformer Cores

............................................................................... 4-3 4.3.2 Improved Transformer Windings

........................................................................ 4-3 4.3.3 Switched-Mode Power Supply Architecture

....................................................... 4-4 4.3.4 Low-Power Integrated Circuit Controllers

.......................................................... 4-4 4.3.5 Schottky Rectifier Diodes

.................................................................................... 4-4 4.3.6 Synchronous Rectification

................................................................................... 4-5 4.3.7 Low-Loss Transistors

........................................................................................... 4-5 4.3.8 Resonant Switching

............................................................................................. 4-5 4.3.9 Resonant Snubbers

............................................................................................... 4-6 4.3.10 Termination

.......................................................................................................... 4-6 4.3.11 Elimination or Limitation of Maintenance Current

............................................. 4-6 4.3.12 Elimination of No-Battery Current

...................................................................... 4-7 4.3.13 Phase Control to Limit Input Power

.................................................................... 4-7 4.4 Conclusion

................................................................................................................. .. 4-7

LIST OF TABLES

Table 4.1. Technology Options for Impr oving BC and EPS Efficiency

..................................... 4-3

4-14.1 Introduction
The purpose of the screening analysis is to identify and eliminate any technology options that DOE will not consider in the rulemaking fo r BCs and EPSs. For the determination analysis, DOE began with the technology opt ions presented in the technology assessment (chapter 3), which were developed following consultations with industry, technical experts, and other interested parties, and by revi ewing the available literature. Before considering the technology options in the engineering analysis (chapter 5), DOE reviewed each technology option or best available technology in light of th e following four criteria, as adap ted from sections 4(a)(4) and 5(b) of the Process Rule 1 :

1. Technological feasibility. DOE will not consider technologies that are not incorporated in commercially available products or working prototypes.

2. Practicability to manufacture, install, a nd service. If DOE determines that mass production of a technology in commercial products and reliable installation and servicing of the technology could not be achieved on th e scale necessary to serve the relevant market by the time of the effective date of the standard, it will not consider that technology further.

3. Adverse impacts on product or equipment utility or availabilit y. If DOE determines that a technology has significant adverse impact on the utility of the product to significant subgroups of consumers, or results in the unava ilability of any covered product type with performance characteristics (including reliability), features, size, capacities, and volumes that are substantially the same as products gene rally available in the United States at the time of the rulemaking, it will not co nsider that technology further.

4. Adverse impacts on health or safety. If DOE determines that a technology will have significant adverse impacts on health or sa fety, it will not consider that technology further.

This chapter discusses all the technology options DOE considered for improving the energy efficiency of BCs and EPSs, and descri bes how DOE applied th e screening criteria. Technology options that were not screened out through this pr ocess were termed “design options” and became instrumental to the deve lopment of cost-efficiency curves in the engineering analysis.

4.2 Technology Options for Improvi ng BC and EPS Efficiency
The technology options for improving BC and EPS efficiency, previously identified in chapter 3, are listed again in Ta ble 4.1 for convenience. As note d in chapter 3, BCs contain a power supply, either external or internal, for converting high-voltage AC wall current to lowvoltage DC, necessary for charging the batter y. Therefore, because many of the technology options are general improvements to power supply efficiency, they are applicable to both BCs and EPSs.

1 10 CFR part 430, subpart C, appendix A.

4-2Table 4.1. Technology Options for Improving BC and EPS Efficiency

Technology Option Area of Improvement Applicability (BC or EPS) Improved Transformer Cores Improved Transformer Windings Switched-Mode Power Supply Architecture Low-Power Integrated Circuit (IC) Controllers Schottky Diode Rectifiers Synchronous Rectification Low-Loss Transistors Resonant Switching Resonant Snubbers Charge Termination Elimination or Limitation of Maintenance Current Elimination of No-Battery Current Primary-Side Phase Control Magnetization Losses

Conduction Losses

General

General

Rectification Losses Rectification Losses Switching Losses Switching Losses Switching Losses Non-Active BC Losses

Non-Active BC Losses

Non-Active BC Losses

Non-Active BC Losses BC, EPS
BC, EPS

BC, EPS

BC, EPS
BC, EPS BC, EPS BC, EPS BC, EPS BC, EPS BC

BC

BC

BC

4.3 Design Options Not Screened Out of the Analysis
In the subsections that follow, these tec hnology options are evalua ted as design options based on the four screen ing analysis criteria.

4.3.1 Improved Transformer Cores

In line-frequency power supplies, whether fo r BC or EPS applications, the transformer has the largest effect on efficiency. Even in sw itched-mode power supplies, gains in efficiency can be made by improving the core of the high- frequency choke, a component with a similar structure and function as the transformer. In either case, DOE found that efficiency can be improved by replacing cores with ones made of lower-loss material.

DOE did not screen out improved cores as a means of improving efficiency. Because this design technique is in commercial use today, DOE considered this technology option to be both technologically feasible and practicable to manufac ture, install, and service. DOE considered but is not aware of any adverse impacts on consumer utility or reliability associated with improved cores. Similarly, DOE is not aware of any advers e impacts on health or safety that might be associated with improved cores.

4.3.2 Improved Transformer Windings Besides the core, a transformer or choke also consists of windings. These are typically composed of long lengths of thin copper wire , which contribute signi ficant resistance. As explained in chapter 3, increasi ng the thickness of the wire is one method of decreasing the losses due to winding resistance.

4-3DOE did not screen out improved windings as a means of improving efficiency. Designers routinely vary winding resistance to meet specifications. Because this design technique is in commercial us e today, DOE considered this technology option to be both technologically feasible and practicable to manufac ture, install, and service. DOE considered but is not aware of any adverse impacts on consumer utility or reliability associated with improved windings. Similarly, DOE is not aware of any advers e impacts on health or safety that might be associated with improved windings.

4.3.3 Switched-Mode Power Supply Architecture Despite improvements that can be made to line-frequency designs, the topology is fundamentally limited in efficiency. By redesi gning the power supply to use a switched-mode circuit architecture, a designer can limit losses associated with both the transformer and the linear regulator that is typically used in line-frequency designs.

DOE did not screen out switched-mode architect ures as a means of improving efficiency. Despite the fact that a switched-mode architectu re represents a complete redesign of the power supply, it is becoming increasingly common even in lower-power applications, where its smaller size promotes mobility. Because this design t echnique is in commercial use today, DOE considered this technology option to be both technologically feasible and practicable to manufacture, install, and service. Although DOE received input during the determination analysis about some applications whose usabilit y was affected by lower ou tput current limits and lesser electromagnetic compatibility of switched- mode EPS designs, DOE does not regard these as insurmountable obstacles to the adoption a nd commercialization of th is technology option. DOE is not aware of any adverse impacts on health or safety that might be associated with a change to switched-mode architecture.

4.3.4 Low-Power Integrated Circuit Controllers The efficiency of the EPS can be furt her improved by substituting in low-power integrated circuit (IC) controller s, which can switch more efficiently in active mode and reduce power consumption in no-load mode.

DOE did not screen out low-power IC controll ers as a means of improving efficiency. IC manufacturers offer numerous lo w-power controllers for use in BCs and EPSs, and many designs already incorporate these compone nts. Because it is in commercial use today, DOE considered this technology option to be both technologically feasible and practicable to manufacture, install, and service. DOE considered but is not aware of any adverse impacts on consumer utility or reliability associated with low-power controlle rs. Similarly, DOE is not aware of any adverse impacts on health or safety that might be associated with low-power IC controllers.

4.3.5 Schottky Rectifier Diodes Except for limited applications that requi re an AC output, both line-frequency and switched-mode power supplies use r ectifier diodes to convert the AC output of the transformer to DC, usable by the application. Schottky diodes, which have lower voltage drops, can replace standard p-n junction diodes to reduce rectification losses, whic h become increasingly significant at lower output voltages.

4-4DOE did not screen out Schottky diodes as a means of improving efficiency. These devices are commonly used in BCs and EPSs w ith lower output voltages. Because it is in commercial use today, DOE considered this technology option to be both technologically feasible and practicable to manufact ure, install, and service. DOE considered but is not aware of any adverse impacts on consumer utility or reliab ility associated with Schottky diodes. Similarly, DOE is not aware of any adverse impacts on health or safety that might be associated with Schottky diodes.

4.3.6 Synchronous Rectification. Synchronous rectification, only used in switched-mode power supplies, further reduces losses by substituting transistors for the rectifying diodes. The voltage drop across a transistor is much lower than that across even a Schottky diode, leading to lower losses in the output rectifier.

DOE did not screen out sync hronous rectification as a m eans of improving efficiency. Despite its high cost and complexity of implem entation, synchronous rectification is available today and is used in EPSs when the application merits it. Because it is in commercial use today, DOE considered this technology option to be both technologically feasible and practicable to manufacture, install, and service. DOE consider ed but is not aware of any adverse impacts on consumer utility or reliability associated with synchronous rectificati on. Similarly, DOE is not aware of any adverse impacts on health or safe ty that might be associated with synchronous rectification.

4.3.7 Low-Loss Transistors The transistor in a switched-mode power suppl y dissipates energy because of its drain-to

source resistance (R DS_ON ) when the current flows through the transistor to the transformer. Using transistors with low R DS_ON can reduce this loss.

DOE did not screen out low-loss transist ors as a means of improving efficiency. Switching transistors continually improve, providing options for increasing efficiency with little added design complexity. Because it is in commercial use today, DOE considered this technology option to be both technol ogically feasible and practicable to manufacture, install, and service. DOE considered but is not aware of any adverse impacts on consumer utility or reliability associated with low-loss transistor s. Similarly, DOE is not aware of any adverse impacts on health or safety that might be associated with low-loss transistors.

4.3.8 Resonant Switching In addition to reducing the R DS_ON of the transistor, power consumption can be lowered further by the IC controller decr easing switching transien ts through zero-voltage or zero-current switching, which greatly limits losses due to switching transients in the transistor.

DOE did not screen out resonant switching as a means of improving efficiency. Resonant switching does involve some additional circ uit complexity, but is a common method of increasing efficiency. Because it is in commerc ial use today, DOE considered this technology option to be both technologically feasible and practicable to manufacture, install, and service. DOE considered but is not aware of any advers e impacts on consumer utility or reliability

4-5associated with resonant switching. Similarly, DOE is not aware of any adverse impacts on health or safety that might be a ssociated with resonant switching.

4.3.9 Resonant Snubbers In switched-mode EPSs, a snubbe r protects the switching transi stor from the high voltage spike that occurs after the transistor turns off. Whereas a conventional snubber dissipates the energy in the voltage spike as heat , a resonant or lossless snubber re cycles that energy, leading to lower losses.

DOE did not screen out resonant snubbers as a means of improving efficiency. As with resonant switching, resonant snubbers involve some additional circuit complexity, but are a common method of increasing efficiency. B ecause it is in commercial use today, DOE considered this technology option to be both technologically feasible and practicable to manufacture, install, and service. DOE consider ed but is not aware of any adverse impacts on consumer utility or reliability associated with resonant snubbers. Similarly, DOE is not aware of any adverse impacts on health or safety that might be associated with resonant snubbers.

4.3.10 Termination Substantially decreasing the charge current de livered by the BC to the battery after it has reached full charge, either by using a timer orsensor, can significantly decrease maintenancemode power consumption. Whereas fast chargers already universally employ this technology option for safety reasons, many slow chargers do not, and wider popularity could lead to increased energy savings.

DOE did not screen out termination as a means of improving efficiency. While termination may require redesign an d significant circuit cost in th e case of slow chargers, it is already universal in fast charge rs. Because it is in commercial use today, DOE considered this technology option to be both technol ogically feasible and practicable to manufacture, install, and service. DOE considered but is not aware of any adverse impacts on consumer utility or reliability associated with termination. Similarl y, DOE is not aware of any adverse impacts on health or safety that might be associated with termination.

4.3.11 Elimination or Limitation of Maintenance Current
Constant maintenance current is not required to keep a batt ery fully charged. Instead, the BC can provide current pulses to "top off" the battery as needed. Elim ination or limitation of maintenance can further decrease ma intenance-mode power consumption.

DOE did not screen out elimination or limita tion of maintenance current as a means of improving efficiency. While this technology may add some circuit complexity in the form of timers or sensors, DOE did not consider th e added design difficulty insurmountable. Unlike many of the other technologies, elimination or limitation of maintenance current is not widespread today, but several manufacturers ha ve suggested it as an option for further eliminating maintenance current. Because manufact urers familiar with the intricacies of BC design identified this technology, DOE considered it to be both technologically feasible and practicable to manufacture, instal l, and service. DOE considered but is not aware of any adverse impacts on consumer utility or reliability asso ciated with limitation of maintenance-mode

4-6current, and in some applications complete elimin ation of the current may be possible. Similarly, DOE is not aware of any adverse impacts on health or safety that might be associated with the elimination or limitation of maintenance-mode current.

4.3.12 Elimination of No-Battery Current
A mechanical AC line switch inside the char ger "cup," or charging base, automatically disconnects the BC from the mains supply when the battery is removed from the charger, thereby eliminating no-battery power consumption without incurring energy consumption penalties in any of the other modes.

DOE did not screen out elimination of no- battery current as a means of improving efficiency. Although AC line switches are not in widespread use today, the fundamentals of this technology option are simple and DOE considered it to be both technologically feasible and practicable to manufacture, inst all, and service. DOE consider ed, but was not aware of any adverse impacts on consumer util ity or reliability associated with elimination of no-battery current. Similarly, DOE was not aware of any advers e impacts on health or safety that might be associated with elimination of no-battery current.

4.3.13 Phase Control to Limit Input Power Even when a typical BC is not delivering its maximum output current to the battery, its power conversion circuitry continues to draw sign ificant power. A phase cont rol circuit, like the one present in most common light dimmers, can be added to the primary side of the BC power supply circuitry to limit input cu rrent in lower-power modes.

DOE did not screen out phase control as a m eans of improving efficiency. Similar to AC line switches, this technology option is not in wi despread use today, but it is well understood and common in other applications outs ide of BCs and EPSs. DOE therefor e considered it to be both technologically feasible and practicable to manufac ture, install, and service. DOE considered but is not aware of any adverse impacts on consumer u tility or reliability asso ciated with elimination of no-battery current. Similarly, DOE is not aware of any adverse impacts on health or safety that might be associated with elim ination of no-battery current.

4.4 Conclusion
Because all of the technology options summari zed in Table 4.1 met the four screening criteria, none were eliminated in the screeni ng analysis. DOE therefore evaluated all of the technology options as design options in the e ngineering analysis de scribed in chapter 5.

4-7CHAPTER 5. ENGINEERING ANALYSIS

5.1 Introduction

............................................................................................................... .... 5-4

5.2 Selection of Representative Product Classes and Representative Units

....................... 5-5 5.2.1 BC Representative Product Classe s and Representative Units

............................ 5-5 5.2.2 EPS Representative Product Classes

................................................................... 5-6 5.2.3 EPS Representative Units

.................................................................................... 5-7

5.3 Selection of Candidate Standard Levels

....................................................................... 5-8 5.3.1 BC Candidate Standard Levels

............................................................................ 5-9 5.3.2 EPS Candidate Standard Levels

......................................................................... 5-10

5.4 Manufacturer Interviews

............................................................................................. 5-12 5.4.1 BC Manufacturer Interview Overview

.............................................................. 5-13 5.4.2 BC Manufacturer Interview Responses and Preferred Design Options

............. 5-14 5.4.3 BC Manufacturer Interview Data Analysis

........................................................ 5-16 5.4.4 Supplements to BC Manufacturer Interview Data

............................................. 5-17 5.4.5 Scaling of BC Manufacturer Interview Data to Representative Units

............... 5-19 5.4.6 BC Manufacturer Markups

................................................................................ 5-21 5.4.7 EPS Manufacturer Interview Overview

............................................................. 5-22 5.4.8 EPS Manufacturer Interview Responses and Preferred Design Options

........... 5-22 5.4.9 Scaling of EPS Manufacturer Interview Da ta to Representative Unit Volume. 5-24 5.4.10 Scaling of EPS Manufacturer Interview Da ta to Representative Unit Power

... 5-25 5.4.11 Scaling of EPS Manufacturer Interview Da ta to Representative Unit Voltage. 5-28 5.4.12 EPS Manufacturer Markups

............................................................................... 5-29

5.5 Efficiency Testing and Teardowns

............................................................................. 5-30 5.5.1 BC Testing

......................................................................................................... 5-30 5.5.2 BC Teardowns

................................................................................................... 5-32 5.5.3 EPS Testing

........................................................................................................ 5-34 5.5.4 EPS Teardown Methodology

............................................................................. 5-37 5.5.5 EPS Teardown Results

....................................................................................... 5-37

5.6 Conclusion

................................................................................................................. . 5-43 APPENDIX 5.A Battery Charger Cost-Efficiency Estimation Survey

.............................. 5-44 APPENDIX 5.B EPS Cost-Efficiency Estimation Survey

................................................. 5-51 APPENDIX 5.C Example BC Teardown Analysis Report

................................................ 5-57

5-1LIST OF FIGURES

Figure 5.1 Comparison of Active Mode Efficien cy and No-Load Power; Arrows Point in Direction of Increased Efficiency

........................................................................... 5-11 Figure 5.2 Relationship Between BC Wall-Adapter No-Load Power and System No-Battery and Maintenance Power

................................................................................................ 5-19 Figure 5.3 Full Cost of Product: Breakdown of Production and Non-Production Costs

........... 5-21 Figure 5.5 Markup Chain Diagram for Battery Chargers

.......................................................... 5-22 Figure 5.6. Schematic Illustration of the Distri bution of Efficiency Versus Maximum Rated Output Power; the ENERGY STAR Level Is Shown as a Pink Line, while the Blue Background Indicates Where Most of the Units Lie

.............................................. 5-26

Figure 5.8. ENERGY STAR Level and Calculated Be st-in-Market and Wors t-in-Market Curves5-27

Figure 5.11 DOE Battery Charger Test Data Supe rimposed over CEC Data gathered by Ecos Figure 5.7. Schematic Illustration of Scaling EPS Efficiency with Output Power

.................... 5-27

Figure 5.9 Relationship Between Out put Voltage and Efficiency

............................................. 5-29 Figure 5.10 DOE Battery Charger Test Result s by Consumer Product Application

................. 5-31

Consulting

............................................................................................................... 5-32 Figure 5.12 Low-Volume Cost Versus Efficiency for Tested and Torn-Down Battery Chargers5-33 Figure 5.13 Illustration of Units in Product Class A Selected for Ph ase 2 Testing and Teardowns5-36 Figure 5.14 Illustration of Units in Product Class B Selected for Ph ase 2 Testing and Teardowns5-36 Figure 5.15 Illustration of Units in Product Class F Selected for Ph ase 2 Testing and Teardowns5-37

Figure 5.19 Average Efficiency and No-Load Po wer Consumption of 5-Watt EPSs with BOM Figure 5.16 BOM Cost versus Average Efficiency of 5-Watt Units

......................................... 5-38 Figure 5.17 BOM Cost vs. No-Load Power of 5-Watt Units

.................................................... 5-39 Figure 5.18 BOM Cost and Efficiency of 5-Watt EPS Units

.................................................... 5-40

Costs; Increasingly Stringent CSLs Are Re presented by Darker Shades of Blue

.. 5-40 Figure 5.20 BOM Cost vs. Average E fficiency of 60-Watt Units

............................................. 5-41 Figure 5.21 BOM Cost versus No-Load Power of 60-Watt Units

............................................. 5-42 Figure 5.22 BOM Cost and Efficiency of 60-Watt EPS Units

.................................................. 5-42 Figure 5.23 Average Efficiency and No-Load Po wer Consumption of 60-Watt EPSs with BOM Costs; the Increasing CSLs Are Repres ented by Darker Shades of Blue

............... 5-43

LIST OF TABLES

Table 5.1 Representative Unit Characte ristics for Battery Chargers

........................................... 5-5 Table 5.2 Additional Characteristic s of BC Representative Units

.............................................. 5-6 Table 5.3 Representative Product Classes Used in the EPS Determination Analysis

................. 5-6 Table 5.4 External Power Supply Repres entative Unit Characteristics

....................................... 5-7 Table 5.5 Additional Characteristics of EPS Representative Units

............................................. 5-8 Table 5.6 BC Candidate Standard Levels by Representative Unit

............................................ 5-10 Table 5.7 EPS Candidate Standard Le vels by Representative Unit

........................................... 5-12 Table 5.8 Maintenance and No-Battery Mode Powe r Consumption Levels Used in Manufacturer Interviews

............................................................................................................... 5-14

5-2Table 5.9 Product Class-Average BC Wall Adapter No-Load Power Consumption

................ 5-18 Table 5.10 Average Calculated BC Performance Used to Supplement Manufacturer Data

..... 5-19 Table 5.11 Typical Markups and Add-Ons fo r Each BC Representative Unit

.......................... 5-22 Table 5.12 Unit Volumes and Volume Discount Rate s for Each EPS Representative Unit

..... 5-24 Table 5.13 Volume Prices Used to Calculat e Average per-Decade Discount Rate

................... 5-25 Table 5.14 Manufacturer Markups Used in the EPS Engineering Analysis

.............................. 5-30 Table 5.15 Phase One Units Purchase d and Their Characteristics

............................................ 5-35 Table 5.16 Phase One Units Torn Down

................................................................................... 5-38

5-35.1 Introduction The purpose of the engineering analysis is to determine the relationship between a power converter’s efficiency and its manufacturer selling price (MSP). 1 This relationship serves as the basis for the underlying costs and benefits to i ndividual consumers (chapter 8, life-cycle cost analysis) and the nation (chapter 10, national impact analysis). The output of the engineering analysis provides the MSP at selected, discrete le vels of efficiency for several “representative” BCs and EPSs. The levels are term ed candidate standard levels (C SLs). This chapter details the development of this portion of the rescheduled determination analysis, which DOE conducted in 2007, and includes descriptions of the analysis structure, inputs, and some draft outputs for stakeholder review and comment.

Representative product classes and units a llow DOE to focus on a few specific power converters and expand that knowledge to all units . Thus, DOE began the e ngineering analysis by identifying the representative product classes and selecting one representa tive unit for analysis from each of the representative product classes. The representative product classes, a subset of the product classes identified in chapter 3, contain the majority of the covered devices available in the market. The representative units, in tur n, are idealized models of the most popular or typical devices within th e representative product classes. Repr esentative units are defined partly by specifications on output power and/or voltage.

During the determination analysis, DOE pr esumed that findings relating to the representative unit would be applic able to all the units in the produc t class. Later, in the national impact analysis (NIA), DOE scaled the analytic al findings for each representative unit to other units in the same representative product class, and from the representa tive product classes to other product classes that DOE di d not explicitly analyze. See section 5.2 for a description of representative product classes and units used in the determination analysis.

Although the efficiency of power converters in the market forms an almost continuous spectrum, DOE focused its analysis at several di screte CSLs (described in section 5.3). In the engineering analysis, DOE examined the cost of meeting each CSL for each representative unit. The resulting relationship, which followed a path of increasing cost with increasing efficiency, was termed an “engineering curve” or “cost-efficiency curve.”

The analysis began with th e baseline CSL, which models the most common, cheapest, least-efficient devices in a product class, and ended with the maximum technologically feasible (“max-tech”) CSL, which is typically the most expensive. To construct engineering curves for the determination analysis conducted in 2007, DOE relied on manufacturer interviews as its primary source of data, structuring the collect ion of this data ar ound the interview guide presented in appendix 5.A.

In its interviews, DOE asked manufacturers to speculate on the co sts of improving each representative unit from the baseline CSL to the maximum technologically feasible CSL. DOE also asked manufacturers to desc ribe the markups they would be likely to apply to the cost of

1 This is the price that a power conve rter manufacturer charges original equipment manufacturers, distributors, and/or retailers. The MSP forms the basis for the price consumers eventually pay.

5-4production, resulting in a manuf acturer selling price to distributors, original equipment manufacturers (OEMs), or retail ers. For a detailed discussion of the interview process, see section 5.4. To validate the information provi ded by manufacturers, DOE performed its own testing and teardowns.

In addition to obtaining information through manufacturer interviews, DOE developed a range of possible costs of production, beginni ng with component costs. DOE then applied markups to arrive at an MSP. The process of evaluating the cost of a BC or EPS started with DOE conducting efficiency tests of commerc ially available BCs and EPSs, followed by teardowns, parts counts, and preparation of bills of materials (BOMs). DOE then scaled these BOM costs to account for the lower prices paid by manufacturers purchas ing at higher volumes.

Following the teardowns, and in cases when manufacturers provided BOM costs rather than MSPs, DOE applied typical manufacturer ma rkups to the resulting high-volume BOM cost to account for additional manufact urer costs not included in the BOM. The manufacturer markups included (1) a production markup, (2) an add-on for packaging and mechanical components, and (3) a non-production markup. The result of this markup chain was an MSP, which could be compared against the prices provided directly by manufact urers. Throughout this process, DOE consulted publicly ava ilable literature and datasets, which served as a third type of validation. For detailed discussion of te sting and teardowns , see section 5.5.

5.2 Selection of Representative Product Classes and Representative Units

5.2.1 BC Representative Product Classes and Representative Units

Each product class discussed in chapter 3 was represented by a unit that served as the focus of the analysis, except for product cla ss C, which was represented by two units. Although fast chargers exist in all three BC product classes, they are particul arly prevalent in high-voltage power-tool chargers, so DOE decided to split th e analysis of the high- voltage product class C by charge rate. Table 5.1 shows the characteristics of the represen tative units. DOE chose these units because they represent high-volume BCs within each of the BC product classes. The engineering analysis that DOE performed on each of these units served as the basis for subsequent analyses of the impacts of potentia l energy conservation standards on consumers and the Nation.

Table 5.1 Representative Unit Char acteristics for Battery Chargers

Product Class Battery Voltage Battery Capacity Charge Rate Typical Application
A 1.2 V 1.2 Ah 0.1 C Shaver
B 4.8 V 1.2 Ah 0.1 C Vacuum
C 18 V 1.5 Ah 0.15 C DIY* tool
C 18 V 2.4 Ah 1 C Pro tool
* Do-it-yourself (DIY) tools are typically purchased by non-professional users.

5-5The efficiency of BCs is affected by other parameters besides battery voltage, battery capacity, and charge rate. These other parameters include the length of the DC output cord (if one exists) and venting, among others. Again, to is olate the impacts of efficiency on cost, these parameters were fixed throughout the anal ysis to the values listed in Table 5.2.

Table 5.2 Additional Characteristics of BC Representative Units

Parameter Value Input Voltage Input Protection

Unit Volume

Packaging Cord Length Regulatory Compliance
Product Lifetime 115 volts rms, 60 Hz Primary current fuse

200,000 units/year
Sealed plastic
6 feet UL, FCC > 2 years

5.2.2 EPS Representative Product Classes

Initially, DOE divided EPSs into six product classes, presented in chapter 3. These classes were based on output power and voltage because of the impact these design parameters have on the efficiency of an EPS. Following further discussion with manufacturers, DOE narrowed its focus within the list of the six pr oduct classes to three representative product classes. While the six EPS product classes were based on output power and voltage, the three representative product classes, presented in Ta ble 5.3, were based solely on output power. DOE chose these representati ve product classes and criteria for di vision because manufacturers design “families” of EPSs with the same output power, but different output voltages. Therefore, for a given output power, low-voltage and high-voltage EPSs share th e same design, often differing only in the choice of component values. Because of this similarity in design, there is a functional relationship between the efficiency achievable by units of different out put voltage. Therefore, DOE did not perform a differential analysis of separate voltage-based representative product classes.

Table 5.3 Representative Product Classes Used in the EPS Determination Analysis

Nameplate Output Power
< 4 watts 4–60 watts > 60 watts
Product Class A B F

5-65.2.3 EPS Representative Units

For each of the three representative EPS product classes described in section 5.2.2, DOE identified a representative unit for evaluation in the engineering analysis. A representative unit is an idealized EPS that shares the design specifi cations of popular EPS in the product class. Using these idealized units allows DOE to vary the active mode efficiency and no-load current while holding all other parameters ( e.g. , nameplate output power, voltage , safety requirements, etc.)
constant.
The representative units for each of the th ree representative product classes discussed previously are listed in Table 5.4. These units model typical EPSs that ship with high-volume applications, such as laptop computers or video- game consoles, in the case of the 90-watt, 19­ volt representative unit for product class F. 2

Similarly, the other EPS repres entative units model typical nameplate output power and voltage combinations for other high-volume pr oducts. DOE chose the representative unit for product class A to represent a typical wall adap ter for a cellular telephone , the consumer product associated with the highest volume of EPS sale s. DOE chose product class B’s representative unit to be characteristic of mi d-power applications such as m odems or wireless routers.

Although DOE recognizes that laptop computer EPSs span a wide range of nameplate output powers and voltages, 90 watts is near the shipment-weighted average output power for the product class, while 19 volts is a common out put voltage. Similarly, the nameplate output powers and voltages of the other representative units are also typical, with the output powers falling near the shipment-weighted averages for each class.

Table 5.4 External Power Supply Rep resentative Unit Characteristics

Representative Product Class Output Power (W) Output Voltage (V) Typical Application
A
B
F 2.75 W
18 W
90 W 5 V
12 V
19 V Cellular Telephone
Modem Laptop Computer

In addition to output current and voltage, ma nufacturers and customers specify other EPS parameters to ensure safe compatibility of th e EPS design with the product it is meant to power. These other parameters, like output cord length, input protection, or transient response, can also have an impact on EPS efficiency and no-lo ad power. Therefore, when conducting the engineering analysis, DOE fixed th ese parameters to eliminate cer tain design options, such as a shorter output cord, that might negatively affect the usability or interoperability of the EPS.

2 The associated framework document includes a discussion of the BC and EPS definitions and how they would be applied to a battery powered product, such as a laptop co mputer, that uses an extern al wall adapter. For the determination analysis, DOE used the ENERGY STAR delin eation whereby wall adapters for electronic products such as laptop computers and cellular telephones were considered EPSs.

5-7A full list of EPS design parameters that DOE fixed for isolating the impacts of efficiency is presented in Table 5.5. In addition to the usability, safet y, and interoperability parameters already mentioned, the table also in cludes the yearly manufacturing volume at which cost information associated with efficiency im provements was obtained or calculated during the engineering analysis. A yearly manufacturing volume was also sp ecified to permit comparisons between data from different sour ces, and to isolate efficiency improvement as the only variable under analysis. This volume was 1,000,000 units/year for represen tative unit A (due to the popularity of cellular telephones) and 500,000 units/year for the ot her two representative units.

Table 5.5 Additional Characteristics of EPS Representative Units

Parameter Value Input Voltage

Input Protection

Output Voltage Regulation Output Voltage Ripple

Transient Response

Output Protection

Unit Volume

Application

Package Output Cord Length

Regulatory Compliance

Product Lifetime 115 volts rms, 60 Hz Primary current fuse, inrush current limiting ± 1% (excluding cord) 1% maximum (peak-to-peak)
0.5 ms for 50% load change typical Overcurrent protection, short-circuit protection 1 M/year for product class A 500 k/year for product classes B & F

Information technology/consumer electronics
Sealed polycarbonate
6 feet UL, FCC, PFC for P IN > 75 W > 2 years

5.3 Selection of Candidate Standard Levels

In the determination engineering analysis, se lection of CSLs followed the identification of representative product classes and representative units, desc ribed in section 5.2. Although the production cost and manufacturer se lling price of a unit would appear in the aggregate as a continuous function of efficiency, data for each point along the curve were not available, so DOE focused its analysis at discrete efficiency levels, or CSLs.

CSLs are generally based on (1) efficien cies achievable by commonly used design options, (2) voluntary guidelines or mandatory standards already in existence that have prompted

5-8manufacturers to develop products at particular efficiency levels, and (3) the max-tech level. 3 For example, DOE often considers the ENERGY STAR level as one CSL, while the least efficient models in a product class serve as the baseline CSL. Basi ng CSLs on established guidelines or standards increases the availabil ity of data because manufacturers may have already designed products to meet the CSL, a nd may therefore be able to provide cost information. Furthermore, products meeting th e CSL may exist in the marketplace and be available for testing and teardowns, fu rther strengthening the analysis.

However, even if CSLs are based on de sign options in units currently being manufactured, they should not be seen as technologically prescriptiv e. In other words, manufacturers are free to use any combination of design options to achieve the efficiency specified by a given CSL. To maintain this ap proach throughout the analysis, DOE specifically did not examine CSLs that could only be achieved through proprietary design options not available to all manufacturers.

5.3.1 BC Candidate Standard Levels

As described in chapter 3, the DOE test pr ocedure references the U.S. Environmental Protection Agency’s (EPA) ENERGY STAR “T est Methodology for Determining the Energy Performance of Battery Charging Systems,” whic h combines measurements of maintenance and no-battery mode power consumption into an integrated metric called the energy ratio. Manufacturers are free to trade off power consump tion in one mode versus the other to meet the energy ratio requirements imposed by each CSL. The CSLs DOE used in the BC determination analysis are presented in Table 5.6.

As the table shows, DOE did not analyze the cost-efficiency relationship at the max-tech CSL due to a lack of data. Instead, DOE increased the level of detail by analyzing data at efficiency levels between such established CS Ls as ENERGY STAR and baseline. Because DOE initially obtained data on a more limited set of CSLs, DOE calculated cost-efficiency data at these additional levels through interpolation.

3 The max-tech level represents the most efficient design that has been demonstrated in a prototype with materials or technologies available today. Max-tech is not constrai ned by economic justification, and typically is the most expensive design option considered in the engineering analysis.

5-9Table 5.6 BC Candidate Standard Levels by Representative Unit

CSL Energy Ratio Representative Product Class A 1.2 V, Slow Representative Product Class B 4.8 V, Slow Representative Product Class C 18 V, Slow Representative Product Class C 18 V, Fast 0

1

2

3

4 Baseline Above Baseline ENERGY

STAR Beyond Standard Best-in-Market

Technology 66.5

27.9

22.0

15.0

8.8 14.0

12.3

11.6

6.3

4.5 13.0

5.5

3.8

2.5

1.5 13.0

5.5

3.8

2.5

1.5

5.3.2 EPS Candidate Standard Levels

The CSLs in the determination analysis were specified in terms of DOE’s efficiency metrics for EPSs (active mode efficiency and no-load power) and BCs (energy ratio). Because both of the efficiency metrics output by the EPS te st procedure affect th e energy consumption of the unit, DOE developed CSLs that included “matched pairs” of limits on both metrics simultaneously.

Matched pairs allowed DOE to base CSLs on existing EPS standards, such as those developed by ENERGY STAR or the Californi a Energy Commission (CEC). As these CSL matched pairs progress from least to most efficien t, either the active mode efficiency or no-load power-consumption requirements, or both, increase in stringency. By preventing a decrease in the stringency of these metrics, DOE makes a tac it assumption that there is no trade-off between EPS performance in the two modes, and increasi ng the energy savings in one mode does not necessarily cause a de crease in energy savings in the other.

To verify this assumption, DOE analyzed the relationship between active mode efficiency and no-load power consumption for products curren tly in the market. Figur e 5.1 plots efficiency measurements conducted by DOE on EPSs with nameplate output power around 5 watts and 60 watts. The figure shows that EPSs with higher active mode efficiencies tend to also have lower no-load-mode power consumption. This is probably true only up to a point, however, and one can imagine cases in which an EPS manufact urer tries to minimize no-load power, but can only do so at the expense of lower active mode efficiency. Therefore, DOE based its matched pairs on those currently seen in the market . The CSLs followed—as much as possible—the efficiency metrics achieved by actual EPSs at representative-unit output powers and voltages. This ensured that for CSLs below max-tech, cu rrent EPSs would be able to meet both active mode and no-load-mode requirements.

5-100 0.5

1 1.5

2 2.5No-Load Power [W] 0–6 Watts Maximum Rated Output Power 40–66 Watts Maximum Rated Output Power

20% 30% 40% 50% 60% 70% 80% 90% 

### Average Efficiency [%]

Figure 5.1 Comparison of Active Mode Efficiency and No-Load Power; Arrows Point in Direction of Increased Efficiency

DOE evaluated the relationship between EPS co st and efficiency for each representative unit at seven CSLs:

• CSL 0: baseline line-frequency

• CSL 1: baseline switched-mode

• CSL 2: meeting CEC Tier 1

• CSL 3: meeting CEC Tier 2

• CSL 4: surpassing CEC Tier 2

• CSL 5: best in market

• CSL 6: maximum technologically feasible

In each case, the name of the CSL refers to the standard upon which the CSL is based, or indicates the types of EPSs that can generally meet the CSL. For example, switched-mode EPSs that contain conventional integrated circuit (IC) pulse-width modula tion (PWM) controllers without any specific provisions for efficiency are likely to meet CSL 1 (baseline switchedmode), but not CSL 2.

The active mode efficiency and no-load pow er requirements corresponding to each CSL are listed in Table 5.7. As can be seen, even t hough the names of the CSLs are the same for each representative unit, th ey correspond to different active mode efficiencies and no-load power consumptions. This is because of technol ogical and scaling differences between the representative units, highlighted in chapter 3. For example, the EPS design a conventional PWM controller (CSL 1) may only achieve 71% e fficiency and 1.5 watts of no-load power consumption at 18 watts and 12 volts, but it should be able to achieve 78% and 2 watts of noload power when redesigned for 90 watts and 19 volts. DOE did not analyze representative unit F at CSL 0 due to a lack of high-power E PSs that use a linear-regulated line-frequency design.

5-11Table 5.7 EPS Candidate Standard Le vels by Representative Unit

CSL Representative Unit A 2.75 W, 5 V Representative Unit B 18 W, 12 V Representative Unit F 90 W, 19 V Mini

mum Effici ency (%) Max. NoLoad Input Power (W) Minimum Efficiency (%) Max. NoLoad Input Power (W) Minimum Efficiency (%) Max. NoLoad Input Power (W) 0 30 2.00 66 2.00 n/a n/a 1 55 0.80 71 1.50 78 2.00 2 58 0.50 75 0.75 84 0.75 3 59 0.50 76 0.50 85 0.50 4 65 0.40 80 0.40 87 0.40 5 72 0.30 85 0.20 89 0.31 6 75 0.20 88 0.15 92 0.15

5.4 Manufacturer Interviews

DOE interviewed eight BC and eight EPS manuf acturers to obtain price estimates for representative units at the CSLs listed in Table 5.7 and Table 5.6. Following aggregation and validation, this price information was combined w ith efficiency data to form one of the key outputs of the engineering analysis.

The interviews were structured according to the manufacturer surveys presented in appendices 5.A and 5.B. In the course of the in terview, DOE contractor s asked manufacturers to provide the costs of reaching each CSL for each re presentative unit. Manu facturers listed the least expensive technology options that met the CSLs and their co sts, either as a BOM cost or the marked-up MSP.

Although manufacturers were initially asked abou t a more limited set of CSLs than those listed in Table 5.7 and Table 5.6, they provided additional information on the costs at other efficiency levels. Additional CSLs were develope d later by fitting curves to data obtained during the interviews and interpolating between the points. These CSLs enabled greater resolution in the downstream analyses.

A further caveat was that manufacturers so metimes provided data for products with parameters close to, but not the same as, th e representative units. This occurred when manufacturers had direct experi ence with a similar unit and coul d provide cost and efficiency data with greater confidence than for the ideal ized representative unit. In these cases, DOE scaled the data the manufacturer provided to align with the representa tive unit. Although DOE could have requested that the manufacturer perf orm the scaling from ma nufacturer-supplied unit to the representative unit, some manufacturers we re reluctant to make statements about BCs or EPSs they had designed. By performing the scali ng itself, DOE could also use a consistent and transparent method.

5-12For example, some manufacturers provided data on EPSs that were similar to the representative units in terms of capacity, functionality, and de sign, but had slightly different output power or output voltage. DOE then used typical relationships between power and efficiency or voltage and efficiency to adjust th e efficiency data so that it would apply to the representative unit. This normalization accounted for any differences in output power, output voltage, volume, and other characteristics, and permitted aggregation of all the manufacturers’ cost-efficiency data. Sections 0 and 5.4.9 pres ent the normalization methods for BCs and EPSs, respectively.

5.4.1 BC Manufacturer Interview Overview

Under non-disclosure agreements, DOE in terviewed representatives of several consumer-product firms that manufacture battery-powered products. Interviewers asked each representative to pr ovide information about technology options for increasing the energy efficiency of BCs that ship with their pr oducts. The following list shows the number of manufacturers that provided datafor each representative unit:

• representative product unit A (personal-care products): 3 manufacturers

• representative product unit B (small tools and floor care): 4 manufacturers

• representative product unit C (DIY power tools): 3 manufacturers

• representative product unit C (profess ional power tools): 3 manufacturers

Before each interview, each manufacturer received a Cost-Efficiency Estimation Survey (appendix 5.A) to guide their estimates. To ensu re consistency among manufacturers, the survey specified the parameters of each BC representati ve unit under consideratio n (Table 5.1 and Table 5.2). Although battery chemistry was not specifie d, most manufacturers provided information for nickel-based chemistries (NiMH and Ni-Cd). Although lithium chemistries have lower selfdischarge and may decrease maintenance current, DOE did not expect significant differences in BC energy consumption due to the increased safe ty and monitoring overhead associated with lithium batteries.

The interviewers asked manufacturers to describe the technological improvements for each representative unit and associated cost s necessary to meet each CSL (section 5.3.1). Although the CSLs for battery charge rs are specified in terms of energy ratio, the DOE metric of non-active energy consumption, the survey presen ted them as disaggregated maintenance and no-battery mode power consumption levels. 4 DOE decided to disagg regate the metrics after finding that manufacturers were more responsive to CSLs dir ectly specified in terms of maintenance and no-battery mode power consumption.

DOE recognizes that separating the inte grated energy ratio metric and asking manufacturers to meet two sepa rate power consumption levels instead of a CSL expressed in terms of a single metric risked over-constraining the manufacturers. Because DOE was in effect asking them to estimate the costs of meeting standards on power consum ption in two distinct

4 The energy ratio is calculated as the sum of maintenance mode power, integrated over 36 hours, and no-battery power, integrated over 12 hours, divided by the battery energy, measured under a 0.2 C discharge.

5-13modes, there was a chance that manufacturers co uld not make the necessary tradeoffs between the two and meet the specified CSL at the lowest cost.

To mitigate this potential problem, DOE used typical maintenance to no-battery mode power consumption of devices cu rrently in the market to disaggregate the energy ratio CSLs. When possible, DOE used BC test results 5 to select maintenance and no-battery mode power consumption of typical BCs that met a particular CSL. DOE then extrapolated additional data from related work on EPSs. Table 5.8 lists the resulting maintenance and no-battery mode power consumption limits for each CSL.

As will be presented later (see Figure 5.2), there is actually a moderate correlation between BC maintenance and no-battery mode pow er. This correlation implies that there are currently no significant tradeoffs between decrea sing power-consumption in one mode versus the other, further decreasing the risk that DOE ove r-constrained manufacturer design options during its interviews.

Table 5.8 Maintenance and No-Battery Mode Power Consumption Levels Used in Manufacturer Interviews

CSL Representative Unit A Representative Unit B Representative Unit C Representative Unit FMaintenance

Mode Power

[W] NoBattery Mode Power

[W] Maintenance

Mode Power

[W] NoBattery Mode Power

[W] Maintenance

Mode Power

[W] NoBattery Mode Power

[W] Maintenance

Mode Power

[W] NoBattery Mode Power

[W]
0

1

2

3 0.80 0.60

0.70 0.50

0.35 0.04

0.10 0.01 1.90 0.60

1.70 0.50

1.50 0.40

0.50 0.05 6.00 1.50

1.50 0.80

1.00 0.30

0.30 0.10 4.70 2.10

4.00 1.80

3.00 1.00

1.20 0.10

5.4.2 BC Manufacturer Interview Responses and Preferred Design Options

Representative unit A models battery charge rs for such small, low-voltage consumer product applications as shavers and beard trimmers . Because of the low battery voltage and small battery capacity, these BCs have a very low outpu t power, and are typicall y composed of a linefrequency center-tapped transformer followed by a fu ll-wave rectifier. Battery charge control is performed through current limiting with a discrete resistor or the winding resistance of the transformer.

The BC described above would charge the batt ery in 10 or more hours. To decrease the charge time, some manufactur ers replaced the slow BC’s line-frequency power supply with a switched-mode power supply, which permits the same size package to deliver higher output power, resulting in faster charging. This developm ent also improved the efficiency of the power supply, both due to the higher efficiency of th e switched-mode power supply and the need for

5 DOE used its own test results as well as datasets provided by Ecos Consulting (a CEC contractor) and ENERGY STAR.

5-14termination when charging at a higher rate . A list of technology improvements that manufacturers suggested during interviews appears below.

• CSL 0: line-frequency transformer, center-tapped rectifier, standard p-n junction rectifier diodes, current-limiting resi stor or winding resistance

• CSL 1: same design as CSL 0, but with im proved transformer core, Schottky rectifier diodes

• CSL 2: switched-mode power supply

• CSL 3: switched-mode power supply with improved components

• CSL 4: not available

Representative unit B models battery chargers for household appliances, such as kitchen tools, floor-care products, and small power tools that are typically pack aged with integral batteries, such as cordless screwdrivers. As for representative unit A, these devices are used infrequently enough that users do not require a fast recharge, so they typically ship with slow chargers. However, as for representative uni t A, some higher-end ma nufacturers have begun packaging products with fast chargers, whic h require switched-mode power supplies and therefore tend to be more efficient than slow chargers, which use line-frequency power supplies.

According to manufacturers interviewed during the dete rmination analysis, the technology options for improving the efficiency of representative un it B are similar to those for representative unit A. Because of the higher battery voltage of representative unit B, more power is delivered to the battery during maintena nce mode, leading to higher charger power consumption during that mode. As a result, termin ation, or significant redu ction of current into the battery during maintenance, becomes a bi gger concern. Manufacturers proposed sensors and timers as a way of limiting power consumption in maintenance mode. A list of manufacturersuggested technology options for repr esentative unit B appears below.

• CSL 0: line-frequency transformer, center-tapped rectifier, standard p-n junction rectifier diodes, current-limiting resi stor or winding resistance

• CSL 1: same design as CSL 0, but with im proved transformer core, Schottky rectifier diodes

• CSL 2: same design as CSL 1, but with timer or other termination circuitry

• CSL 3: switched-mode power supply

• CSL 4: switched-mode power supply with improved components

Representative unit C models slow, higher-vol tage BCs that typica lly ship with power tools for DIY use. Because the architecture of this charger is similar to representative unit B, the technology options for efficiency improvement are generally similar as well. However, due to the much higher battery voltage 6 and consequent battery ch arger output power, certain technology options result in much greater savings th an in the case of representative unit B. For example, the amount of power delivered to the primary side of a line- frequency power supply can be controlled with the use of a phase-control circuit, limiting the power dissipated in the transformer core. A list of some of the typica l technology options that manufacturers identified for representative unit C appears below.

6 Representative unit C has an 18-volt battery, compared to the 4.8-volt battery of representative unit B.

5-15• CSL 0: line-frequency transformer, center-tapped rectifier, standard p-n junction rectifier diodes, current-limiting resi stor or winding resistance

• CSL 1: same design as CSL 0, but with improved transformer core

• CSL 2: same design as CSL 1, but with timer or other termination circuitry and/or primary-side phase control

• CSL 3: switched-mode power supply

• CSL 4: switched-mode power supply with improved components, termination, and/or AC switch during no-battery mode

Representative unit D is also typically used for charging power-too l batteries. This unit differs from the power tool ch argers described previously be cause the application—professional power tools—gets frequent use and requires frequent recharging. As a result, the BCs are fast chargers, with charge rates typically at or above 1 C.

Because the output power of a BC is directly proportional to the charge rate, professional power-tool fast chargers can ha ve output power an order of ma gnitude higher than the slow chargers modeled by representative product unit C. Therefore, the following technology options differ significantly from those discusse d for the other representative units:

• CSL 0: switched-mode power supply and charge controller, or line- frequency transformer followed by silicon-controlled rectifiers (SCRs)

• CSL 1: switched-mode power supply, but with improved components

• CSL 2: same design as CSL 1, but w ith improved power supply compensation

• CSL 3: same design as CSL 2, but with lo wer power consumption during maintenance mode

• CSL 4: same design as CSL 3, but with improved startup circuit, synchronous rectification, and/or automatic AC-side switch during no-battery mode

5.4.3 BC Manufacturer Interview Data Analysis

During interviews, manufacturers followed th e power consumption levels contained in the survey only loosely. When responding, they typically considered a unit currently under production as the baseline, reporting its measur ed power consumption in maintenance, nobattery, and in some cases, active mode. They then speculated on methods for improving the baseline unit, such as improving components, adding or exchanging subcircuits, or redesigning the topology. They accompanied each set of impr ovements with the increased costs over the baseline as well as incremental gains in efficien cy, again expressed in terms of power consumed during the three modes of operation.

DOE calculated a non-active energy ratio fr om the maintenance and no-battery mode power consumption provided by manufacturers. To represent active mode energy consumption, DOE used integrated, 24-hour, active and maintenance mode energy consumption that represents consumption experienced by a t ypical user over a 24- hour charging cycle. Manufacturers, however, expressed the active mode performance of their BCs in terms of power consumption during active mode, if at all. DOE therefore calculated the 24-hour integrated energy consumption figure us ing the following formula:

5-161 1 E = P + (24hr

− ) P
,

24 ACTIVE MAINT r η r η CELL CELL
Eq. 5.1

where:

r

is the charge rate of the BC in units of 1/hours;

η CELL is the cell efficiency, assumed to be 80 percent;

P

ACTIVE is the power consumption of the BC in active mode while charging the battery; and

P

MAINT is the power consumption of the BC in mainte nance mode after the ba ttery has been fully charged.

As Equation 1 shows, DOE used the BC’s charge rate to calculate the charge time, which also depends on the cell efficiency of the batter y being charged. During the remainder of the 24 hours, DOE assumed the charger to be in mainte nance mode. Most manufacturers, however, only provided estimates of power consumption in maintenance mode, not in active mode.

When manufacturers did not provide the active mode power consumption, DOE estimated this metric in one of two ways. If the charger was a slow charger and no additional information was available, DOE substituted the maintenance mode figure for active mode power consumption because of the lack of clear distin ction between active mode and maintenance mode in slow chargers. If the manufacturer provided BC “efficiency,” defined as the power delivered to the battery over the power consumed, DOE ca lculated the active m ode power consumption from the power required to charge the battery, di vided by this BC efficiency. In either case, these calculations allowed DOE to estimate the typical energy consumption of a BC in all three modes.

5.4.4 Supplements to BC Manufacturer Interview Data

Although some of the consumer-product manuf acturers DOE interviewed designed BCs for their products in-house, ma ny acquired their BCs from outs ide vendors. These manufacturers were therefore unable to provide detailed information about the de sign options necessary to meet the CSLs or even to decrease energy consumption in the three modes.

This lack of familiarity with energy effici ent design prevented many manufacturers from providing detailed power consumption estimates in the three modes of BC operation. They were often able to supply only two cost-efficiency point s, one before and one after the enactment of California’s Title 20 appliance efficiency standa rds for EPSs, which affected some BCs. Because many slow BCs fell under the California Energy Commission (CEC) definition of EPSs, many manufacturers had to ensure their products complie d with these standards, which went into effect July 1, 2007.

5-17Nonetheless, the burden of redesigning for compliance remained with the outside BC vendors, and some of the manufact urers interviewed could not o ffer more detail than the CEC compliance status of the wall adapter. Where manuf acturers could not provide detailed efficiency data, DOE sought to acquire the specific uni ts described by the ma nufacturer, performing efficiency tests and using that information to fill in gaps in the data.

When DOE could not purchase the requisite BC and therefore no direct substitution of measurement results was possible, DOE averaged the performance of the wall adapter components of other BCs in its test database th at were in the same product class. DOE then paired these averages with the manufacturer costs to arrive at an estimate of the manufacturer’s cost-efficiency relationship.

Table 5.9 Product Class-Average BC Wa ll Adapter No-Load Power Consumption

Product

Class Voltage Range Non-CEC Compliant CEC Compliant Number of Adapters Class-Average NoLoad Power [W] Number of Adapters Class-Average NoLoad Power [W] A B C 0 V–3 V 3 V–9 V 9 V–36 V 4 0.93 20 0.81 4 1.13 0 – 6 0.15 2 0.35

Manufacturers, however, only specified whet her the BC’s wall adapter component had met the CEC EPS standard based on its active m ode efficiency and no-load power, as measured by the EPS test procedure. Because nothing more was known about these units, DOE had to extrapolate from the wall adapter to the entire BC system, by estimating the energy consumption in all three BC modes based on the average BC wall-adapter no-load power consumption in Table 5.9.

Figure 5.13 shows, however, that no-load power consumption is a fairly good predictor of battery charger power consumption in no-load a nd maintenance modes. DOE therefore used the relationship between the two metrics to estimate class-average no-load- and maintenance mode power consumption for pre- and post-CEC BCs. Again, because these were slow chargers without a clear distinction between maintenan ce and active modes, DOE substituted maintenance mode power consumption for active mode power consumption. The resulting three average metrics appear in Table 5.10.

5-18Maintenance or No-Battery Power[W] 3.00

2.50

2.00

1.50

1.00

0.50

0.00 y = 1.0023x R 2 = 0.9896 y = 2.1306x + 0.4198 R 2 = 0.6386 No-Battery Power w/o Outliers

Maintenance Power w/o Outliers

0.00 0.10 0.20 0.30 0.40 0.50 0.60 0.70 0.80 0.90 1.00 EPS No-Load Power [W]
Figure 5.2 Relationship Between BC Wall- Adapter No-Load Power and System NoBattery and Maintenance Power

Table 5.10 Average Calculated BC Performan ce Used to Supplement Manufacturer Data

Product

Class Voltage Range Non-CEC Compliant CEC Compliant Maint. Mode Power

[W] NoBattery Power

[W] 24-Hour Charge and Maint. Energy [Wh] Maint. Mode Power

[W] NoBattery Power

[W] 24-Hour Charging and Main. Energy [Wh] A B C 0 V–3 V 3 V–9 V 9 V–36 V 2.36 0.93 56.56 2.10 0.81 50.49 2.77 1.13 66.39 1.06 7 0.76 1.15 0.30 7 25.39 7 0.15 18.15 0.35 27.61

5.4.5 Scaling of BC Manufacturer Interview Data to Representative Units

Following the collection of data from the ma nufacturers and supplem entation with test results, DOE scaled the cost-efficiency data, alig ning them with the representative units to permit aggregation of data from various sources. As described earlier, manufacturers often based their data submission on actual BCs currently in prod uction. These did not always have the same specifications as the representative units, but were similar enough that DOE could scale the power consumption estimates provided by manufactur ers to be applicable to the representative units.

For example, the BC upon which a manufacturer had based its data submission could have been charging a battery with a capacity twice that of the closes t representative unit. In this case, DOE calculated what the energy consumpti on would have been had the battery capacity

7 Since no data were available on low-voltage CEC-compliant chargers (Table 5.9), DOE assumed a moderate noload power consumption value of 0.3 W.

5-19been decreased to that of the representative uni t, keeping all other char acteristics of the design
constant.
Only the maintenance and no-battery mode pow er consumption metrics were scaled to the representative units. DOE did not scale th e active mode power consumption or the 24-hour integrated active and maintenance mode en ergy consumption because of the excessive complexity of modeling the effects of unit para meters on active mode performance and the lack of empirical data upon which to base a simpler, linearized model.

DOE scaled the maintenance mode power consumption by the ratio of the battery voltages of the representative unit and the manufacturer-described unit as follows:

V ′ P ′ = B P
,

MAINT MAINT V

B
Eq. 5.2

where the primed quantities pertain to the representative unit.

Since a maintenance current into a battery of a higher voltage re sults in proportionally higher power into the battery, DOE modeled the change in the maintenance mode power consumption as proportional to the ratio of batt ery voltages. DOE did not include a dependence on battery capacity after learning from manufact urers that the maintenance current into the battery is typically held constant by the BC a nd does not vary with battery capacity, even though higher-capacity batteries will have a higher self-d ischarge current, and should compensate with a higher maintenance current. DOE also did not include a dependence on charge rate, as maintenance mode power consumption did not depend on charge rate. 8

No-battery mode power consumption was lik ewise scaled, using the following equation:
 V B ′ C B ′ r ′  2 3 P ′ =     P
, NO

_ BATTERY NO

_ BATTERY V C r  B B 

Eq. 5.3

where:

V

B is the battery voltage;

C B is the battery capacity, e xpressed in ampere-hours;

8 Chargers of 1 C and 2 C (where C is the unit of charge rate equivalent to 1/hour) made by the same manufacturer are likely to have the same maintenance current, and therefore maintenance mode power consumption, as the operational characteristics of the BC in active and maintenance modes are specified independently.

5-20r is the charge rate or the charge current divi ded by the battery capacity, expressed in units of C or 1/hour; and

all primed quantities refer to the representative unit.

Most no-battery mode power consumption in a slow battery charger can be attributed to magnetization and winding losses in the line-frequency transforme r, which typically scale in relation to its volt-ampere (VA) rating, raised to the 2/3 power. Furthermore, in a battery charger, the volt-ampere rating of the transformer is de termined by the peak power delivered to the battery during active mode, which is the product of the battery voltage, battery capacity, and the charge rate. Although this scaling of no-load pow er consumption should also affect maintenance mode power consumption because transformer losse s are always present, the scaling model did not account for this second-order effect.

5.4.6 BC Manufacturer Markups

The BOM costs manufacturers provided inco rporate only a portion of the full production cost. Full production cost is defined as the sum of direct material, di rect labor, and overhead (including investment depreciati on). Other cost elements (sales , general and administrative, research and development, interest, and prof it) comprise the non-produc tion costs. Together these costs make up the full cost, or manufacture r’s selling price, of a product (Figure 5.3).

Figure 5.3 Full Cost of Product: Breakdown of Production and Non-Production Costs

In addition to the electronics, the direct ma terial costs also include the BC’s plastic enclosure, AC or DC cord, and mechanical co mponents such as contacts and springs. For the determination analysis, DOE assumed that the cost s of these components would stay constant as efficiency improved and would not scale in proportion to the elec tronics BOM cost, in contrast with production overheads such as direct labor.

Figure 5.11 shows the relationship between the two types of direct material costs, the other production cost (consolidated into a single production markup) , and the non-production costs (another markup). DOE used the typical va lues in Figure 5.11, aggregated from data obtained during manufacturer interviews, in c onjunction with this markup chain to scale manufacturer-provided electr onics BOM costs to MSP.

5-21Figure 5.5 Markup Chain Diagram for Battery Chargers

Table 5.11 Typical Markups and Add-Ons for Each BC Representative Unit Electronics BOM Cos t Production Cost Markup Mechanical Component

Add-On NonProduction

Markups 

## × + × = Manufacturer’s Sellin g Price

Representative Unit Electronic Component Production

Markup Case, Cord, and Mechanical Components Add-On Total Non-Production Markups (Includes Corporate, Shipping, and Tariffs) A B C D 28% 28% 32% 32% $0.24 $0.40 $0.73 $1.50 92% 77% 63% 63%

5.4.7 EPS Manufacturer Interview Overview

Between October and December 2008, DOE conducted interviews and received data from manufacturers of EPSs a nd manufacturers of integrated ci rcuits (ICs) for EPSs. Each manufacturer reviewed DOE’s methodology and assu mptions, and in addition to cost-efficiency data, supplied DOE with information about the EP S design process, the structure of the supply chain, production volumes, and related issues.

The manufacturer survey (appe ndix 5.B) sought to obtain esti mates of the MSP paid to the manufacturer by distributors or OEMs for repr esentative-unit EPSs at each CSL. To develop a more accurate price estimate, DOE also asked ma nufacturers to list and cost the design options they would use to meet the CSLs. The consensu s views for each representative unit follow.

5.4.8 EPS Manufacturer Interview Responses and Preferred Design Options

Representative unit A models EPSs with nameplate output power intended for such applications as charging cellular or cordless telephones or powering small appliances. Because of the popularity of cellular telephones , EPSs in product class A are typically sold in large volumes but, because of the high degree of competition, are subject to smaller manufacturer markups.

Portability also affects the cost-efficiency re lationship of representative unit A. The lower the power, the smaller the transformer in a baseline line-frequency EPS, and the lower the costs associated with the steel core and copper wi ndings. Throughout represen tative product class A,

5-22switched-mode designs cost sign ificantly more than line-frequency designs, which would be universally adopted were it not for the need fo r portability. Because consumers demand smaller, more portable EPSs for charging cellular te lephones while traveling, manufacturers use switched-mode power supplies 9 for this application, by far the biggest in terms of volume. This change in design from line-frequency to switche d-mode also decreases the energy consumption of the EPS, allowing it to meet CSL 1. Ma nufacturers provided the following list of design options that are necessary for the representative unit to meet each CSL:

• CSL 0: line-frequency transfor mer, Schottky rectifier diodes

• CSL 1: switched-mode EPS with standard IC PWM controller or ring ing-choke controller

• CSL 2: switched-mode EPS with energy-efficient IC PWM

• CSL 3: same design as above , with improved components

• CSL 4: same design as above , with improved components

• CSL 5: switched-mode EPS with zero-voltage switching, lower-resistance field-effect transistor (FET) switch, more copper in choke

• CSL 6: not available

The representative unit for product class B ha s a nameplate output power of 18 watts and output voltage of 12 volts. This unit is typically used to power household networking appliances such as modems or other computer peripherals. Because of the immobility of these devices, there has been no strong pressure on manufacturers to produce smaller and lighter EPSs. During the determination analysis, the typical EPS in pr oduct class B featured a line-frequency design, which at this output power tended to still be less expensive than an e quivalent switched-mode design. A switched-mode design, however, woul d be necessary for meeting CSL 1, as the following list of design options—suggested by a consensus of manufacturers during interviews—shows.

• CSL 0: line-frequency transforme r, standard rectifier diodes

• CSL 1: switched-mode EPS with standard IC PWM controller

• CSL 2: switched-mode EPS with energy-efficient IC PWM

• CSL 3: same design as above , with improved components

• CSL 4: same design as above , with improved components

• CSL 5: better core material, improved FET switch

• CSL 6: synchronous rectification, resonant s nubbers, zero-voltage/ zero-current switching

The final representative unit analyzed duri ng the determination an alysis (for product class F) has a nameplate output power of 90 watts and output vo ltage of 19 volts. The main application of this high-power device is suppl ying laptop computers an d video-game consoles. Throughout product class F, it is no longer practical to produce line-frequency EPSs due to the large size of the transformer and high cost of th e necessary steel and copper. Therefore, even though DOE did not consider line- frequency designs applicable for this representative unit,

9 Switched-mode power supplies are smaller and lighter than line-frequency designs at the same nameplate output power.

5-23CSL 0 was reserved in the analysis for consis tency with the other re presentative units. The design options necessary for meeting the other CSLs are listed below.

• CSL 0: not applicable

• CSL 1: switched-mode EPS with standard IC PWM controller

• CSL 2: switched-mode EPS with energy-efficient IC PWM

• CSL 3: same design as above , with improved components

• CSL 4: same design as above , with improved components

• CSL 5: better core material, more copper, improved components

• CSL 6: synchronous rectification, resonant s nubbers, zero-voltage/ zero-current switching

5.4.9 Scaling of EPS Manufacturer Interview Data to Representative Unit Volume

After marking up the BOM costs to arrive at manufacturer selling prices, DOE had to further adjust the individual manufacturer prices to a common yearly volume. Although manufacturers were asked to provide their prices at a common volume, not all were able to do so. Therefore, DOE marked up or marked down the MSP, as appropriate, to arrive at commonvolume prices that were comparable to one anot her. Table 5.12 presents these common volumes and the rate DOE used to scale the prices according to volume.

Table 5.12 Unit Volumes and Volume Discount Rates for Each EPS Representative Unit

Representative Unit Volume of Representative Unit Per-Decade Discount Rate (percent) A B C 1,000,000 units/year 500,000 units/year 500,000 units/year 17.7 17.7 17.7

The discount rate DOE used to scale prices across decades ( i.e. , factors of ten) of volume was based on MSPs for 2-watt and 5-watt swit ched-mode EPSs reported by the manufacturer Ten Pao in a public comment submitted by the Natural Resources Defense Council to the California Energy Commission during the 2006 A ppliance Efficiency Standards rulemaking. 10 Table 5.13 shows the prices and discount-rate ca lculations, which result in an average volume discount rate of 17.7 percent per decade.

10 This comments is available at www.energy.ca.gov/appliances/2006rulemaking2/documents/comments/NRDC.PDF

.

5-24Table 5.13 Volume Prices Used to Calcul ate Average per-Decade Discount Rate

Quantity [Units/Year] 2 W EPS Manufacturer Selling Price at Quantity [$] Percentage Difference from 2 W

Price at Next-Lowest Volume Percentage Difference

in 2 W Price per Decade 5 W EPS Manufacturer Selling Price at Quantity [$] Percentage Difference from 5 W

Price at Next-Lowest Volume Percentage Difference

in 5 W Price per Decade 50,000 100,000 1,000,000 10,000,000 1.65 1.50 1.35 1.20 – -09.1 -10.0 -11.1 – -30.2 -10.0 -11.1 2.10 1.89 1.60 1.50 – -10.0 -15.3 -6.3 – -33.2 -15.3 -6.3

Average -17.1 -18.3 Average across 2 W and 5 W Units -17.7

5.4.10 Scaling of EPS Manufacturer Interview Data to Representative Unit Power

Similarly to how it scaled manuf acturer-provided data to the volume of the representative unit, DOE also scaled data to the power of the representative unit. Although manufacturers provided data on units within the same repres entative product class, not all manufacturers produce EPSs with 90-watt nameplate output powe r or 19-volt output voltage. Therefore, both the price and efficiency data th ey provided had to be scaled to the representative unit output power to account for the fact that higher-power units tend to be not only more expensive, but also more efficient.

To determine the dependence of cost on output power, DOE examined an EPS manufacturer’s price lis t, obtained under a conf identiality agreement. The price charged by the manufacturers to distributors se emed to be proportional to the output power, across a wide range of efficiencies and spanning output powers from 4 watts to 150 watts. DOE used the slope of the least-squares line passing th rough the points, with an R 2 value of 0.984, to scale the costs to the output powers of the representative unit.

Because the practically achievable efficien cy of an EPS also depends on the output power, DOE expects that shifting the manufacturer-provided cost-e fficiency data to the output power of the representative unit w ould result in a change in active mode efficiency. Figure 5.6 is a schematic representation of the EPS efficien cy distribution with power, which shows the general trend in EPS. DOE therefore assumed that if a manufacturer were to design two similar EPSs with slightly different powers, the effici ency of the higher-power EPS would be higher, and vice versa. However, there is a wider range of efficiency at low out put power than at high output power. Any shift of a manuf acturer’s unit to th e representative unit output power should therefore preserve a unit’s rela tive standing in terms of effi ciency among other units in the market.

5-25ENERGY STAR demarcates the 75 th percentile of efficiency.Efficiency [%]



### Pout_max [W]

Figure 5.6. Schematic Illustrati on of the Distribution of Efficiency Versus Maximum Rated Output Power; the ENERGY STAR Leve l Is Shown as a Pink Line, while the Blue Background Indicates Where Most of the Units Lie

To preserve the relative standing of the manu facturer’s unit in the market, while shifting the results to the representati ve unit output power, DOE mainta ined the ratios among the unit’s efficiency, the ENERGY STAR level, and the be st-in-market level. Figure 5.8 shows how DOE generated the best-in-market curv e-fit using data on the highest-p erforming units taken from the ENERGY STAR qualifying products database. Sin ce no correlation has been found between noload power and output power, DOE did not scale the no-load power.

5-26Efficiency [%] 

### η BEST_IN_MARKET



### η ′ MFR_UNIT 

### η ENERGY_STAR



### η MFR_UNIT 

### Shift

P

MFR_UNIT 

### P REP_UNIT 

### Pout_max [W]

Figure 5.7. Schematic Illustrati on of Scaling EPS Efficiency with Output Power

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

0 50 100 150 200 250 Rated Output Power [W]Conversion Efficiency

Highest performing units
ENERGY STAR v. 1.1 level
Best-in-market level
Worst-in-market level

Figure 5.8. ENERGY STAR Level and Calculated Best-in-Market and Worst-in-Market Curves

5-27DOE performed the shift in efficiency rela tive to the best-in-market and ENERGY STAR levels using the following equations:

η ′ = η ′

− r ⋅ 

# ( η ′

− η ′ MFR

_ UNIT BEST

_ IN

_ MARKET BEST

_ IN

_ MARKET ENERGY

_ STAR 

# )

Eq. 5.4

and

η

− η BEST

_ IN

_ MARKET MFR

_ UNIT r = , η BEST

_ IN

_ MARKET − η ENERGY

_ STAR Eq. 5.5

where:

η MFR

_ UNIT , η BEST

_ IN

_ MARKET , and η ENERGY

_ STAR are the efficiencies of the unit under analysis, the best-in-market point, and the ENER GY STAR level, respectively, at the manufacturer-provided name plate output power, while

the primed terms refer to the same quantities at the nameplate output power of the representative unit, to which the unit efficiency is being scaled, and

r

is a scaling ratio that represents the position of the efficiency of the manufacturer-provided unit to that of other EPSs in the market.

5.4.11 Scaling of EPS Manufacturer Interview Da ta to Representative Unit Voltage

After scaling manufacture r-provided cost-efficiency data to account for any differences in output power, DOE scaled the efficiency to account for any differences in output voltage. As mentioned in chapter 3, for a given output power, EPS output voltage has a strong effect on efficiency because of conduction loss es and rectifier voltage drops.

By testing families of EPSs produced by the same manufacturer with the same nameplate output power but different voltage , DOE was able to establish a relationship between voltage and efficiency. The relationship is illustrated in Figure 5.9, which shows the results of tests conducted on four pairs of EPSs with nameplate output power of 60 watts. Each pair was part of the same product family, and included a 12-volt un it and another unit with an output of 18 volts or 24 volts. The gains in efficiency due to incr easing the output voltage are described well by a best-fit line with an R 2 value of 0.914; DOE used the slope ofthe line to scale the manufacturerprovided efficiency data.

5-28y = 0.0023x - 0.0275 R

2 = 0.9137

0% 1% 2% 3% 4%

0 5 10 15 20 25 30
Voltage [V]Gain in Efficiency over 12 V

Figure 5.9 Relationship Between Ou tput Voltage and Efficiency

While EPS output voltage has a pronounced e ffect on efficiency, av ailable l iterature suggests and manufacturer intervie ws confirm that output voltage does not influence EPS price. Therefore, DOE did not scale the price with voltage as it had done for efficiency.

5.4.12 EPS Manufacturer Markups

Although the output of the engineering analysis is the MSP of the representative units at each CSL, some manufacturers did not provide it during the interviews. Instead, they focused on what they knew most intimately and reported the total BOM cost, which in contrast with the BC interviews, included both electr onic components and mechanical hardware and packaging. DOE therefore asked additional questions to construct an appropria te model of manufacturer markups and obtain the MSP from the BOM cost.

As in the description of BC markups in sec tion 5.4.6, manufacturer markups fall into two categories: production and non-pr oduction markups (Figure 5.5 ). Low and high estimates for the two types of markups, constructed from averages of data provided by manufacturers during interviews, appear in Table 5.14. To obtain th e MSP of a representative unit, DOE multiplied the BOM cost first by the production markup and then by the non-production markup appropriate to that representative unit. Because EPS manufact urers provided a total BOM cost, DOE did not have to apply a separate mechanical co mponent add-on, as during the BC analysis.

5-29Table 5.14 Manufacturer Markups Used in the EPS Engineering Analysis

Representative Typical Production Markup (%) Typical NonProduction Markup (%) Average Total Manufacturer Markup (%) Unit Low High Low High Low High

A B F 18 37 24 39 24 39 18 25 18 30 18 30 45 74 47 81 47 81

Following the markups and scaling described above, the manufacturer-provided MSPs at each CSL were validated through DOE testing and teardowns. The MSPs and CSLs served as inputs into subsequent analyses.

5.5 Efficiency Testing and Teardowns To validate data manufacturers provided duri ng interviews (section 5.4.7), DOE conducted tests and teardowns of commerci ally available BCs and EPSs. The tests and teardowns also served to validate publicly available efficiency data and identify common EPS design features in support of the product classes described in chapter 3.

DOE conducted the efficiency tests in accord ance with its BC and EPS test procedures, as codified in appendices Y and Z of subpart B to 10 CFR part 430. DOE also disassembled numerous BCs and all 46 of the purchased EPSs, noting the defining features of their circuits. DOE also tore down a subset of these units to evaluate the relations hip between cost and efficiency among units with comparable design characteristics. The teardowns involved a detailed parts count and cost es timate (sections 5.5.2 and 5.5.4). Because it is not possible to purchase and test models with the maximum te chnologically feasible efficiency, DOE was only able to examine devices with efficiencies between baseline and best-in-market.

5.5.1 BC Testing

In September 2007, DOE purchased 29 battery chargers for testing and teardown. The BCs were purchased either as part of a kit th at included a battery-operated consumer product and battery or independently of the product and packaged w ith just the battery.

DOE performed the testing and teardowns to achieve the following goals, listed from general to specific:

1. gain an understanding of BCs and battery- powered products in the market today, 2. evaluate the DOE and CEC BC te st procedures, and also test BC wall adapters using the DOE EPS test procedure, 3. validate efficiency test data stakeholders provided in comments to DOE, and 4. validate efficiency and cost data ma nufacturers provided during interviews.

5-30The BCs purchased for testing spanned a wide range of applications and voltages and were selected for the apparent popularity of the products with which they were sold, 11 ensuring a sample typical of the market.

Figure 5.10 shows the results of the efficiency tests conduc ted on the BCs, expressed in terms of energy ratio. The consumer product appli cations served by the BC s are also indicated on the plot, confirming the typical voltage-based divisions described in chapter 3. Figure 5.11 superimposes the results of DOE’s efficiency da ta on CEC test data gathered by its contractor, Ecos Consulting, showing genera l agreement between DOE test da ta and that gathered during prior tests.

0 10 20 30 40 50 60 70Energy Ratio Shavers
Universal BC
Floor Care
Power Tools
Other

0 5 10 15 20 25 Voltage [V]

Figure 5.10 DOE Battery Charger Test Resu lts by Consumer Product Application

11 DOE evaluated popularity based on the product’s sale s rank on retailer websites and ConsumerReports.com.

5-310 10 20 30 40 50 60 70 80Energy Ratio Ecos Test Results
DOE Test Results

0 5 10 15 20 25 30 Voltage [V]

Figure 5.11 DOE Battery Charger Test Data Superimposed over CEC Data gathered by Ecos Consulting

5.5.2 BC Teardowns

Following efficiency testing, DOE tore down the purchased BCs to evaluate costs. The process began with the disassembly of the ba ttery chargers, and when any battery charging circuitry resided outside the charger, the a ssociated consumer produc ts itself. Following disassembly, DOE listed all the electronic com ponents pertaining to battery charging. As explained in section 5.2.1, the batter ies were excluded from the analysis.

To aid in the next step, DOE compiled a mast er list of component costs taken from two online electronic component distributors 12 at quantities of 1,000 pieces. For components that were either unmarked or unavailab le in the manufacturer catalogs ( e.g. , magnetic components), DOE estimated their costs based on the costs of parts with similar specifications, construction, weight, and materials. Appendix 5.C provide s an example teardown analysis report.

Although DOE purchased 29 BCs, not all were co mparable to the four representative units described in section 5.2.1.Therefore, DOE only tore down the 11 units that could be immediately used to validate or complete the cost-efficiency data manufacturers supplied. The results of the teardowns appear in Figure 5.12, which plots BOM cost versus energy ratio for each unit. Data points of different cost a nd shape denote different battery voltages.

Although there are some outliers, Figure 5. 12 shows a clear pattern for BCs with the same output voltage. For example, the BOM cost of a 6-volt unit with an energy ratio of 2.4 is

12 The Digi-Key catalog can be viewed at www.digikey.com . The Mouser catalog can also be viewed at

www.mouser.com

.

5-32greater than $5, while the costs of two other less efficient units, as well as a comparable 4.8-volt unit, with energy ratios between 7 and 11, are around $0.50.

$0.00 $1.00 $2.00 $3.00 $4.00 $5.00 $6.00 $7.00 $8.00 $9.00BOM Cost [USD] 1.2 V
2.4 V
4.8 V
6 V
18 V

0 5 10 15 20 25 30 35 40 Energy Ratio

Figure 5.12 Low-Volume Cost Versus Effici ency for Tested and Torn-Down Battery Chargers

Although DOE had not thoroughly analyzed the outliers at the time the determination analysis was rescheduled in December 2007, one possible explanation may lie in the BC charge rate. The more expensive units are all fast chargers that charge the battery in up to one-tenth the time of the slow chargers, requiring higher charger output power and more expensive components capable of handling the higher pow er. There are numerous such complicating factors, such as the ability of a BC to double as an EPS in a “cord-cordless” product; additional circuitry in multi-voltage or multi-port chargers ; and proprietary designs that may distinguish products by different manufacturers, especially at the higher charge rates and costs.

One of the goals of the first round of BC tes ting and teardowns was to identify these sorts of dependencies, though further BC purchases may be necessary to establish a clearer relationship between cost and e fficiency, independent of the complicating factors mentioned above. Nonetheless, because there was significant overlap between the units torn down and those described by manufacturers (section 5.4), the results of the tests and teardowns were immediately useful in validating the inform ation manufactur ers provided.

To compare data provided by manufacturers and the materials costs calculated by DOE’s subject matter experts, 13 DOE discounted the calculated costs to reflect the higher volumes at which BC manufacturers typically op erate. DOE scaled volume with the aid of a high-volume quote and simplification of the method described in section 5.5.3, which resulted in an 80­

13 DOE relied on two subject matter experts (SMEs), who are independent engineering contractors with extensive experience in the design of battery chargers and ex ternal power supplies, when conducting its analyses.

5-33percent discount on all electroni c components. Magnetic component s were not discounted, as their price was already estimated based on high-volume commodity ( i.e. , steel and copper) prices.

In subsequent calculations, the scaled, high-volume BOM costs were marked up to include additional production and non-production costs, as was done for data provided during manufacturer interviews (section 5.4. DOE then aggregated the MSP and efficiency data for each teardown unit with data provided by manufacturers to create aver age price-efficiency curves. These curves fed into subsequent analyses of the potential impacts of standards on consumers and the Nation.

5.5.3 EPS Testing

As with BC testing, DOE conducted EPS testin g and teardowns to ga in insight into the design of commercially available EPSs, which influenced the technology assessment presented in chapter 3. A further goal was the validati on of cost-efficiency data obtained during manufacturer interviews.

DOE performed EPS testing and teardowns for the determination analysis in two phases. Phase 1 consisted of two groups of EPSs whos e nameplate output power ranged between 1 watt and 6 watts, and between 40 watts and 66 watts. Within these two ranges, DOE subjected EPSs with 5-watt and 60-watt output power to detailed teardowns to assess the cost-efficiency relationship at these two wattage ratings. DOE selected the 5- watt and 60-watt ratings due to their popularity, based on a review of eight EPS manufacturer catalogs 14 and the advice of its subject matter experts.

Table 5.15 lists some of the parameters of th e 46 units purchased in phase 1. In the batch of units purchased, 12 units (26 percent) were ENERGY STAR/CEC Tier 1 compliant.

14 DOE surveyed the websites of the following companie s: Delta Electronics, Ast ec, FRIWO Group, Phihong, Leader Electronics, AcBel Polytech, FSP Group, and Dee Van Enterprises.

5-34Table 5.15 Phase One Units Purchased and Their Characteristics

Number of Units Output Power Output Voltage ENERGY STAR Number of Units Output Power Output Voltage ENERGY STAR 1
1
1
3
2
3
2
7
1
1
1
1
1
1
1
1 1.125
2.4
2.5
3
3.6
4.8
5
5
5.15
5.2
6
40
40
40
45
45 5
6
5
5
6
6
5
5
5.15
5.2
5
24
24
48
12
18 Yes

Yes

Yes

Yes 1
1
1
1
1
1
1
2
2
1
1
2
1
1
1 48
48
50
50
50
50
55
60
60
60
60
60
65
66
66 12
24
5
12
18
24
19
12
12
18
20
24
24
15
18 Yes
Yes

Yes

Yes
Yes

46 total

- - -

Following the development of the EPS produc t classes described in chapter 3, DOE purchased additional EPSs, many selected to have the same power or almost the same power as the representative units. To further isolate the effect of efficiency on cost, DOE strove to purchase multiple units by the same manufactur er. Additional EPSs by the same manufacturer were purchased, with output powers either highe r or lower than the representative unit, to determine how the cost and efficiency scales wi th power within a product class, to validate the product-class boundaries defined in ch apter 3, and to asses the vari ability of EPSs design within each product class.

Figure 5.13, Figure 5.14, and Fi gure 5.15 present diagrams of EPSs purchased in phase 2, with efficiency on the y -axis and output power on the x -axis. To promote comparisons within and among different output power ranges, the EPSs were purchased such that a plot of their output power and efficiency would form an “inverted le tter T.” The leg of each inverted T in the figures helped determine the cost-efficiency relationship, while the arms allowed DOE to validate product class divisions and improve its understanding of scaling. EPSs contributing additional points in the figures were purch ased to enable additional comparisons.

5-35

### Increasing Efficiency

2.5 W 1.75 W

2.6 W 3 W 2.5 W 2.75 W 4 W 

### Legend:
Phihong

Other

3 W 4 W 2.5 W 0.5 W 1.7 W 

### Nameplate Output Power
Figure 5.13 Illustration of Units in Product Class A Selected for Phase 2 Testing and Teardowns



### Increasing Legend: Efficiency Elpac

SL Power 18 W
12 W 18 W

10.2 W 18 W 30W 60 W 50 W 10 W 18 W 

### Nameplate Output Power
Figure 5.14 Illustration of Units in Product Class B Selected for Phase 2 Testing and Teardowns

5-36

### Increasing Efficiency

120 W
100 W
96 W 120 W
100 W 66 W 120 W 150 W 

### Legend:
Elpac XP Power

SL Power Other



### Nameplate Output Power

Figure 5.15 Illustration of Units in Product Class F Selected for Phase 2 Testing and Teardowns

5.5.4 EPS Teardown Methodology

DOE tore down a subset of the previous ly tested EPS units to identify design characteristics that can be used to improve E PS efficiency and to determine their associated costs. The end result of each teardown was a bi ll of materials, which included the electronic components of the EPS. This BOM was the only component of costs dire ctly evaluated by DOE during the teardown portion of the EPS determina tion analysis. DOE estimated electronics BOM costs using the same method as for BCs (section 5.5.2). This included a master list of commonly available components, combined with catalog lookups and price estimates of similar parts when a given part was unavailable.

While the online distributor catalogs provide a consistent set of prices at low volumes, most EPS are manufactured in very large volum es. Thus, DOE developed a second cost estimate assuming large-volume orders of 100,000 to 1,000,000 pieces. To develop the high-volume estimate, a separate volume discount was applie d to each component category in the BOM ( e.g. , resistors, capacitors, semiconductors, magnetic parts). DOE developed these volume discounts by obtaining a high-volume quote for a power co nverter BOM and comparing the high-volume costs, from the quote, with low-volume costs obtai ned from distributor catalogs. The results of this comparison were then averaged by component category. DOE used the averages to scale the low-volume BOM costs of components in each category.

5.5.5 EPS Teardown Results Using the above scaled BOM costs, DOE deve loped cost-efficiency plots for 5-watt and 60-watt power supplies. Table 5. 16 summarizes the 5-watt units DOE evaluated, which all had the same output voltage. The 60-watt EPSs were analyzed at four different output voltages: 12 volts, 18 volts, 20 volts, and 24 volts. Because active mode efficiency depends on voltage, the 12-volt units would have a different efficiency than the 24 volt units, even given the same

5-37energy-efficient design and components. Therefore, only the results for th e 60-watt, 12-volt unit were analyzed.

Table 5.16 Phase One Units Torn Down

Maximum Rated Output Power (W) Rated Voltage (V) Number of Units Analyzed
5
60
60
60
60 5
12
18
20
24 9
4
1
1
2

Figure 5.16 presents the cost versus active m ode average efficiency plot for the 5-watt EPS units. The costs are shown for the two comp onent cost estimates—high and low—calculated using the low-volume catalog lookup a nd the high-volume quote, respectively.

$0.00 $1.00 $2.00 $3.00 $4.00 $5.00 $6.00BOM Cost [USD] Low Estimate High Estimate

30% 40% 50% 60% 70% 80% Average Efficiency [%]

Figure 5.16 BOM Cost versus Average Efficiency of 5-Watt Units

Figure 5.16 shows that there was approximate ly a four-fold difference in BOM costs between the high estimate calcula ted using distributor catalogs alone and the low estimate calculated through the vo lume quote and discounting. Consid ering that the electronics BOM costs presented in the figure would be mark ed up to account for mechanical components and packaging, as well as producti on and non-production costs, to arri ve at an MSP, the low cost estimate is more representative of typical EPS costs.

5-38Figure 5.16 also shows that costs tended to increase significantly between 35-percent efficiency and 60-percent efficiency due to th e necessary transition from line-frequency to switched-mode power supply (SMPS) technology . However, once the designs incorporated SMPS technology and surpassed 65 percent efficien cy, there was no clear relationship between cost and efficiency.

Figure 5.17 presents the BOM cost versus no-load energy consumption for the 5-watt EPS units. As was the case with active mode efficiency, there was a significant cost increase associated with lowering no-load power from approximately 1.5 watt to 0.5 watt, corresponding with the shift from line-frequency to switched- mode designs. Further re ductions in no-load power seem to incur no additional cost.

$0.00 $1.00 $2.00 $3.00 $4.00 $5.00 $6.00BOM Cost [USD] Low Estimate High Estimate

0 0.2 0.4 0.6 0.8 1 1.2 1.4 1.6 1.8 No-Load Power [W]

Figure 5.17 BOM Cost vs. No-Load Power of 5-Watt Units

Figure 5.18 presents the high-volume ( i.e. , low estimate) BOM costs versus average efficiency of 5-watt EPS units, but combines energy consumption in both active and no-load modes. The color and shape of the data points reflect the CSL (section 5.3.2) met by each unit. For example, green circles represent units exceed ing the CEC Tier 2 standard for active mode efficiency and no-load power consumption. The fi gure shows that increases in average efficiency track reductions in no-load power for the 5-watt units analyzed, but the only significant change in price is the increase caused by the shift in technology from line-frequency to switch-mode designs.

5-39 2$1.50

$1.25BOM Cost [USD] $1.00

$0.75

$0.50

$0.25

$0.00 Baseline Line-Frequency Baseline Switch-Mode CEC 2

> CEC 2 Market Best

30% 40% 50% 60% 70% 80% Average Efficiency [%]

Figure 5.18 BOM Cost and Efficiency of 5-Watt EPS Units

Figure 5.19 displays the same data in a differe nt way, plotting the active mode efficiency of the 5-watt EPSs directly against the no-lo ad power consumption. Because the CSLs are defined in terms of these two metrics, they are al so portrayed in the figure as shaded rectangles, with the most efficient CSLs gr ouped in the lower right of the fi gure. The shape and color of the data points indicate the low estimate of th e BOM cost. Once an EPS uses switch-mode technology, there are no discernable incremental costs associated with meeting levels just beyond CEC 2.

Baseline Switch-Mode

CEC 1 & 2 > CEC

0 0.25

0.5 0.75 1 1.25

1.5 1.75 2No-Load Power [W]

< $0.50 $0.50–0.75 $0.75–1.00 $1.00–1.25 > $1.25

30% 40% 50% 60% 70% 80% Average Efficiency [%]

Figure 5.19 Average Efficiency and No-Load Power Consumption of 5-Watt EPSs with BOM Costs; Increasingly Stringent CSLs A re Represented by Darker Shades of Blue

As with its analysis of the 5-watt unit s, DOE tore down 60-watt, 12-volt EPSs and estimated high and low BOM costs using the sa me methodology that included the master price lists and volume discounting using the high-volume quote. Figure 5. 20 presents the cost versus

5-40active mode average efficiency for the 60-watt E PS units. Figure 5.20 shows there is no apparent increase in cost for efficiency points greater than 65 percent. Since all the 60-watt EPSs DOE tore down incorporated switch-mode designs, th ese findings are consistent with the cost relationship for switch-mode 5-wa tt units presented in Figure 5.16. The small sample size, however, made robust co mparisons difficult.

$0.00 $2.00 $4.00 $6.00 $8.00 $10.00 $12.00 $14.00 $16.00BOM Cost [USD]

Low Estimate High Estimate

77% 78% 79% 80% 81% 82% 83% 84% 85% 86% 87% Average Efficiency [%]
Figure 5.20 BOM Cost vs. Average Efficiency of 60-Watt Units

Figure 5.21 presents the BOM cost and no-lo ad energy consumption for the 60-watt EPS units. The costs are shown again for the low and high price estimates. Figure 5.21 shows there was no significant relationship between cost a nd no-load power for the EPSs DOE analyzed. This is similar to the conclusion DOE reached for 5-watt switched-mode EPSs.

5-41$0.00 $2.00 $4.00 $6.00 $8.00 $10.00 $12.00 $14.00 $16.00BOM Cost [USD]
Low Estimate High Estimate

0 0

. 5 1 1

. 5 2 2

. 5 No-Load Power [W]
Figure 5.21 BOM Cost versus No -Load Power of 60-Watt Units

Figure 5.22 presents the high-volume BOM cost s and active mode efficiency of 60-watt EPS units. The color and shape of the data poi nts provide a measure of the no-load mode efficiency for each unit. For example, the yellow triangles represent 60-watt, 12-volt EPSs that meet the CEC Tier 2 standard for active mode efficiency and no-load power consumption. The figure seems to show that increases in average e fficiency tended to track reductions in no-load power in the sample of torn-down units, and that efficiency appeared to increase without a corresponding increase in cost.

$4.00
$3.50BOM Cost [USD] $3.00
$2.50
$2.00
$1.50
$1.00
$0.50
$0.00 Baseline Switch-Mode CEC 2

> CEC 2 Market Best

75% 77% 79% 81% 83% 85% 87% 89% Average Efficiency [%]

Figure 5.22 BOM Cost and Efficiency of 60-Watt EPS Units

Figure 5.23 rearranges the same data, presen ting active mode efficiency and no-load power. Units in the lower-right corner meet the highest CSLs of effici ency, in terms of both active mode efficiency and no-load power. The shape and color of the data points indicate the calculated BOM costs.

5-42Baseline Switch-Mode

CEC 1

> CEC 2

CEC 2

0 0.5

1 1.5

2 2.5No-Load Power [W]

< $3.00 > $3.00

76% 78% 80% 82% 84% 86% 88% Average Efficiency [%]

Figure 5.23 Average Efficiency and No-Load Power Consumption of 60-Watt EPSs with BOM Costs; the Increasing CSLs Are Represented by Darker Shades of Blue

5.6 Conclusion

DOE did not finish the validation component of the engineering analysis, which consisted of testing and teardowns, before the rescheduli ng of the determination analysis in December 2007. As a result, additional teardowns of BCs and EPSs, necessary to address some of the issues raised above, remained unfinished. Despite its incompleteness, the above description provides examples of the methods that DOE had planned to use to arrive at cost-efficiency estimates, such as output power and voltage scaling, as well as volume discounts and manufacturer markups. These results would have been in corporated into the life-cycle cost and payback period analyses and the national impact assessment described in the following chapters.

5-43APPENDIX 5.ABattery Charger Cost-Efficiency Estimation SurveyNavigant Consulting, Inc. (NCI) is conducting an engineeringanalysis to understand the relationship between manufacturers’cost and the energy efficiency of Battery Chargers. This engineering analysis is part of a larger determination analysis on whether theU.S.Department of Energy should conduct an energy conservation standards rulemaking on battery chargers and external powersupplies (BC-EPSs). Through this survey,NCI is seeking your guidance on design improvements you might make to battery chargersto improve their efficiency. All information you provide iscovered by the Non-DisclosureAgreement between NCI and yourcompany.NCI is focusing the engineering analysis onfour types of battery chargers with differing charge rates, operating voltages, batterycapacities, and consumer product applications. NCI believes each ofthese units is representativeof other commonly used consumerproduct chargers. These fourbattery chargers are:•C/10, 1.2 V, 1.2 Ah, representing chargers forinfrequentlyused personal care products, such as electric shavers;•C/10, 4.8 V, 1.2 Ah, representing chargers forcradledevices that typically remain in the charging cradle, such as handheldvacuums and kitchen appliances;•C/8, 18 V, 1.5 Ah, representing chargers fordo-it-yourself (DIY)power tools that are used sporadically; and•1 C, 18 V, 2.5 Ah, representing chargers forprofessionalpower tools that are used frequently.For each of the above chargers, please use the tables on the following pages to describe the changes in factory cost and manufacturer’sselling price associated with redesigning a baseline unit to achieve higher energy-efficiency levels. The efficiency levels are definedas:0.The industry-average energy consumption for typical chargers manufacturedtoday (i.e., the “baseline” charger).1a. The energy consumption of infrequently-used and some cradle chargers with a walladapter that meets CEC Tier 1 standardsfor external power supplies,adopted in January 2007.1b. The energy consumption of chargers without a wall adapter (i.e., some cradle, DIY-tool, and pro-tool chargers) that meet thevoluntary ENERGY STAR battery-charger standard.2.The lowest energy consumption achieved by comparable battery chargers in the market today.3.The lowest energy consumption feasible, regardless of price(e.g., by using premium components,redesigning the architecture,using exotic materials, etc.).In the data tables that follow, the energy consumption target ateach efficiency level is based on the results of tests commissioned bythe Department of Energy, the Environmental Protection Agency,and the California Energy Commission, as well as NCI estimates.In each case, the energy-efficiency of a charger is evaluated in termsof its maintenancemode power and No-Battery mode power.The5-44former is defined as the power consumed by the charger to maintain a fully-charged battery, while the latter is the power consumed bythe charger once the batteryor appliance has been disconnected from the charger.In addition to providing the manufacturer’s selling price of a unit that meets a given efficiency level, please also describe the designimprovements that would be necessary to attain that level, as well as the resultant active mode efficiency exclusive of cell efficiency.Also, please estimate the incremental change in production cost over the baseline for each designimprovement. If it is not possible toitemize the cost changes, please specify the total factory bill-of-materials (BOM) cost increase for all the improvements.We would also welcome your input on the current distribution of battery chargers in each category byefficiency level, as wellas thetypical lifetime of the consumerproducts that use those chargers.We recognize that detailed designs would be burdensome to prepare; therefore, in the interests of generating reasonable resultsin ashort amount of time, we invite you to use your best judgment and experience when completing the following tables.Please use the following design specificationsfor all chargers (or please indicate to usif one or more of these need modification):Input voltage: 115 volts rms, 60 HzInput protection: Primary current fuseUnit volume:500,000 units/yearPackaging: SealedplasticCord length:6 feetRegulatory compliance: UL, FCCProduct lifetime: > 2 yearsThank you for your input. If you have any questions or suggestions, please contact:Matt MalinowskiMichael Vladimer202-481-7304202-481-7323Matt.Malinowski@NavigantConsulting.comMVladimer@NavigantConsulting.com5-45Example: Infrequently-Used Charger; C/10, 1.2 V, 1.2 Ah;The table on this page provides an exampleof the kind of information we are seeking tocreate an engineering-analysis cost-efficiencycurve for battery chargers. In this particular example, we show one set of improvements for increasing the efficiency of a charger fora 1.2 V electric shaver to meet the requirements of the CEC Tier 1 external power supply standard. This example is purely illustrative,and should not be interpreted as the only path to making a CEC-compliant shaver adapter. However, this table does provide anindication of the level of detail being requested for the following tables. The columnlabeled “Incremental Change in Mfr. ProductionCost” represents the cost of the specific improvement described.If additional rows are needed to describe all the designimprovements you would make, please feel freeto modify the tables. The column labeled “Total Mfr. Unit Selling Price” is yourfinalselling price to your customers, such as retail chains orother manufacturers (for bundling with a consumer product).#Efficiency LevelMaint.­ModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsMfr.ProductionCost[$]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]0Baseline: Lowestcost BatteryCharging System0.80 W0.60 W30 %60-Hz linear powersupply$0.69$1.5060 %Rectifier diode$0.011.2 Ah NiMH cell$0.30#Efficiency LevelMaint.­ModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsIncrementalChange inMfr.ProductionCost[+/- $]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]1aCharger WallAdapter MeetsCEC Tier 10.70 W0.50 W60 %Improved core steel+ $0.20$1.9535 %Schottky diodes+ $0.105-46BC 1: Infrequently Used Charger; C/10, 1.2 V, 1.2 Ah;#EfficiencyLevelMaint.-ModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsMfr.ProductionCost[$]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]Baseline:0Lowest-costBatteryChargingSystem0.80 W0.60 W#EfficiencyLevelMaint.-ModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsIncrementalChange inMfr.ProductionCost[+/- $]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]1aCharger withWall Adapterthat MeetsCEC Tier 10.70 W0.50 W2Best in Market0.35 W0.04 W3MaximumTechnologicallyFeasible0.10 W0.01 W5-47BC 2: Cradle Charger; C/10, 4.8 V, 1.2 Ah;#Efficiency LevelMaintenanceModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsMfr.ProductionCost[$]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]Baseline:0Lowest-costBattery ChargingSystem1.9 W0.6 W#Efficiency LevelMaintenanceModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsIncrementalChange inMfr.ProductionCost[+/- $]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]1aCharger withWall Adapterthat MeetsCEC Tier 11.7 W0.5 W2Best in Market1.5 W0.4 W3MaximumTechnologicallyFeasible0.5 W0.05 W5-48BC 3: DIY Tool Charger; C/8 18 V, 1.5 Ah;#EfficiencyLevelMaint.­ModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsMfr.ProductionCost[$]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]Baseline:0Lowest-costBatteryChargingSystem6 W1.5 W#EfficiencyLevelMaint.­ModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsIncrementalChange inMfr.ProductionCost[+/- $]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]1bCharger MeetsENERGYSTARRequirements1.5 W0.8 W2Best in Market1 W0.3 W3MaximumTechnologicallyFeasible0.3 W0.1 W5-49BC 4: Pro Tool Charger; 1 C, 18 V, 2.5 Ah;#EfficiencyLevelMaint.­ModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsMfr.ProductionCost[$]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]Baseline:0Lowest-costBatteryCharging4.7 W2.1 WSystem#EfficiencyLevelMaint.­ModePower[W]NoBatteryPower[W]Active-ModeConversionEfficiency[%]Defining DesignCharacteristicsIncrementalChange inMfr.ProductionCost[+/- $]Total Mfr.Unit SellingPrice[$]Proportion ofProducts atthis EfficiencyLevel[%]1bCharger MeetsENERGYSTARRequirements4.0 W1.8 W2Best in Market3.0 W1.0 W3MaximumTechnologicallyFeasible1.2 W0.1 W5-50APPENDIX 5.B EPS Cost-Efficiency Estimation Survey

Navigant Consulting, Inc. (N CI) is conducting an engineeri ng analysis to understand the relationship between manufacturer s’ cost and the efficiency 15 of EPSs. This engineering analysis is part of a larger determination analysis on whether the U.S. Depart ment of Energy should conduct an energy conservation st andards rulemaking on battery chargers and external power supplies (BC-EPSs). Through this worksheet, NCI is seeking your guidance on design changes you might make to external power supplies to improve their efficiency. All information you provide is covered by the Non-Disclosure Agreement between NCI and your company.

NCI is focusing its analysis on three switch-mode power supplies (SMPSs) with output powers of 75 W, 12 W and 2.75 W. NCI believes each of these units represents similar SMPSs. In particular:

• The 75 W, 12 V SMPS represents higher-pow er models that re quire power-factor correction (PFC) and therefore typically employ a two-stage forward topology;

• The 12 W, 12 V SMPS represents general-pur pose models with a single-stage flyback topology and PWM cont roller IC; and

• The 2.75 W, 5 V SMPS represents lower-powermodels that typically employ a singlestage ring-choke converter t opology, foregoing a PWM controller IC to save costs.

For each of the supplies, please describe the discrete design steps you would undertake to achieve the efficiency level and no-load power sp ecification shown in the table. In each case, start with a baseline SMPS, and list the necessary design changes to enable it to meet the higher efficiency levels. The efficiency levels are defined to be: 0. The industry-average efficiency level, cir ca 2005, prior to the adoption of ENERGY STAR and California Energy Commission (C EC) Tier I, efficiency standards 1. The level specified by the (voluntary ) EPA ENERGY STAR program in 2006 and (mandatory) CEC Tier I standard in 2007 2. The Tier II level adopted by the CEC, which will become the (mandatory) CEC standard on July 1, 2008. 3. The maximum efficiency level achieve d by products in the market today. 4. The maximum efficiency level feasible rega rdless of price, using premium components and exotic materials. For each design change, please also provide an esti mate of your incremental production cost over the baseline, as well as the total unit selling pri ce to an OEM or distributor. In case it is not possible to list the increase in cost per design change, please specify the total bill-of-materials (BOM) cost increase for all the improvements. Fi nally, please describe your markup structure to make it clear how increases in production costs impact the total per-unit manufacturer’s selling price.

We recognize that detailed designs may be difficu lt to prepare; therefore, in the interests of generating reasonable results in a short space of time, we invite you to use your best judgment and experience when completing the following tables.

15 “Efficiency” is used in this worksheet as a prox y for both conversion effi ciency and no-load power.

5-51Please use the following design specifications for al l three SMPSs (or please indicate to us if one or more of these are problematic):

Input voltage: 115 volts rms, 60 Hz Unit volume: 1 million units

Input protection: Primary current fuse, inrush current limiting Application: Information technology/ consumer electronics Output voltage regulation: ± 1% (excluding cord) Pack age: Sealed polycarbonate

Output voltage ripple: 1% V P-P maximum Output cord length: 6 feet

Transient response: 0.5 ms for 50% load change typical Regulatory compliance: UL, FCC, PFC for P IN > 75 W

Output protection: Overcurrent protection, short-circuit protection Product lifetime: > 2 years

Thank you for your input. If you have any questions or suggestions, please contact:

Matt Malinowski Michael Vladimer 202-481-7304 202-481-7323 Matt.Malinowski@NavigantConsulting.com MVladimer@NavigantConsulting.com

5-52The table on this page provides an example of the kind of information we need in order to create a cost-efficiency curve for SMPSs. In this partic ular example, we show one set of improvements for increasing the efficiency of an 80%-efficien t 75 W, 12 V SMPS to meet the requirements of the ENERGY STAR program. This example is purel y illustrative, and shoul d not be taken as the only pathway to make a 75 W ENERGY-STAR SMPS. However, this table does provide an indication of the level of detail being requested for the tables on pages 3 through 5. The column labeled “Incremental Unit Cost per Improveme nt” represents the cost of the specific improvement described. If additional rows ar e needed to describe all the design changes you would make, please feel free to modify the tables . The column labeled “Total Mfr. Unit Selling Price” is your final selling pr ice to your customers, such as OEMs or distributors.

# Efficiency Level End-of-Cord Conversion Efficiency Example: EPS 1: P OUT = 75 W, V OUT = 12 V

No-Load

Power Defining Design Characteristics Mfr. Production Cost Total Mfr. Unit Selling Price

0 Baseline: lowest-cost SMPS 74% 16 1 W 2-stage topology with PFC -

$8 UC3844 PWM controller -

- Output rectifier w/ Schottkies E-type transformer

- Size: 4 in x 2.5 in x 1.5 in -

# Efficiency Level End-of-Cord Conversion Efficiency No-Load Power Improvements over Baseline to Meet Efficiency Level Incremental Cost (over Baseline) per Improvement Total Mfr. Unit Selling Price

1 Efficiency Level

(ENERGY STAR, CEC Tier I) III

84 % 0.75 W Variable-frequency PWM controller IC + $0.05

$10 Change in transformer due to higher IC switching frequency + $0.20

Additional filtering caps due to higher IC EMI + $0.12

Miscellaneous additional components (e.g., XXXXX) + $0.10

16 These are NCI’s straw-man estimates of efficiency values. We welcome your input on these values.

5-53EPS 1: P OUT = 90 W, V OUT = 12 V

# Efficiency Level End-of-Cord Conversion Efficiency 17 NoLoad Power Defining Design Characteristics Mfr. Production Cost Total Mfr. Unit Selling Price

Baseline:
0 lowest-cost SMPS 82% 18 0.8 W 4

# Efficiency Level End-of-Cord Conversion Efficiency NoLoad Power Improvements over Baseline to Meet Efficiency Level Incremental Cost (over Baseline) per Improvement Total Mfr. Unit Selling Price

1 Efficiency Level

(ENERGY STAR, CEC Tier I) III 84% 0.75 W

2 Efficiency Level

(CEC Tier II) IV 85% 0.5 W

3 Maximum Commercially Achieved (U.S.

EPA, 2007) 88% 0.18 W

4 Maximum Technologically Feasible 92% 4 0.1 W 4

• How do you apply markups to your production costs in order to arrive at an OEM and distributor selling price?

17 Conversion efficiency, as defined by DOE, ENERGY STAR, and CEC test procedures, is the arithmetic mean of efficiencies at 100%, 75%, 50%, and 25% of maximum rated output current.
18 These are NCI’s straw-man estimates of efficiency values. We welcome your input on these values.

5-54EPS 2: P OUT = 18 W, V OUT = 12 V

# Efficiency Level End-of-Cord Conversion Efficiency 19 NoLoad Power Defining Design Characteristics Mfr. Production Cost Total Mfr. Unit Selling Price

0 Baseline: lowest-cost SMPS 67% 20 1.4 W 6

# Efficiency Level End-of-Cord Conversion Efficiency NoLoad Power Improvements over Baseline to Meet Efficiency Level Incremental Cost (over Baseline) per Improvement Total Mfr. Unit Selling Price

1 Efficiency Level

(ENERGY STAR, CEC Tier I) III 75% 0.5 W

2 Efficiency Level

(CEC Tier II) IV 76% 0.5 W

3 Maximum Commercially Achieved (U.S.

EPA, 2007) 85% 0.06 W

4 Maximum Technologically Feasible 88% 6 0.04 W 6

• How do you apply markups to your production costs in order to arrive at an OEM and distributor selling price?

19 Conversion efficiency, as defined by DOE, ENERGY STAR, and CEC test procedures, is the arithmetic mean of efficiencies at 100%, 75%, 50%, and 25% of maximum rated output current.
20 These are NCI’s straw-man estimates of efficiency values. We welcome your input on these values.

5-55EPS 3: P OUT = 2.75 W, V OUT = 5 V

# Efficiency Level End-of-Cord Conversion Efficiency 21 NoLoad Power Defining Design Characteristics Mfr. Production Cost Total Mfr. Unit Selling Price

0 Baseline: lowest-cost SMPS 55% 22 0.77 W 8

# Efficiency Level End-of-Cord Conversion Efficiency NoLoad Power Improvements over Baseline to Meet Efficiency Level Incremental Cost (over Baseline) per Improvement Total Mfr. Unit Selling Price

1 Efficiency Level

(ENERGY STAR, CEC Tier I) III 58% 0.5 W

2 Efficiency Level

(CEC Tier II) IV 59% 0.5 W

3 Maximum Commercially Achieved (U.S.

EPA, 2007) 72% 0.02 W

4 Maximum Technologically Feasible 75% 8 0.01 W 8

21 Conversion efficiency, as defined by DOE, ENERGY STAR, and CEC test procedures, is the arithmetic mean of efficiencies at 100%, 75%, 50%, and 25% of maximum rated output current.
22 These are NCI’s straw-man estimates of efficiency values. We welcome your input on these values.

5-56APPENDIX 5.C Example BC Teardown Analysis Report 

### Cost Estimate - External Power Supplies BC #2 Rev. B

Estimate conducted by: J. Wexler Date: 2Dec07 EPS Testing Label Number: 2 Maximum Rated Output Power [W]: 6.3 Output Voltage [V] 15 Regulation Type: switch mode Manufacturer: China-made for Philips Model Number 8000X Estimated part costs taken from: Mouser, Digi-Key Total number of parts: 54; 23 leaded, 31surface mount Estimated Total Cost [$] $2.529

Cost per part breakdown breakdown:

Part Type mount: Surface/ Lead Part Details Part count Cost/ part [$] Cost [$]
Choke L Axial lead choke 3.9mH TDK in Mouser 2 0.35 0.70

Diode L FR07 5 0.05 0.25 Capacitor L 10uF, 400V 1 0.23 Capacitor L 1500pF ceramic 1 0.025 Zener L 1/2W 4 0.025 0.10 Resistor L 1/4W 2 0.012 0.024 Diode L 1N4148 2 0.02 0.04 Transistor L TO-92 STBV32 1 0.10 Capacitor L 100uF 25V 1 0.10 Capacitor L 0.47uF 50V 1 0.05 Diode L HEF02 1 0.07 Transformer L Flyback choke 1 0.40 Choke L Ferrite bead wound as small common mode choke 1 0.10

Resistor S 0603 13 0.007 0.091 Resistor S 1206 13 0.012 0.156 Capacitor S 0603 3 0.014 0.042 Transistor S SOT-23 1 0.03 Zener S SOT-23 1 0.021

5-57CHAPTER 6 ENERGY USE AND END-US E LOAD CHARACTERIZATION

6.1 Introduction

.......................................................................................................... 6-2 6.2 Battery Chargers

.................................................................................................. 6-2 6.2.1 Battery Charger Usage Profiles

............................................................... 6-2 6.2.2 Battery Charger Energy Consumption

..................................................... 6-4 6.3 External Power Supplies

...................................................................................... 6-6 6.3.1 External Power Supply Usage Profiles

.................................................... 6-6 6.3.2 External Power Supply Energy Consumption

......................................... 6-8

LIST OF FIGURES

Figure 6.1. Weekly Usage Profiles for BC Applications

................................................. 6-3 Figure 6.2. Usage Profiles for EPS Applications

............................................................. 6-7

LIST OF TABLES

Table 6.1. Weekly Usage Profiles for BC Applications–Numeric Values

...................... 6-4 Table 6.2. Energy Consumption Characteristics by Representative Product Class and Efficiency Level

.............................................................................................. 6-5 Table 6.3. Unit Energy Consumption by Represen tative Product Class and Efficiency Level (kilowatt hours per year (kWh/yr)

......................................................... 6-6 Table 6.4. Usage Profiles for EPS Applications

.............................................................. 6-8 Table 6.5 EPS Active Mode Conversion E fficiency and No-Load Input Power by Efficiency Level

............................................................................................ 6-10 Table 6.6. Average EPS Nameplate Ou tput Power by Applications

............................. 6-11 Table 6.7 External Power Supply Activ e Mode Capacity Factors

................................ 6-12 Table 6.8 Unit Energy Consumption of EPSs in Representative Product Class A (kWh/yr)

........................................................................................................ 6-18 Table 6.9 Unit Energy Consumption of EPSs in Representative Product Class B (kWh/yr)

........................................................................................................ 6-19 Table 6.10 Unit Energy Consumption of E PSs in Representative Product Class F (kWh/yr)

........................................................................................................ 6-20

6-16.1 Introduction For the determination analysis, the Depa rtment of Energy (DOE) calculated unit energy consumption (UEC) using a combinati on of the inputs described in the following sections. The UEC represented the weighted average energy consumption of a single unit within a representative produc t class, and allowed for th e simplified calculation of aggregate savings when combined with shipments. As a simplification, DOE assumed that the power and energy requirements of external power supply (EPS) applications would not change during the analysis pe riod. In this section, DOE describes the calculation of usage profiles and unit energy consumption fo r battery chargers and for external power supplies.

6.2 Battery Chargers

6.2.1 Battery Charger Usage Profiles For the determination analysis, DOE developed usage profiles for each of the four representative product classes of battery chargers (BCs) by considering how their associated applications are used. Given th e lack of published da ta on the subject, DOE relied heavily on input from i ndustry experts to determine how applications are used.

DOE developed usage patterns for each BC application, as an expression of the total time (in hours) spent per week in active mode, maintenance mode, no-battery mode, and stowed/unplugged. To better capture energy consumption across all potential usage behaviors, active mode and a portion of ma intenance mode were grouped into 24-hour charge cycles. A 24-hour charge cycle is com posed of the time spent in active mode to charge the battery and the remaining hours, which are spent in maintenance mode. Therefore, the modified usage profiles were expressed as a combination of the number of 24-hour charge cycles, additional time spent in maintenance mode, no-battery mode, and unplugged. Figure 6.1 and Table 6.1 detail the weekly usage profiles for each BC application.

6-2Charge Cycle Maintenance Mode No Battery Mode Unplugged Mode

Personal Care Products

Kitchen Products

Floor Care Products

Universal Battery Chargers

Digital Cameras*

Video Cameras*

Power Tools (non-professional)

Power Tools (professional)Application

0 24 48 72 96 120 144 168 Hours per Week

Figure 6.1. Weekly Usage Profiles for BC Applications
Source: DOE, based on input from the Power Tool Institute and the Association of Home Appliance Manufacturers. * Only those digital cameras and camcorders that have a separate charging base and a battery designed to be removed from the camera for charging were considered BC applications.

6-3Table 6.1. Weekly Usage Profiles for BC Applications–Numeric Values

Representative Product Class Product Application Weekly Usage Profile Number of 24-Hour Charge Cycles Maintenance Mode Hours No-Battery Mode Hours Unplugged Hours

Class A (0 to ≤ 3 V) Personal Care Products 1 72 6 66

Class B (3 < to ≤ 9 V) Kitchen Products 1 143 1 0

Floor Care Products 1 143 1 0
Universal Battery Chargers 1 72 36 36

Digital Cameras* 1 48 72 24

Video Cameras* 1 72 48 24
All Applications (shipment

weighted avg.) 1 83 38 23

Class C (> 9V, Slow Charge) Power Tools (non

professional) 3 72 24 0
Class F (> 9V, Fast Charge) Power Tools (professional) 5 36 12 0 Source: DOE, based on input from the Power Tool Institute and the Association of Home Appliance Manufacturers. * Only those digital cameras and camcorders that have a separate charging base and a battery designed to be removed from the camera for charging were considered BC applications.

6.2.2 Battery Charger Energy Consumption For the determination, DOE expressed BC energy consumption as the sum of energy consumed during 24-hour charge cycles (UEC 24hr ), maintenance mode (UEC Maintenance ) and no-battery mode (UEC NoBattery ). DOE calculated energy consumption for each representative product cla ss using the following formulas:

UEC = ( UEC 24 hr + UEC Ma int enance + UEC NoBattery )*365 / 7 Eq. 6.1

Where:

UEC = E × N 24 hr 24 hr 24 hr UEC = P * t Ma int enance Ma int enance Ma int enance UEC = P * t NoBattery NoBattery NoBattery

and

6-4E 24 represents the energy consumed from mains by the battery charging system during a 24 hour charge cycle, less the energy capacity of the battery, e xpressed in watt-hours (Wh); N

24 represents the total number of 24-hour char ge cycles per week; P

Maintenance represents the average input power consumption of the battery charging system while in maintenance mode, expressed in watts (W);
t Maintenance represents the time spent per week in maintenance mode, expressed in hours per week; P

NoBattery represents the average input power cons umption of the battery charging system while in no-battery mode, expressed in watts;
t NoBattery represents the time spent per week in no battery mode, expressed in hours per week; and 365/7 represents the adjustment for convert ing weekly energy consumption to annual energy consumption.

6.2.2.1 E 24 , P Maintenance , P NoBattery From the engineering analysis in ch apter 5, DOE calculated 24-hour energy consumption, maintenance mode input power , and no-battery mode input power value pairs for each representative product class at each candidate standard level CSL. Table 6.2 gives these values. Table 6.2. Energy Consumption Characterist ics by Representative Product Class and Efficiency Level
Representative Product Class Characteristic Efficiency Level CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 Class A (0 to ≤ 3 V) E24 (Wh) 55.0 22.0 14.0 10.0 7.0

PMaintenance (W) 2.4 1.0 0.7 0.5 0.3

PNoBattery (W) 0.9 0.5 0.5 0.3 0.2

Class B (3 < to ≤ 9 Volts(V)) E24 (Wh) 60.0 48.0 45.0 40.0 20.0

PMaintenance (W) 2.0 1.8 1.7 0.9 0.7

PNoBattery (W) 0.7 0.5 0.4 0.3 0.2

Class C (> 9V, Slow Charge) E24 (Wh) 150.0 90.0 43.0 40.0 25.0

PMaintenance (W) 9.4 3.8 2.4 1.7 1.0

PNoBattery (W) 1.0 1.1 1.3 0.6 0.3

Class F (> 9V, Fast Charge) E24 (Wh) 140.0 135.0 110.0 93.0 58.0

PMaintenance (W) 14.2 5.0 4.2 2.7 1.7

PNoBattery (W) 6.0 5.5 1.5 1.2 0.5

6-5Based on these inputs, DOE calculated the following values for UEC for each representative product class and each CSL. Table 6.3. Unit Energy Consumption by Representative Product Class and Efficiency Level (kilowatt hours per year (kWh/yr)

Representative Product Class Efficiency Level CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 Class A (0 to ≤ 3 V) 12.0 4.9 3.5 2.5 1.5 Class B (3 to ≤ 9 V) 13.2 11.3 10.6 6.6 4.3 Class C (> 9V, Slow Charge) 60.0 29.5 17.4 13.4 8.0 Class F (> 9V, Fast Charge) 66.9 48.0 37.5 30.1 18.6

6.3 External Power Supplies

6.3.1 External Power Supply Usage Profiles For the determination analysis, DOE developed usage profiles for each of the three representative produc t classes of EPSs by consid ering how the associated applications are used. DOE developed usage pa tterns for each EPS application, as an expression of the total time (in hours) spent per week in active mode, no-load mode, and stowed/unplugged.

Considerable information was available on usage of EPS powered applications. DOE used the following sources to deve lop usage profiles fo r EPS applications: Porter, Moorefield, Ostendorp. Final Fiel d Research Report. October 2006. Ecos Consulting: Durango, CO. Rosen and Meier. Energy Use of Consumer Electronics at the End of the 20th Century. 2000. Lawrence Berkeley National Laboratory: Berkeley, CA. Roth, Ponoum, and Goldstein. US Resi dential Information Technology Energy Consumption in 2005 and 2010. May 2006. TIAX: Cambridge, MA TIAX LLC. Assessment of Analyses Performe d for the California Energy Efficiency Regulations for Consumer Electronics Products. Prepared by TIAX for CEA. 2 February 2006. TIAX LLC: Cambridge, MA.

Figure 6.2 and Table 6.4 show the usage pr ofiles DOE developed for EPS applications.

6-6Camcorders
Cordless Phones Digital Cameras

Flat Panel Monitors

Flatbed Scanners Ink-jet Computer Printers LAN Equipment
Modems/fax Modems Notebook Computers Portable Audio Players Portable Gaming Devices

Portable Video Players
Small LCD TVs Telephone Answering Devices

Wi-Fi Access Points Wireless telephones

0% 20% 40% 60% 80% 100%
Percent of TimeApplication

A ctive No-Load Unplugged

Figure 6.2. Usage Profiles for EPS Applications

6-7Table 6.4. Usage Profiles for EPS Applications

Product Application Usage Profile Percent Time Spent in Active Mode Percent TimeSpent in Noload Mode Percent Time Spent Unplugged Camcorders 10 10 80 Cordless Phones 100 0 0 Digital Cameras* 10 10 80 Flat Panel Monitors 100 0 0 Flatbed Scanners 100 0 0 Ink-Jet Computer Printers 100 0 0 LAN Equipment 100 0 0 Modems/Fax Modems 100 0 0 Notebook Computers 82 10 8 Portable Audio Players 18 36 46 Portable Gaming Devices 70 20 10 Portable Video Players 80 20 0 Small LCD TVs 100 0 0 Telephone Answering Devices 100 0 0 Wi-Fi Access Points 100 0 0 Wireless telephones 42 50 8 * Only those digital cameras and camcorders that used an EPS in combination with an integrated charger and battery designed to remain in the camera for charging were considered EPS applications.

6.3.2 External Power Supply Energy Consumption EPS energy consumption is the sum of energy consumed in active mode (UEC active ) and in no-load mode (UEC NL ).

To calculate energy consumption for E PS, DOE first calculated UECs for each application, then calculated an average UEC for each representative product class based on shipment weighting in each representative produc t class. This is in contrast to BCs, for which DOE calculated UECs for each repres entative product class based on weighted average usage and consumption characteristics. . This was due primarily to the greater availability of data on the us age and energy consumption for E PS applications, as well as the fact that many applications spanned mu ltiple representative product classes. In addition, DOE assumed the UEC of an E PS application to be a function of EPS nameplate output power and application usage, both of which vary considerably from application to application.

6-8DOE calculated energy consumption for a gi ven application and efficiency level using the following formulas:

UEC = UEC + UEC Eq. 6.2 active NL
Where: 

## ( 1

− η 

## )
active UEC = × P × D × t active out active η

active

UEC = P * t NL NL NL

and
η active represents the active mode conversion efficiency of the EPS, expressed as percentage; P out represents the nameplate output power of the EPS, expressed in watts; D represents the capacity factor of the EPS, based on the application, expressed as percentage;
t active and t NL

represents the active mode time and no-load mode time, based on the usage profile previously discussed in this s ection, expressed in hours per year; and P

NL

represents the no-load input power, expressed in watts.

6-96.3.2.1 Active Mode Conversion Efficiency, No-Load Input Power From the engineering analysis in ch apter 5, DOE calculated active mode conversion efficiencies and no- load input power value pair s for each CSL. Table 6.5, taken from chapter 5, Table 5.7 gives these values.

Table 6.5 EPS Active Mode Conversion Efficiency and No-Load Input Power by Efficiency Level Efficiency Level CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 CSL5 CSL 6 Representative Product Class A (0 to < 4 W) Active Mode Conversion Efficiency 30% 55% 58% 59% 65% 72% 75%

No-Load Input Power (W) 2.00 0.80 0.50 0.50 0.40 0.30 0.20

Representative Product Class B (4 ≤ to ≤ 60 W) Active Mode Conversion Efficiency 66% 71% 75% 76% 80% 85% 88%

No-Load Input Power (W) 2.00 1.50 0.75 0.50 0.40 0.20 0.15

Representative Product Class F (>60 W) Active Mode Conversion Efficiency N/A* 78% 84% 85% 87% 89% 92%

No-Load Input Power (W) N/A* 2.00 0.75 0.50 0.40 0.31 0.15

*During the determination, DOE found that all EPSs from representative product class F were already switch mode, therefore no values were calculated for CSL 0.

6.3.2.2 Nameplate Output Power Table 6.6 lists the average nameplate output power for each application as used in the determination. Where applications spa nned two representative product classes, separate average nameplate output powers we re estimated for each. DOE used data from the qualified product (QP) lis t for ENERGY STAR end-use products and matched these applications with their associated EPSs in the QP list for ENERGY STAR qualified EPSs. 1,2 For each application, DOE calculated the average nameplate output power of the associated EPSs. These estimates were ve rified by examining the distribution of EPS shipments across output powers in a re port produced for the California Energy

6-10Commission. 3 This report was also used to estimate the average nameplate output power for those applications not include d in the ENERGY STAR product lists. Table 6.6. Average EPS Nameplate Ou tput Power by Applications Average Nameplate Output Power (W)

Application Representative Product Class A <4W Representative Product Class B 4-60W Representative Product Class F >60W Camcorders

- 8

-
Cordless Phones 2.75 5

- Digital Cameras 2.75 8

- Flat Panel Monitors

- 40 70 Flatbed Scanners

- 20

- Ink-Jet Computer Printers

- 25

- LAN Equipment

- 12

- Modems/Fax Modems

- 20 70 Notebook Computers

- 60 90 Portable Audio Players 2.75 6

- Portable Gaming Devices

- 8

- Portable Video Players

- 15

- Small LCD TVs

- 45 70 Telephone Answering Devices 2.75 5

- Wi-Fi Access Points

- 10

- Wireless Telephones & PDAs 2.75 5

-

6.3.2.3 External Power Supply Capacity Factor For the determination, DOE used capacity factors to account for the fact that nearly all EPS-powered applic ations draw only a fraction of the nameplate output power of their EPS at any given time. This is because by definition, active mode accounts for all the time an EPS is plugged into mains and atta ched to an application. Many applications have multiple energy-consuming states that may fall under active mode consumption. To account for the variety of energy consuming active mode states, and using the same sources as those used to develop overall usage profiles, DOE then subdivided active mode into four states, incl uding a) high-power start-up or energy-intensive states, b) medium power normal mode states, c) lower po wer idle states while “on”, and, d) “off” states. To estimate capacity factor, DOE consid ered the output power (as a percentage of nameplate output power) and time spent in e ach state (as a percentage of active mode time). DOE then calculated capac ity factor as the weighted average of all states. Table 6.7 shows the values used in the determina tion analysis. Where DOE could not determine capacity factor due to lack of information on either output power or time spent in each state, it used a default of 50 percent for capacity factor.

6-11Table 6.7 External Power Supply Ac tive Mode Capacity Factors

Camcorders

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Charging 80 25 20 Battery Maintenance 18 75 13.5 Total Time 100% Sum Product Capacity Factor 33.5%

Cordless Phones

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Charging Handset 80 60 48 Transmitting 69 5 4.8 Standby 58 35 20.3 Total Time 100 Sum Product Capacity Factor 73.1%

Digital Cameras

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Charging 80 25 20 Battery Maintenance 18 75 13.5 Total Time 100 Sum Product Capacity Factor 33.5%

6-12Flat Panel Monitors

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Active 80 26 20.8 Sleep 5 1 0.1 Off 3 73 2.2 Total Time 100 Sum Product Capacity Factor 23.1%

Flatbed Scanners

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Active 80 1 0.8 Sleep 37 71 26.3 Off 13 28 3.6 Total Time 100% Sum Product Capacity Factor 30.7%

Ink-Jet Computer Printers

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Printing 80 1 0.8 Sleep 24 18 4.3 Off 9 81 7.3 Total Time 100 Sum Product Capacity Factor 12.4%

6-13LAN Equipment

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Active 80 100 80 Total Time 100 Sum Product Capacity Factor 80%

Modems/Fax Modems

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Active 80 100 80 Total Time 100 Sum Product Capacity Factor 80%

Notebook Computers

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode High Power 80 13 10.4 Low Power 33 14 4.6 Sleep 3 11 0.3 Off 3 62 1.9 Total Time 100 Sum Product Capacity Factor 17.2%

Portable Audio Players

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Active 80 4 3.2 Sleep 59 7 4.1 Off 34 89 30.3 Total Time 100 Sum Product Capacity Factor 37.6%

6-14Portable Gaming Devices

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Charging 80 50 40 Battery Maintenance 20 50 10 Total Time 100 Sum Product Capacity Factor 50%

Portable Video Players

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Charging 80 50 40 Battery Maintenance 20 50 10 Total Time 100 Sum Product Capacity Factor 50%

Small LCD TVs

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Active 80 17 13.6 Off 3 83 2.5 Total Time 100% Sum Product Capacity Factor 16.1%

Telephone Answering Devices

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Play/Record 80 1 0.8 Standby 71 99 70.3 Total Time 100% Sum Product Capacity Factor 71.1%

6-15Wi-Fi Access Points

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Active 80 100 80 Total Time 100 Sum Product Capacity Factor 80%

Wireless Telephones

EPS Mode Application State Percent of Nameplate Output Power (A) Percent of Time (B) Product (A×B) (Percent)

Active Mode Charging Handset 80 20 16 Transmitting 15 2 0.3 Standby 6 78 4.7 Total Time 100 Sum Product Capacity Factor 21%

6.3.2.4 Calculating Unit Energy Consumption by Application and Efficiency Level Using the inputs and formula given above, DOE calculated a UEC for each combination of application, efficiency le vel, and representative product class. These values are given in

6-16Table 6.8, Table 6.9, and Table 6.10. Using shipment weighting within each representative product class, DOE then calcu lated UECs for each representative product class at each efficiency level. These values are shown in the last row of the tables.

6-17Table 6.8 Unit Energy Consumption of EPSs in Representative Product Class A (kWh/yr)

Application Efficiency Level CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 Camcorders

- - - - - - - Cordless Phones 40.47 14.19 12.56 12.05 9.34 6.75 5.78 Digital Cameras 3.61 1.35 1.01 0.99 0.78 0.57 0.44 Flat Panel Monitors

- - - - - - - Flatbed Scanners

- - - - - - - Ink-Jet Computer Printers

- - - - - - - LAN Equipment

- - - - - - - Medical Devices 39.48 14.02 12.04 11.59 9.00 6.52 5.49 Modems/Fax Modems

- - - - - - - Notebook Computers

- - - - - - - Portable Audio Players 10.05 3.84 2.74 2.69 2.13 1.57 1.17 Portable Gaming Devices

- - - - - - - Portable Video Players

- - - - - - - Small LCD TVs

- - - - - - - Telephone Answering Devices 39.91 13.99 12.39 11.89 9.21 6.65 5.70 Wi-Fi Access Points

- - - - - - - Wireless Telephones 13.72 5.24 3.73 3.67 2.90 2.14 1.58 Representative Product Class A UEC 21.30 7.76 6.25 6.06 4.73 3.45 2.79

6-18Table 6.9 Unit Energy Consumption of EPSs in Representative Product Class B (kWh/yr)

Application Efficiency Level CSL 0 CSL 1 CSL 2 CSL 3 CSL4 CSL 5 CSL 6 Camcorders 3.56 2.75 1.83 1.54 1.23 0.79 0.61 Cordless Phones 16.25 12.88 10.51 9.96 7.88 5.57 4.30 Digital Cameras 2.94 2.26 1.43 1.17 0.93 0.58 0.45 Flat Panel Monitors 41.52 32.92 26.86 25.45 20.15 14.22 10.99 Flatbed Scanners 27.98 22.18 18.10 17.15 13.58 9.58 7.41 Ink-Jet Computer Printers 14.67 11.63 9.49 8.99 7.12 5.02 3.88 LAN Equipment 43.32 34.35 28.03 26.56 21.02 14.84 11.47 Medical Devices 55.49 43.85 34.95 32.74 25.93 18.16 14.02 Modems/Fax Modems 72.20 57.25 46.72 44.26 35.04 24.73 19.11 Notebook Computers 39.50 31.24 25.08 23.58 18.67 13.10 10.12 Portable Audio Players 8.11 6.16 3.53 2.68 2.14 1.25 0.95 Portable Gaming Devices 16.14 12.65 9.49 8.62 6.83 4.68 3.61 Portable Video Players 30.58 24.10 18.83 17.47 13.84 9.63 7.43 Small LCD TVs 32.49 25.76 21.02 19.92 15.77 11.13 8.60 Telephone Answering Devices 16.02 12.70 10.37 9.82 7.77 5.49 4.24 Wi-Fi Access Points 36.10 28.62 23.36 22.13 17.52 12.37 9.56 Wireless Telephones 10.75 8.15 4.57 3.41 2.72 1.56 1.18 Representative Product Class B UEC 29.39 23.15 18.03 16.69 13.22 9.18 7.09

6-19Table 6.10 Unit Energy Consumption of EPSs in Representative Product Class F (kWh/yr)

Application Efficiency Level CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 CSL 6 Camcorders

- - - - - - Cordless Phones

- - - - - - Digital Cameras

- - - - - - Flat Panel Monitors 39.78 26.86 24.89 21.07 17.43 12.26 Flatbed Scanners

- - - - - - Ink-Jet Computer Printers

- - - - - - LAN Equipment

- - - - - - Medical Devices 114.19 76.07 70.13 59.34 49.05 34.39 Modems/Fax Modems 138.36 93.44 86.57 73.30 60.63 42.66 Notebook Computers 32.75 21.59 19.83 16.77 13.86 9.69 Portable Audio Players

- - - - - - Portable Gaming Devices

- - - - - - Portable Video Players

- - - - - - Small LCD TVs 27.67 18.69 17.31 14.66 12.13 8.53 Telephone Answering Devices

- - - - - - Wi-Fi Access Points

- - - - - - Wireless Telephones

- - - - - - Representative Product Class C UEC 40.63 27.04 24.92 21.09 17.43 12.21

References

1 Environmental Protection Agency. Qualified Product (QP) List for ENERGY STAR End-Use Products. http://energystar.gov/ia/produ cts/prod_lists/eup_prod_list.xls . Last Accessed December 17, 2007.
2 Environmental Protection Agency. Qualified Product (QP) Li st for ENERGY STAR AcDc Qualified External Power Supplies

. http://www.energystar.gov/ia/products /prod_lists/eps_ac_dc_prod_list.pdf . Last accessed December 17, 2007. 3 TIAX LLC. “Assessment of Analyses Performed for the California Energy Efficiency Regulations for Consumer Electronics Products.” February 2006. TIAX LLC: Cambridge, MA.

6-20CHAPTER 7. PRODUCT PRICE DETERMINATION

7.1 Introduction

...................................................................................................... 7-2 7.2 Battery Charger Markups

................................................................................. 7-3 7.3 External Power Supply Markups

..................................................................... 7-4

LIST OF FIGURES Figure 7.1. BC and EPS Product Di stribution Networks

................................................. 7-2

LIST OF TABLES Table 7.1. Retailer Markups for Battery Chargers

........................................................... 7-3 Table 7.2. BC Manufacturer-to-Consumer Markups

....................................................... 7-4 Table 7.3. OEM Markups for External Power Supplies

.................................................. 7-4 Table 7.4. Retailer Markups for External Power Supplies

.............................................. 7-5 Table 7.5. EPS Manufacturer-to-Consumer Markups

..................................................... 7-5

7-17.1 Introduction The purpose of the product price determina tion is to assess the impacts of the relationship between efficien cy and manufacturer selli ng price (MSP) on end users. Therefore, during the determination analys is, DOE developed a retail (consumer) price for each candidate standard level (CSL) used in the life-cycle cost (LCC) and pay back period (PBP) analyses and the national impact analysis. DOE used MSP estimates (chapter 5) and studied the distribution value chain for battery chargers (BCs) and external power supplies (EPSs) moving from manufacturer to end user. With that information, DOE calculated a manufacturer-to- retail markup to convert MSP estimates to retail price estimates. DOE also developed a sales tax estimate, which it applied to the retail price estimates to arrive at end-user product prices.

Component Manufacturers

BC Manufacturers

Consumer Product Retailers

Consumers OEMs Component Manufacturers

EPS Manufacturers

Consumer Product Retailers

Consumers OEMs EPS Distributors Battery Charger Distribution External Power Supply Distribution

Figure 7.1. BC and EPS Produc t Distribution Networks

Figure 7.1 shows the distribution networks for BCs and EPSs discussed in chapter 3. DOE estimated MSPs in its engineering analysis. To estimate OEM and retailer markups, DOE used publicly available data on the gross margins of major publicly traded manufacturers and retailers. 1 Gross margin represents that portion of revenues that are over and above the cost of goods sold. The cost of goods sold includes variable and fixed costs directly linked to the product, such as material and labor. DOE used the following formula to derive markups from gross margins:

7-2GrossM arg in Markup = 1 + Eq.7.1 1

− GrossM arg in

7.2 Battery Charger Markups Table 7.1 displays the retailers and thei r respective gross margins, which DOE used to estimate markups for the determination analysis. DOE chose these retailers because they represent significant distributi on channels for BC-powered applications. For BCs, DOE did not derive separate original equipment manufacturer (OEM) markups, because it received information from manufact urers about the prices at which BCs are sold to retailers. Table 7.1. Retailer Markups for Battery Chargers Battery Voltage Dominant Applications Leading Retailers Gross Margin (%) Markup Representative Product Class A

0 to ≤ 3 V Personal care products Wal-Mart 24.21 1.32 Target 32.74 1.49

CVS 22.83 1.30 Walgreens 28.35 1.40 Average Markup 1.37

Representative Product Class B

>3 to ≤ 9 V Universal battery chargers, digital cameras,

kitchen and

floor care appliances Wal-Mart 24.21 1.32 Target 32.74 1.49 Best Buy 23.99 1.31

Sears 28.37 1.40

Bed Bath & Beyond 42.47 1.74

Average Markup 1.45

Representative Product Classes C and F

> 9 V Power tools Home Depot 32.65 1.48
Lowe’s 34.76 1.53 Average Markup 1.51 Note: Gross margins current as of December 21, 2007.

The sales tax represents state and local sales taxes and is a multiplicative factor that increases the end-user product price. DOE obtained information on state and local sales taxes from the Sales Tax Clearinghous e. The Clearinghouse was established in August 1999 to facilitate the calculation of sale s and use taxes administered by the Nation's 7,000 taxing authorities at th e State, county, and city levels. 2 DOE used a national, population-weighted average sale s tax of 6.9 percent in its determination analysis.

7-3Using the sales tax information and information on markups by OEMs and retailers, DOE calculated the total markup for representati ve BC product classes (Table 7.2). Table 7.2. BC Manufacturer-to-Consumer Markups Battery Voltage

0 to ≤ 3 V >3 to ≤ 9 V > 9 V Slow Charging >9 V Fast Charging Retailer Markup 1.37 1.45 1.51 1.51 Sales Tax 1.069 1.069 1.069 1.069 Total Markup 1.46 1.55 1.61 1.61 Note: Total markup equals the product of the thr ee markups. Multiplying the manufacturer selling price by the total markup yields the consumer purchase price.

Take, for example, low-voltage BCs, whose ba ttery voltage is less than or equal to 3 volts. The manufacturer selling prices DOE used as inputs in its preliminary BC analysis represent the prices at which BCs are sold to retailers. DOE found that the principal retailers mark up products by 37 perc ent over their wholesale price, resulting in a markup of 1.37. The Sales Tax Clearinghouse re ported a national average sales tax of 6.9 percent or 1.069. Multiplying these markups gives a total markup of 46 percent or 1.46 for low-voltage BCs. DOE used the same process to arrive at manufacturer-to

consumer markups for EPSs and other BCs.

7.3 External Power Supply Markups Most EPSs are manufactured for an OE M and sold through a retailer to the consumer. DOE gathered gross margin data of major OEM manufacturers in each representative product class, in addition to gross margins for major retailers of those products (Table 7.3 and Table 7.4). Because the retail outlets fo r the dominant EPS product applications are similar, DOE used a single retailer markup for all EPSs. During work on its determination analysis, DOE did not adjust its gross margin figures to account for alternate distribution patterns for EPSs, such as direct sales from an OEM to a

consumer. Table 7.3. OEM Markups for External Power Supplies Representative Product Classes A and B Nameplate Output Power Dominant Applications Leading OEMs Gross Margin

(%) Markup

0 to < 4 W and ≥ 4 to ≤ 60 W Telecommunications equipment Nokia 32.73 1.49 Motorola 27.22 1.37 Average Markup 1.43

7-4Representative Product Class F Nameplate Output Power Dominant Applications Leading OEMs Gross Margin

(%) Markup

> 60 W Notebook computers Dell, Inc. 18.71 1.23 Hewlett Packard 24.36 1.32 Apple, Inc. 33.97 1.51 Average Markup 1.37 Table 7.4. Retailer Markups for External Power Supplies All Representative Product Classes

Nameplate Output Power Dominant Applications Leading Retailers Gross Margin

(%) Markup

All EPSs Consumer electronics Best Buy 24.00 1.32 Circuit City 22.50 1.29

Wal-Mart 24.21 1.32 Average Markup 1.31

Using the sales tax information and information on markups by OEMs and retailers, DOE calculated the to tal markup for representative EPS product classes (Table 7.5. Table 7.5. EPS Manufacturer-to-Consumer Markups Nameplate Output Power 0 to < 4 W ≥ 4 to ≤ 60 W > 60 W OEM Markup 1.43 1.43 1.36 Retailer Markup 1.31 1.31 1.31 Sales Tax 1.069 1.069 1.069 Total Markup 2.00 2.00 1.90 Note: Total markup equals the product of the thr ee markups. Multiplying the manufacturer selling price by the total markup yields the consumer purchase price.

References

1 Yahoo! Finance. . . . http://finance.yahoo.com . . . . Last accessed December 21, 2007.

2 Further information on the Sales Tax Cl earinghouse can be found at www.thestc.com.

7-5CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES

8.1 Introduction

............................................................................................................... .... 8-2

8.2 Overview of LCC and PBP Inputs

................................................................................ 8-2

8.3 Life-Cycle Cost Inputs

.................................................................................................. 8-5 8.3.1 Total Installed Cost Inputs

................................................................................... 8-6 8.3.2 Operating Cost Inputs

.......................................................................................... 8-8 8.3.3 Electricity Prices

................................................................................................ 8-10 8.3.4 Life-Cycle Cost Di scount Rates

......................................................................... 8-11 8.3.5 BC and EPS Operational Lifetimes

................................................................... 8-12

LIST OF FIGURES Figure 8.1. Flow Diagram of Inputs for th e Determination of LCC and PBP

............................. 8-4 Figure 8.2. AEO 2007 Residential Electri city Price Trend Forecast

......................................... 8-11

LIST OF TABLES Table 8.1. Draft Inputs to the Life-Cycle Cost and Payback Period Analysis

............................. 8-5 Table 8.3. Sales Tax by Divisi on and Large States

..................................................................... 8-8 Table 8.5. Shares and Interest or Return Rates Us ed for Household Debt and Equity Types

... 8-12 Table 8.6. Average Lifetimes for Ba ttery Charger Applications

............................................... 8-13 Table 8.7. Shipment-Weighted Average Lifetimes for Battery Chargers

................................. 8-13 Table 8.8. Average Lifetimes for Extern al Power Supply Applications

................................... 8-14 Table 8.9. Shipment-Weighted Average Lifetimes for External Power Supplies

..................... 8-14

8-18.1 Introduction This chapter describes the methodology that the Department of Energy (DOE) used to analyze the economic impacts of possible energy efficiency standa rds on individual consumers. DOE performed this analysis for the determinatio n analysis on the same representative units evaluated in the engineering analysis. The effect of standards on individual consumers includes a change in operating expense (u sually decreased) and a change in purchase price (usually increased). This chapter describes the two metrics DOE used in the consumer analysis to determine the effect of potential standards on individual consumers:

• Life-cycle cost (LCC) is the total consumer expe nse over the life of an appliance, including purchase price a nd operating costs (including energy expenditures). DOE discounts future operating costs to the time of purchase, and sums them over the lifetime of the equipment.

• Payback period (PBP) measures the amount of time it takes customers to recover the assumed higher purchase price of more energy-efficient equipment through lower operating costs. It represents the number of years it would ta ke the customer to recover the increased purchase price through decreased operating expenses.

DOE analyzed the net effect on consumers by calculating the LCC and PBP using data from the engineering analysis, the energy-use an d end-use load characte rization, and the product price determination.

8.2 Overview of LCC and PBP Inputs For the determination analysis, DOE categori zed inputs to the LCC and PBP analysis as follows: (1) inputs for establishi ng the purchase price, otherwis e known as the total installed cost, and (2) inputs for calc ulating the operating cost.

The primary inputs for establishing the total installed cost are:

• baseline manufacturer cost , or the costs incurred by the manufacturer to produce equipment meeting existing minimum efficiency standards;

• standard-level manufacturer cost increases , or the change in manufacturer cost associated with producing equipment to meet a particular standard level; and

• markups and sales tax , or the markups and sales tax associated with converting the manufacturer cost to a consumer equipment price (chapter 7).

The primary inputs for calcula ting the operating cost are:

• equipment energy consumption , the site energy use asso ciated with operating the equipment;

8-2• equipment efficiency , which dictates the equipment en ergy consumption associated with standard-level equipment ( i.e. , equipment with efficiencies greater than baseline equipment);

• energy prices , the prices paid by consumers for energy ( i.e. , electricity), determined using current energy prices based on data from DOE‘s Energy Information Administration (EIA);

• energy price trends , derived from the EIA Annual Energy Outlook 2007 (

AEO2007 ) to forecast energy prices into the future a ;

• lifetime , the age at which the equipment is retired from service; and

• discount rate , the rate at which DOE discounted fu ture expenditures to establish their present value.

Figure 8.1 presents the flow diagram for the draft determination analysis LCC developed in 2007. The figure depicts, from left to right, LCC inputs in yellow boxes, interim calculated values in green boxes, and final output values ( i.e. , LCC and PBP) in blue boxes. Table 8.1. lists the draft inputs DOE developed in 2 007 for the determination analysis.

a For the results presented in this chapter, DOE used the AEO2007 reference case to forecast future energy prices.

8-3Figure 8.1. Flow Diagram of Inputs for the Determination of LCC and PBP

8-4Table 8.1. Draft Inputs to the Life-Cycle Cost and Payback Period Analysis

Input Description Average or Typical Value Sources

Product Price The retail price before tax ( i.e.
, bundled with a consumer product). Based on a manufacturer selling price marked up through the distribution chain. Varies Distributor catalogs, highvolume price estimates, manufacturer interviews.

Sales Tax Used to convert the product price to a final consumer purchase price including sales
tax. 6.9% Weighted average of sales tax in 13 geographic regions and large states.

Unit Energy Consumption The annual on-site electricity consumption associated with a BC or EPS. Varies Developed in section 6, Energyuse and End-use Load Characterization. Electricity Prices The national residential sector average price per kilowatt-hour ( i.e. , $/kWh). $0.097/kWh in 2005 Energy Information Administration (EIA), discussed in section 8.3.3. Electricity Price Trends Projects changes in the price of electricity over the analysis period. Includes a high and low scenario. Varies The Annual Energy Outlook from the EIA.

Product Lifetime The total years in use after which the consumer retires the BC or EPS from service. The BC or EPS may be retired before the end of its useful life if the consumer product it operates is retired from service. 3 - 5 years Discussed in section 8.3.5.

Discount Rate The rate DOE estimates to be representative of BC and EPS consumers, used to discount future expenditures and establish their present value. 5.6% Weighted average of residential financing methods, discussed in section 8.3.4.

Analysis Period The time period over which DOE calculates the LCC. Product lifetime Discussed in section 8.3.5.

8.3 Life-Cycle Cost Inputs When calculating the LCC, DOE discounted future operating costs to the time of purchase and summed them over the lifetime of the equipment, as shown in Equation 1:

8-5N OC LCC = IC + 

## ∑ t
t Eq.8-1 

## ( 1 + r 

## )
t = 1

where:

LCC = life-cycle cost in dollars, IC = total installed cost in dollars, ∑ = sum over the lifetime, from year 1 to year N, N

= lifetime of product in years, OC = operating cost in dollars,

r

= discount rate, and
t = year for which operating cost is being determined.

DOE conducted preliminary work on the LCC as part of its determination analysis directed by EPACT 2005. The te xt that follows discusses some of these inputs and methodologies that DOE was developing wh en the analysis was rescheduled.

DOE developed an LCC methodology based on the approach followed in other rulemakings, but tailored it for some unique aspects of BCs and EPSs. For example, while the equation above mentions “total in stalled cost” in its list of LC C input variables, DOE considers these costs to be just the equipment price, because BCEPS installation typically entails a consumer simply unpacking the BC or EPS from the box it was sold in and connecting the device to mains power and its associated product or battery. Because the cost of this “installation” (which may be considered tem porary, as intermittently used devices might be unplugged for storage) is not quantif iable in dollar terms, DOE cons iders the installation cost to be zero.

The following sections discuss total installe d cost, operating cost, lifetime, and discount
rate.

8.3.1 Total Installed Cost Inputs DOE defines the total installed co st using the following equation:

IC = EQP Eq.8-2

where:

IC= total installed cost, e xpressed in dollars, and EQP = equipment price (i.e. , purchase price for the equipment only), expressed in dollars.

The equipment price is based on how the consumer purchases the equipment. DOE defined markups and sales taxes for converting manufacturing costs into consumer equipment prices. For BCs and EPSs the cost of installation is zero; therefore, it is not included in the equation.

8-6There are four inputs that de termine total in stalled cost.

• Baseline Manufacturer Cost

• Standard-Level Manufacturer Cost

• Markups

• Sales Tax

The baseline manufacturer cost is the cost incurred by the manufacturer to produce equipment meeting existing minimum efficiency standards. Standard-level manufacturer cost increases are the change in manufacturer cost associ ated with producing equipment at a standard level. Markups and sales tax convert the manufacturer cost to a consumer equipment price. Thus, the total installed cost accounts for all factors contributing to the consumer equipment price. DOE calculated the total instal led cost for baseline products based on the following equation:

IC BASE = EQP BASE Eq.8-3

= COST MFG × MU OVERALL

where:

IC BASE = baseline total installed cost, EQP BASE = consumer equipment price for baseline models, COST MFG = manufacturer cost for baseline models, and MU OVERALL = overall markup (product of manufacturer markup, retailer or distributor markup, and sales tax).

DOE calculated the total installed cost for st andard-level products based on the following equation:

IC = EQP STD STD

= 

## ( EQP BASE + ∆ EQP STD 

## ) Eq.8-4

= 

## ( IC + ∆ COST 

## ) × MU BASE MFG OVERALL

where:

IC STD = standard-level total installed cost, EQP STD = consumer equipment price for standard-level models, EQP BASE = consumer equipment price for baseline models, ∆ EQP STD = change in equipment price for standard-level models, IC BASE = baseline total installed cost, and ∆ COST MFG = change in manufacturer cost for standard-level models. MU OVERALL = overall markup (product of manufacturer markup, retailer or distributor markup, and sales tax).

8-7DOE researched information about each of th e above input variables that it used to calculate the total installed cost for external power supplies and battery chargers. DOE developed its manufacturer prices through manufacturer inte rviews, testing and teardowns, and researching distributor catalogues (chapt er 5). OEM, distributor, and retailer markups came from manufacturer interviews and a review of publicly available company fina ncial filings. Sales tax was based on a weighted average in 13 geograp hic regions and large states (Table 8.2).

Table 8.2. Sales Tax by Division and Large States

State/Region Sales Tax (%) 1 2 3 4 5 6 7 8 9 10 11 12 13 New England Mid Atlantic East North Central West North Central South Atlantic East South Central West South Central Mountain Pacific New York State California Texas Florida 4.8 7.1 15.5

6.7 13.0

5.9 3.6 7.0 4.0 6.4 12.2

7.9 6.0 U.S. Average 6.9

8.3.2 Operating Cost Inputs DOE defines the operating cost by the following equation:

OC = EC Eq.8-5

where:

OC = operating cost, expressed in dollars, and EC = energy expenditure asso ciated with operating the equipment.

Although operating costs typically encompa ss repair and maintenance costs, DOE considered those costs (which ar e usually associated with larger products and appliances) to be zero in the draft LCC for the determination an alysis. In making this decision, DOE recognized the reality of the marketplace, where the service life of a BC or EPS typically exceeds that of the consumer product with which it is designed to oper ate. Thus, a consumer would not incur repair or maintenance costs for a BC or EPS. Also, if a BC or EPS did fail, DOE expects that consumers would typically discard the devi ce and purchase a replacement BC or EPS.

8-8__ The inputs for determining the operating costs are listed below.

• Annual Energy Consumption

• Energy Prices

• Energy Trends

• Product Lifetime

• Discount Rate

• Effective Date of Standard

The annual energy consumption is the site energy use associated with operating the equipment. The annual energy consumption varies with the product efficiency. That is, the energy consumption associated w ith standard-level equipment ( i.e. , equipment with efficiencies greater than baseline equipment) is less than the consumptions asso ciated with baseline equipment. Energy prices are the prices paid by consumers for energy ( i.e. , electricity). Multiplying the annual energy by the energy prices yields the annual energy cost. DOE used energy price trends to forecast energy prices into the future and, along with the product lifetime and discount rate, to establish the lifetime energy costs. The product lifetime is the age at which the equipment is retired from service. The discount rate is the rate at which DOE discounted future expenditures to establish their present value. DOE calculated the operating cost for baseline products based on the following equation:

OC = EC BASE BASE Eq.8-6

= AEC BASE × PRICE ENERGY

where:

OC BASE = baseline operating cost, EC BASE = energy expenditure associated with operating the baseline equipment, AEC BASE = annual energy consumption for baseline equipment, and PRICE ENERGY = energy price.

DOE calculated the operating cost for standard-level products based on the following equation:

OC STD = EC STD

= AEC × PRICE Eq.8.7 STD ENERGY

= 

# ( AEC ∆ AEC 

# ) × PRICE BASE STD ENERGY

where:

OC STD = standard-level operating cost, EC STD = energy expenditure associat ed with operating standardlevel equipment, AEC STD = annual energy consumption for standard-level equipment,

8-9PRICE ENERGY = energy price, ∆

AEC STD = change in annual energy c onsumption caused by standardlevel equipment, and AEC BASE = annual energy consumption for baseline equipment.

The following sections provide information about electricity pri ces, discount rate, and product lifetime that DOE used to calculate the operating costs for external power supplies and battery chargers. Annual energy consum ption is discussed in chapter 6.

8.3.3 Electricity Prices For residential consumers of BCs and EPSs, DOE used projections of national average electricity prices from EIA’s Annual Energy Outlook ( AEO ) for the most recent year available. In other rulemakings, DOE has calculated a regiona lly-weighted average electricity price, based on inventories of products developed through EI A’s Residential Energy Consumption Survey. This data allows the electricity price used in the LCC to be more accurate if products have different regional sales rates ( i.e. , heaters in colder regions). Howe ver, the survey did not include questions on inventories of BCs and EPSs; th erefore, DOE was unable to create a national installed-base-weighted averag e electricity price. Instead, DOE used the national average electricity price, as published by EIA.

To ascertain the sensitivity of the LCC to fu ture electricity price trends as well as the reference case, DOE evaluated the LCC using both the low and high economic growth cases. Together, these three cases reflec t the uncertainty in electricity prices over the analysis period. Figure 8.2 presents the residen tial electricity price trends (in constant 2007$), based on AEO 2007 projections.

8-10Cents/kWh (2007$) 10.8

10.7

10.6

10.5

10.4

10.3

10.2

10.1

10.0

9.9 High

Low

Ref

9.8

2006 2008 2010 2012 2014 2016 2018 2020 2022

Figure 8.2. AEO 2007 Residential Elect ricity Price Trend Forecast

8.3.4 Life-Cycle Cost Discount Rates Discounting reflects the current value of money spent or saved in the future. As discussed, calculating consumer LCC required DOE to use a di scount rate to determine the present value of the money the consumer would spend to operate the BCs and EPSs over their lifetime. Because consumers can use a variety of financial means to purchase a BC or EPS, the discount rate should equal the average cost of capital to the consum er. DOE assumed these financial means, listed in Table 8.3, to be simila r to the ones consumers use when purchasing and financing replacement appliances for the home.

DOE adapted the LCC discount rate derived in the home appliances rulemaking to its draft analysis. DOE’s approach involved identi fying all possible debt or asset classes that consumers might use to purchase replacement equi pment, including household assets that might be affected indirectly.

DOE estimated the shares of the various de bt and equity classes in the typical U.S. household portfolio using the Federal Reserve’s Survey of Consumer Finances ( SCF ) data for 1989, 1992, 1995, 1998, 2001, and 2004. DOE also used SCF data to determine rates of return for each class. DOE then calculated an average rate weighted by the share of each class of debt or equity, equal to 5.6 percent, to represent a household discount rate , shown in Table 8.3.

8-11Table 8.3. Shares and Interest or Return Rate s Used for Household Debt and Equity Types

Type Average Share of Household Debt Plus Equity* (%) Mean Real Effective Discount Rate** (%) Home Equity Loans 3.6
Credit Cards 2.0
Other Installment Loans 1.7
Other Residential Loans 4.9
Other Line of Credit 0.5 Checking Accounts 4.5 Savings and Money Market Accounts 15.7 Certificates of Deposit 9.0 Savings Bonds 1.5
Bonds 10.0
Stocks 29.1
Mutual Funds 17.5 4.0 11.0

6.0 4.6 8.7 0.0 2.3 2.4 3.5
4.2 8.8 7.0 Total/Weighted-Average Discount Rate 100

* Not including primary mortgage or retirement accounts. ** Adjusted for inflation and, for home equity loans, loan interest tax deduction. 5.6

8.3.5 BC and EPS Operational Lifetimes Lifetime data are important for determining life-cycle costs and pa yback periods. In the NIA, lifetime data allow for an estimate of the total stock of EPSs being used. Because BCs and EPSs are often made specifically for use with par ticular consumer products, their lifetimes relate directly to the lifetim es of those products. DOE assumed that once the consumer product has reached the end of its useful life, the user typically discards the associated BC or EPS. Therefore, for each group of BCs and EPSs, DOE gather ed lifetime values for consumer product applications and combined them with shipment estimates to derive a shipment-weighted average lifetime representative of the group. Average lifetim es for BC and EPS applications are shown in Table 8.4 and Table 8.6.

DOE estimated lifetimes for categories that include multiple applications by examining the lifetimes of popular applications within them. For example, DOE examined the lifetimes of shavers, beard trimmers, hand-held massagers, and heating pads and used their relative shipments to derive the lifetime of personal care products . With shipments data and these application lifetimes, DOE calculated the shipment-weighted average lifetime of each representative product class of BCs and EPSs. These values are shown in 1. Appliance Magazine. . 30th Annual Portrait of the U.S. Appliance Industry. . September 2007. 2. U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy. . FY2005 Preliminary PrioritySetting Summary Report and Actions Proposed. . Appendix A: FY2005 Technical Support Document. . Table A9-1:

8-12Background Data on Battery Chargers and Power Supplies . Cited henceforth as DOE FY05 Rulemaking Appendix A9

.
Table 8.5 and Table 8.7.

Table 8.4. Average Lifetimes for Battery Charger Applications

Representative Product Class Application Lifetime (Years) Source

A Personal Care Products 3 Appliance Magazine 1 Kitchen Products 6 Appliance Magazine 1 Floor Care Products 6 Appliance Magazine 1 Universal Battery Chargers 4 DOE estimate B Digital Cameras 6 DOE FY05 Rulemaking Appendix A9 2 Camcorders 6 DOE FY05 Rulemaking Appendix A9 2
C DIY Power Tools 5 DOE estimate F Pro Power Tools 5 DOE estimate 1. Appliance Magazine. . 30th Annual Portrait of the U.S. Appliance Industry. . September 2007. 2. U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy. . FY2005 Preliminary PrioritySetting Summary Report and Actions Proposed. . Appendix A: FY2005 Technical Support Document. . Table A9-1: Background Data on Battery Chargers and Power Supplies . Cited henceforth as DOE FY05 Rulemaking Appendix A9

.

Table 8.5. Shipment-Weighted Average Lifetimes for Battery Chargers

Battery Voltage
0 to ≤ 3 V >3 to ≤ 9 V > 9 V Slow Charging >9 V Fast Charging
Lifetime 3 years 5 years 5 years 5 years

8-13Table 8.6. Average Lifetimes for Ext ernal Power Supply Applications

Application Lifetime (Years) Source

Ink-Jet Computer Printers 5 DOE FY05 Rulemaking Appendix A9 Notebook Computers 4 DOE FY05 Rulemaking Appendix A9 Modems/Fax Modems 4 DOE FY05 Rulemaking Appendix A9 LAN Equipment 4 DOE FY05 Rulemaking Appendix A9 Wi-Fi Access Points 4 DOE FY05 Rulemaking Appendix A9 Flat Panel Monitors 4 DOE FY05 Rulemaking Appendix A9 Flatbed Scanners 4 Estimated based on average computer peripheral lifetime Portable Video Players 4 Estimated based on TV/VCR/DVD combined lifetime of 6 years, adjusting for increased wear and tear Cordless Phones 6 DOE FY05 Rulemaking Appendix A9 Wireless Telephones 2 DOE FY05 Rulemaking Appendix A9 Telephone Answering Devices 6 DOE FY05 Rulemaking Appendix A9 Digital Cameras 6 DOE FY05 Rulemaking Appendix A9

Portable Gaming Devices 2 Estimated based on fast turnover of gaming operating systems and software, as well as greater wear and tear relative to stationary gaming systems. Small LCD TVs 6 DOE FY05 Rulemaking Appendix A9 Portable Audio Players 6 DOE estimate Camcorders 6 DOE FY05 Rulemaking Appendix A9 Table 8.7. Shipment-Weighted Average Li fetimes for External Power Supplies

Nameplate Output Power
0 to < 4 W ≥ 4 to ≤ 60 W > 60 W
Lifetime 4 years 5 years 4 years

References 1. Appliance Magazine. . 30th Annual Portrait of the U.S. Appliance Industry. . September 2007. 2. U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy. . FY2005 Preliminary Priority-Setting Summary Report and Actions Proposed. . Appendix A: FY2005 Technical Support Document. . Table A9-1: Background Data on Battery Chargers and Power Supplies . . (Last accessed March 3, 2006.) www.eere.energy.gov/buildings/appliance_stan dards/pdfs/fy05_priority_setting_app_a.pdf

.

8-14CHAPTER 9. SHIPMENTS ANALYSIS

9.1 Current Year Shipments

................................................................................... 9-3 9.1.1 Battery Charger Shipments

...................................................................... 9-3 9.1.2 External Power Supply Shipments

........................................................... 9-4 9.2 Base Case Shipments Forecasts

....................................................................... 9-8 9.2.1 Total Annual Shipments

.......................................................................... 9-8 9.2.2 Natural Progression of E fficiency Over Time

......................................... 9-9 9.3 Standards Case Shipments Forecasts

............................................................. 9-12 9.3.1 Impact of Standards on Total Annual Shipments

.................................. 9-13 9.3.2 Impact of Standards on Distribution of Shipments Across Efficiency Levels 9-13 9.3.3 Adjusting Dynamic Progression Rates Following the Standard

............ 9-14

LIST OF FIGURES

Figure 9.1. Progression in a D ynamic Market State

...................................................... 9-15

LIST OF TABLES

Table 9.1. Battery Charger Shipments by Repr esentative Product Class in 2007

........... 9-3 Table 9.2. Distribution of BC Sh ipments Across Efficiency Levels by Representative

Table 9.4. Distribution of E PS Application Shipments Ac ross Representative Product

Table 9.5. External Power Supply Shipments by Representative Product Class in 20079-6

Table 9.9. Final Distribution of Shipments by Ef ficiency for External Power Supplies.9-8

Table 9.16. EPS Representative Product Cla ss A, Dynamic Natural Progression, Base

Table 9.17. EPS Representative Product Class A, Dynamic Natural Progression, Standard Product Class in 2007

...................................................................................................... 9-3 Table 9.3. Distribution of BCs in Repres entative Product Class B by CSL

.................... 9-4

Classes in 2007 (as a Percentage of Total Shipments)

.................................................... 9-6

Table 9.6. Distribution of External Power Suppl y Shipments by Efficiency – Part 1

..... 9-7 Table 9.7. Distribution of External Power Suppl y Shipments by Efficiency – Part 2

..... 9-7 Table 9.8. Distribution of 2.75-Watt External Power Supply Models by Efficiency

...... 9-8

Table 9.10. Base Case Shipments Grow th Rates for BCs and EPSs

............................... 9-9 Table 9.11. Static Scenario for Grou p A EPSs in the Base Case

................................... 9-11 Table 9.12. Dynamic Scenario for Group A EPSs in the Base Case

............................. 9-12 Table 9.13. Example of a Roll-Up Response

................................................................. 9-14 Table 9.14. Example of a Shift Response

...................................................................... 9-14 Table 9.15. List of Following Ro ll-Up and Shift Tables

............................................... 9-16

Case

........................................................................................................................... ..... 9-17

at CSL3, Roll-Up Response

........................................................................................... 9-18

9-1Table 9.18. EPS Representative Product Class A, Dynamic Natural Progression, Standard at CSL3, Shift Response

................................................................................................ 9-19 Table 9.19. EPS Representative Product Cla ss B, Dynamic Natural Progression, Base

Table 9.20. EPS Representative Product Class B, Dynamic Natural Progression, Standard

Table 9.21. EPS Representative Product Class B, Dynamic Natural Progression, Standard

Table 9.22. EPS Representative Product Cla ss F, Dynamic Natural Progression, Base

Table 9.23. EPS Representative Product Class F, Dynamic Natural Progression, Standard

Table 9.24. EPS Representative Product Class F, Dynamic Natural Progression, Standard Case

........................................................................................................................... ..... 9-20

at CSL3, Roll-Up Response

........................................................................................... 9-21

at CSL3, Shift Response

................................................................................................ 9-22

Case

........................................................................................................................... ..... 9-23

at CSL3, Roll-Up Response

........................................................................................... 9-24

at CSL3, Shift Response

................................................................................................ 9-25

9-29.1 Current Year Shipments In its work on the determination analys is, DOE estimated that 70 million battery chargers and 397 million external power supplie s were sold in the United States in 2007. DOE divided total shipments into the BC and EPS representative product classes described in chapter 3.

9.1.1 Battery Charger Shipments Based on its analysis and i nput from manufacturers, DOE divided BC applications into three representative product classes, grouped by battery voltage. Because of the prevalence of fast chargers for professional pow er tool applications, the analysis of the high-voltage product class C further focused on two representative units differing in charge rate. Table 9.1 shows the distribution of BC shipments by representative product class. Table 9.1. Battery Charger Shipments by Representative Product Class in 2007

Representative Product Class Dominant Applications Total Shipments (millions) Class A (0 to ≤ 3 V) Personal Care Products 5.1

Classes B (>3 to ≤ 9 V) Kitchen Products Floor Care Products Universal BCs Digital Cameras Camcorders 41.7

Class C (> 9 V) Power Tools 22.8 All Groups All Applications 69.6

Table 9.2 shows the distribution of BC sh ipments by candidate standard level (CSL) used in the determination analysis. To divide the shipments of BCs among the CSLs (discussed in chapter 5 of the Draft Technical Report), DOE began with a large dataset published by the California Energy Co mmission, counting the number of models that met each CSL. 1 However, DOE included in the c ount only those BCs with a battery voltage close to those of th e representative units. As a result, the sample sizes are relatively small. Table 9.2. Distribution of BC Shipments Acro ss Efficiency Levels by Representative Product Class in 2007

CSL Efficiency Level Class A (0 to ≤ 3 V)

(percent) Class B (>3 to ≤ 9 V) (percent) Class C (>9 V) (percent) CSL0 Baseline 60 45 65 CSL1 Slightly Improved 20 13 10 CSL2 CEC Tier 1/ENERGY STAR 13 26 10 CSL3 Beyond Standard 0 10 15 CSL4 Best-in-Market Technology 7 6 0 All Levels 100 100 100

9-3Product class A had a representative unit with a battery voltage of 1.2 volts, but DOE included in the count all uni ts with a battery voltage between 0 volts and 3 volts to ensure an adequate sample size. Similarly, th e representative unit for product class B had a battery voltage of 4.8 volts, but DOE include d in the count all units with a battery voltage between 3.6 volts and 6 volts. For pr oduct class C, DOE included all BCs with a battery voltage between 18 volts and 19.2 volts . DOE did not differentiate between fast and slow models when counting BCs in this class.

The final count used to distribute BCs among the CSLs included 15 units for representative product class A, 62 for product class B, and 20 for product class C. Table 9.3 shows how representative units from the da taset were distributed among the CSLs for representative product class B. Table 9.3. Distribution of BCs in Rep resentative Product Class B by CSL

CSL Efficiency Level Number of Units, 3.6 to 6 V Percent of Total

CSL0 Base Line 33 45 CSL1 Slightly Improved 8 13 CSL2 CEC Tier 1/ENERGY STAR 22 26 CSL3 Beyond Standard 6 10 CSL4 Best-in-Market 7 6 All Levels 62 100

Because shipments data for the individual BCs in the dataset were not available, the BC models in the dataset that DOE include d in the count were not weighted by their shipments. Thus, the base case distribution in Table 9.3 is only a rough representation of the population of BCs in the market.

9.1.2 External Power Supply Shipments DOE divided EPSs into three representative product classes based on nameplate output power. However, many applications us ing an EPS spanned tw o product classes. DOE referred to prior work by the California Energy Commission on consumer electronic products for guidance on fitting a pplications into the three representative product classes. 2

9-4Table 9.4 shows the distribution of EPS app lication shipments across product classes; Table 9.5 shows the total EPS shipments in each product class.

9-5Table 9.4. Distribution of EPS Applicat ion Shipments Across Representative Product Classes in 2007 (as a Percentage of Total Shipments)
Application Class A 0 to < 4 W

(percent) Class B ≥ 4 to ≤ 60 W (percent) Class F > 60 W (percent All Classes (percent) Ink-Jet Computer Printers 0 100 0 100 Notebook Computers 0 15 85 100 Modems/Fax Modems 0 92 8 100 LAN Equipment 0 100 0 100 Wi-Fi Access Points 0 100 0 100 Flat Panel Monitors 0 100 0 100 Flatbed Scanners 0 100 0 100 Medical Devices 10 87 3 100 Portable Video Players 0 100 0 100 Cordless Telephones 75 25 0 100 Cellular Telephones 50 50 0 100 Telephone Answering Devices 50 50 0 100 Digital Cameras 25 75 0 100 Portable Gaming Devices 0 100 0 100 Small LCD Tvs 0 70 30 100 Portable Audio Players 40 60 0 100 Camcorders 0 100 0 100

Table 9.5. External Power Supply Shipments by Representative Product Class in 2007

Representative Product Class Shipments (millions) Class A (0 to < 4 W) 112.2 Class B ( ≥ 4 to ≤ 60 W) 249.5 Class F (> 60 W) 35.5

During work on the determination analysis, DOE found limited information on the distribution of shipments by efficiency level. The Darn ell Group forecasted that in 2007, 21 percent of EPSs on the market woul d use line-frequency technology and the remaining EPSs would use switched-mode technology. 3 However, during the Scoping Workshop in January 2007, some stakeholde rs noted that this figure was too high. 4 For simplicity, DOE assumed that line-fre quency EPSs made up 20 percent of 2007 shipments (79.4 million of 397.2 million total E PSs). Although some of the available line-frequency power supplies met CSL2, the specific number of shipments was unknown. DOE estimated that the number is likely to be very small. To simplify matters, DOE assumed that all line-f requency power supplies fell into CSL0, and divided the remaining 80 percent among the higher CSLs.

Information gathered during work on the e ngineering analysis suggested that as output power increases, line-frequency power supplies become less common. DOE assumed product class F contained no line-fr equency supplies. DOE also assumed that half of all line-frequency power supplies are in product class A (39.7 million of 112.2 million EPSs) and half in product class B (39.7 million of 249.5 million EPSs). Thus, 35

9-6percent of total shipments in product class A fell in CSL0. In product class B, 16 percent of total shipments fell in CSL0.

Before CEC Tier 1 became a mandatory standard in California, a 2004 study completed by Pacific Gas and Electric estimated that 40 percent of the market already met the qualifications, which corresponded to CSL2. 5 DOE assumed this 40 percent was distributed evenly across re presentative product classes. a In product class A, if 35 percent of EPSs are in CSL0 and 40 percent meet CS L2 or better, then the remaining 25 percent meet CSL1. Applying this logic to repres entative product classes B and F, CSL1 comprises 44 and 60 percent of EPSs in each class, respectively (Table 9.6). Table 9.6. Distribution of External Power Supply Shipments by Efficiency – Part 1

CSL Efficiency Level Group A (0 to < 4 W) (percent) Group B ( ≥ 4 to ≤ 60 W) (percent) Group F (> 60 W) (percent) CSL0 Baseline Line Frequency 35 16 0 CSL1 Baseline SMPS 25 44 60 CSL2 CEC 1

40 40 40 CSL3 CEC 2 CSL4 > CEC 2 CSL5 Market Best CSL6 Max Tech All Levels 100 100 100
The study further estimated that 25 percent of the 2004 EPS market was at least as efficient as CEC Tier 2 Standards, corres ponding to CSL3. With this information, DOE calculated the percentage of E PSs in CSL2 as 15 percent - th e remainder of the original 40 percent meeting CEC Tier 1 or better (Table 9.7). DOE assumed that no products on the market met the max-tech efficiency level (CSL6).

Table 9.7. Distribution of External Power Supply Shipments by Efficiency – Part 2

CSL Efficiency Level Group A 0 to < 4 W

(percent) Group B ≥ 4 to ≤ 60 W (percent) Group F > 60 W (percent) CSL0 Baseline Line Frequency 35 16 0 CSL1 Baseline SMPS 25 44 60 CSL2 CEC 1 15 15 15 CSL3 CEC 2 25 25 25 CSL4 > CEC 2 CSL5 Market Best CSL6 Max Tech 0 0 0 Total 100 100 100
To divide the final 25 percent of ship ments among CSL3, CSL4, and CSL5, DOE used the ENERGY STAR list of qualified EPS units. 6 DOE examined a subset of EPSs

a The CEC Tier 1 standard that California adopted is slightly more stringent than that suggested by the literature above. This should not have a significant impact on the percentage of the market that already met the standard.

9-7whose nameplate output power matched that of the representative units (developed in the engineering analysis) in each representative pr oduct class. Units selected met or exceeded CSL3 active mode efficiency. The list in cluded 10 units at 2.75 watts, 39 units at 18 watts, and 16 units at 120 watts, which we re then divided am ong CSL3, CSL4, and CSL5. Table 9.8 shows the categorization of units at 2.75 watts by active mode efficiency. DOE applied the same technique to representative product classes B and F. Because shipments data for the individual EPSs in the data set were not available DOE did not weight the EPSs in CSL3, CSL4, and CSL5 by their shipments. Thus, the distribution in those CSLs may not have accu rately represented the population of EPSs shipped to the market.

Table 9.8. Distribution of 2.75-Watt External Power Supply Models by Efficiency

CSL Name Number of Units, 2.75 W Percent of Total

CSL3 CEC 2 5 50 CSL4 > CEC 2 4 40 CSL5 Market Best 1 10 CSL6 Max Tech 0 0 Total 10 100

This last piece of information provides the entire distributi on of shipments across efficiency levels that DOE used in its determination analysis.

Table 9.9. Final Distribution of Shipments by Efficiency for External Power Supplies

CSL Name Group A 0 to < 4 W

(percent) Group B ≥ 4 to ≤ 60 W (percent) Group F > 60 W (percent) CSL0 Baseline Line Frequency 35 16 0 CSL1 Baseline SMPS 25 44 60 CSL2 CEC 1 15 15 15 CSL3 CEC 2 12 6 9 CSL4 > CEC 2 10 18 5 CSL5 Market Best 3 1 11 CSL6 Max Tech 0 0 0

9.2 Base Case Shipments Forecasts

9.2.1 Total Annual Shipments To evaluate the various impacts of st andards, DOE developed a base case shipments forecast against which to compar e the standards case shipments forecasts developed for each CSL. For the determination analysis, DOE designed the base case forecasts based on what it anticipated would happen to energy consumption and energy costs over time if federal energy conservation standards were not adopted. In determining the base case forecasts, DOE considered hist orical shipments, the mix of BC and EPS

9-8efficiencies currently sold, and how that mix might change over time if new standards are not adopted.

The base case shipments model tracked the aging and replacement of BCs and EPSs given product lifetimes (chapter 8) a nd projected future BC and EPS sales growth. Shipments growth rates for many applications using BCs and EPSs have been historically high. This has been especially true for higher-wattage EPS applications. Also, as applications incorporate more features, output powers have risen to accommodate them. For example, compared to a basic cellular telephone, cellular tele phones that incorporate a digital camera and PDA functionality requir e a higher-capacity battery and therefore an EPS with a higher output power to charge it.

In the determination analysis, DOE used th e constant annual growth rates in Table 9.10 as reference values. These growth rates considered historic shipments of BCs and EPSs, market saturation of those products, and U.S. popul ation growth. High saturation of consumer products would tend to slow growth in BC and EPS shipments. DOE considered population growth, which was pr ojected to average 0.79 percent per year during the analysis period (2014 to 2039) to be the lower bound of its considered growth
rates. 7

Because recent improvements in battery charging systems such as shorter charge times helped increase demand for BCs, DOE es timated growth rates to be 4 percent per year for each BC product class. Because of a high saturation of cellular telephones and their dominance in the 0 to 4 watt EPS cate gory, DOE estimated growth to be only 2 percent per year over th e analysis period for this product class. EPSs with higher output have been growing more quickly in recen t years, with the highest output category experiencing the fastest growth and the least saturation. DOE es timated that EPSs between 4 and 60 watts would grow 3 percent per year and EPSs above 60 watts would grow 4 percent per year between 2014 and 2039.

Table 9.10. Base Case Shipments Growth Rates for BCs and EPSs
Battery Chargers Compound Annual Growth Rate

(percent) All Representative Product Classes 4

External Power Supplies Compound Annual Growth Rate

(percent) Representative Product Class A (0 to < 4 W) 2 Representative Product Class B ( ≥ 4 and ≤ 60 W) 3 Representative Product Class F (> 60 W) 4

9.2.2 Natural Progression of Efficiency Over Time To provide an upper and lower bound for estimated energy savings in the NIA, DOE considered two possibilities for the natu ral market state of efficiencies over time.

9-9Natural in this case referred to improvements in efficiency that might take place independent of a federal standard. These two market states, static and dynamic, presented situations in which the BC and EPS market s would experience either no improvement in efficiency (static) or progressive improvements in efficiency (dynamic).

To simplify calculations, DOE assumed that the natural market state could be either static or dynamic, but that the market could not change states within the period of analysis. That is, markets could not change from static to dynamic or from dynamic to static.

The static market state represented the case in which there would be no progression toward higher efficiency. Because the efficiency of BCs or EPSs would remain unchanged outside a standard, scenario s with a static market state represented cases in which a standard would have the mo st impact in generating energy savings and thus provided an upper bound for energy savings . As reflected in the National Energy Savings model, a static natural market state was represented by an unchanging distribution of efficiencies over time. Table 9.11 gives the static scenario for group A EPSs in the base case (no standard) as cal culated for the NES in the determination analysis. Although only EPS tables are provi ded as examples, the same model would apply to BCs; however, DOE did not comple te equivalent tables for BCs for the determination analysis.

9-10Table 9.11. Static Scenario for Group A EPSs in the Base Case

Year Distribution of Shipments A cross Efficiency Levels (percent) CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 CSL6 2007 35 25 15 12 10 3 0 2008 35 25 15 12 10 3 0 2009 35 25 15 12 10 3 0 2010 35 25 15 12 10 3 0 2011 35 25 15 12 10 3 0 2012 35 25 15 12 10 3 0 2013 35 25 15 12 10 3 0 2014 35 25 15 12 10 3 0 2015 35 25 15 12 10 3 0 2016 35 25 15 12 10 3 0 2017 35 25 15 12 10 3 0 2018 35 25 15 12 10 3 0 2019 35 25 15 12 10 3 0 2020 35 25 15 12 10 3 0 2021 35 25 15 12 10 3 0 2022 35 25 15 12 10 3 0 2023 35 25 15 12 10 3 0 2024 35 25 15 12 10 3 0 2025 35 25 15 12 10 3 0 2026 35 25 15 12 10 3 0 2027 35 25 15 12 10 3 0 2028 35 25 15 12 10 3 0 2029 35 25 15 12 10 3 0 2030 35 25 15 12 10 3 0 2031 35 25 15 12 10 3 0 2032 35 25 15 12 10 3 0 2033 35 25 15 12 10 3 0 2034 35 25 15 12 10 3 0 2035 35 25 15 12 10 3 0 2036 35 25 15 12 10 3 0 2037 35 25 15 12 10 3 0 2038 35 25 15 12 10 3 0

The dynamic market state represented the case in which the BC and EPS market would progress toward higher efficiency regardless of the presence of a standard. Because the efficiencies of BCs and EPSs would improve naturally, scenarios with a dynamic market state represented cases in whic h a standard would have the least impact on generating energy savings, and thus pr ovided the lower bound for energy savings.

During its work on the determination analysis, DOE assumed that a dynamic market state would progress toward CS L5 (Best-in-Market Technology), with 100 percent of production in CSL5 in the last y ear of the analysis period. To reflect the assumption of diminishing returns on effi ciency improvements, the time for each subsequent progression step was increased, i.e. , while the progression from CSL0 to CSL1 would take only 3 years, the progressi on from CSL1 to CSL2 would take 4 years,

9-11the progression from CSL2 to CSL3 would take 6 years, etc. Table 9.12 gives the dynamic scenario for class A EPSs in the base case (no standard) as calculated for the NES in the determination analysis.

Table 9.12. Dynamic Scenario for Group A EPSs in the Base Case

Year Distribution of Shipments Acro ss Efficiency Levels (percent) CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 CSL6 2007 35 25 15 12 10 3 0 2008 23 33 17 13 10 5 0 2009 12 40 18 13 11 6 0 2010 0 48 20 14 11 8 0 2011 0 36 29 14 11 9 0 2012 0 24 39 15 12 11 0 2013 0 12 48 16 12 12 0 2014 0 0 58 17 12 14 0 2015 0 0 48 25 13 15 0 2016 0 0 38 33 13 16 0 2017 0 0 29 41 13 17 0 2018 0 0 19 50 14 18 0 2019 0 0 10 58 14 19 0 2020 0 0 0 66 15 20 0 2021 0 0 0 58 22 21 0 2022 0 0 0 49 29 21 0 2023 0 0 0 41 36 22 0 2024 0 0 0 33 44 23 0 2025 0 0 0 25 51 24 0 2026 0 0 0 16 58 25 0 2027 0 0 0 8 66 26 0 2028 0 0 0 0 73 27 0 2029 0 0 0 0 66 34 0 2030 0 0 0 0 59 42 0 2031 0 0 0 0 51 49 0 2032 0 0 0 0 44 56 0 2033 0 0 0 0 37 63 0 2034 0 0 0 0 29 71 0 2035 0 0 0 0 22 78 0 2036 0 0 0 0 15 85 0 2037 0 0 0 0 7 93 0 2038 0 0 0 0 0 100 0

9.3 Standards Case Shipments Forecasts After calculating the volume of shipments and distribution across efficiency levels in the base case, DOE considered the market response to the standard with respect to (1) the total volume of shipments, and (2) the distribution of those shipments across efficiency levels.

9-129.3.1 Impact of Standards on Total Annual Shipments For the determination analysis, DOE made the simplifying assumption that the aggregate demand for BCs and EPSs would be the same in the standards case as in the base case. This assumption was based on two f actors. First, the cost of BCs and EPSs would not increase much relative to the cost of the application; therefore, the increased manufacturing cost would not materia lly affect consumer demand. Second, the substitution options for BCs a nd EPSs are limited due to the design considerations and functionality of BCs and EPSs. That is, desi gners cannot easily substitute another power supply technology when size or the ability to operate without mains power are important attributes of the product. Th erefore, DOE assumed that st andards would have no impact on the volume of shipments of BCs and EPSs, a nd the shipment growth rate as calculated in section 9.2.1 could be used fo r both base and standards cases.

9.3.2 Impact of Standards on Distribution of Shipments Across Efficiency Levels To account for the change in distribution across efficiencies due to a standard, DOE considered two possibilities for how ma nufacturers would adapt production: roll-up and shift. Note that these two responses occur between the year immediately preceding the standard and the year the standard ta kes effect, and are intended to reflect the immediate need of the market to comply w ith the increased efficiency required by the standard.

9.3.2.1 Roll-Up Response In the roll-up scenario, DOE assumed that manufacturers would stop producing units that did not meet the standard but would maintain total production levels by producing more of those units that just met the standard. Looking at the overall distribution of efficiencies in the marketplace, those units that did not meet the standard would be “rolled up” to the minimum effici ency level set by the standard, while units already meeting the standard would remain unchanged. This response gives a lower bound on energy savings, because the roll-up response represents the minimum possible improvement in energy efficiency.

Table 9.13 gives an example of a roll-up res ponse to a standard set at CSL2 for EPSs in representative product class A. In the year before the effective date of the standard (2013), units are produced at all effi ciency levels. The year the standard takes effect (2014), units at CSL0 and CSL1 no l onger meet the efficiency required by the standard. As a result, the units produced at those levels are rolled up to CSL2. Thus:

• the 35 percent of the market at CSL0 and the 25 percent of the market at CSL1 are rolled up and added to the 15 percent of the market at CSL2; and

• the portions of the market at CSL3, CSL4, and CSL5 are unaffected and are carried down with no changes.

9-13Table 9.13. Example of a Roll-Up Response

Distribution of Shipments A cross Efficiency Levels (percent) Year CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2013 35 25 15 12 10 3 2014 0 0 75 12 10 3

9.3.2.2 Shift Response In the shift scenario, DOE assumed th at manufacturers would respond to a standard by improving those units that did not meet the standard, but would also improve units that already met the st andard. In the shift scenari o, the distribution of products across efficiency levels remains the same, but the base level of existing production is shifted to the standard level, and higher levels are shifted the same nu mber of levels, with a cap at the best-in-market level (CSL5) . This response gives an upper bound on energy savings.

Table 9.14 gives an example of a shift res ponse to a standard (with an effective start date of 2014) set at CSL2 for EPSs in Representative Product Class A. In the year before the standard (2013), units are produced at all efficiency levels. The year the standard takes effect (2014) , units at CSL0 and CSL1 no longer meet the efficiency required by the standard. As a result, the entire distribution moves, so that the portion of the market at the lowest efficiency level (C SL0) shifts up to the minimum level required by the standard (CSL2), while the portions of the market at a ll other levels shift the same number of levels. No units exceed CSL5. Thus:

• the 35 percent of the market at CSL0 shifts up to CSL2;

• the 25 percent of the market at CSL1 shifts up to CSL3;

• the 15 percent of the market at CSL2 shifts up to CSL4;

• the 12 percent of the market at CSL3 shifts up to CSL5; and

• the 10 percent of the market at CSL4 shif ts up to CSL5 (due to the cap); while

• the 3 percent of the market at CSL5 is unaffected.

Table 9.14. Example of a Shift Response

Distribution of Shipments A cross Efficiency Levels (percent) Year CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2013 35 25 15 12 10 3 2014 0 0 35 25 15 25

9.3.3 Adjusting Dynamic Progression Rates Following the Standard In those scenarios with a dynamic market state, DOE assumed that units would continue to improve in efficiency following the market’s initial re sponse to the standard. However, DOE chose not to consider efficiency levels beyond the available best-in

market technologies, because such levels would be speculative. Therefore, DOE adjusted the progression rate following the market re sponse. Efficiency would progress toward 100 percent distribution at CSL5, limiting potential energy savings to bounds based on

9-14practical technologies, rather than the max-tech technologies at CSL6. Figure 9.1 provides a visual representation of an adjust ed progression rate in the standards case.

Progression in a Dynamic Market State

200 7 2 0

0

9 201 1 2 0

1 3 2015 2 017 2

0

1 9 2 021 202 3 2 0

2

5 202 7 2 0

2

9 2 0

3

1 2033 2 0

3

5 2 037 2

0

3

9

YearEfficiency

B a se C a se S t an da rd C a s e

Figure 9.1. Progression in a Dynamic Market State

Tables 16 to 24 give an example of how the dynamic progression in the base case would eventually catch up with the accelerated progression in the standards case. By the end of the analysis period, however, the distri butions in the base cas e eventually catch up to the standards case.

Tables 16 to 24 are further examples of the roll-up and shift responses to standards in the context of a dynamic market state. For all tables except the first, which represents the base case, DOE used the sta ndard level of CSL3. These tables reflect actual tables DOE calculated for the determination analysis.

9-15Table 9.15

. List of Following Roll-Up and Shift Tables EPS Representative Product Class Base Case Roll-Up Response to Standard Shift Response to Standard A Table 9.16 Table 9.17 Table 9.18 B Table 9.19 Table 9.20 Table 9.21 F Table 9.22 Table 9.23 Table 9.24

9-16Table 9.16. EPS Representative Product Class A, Dynamic Natural Progression, Base Case

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 35 25 15 12 10 3 2008 23 33 17 13 10 5 2009 12 40 18 13 11 6 2010 0 48 20 14 11 8 2011 0 36 29 14 11 9 2012 0 24 39 15 12 11 2013 0 12 48 16 12 12 2014 0 0 58 17 12 14 2015 0 0 48 25 13 15 2016 0 0 38 33 13 16 2017 0 0 29 41 13 17 2018 0 0 19 50 14 18 2019 0 0 10 58 14 19 2020 0 0 0 66 15 20 2021 0 0 0 58 22 21 2022 0 0 0 49 29 21 2023 0 0 0 41 36 22 2024 0 0 0 33 44 23 2025 0 0 0 25 51 24 2026 0 0 0 16 58 25 2027 0 0 0 8 66 26 2028 0 0 0 0 73 27 2029 0 0 0 0 66 34 2030 0 0 0 0 59 42 2031 0 0 0 0 51 49 2032 0 0 0 0 44 56 2033 0 0 0 0 37 63 2034 0 0 0 0 29 71 2035 0 0 0 0 22 78 2036 0 0 0 0 15 85 2037 0 0 0 0 7 93 2038 0 0 0 0 0 100

9-17Table 9.17. EPS Representative Product Class A, Dynamic Natural Progression, Standard at CSL3, Roll-Up Response

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 35 25 15 12 10 3 2008 23 33 17 13 10 5 2009 12 40 18 13 11 6 2010 0 48 20 14 11 8 2011 0 36 29 14 11 9 2012 0 24 39 15 12 11 2013 0 12 48 16 12 12 2014 0 0 0 74 12 14 2015 0 0 0 68 17 15 2016 0 0 0 62 23 16 2017 0 0 0 56 28 17 2018 0 0 0 50 33 18 2019 0 0 0 43 38 19 2020 0 0 0 37 43 20 2021 0 0 0 32 45 22 2022 0 0 0 28 47 25 2023 0 0 0 23 49 28 2024 0 0 0 19 51 30 2025 0 0 0 14 53 33 2026 0 0 0 9 55 36 2027 0 0 0 5 57 39 2028 0 0 0 0 59 41 2029 0 0 0 0 53 47 2030 0 0 0 0 47 53 2031 0 0 0 0 41 59 2032 0 0 0 0 35 65 2033 0 0 0 0 29 71 2034 0 0 0 0 24 77 2035 0 0 0 0 18 82 2036 0 0 0 0 12 88 2037 0 0 0 0 6 94 2038 0 0 0 0 0 100

9-18Table 9.18. EPS Representative Product Class A, Dynamic Natural Progression, Standard at CSL3, Shift Response

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 35 25 15 12 10 3 2008 23 33 17 13 10 5 2009 12 40 18 13 11 6 2010 0 48 20 14 11 8 2011 0 36 29 14 11 9 2012 0 24 39 15 12 11 2013 0 12 48 16 12 12 2014 0 0 0 12 48 40 2015 0 0 0 11 45 44 2016 0 0 0 10 42 48 2017 0 0 0 9 39 52 2018 0 0 0 8 36 56 2019 0 0 0 7 33 60 2020 0 0 0 6 30 64 2021 0 0 0 5 29 66 2022 0 0 0 4 28 68 2023 0 0 0 4 27 70 2024 0 0 0 3 25 72 2025 0 0 0 2 24 73 2026 0 0 0 1 23 75 2027 0 0 0 1 22 77 2028 0 0 0 0 21 79 2029 0 0 0 0 19 81 2030 0 0 0 0 17 83 2031 0 0 0 0 15 85 2032 0 0 0 0 13 87 2033 0 0 0 0 10 90 2034 0 0 0 0 8 92 2035 0 0 0 0 6 94 2036 0 0 0 0 4 96 2037 0 0 0 0 2 98 2038 0 0 0 0 0 100

9-19Table 9.19. EPS Representative Product Class B, Dynamic Natural Progression, Base Case

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 15 45 15 6 18 1 2008 10 43 20 8 16 4 2009 5 40 25 9 14 7 2010 0 38 30 11 12 10 2011 0 28 36 13 12 12 2012 0 19 41 15 12 13 2013 0 9 47 18 11 15 2014 0 0 53 20 11 16 2015 0 0 44 27 12 17 2016 0 0 35 34 13 18 2017 0 0 26 41 14 19 2018 0 0 18 49 14 20 2019 0 0 9 56 15 21 2020 0 0 0 63 16 22 2021 0 0 0 55 23 23 2022 0 0 0 47 29 24 2023 0 0 0 39 36 25 2024 0 0 0 31 43 26 2025 0 0 0 23 50 27 2026 0 0 0 16 57 28 2027 0 0 0 8 64 29 2028 0 0 0 0 71 30 2029 0 0 0 0 63 37 2030 0 0 0 0 56 44 2031 0 0 0 0 49 51 2032 0 0 0 0 42 58 2033 0 0 0 0 35 65 2034 0 0 0 0 28 72 2035 0 0 0 0 21 79 2036 0 0 0 0 14 86 2037 0 0 0 0 7 93 2038 0 0 0 0 0 100

9-20Table 9.20. EPS Representative Product Class B, Dynamic Natural Progression, Standard at CSL3, Roll-Up Response

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 15 45 15 6 18 1 2008 10 43 20 8 16 4 2009 5 40 25 9 14 7 2010 0 38 30 11 12 10 2011 0 28 36 13 12 12 2012 0 19 41 15 12 13 2013 0 9 47 18 11 15 2014 0 0 0 73 11 16 2015 0 0 0 67 16 17 2016 0 0 0 61 22 18 2017 0 0 0 55 27 19 2018 0 0 0 49 32 20 2019 0 0 0 42 37 21 2020 0 0 0 36 42 22 2021 0 0 0 32 44 24 2022 0 0 0 27 46 27 2023 0 0 0 23 48 30 2024 0 0 0 18 50 32 2025 0 0 0 14 52 35 2026 0 0 0 9 54 37 2027 0 0 0 5 55 40 2028 0 0 0 0 57 43 2029 0 0 0 0 52 48 2030 0 0 0 0 46 54 2031 0 0 0 0 40 60 2032 0 0 0 0 34 66 2033 0 0 0 0 29 71 2034 0 0 0 0 23 77 2035 0 0 0 0 17 83 2036 0 0 0 0 11 89 2037 0 0 0 0 6 94 2038 0 0 0 0 0 100

9-21Table 9.21. EPS Representative Product Class B, Dynamic Natural Progression, Standard at CSL3, Shift Response

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 15 45 15 6 18 1 2008 10 43 20 8 16 4 2009 5 40 25 9 14 7 2010 0 38 30 11 12 10 2011 0 28 36 13 12 12 2012 0 19 41 15 12 13 2013 0 9 47 18 11 15 2014 0 0 0 9 47 44 2015 0 0 0 9 44 48 2016 0 0 0 8 41 52 2017 0 0 0 7 38 55 2018 0 0 0 6 34 59 2019 0 0 0 5 31 63 2020 0 0 0 5 28 67 2021 0 0 0 4 27 69 2022 0 0 0 4 26 71 2023 0 0 0 3 25 72 2024 0 0 0 2 23 74 2025 0 0 0 2 22 76 2026 0 0 0 1 21 78 2027 0 0 0 1 20 79 2028 0 0 0 0 19 81 2029 0 0 0 0 17 83 2030 0 0 0 0 15 85 2031 0 0 0 0 13 87 2032 0 0 0 0 11 89 2033 0 0 0 0 9 91 2034 0 0 0 0 8 93 2035 0 0 0 0 6 94 2036 0 0 0 0 4 96 2037 0 0 0 0 2 98 2038 0 0 0 0 0 100

9-22Table 9.22. EPS Representative Product Class F, Dynamic Natural Progression, Base Case

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 0 60 15 9 5 11 2008 0 50 23 10 6 12 2009 0 40 30 11 6 13 2010 0 30 38 12 7 14 2011 0 23 40 15 8 14 2012 0 15 43 18 8 15 2013 0 8 46 22 9 16 2014 0 0 49 25 10 17 2015 0 0 41 31 11 18 2016 0 0 33 37 12 19 2017 0 0 24 43 13 19 2018 0 0 16 49 15 20 2019 0 0 8 55 16 21 2020 0 0 0 61 17 22 2021 0 0 0 53 24 23 2022 0 0 0 46 30 24 2023 0 0 0 38 37 25 2024 0 0 0 31 43 26 2025 0 0 0 23 50 27 2026 0 0 0 15 57 28 2027 0 0 0 8 63 29 2028 0 0 0 0 70 30 2029 0 0 0 0 63 37 2030 0 0 0 0 56 44 2031 0 0 0 0 49 51 2032 0 0 0 0 42 58 2033 0 0 0 0 35 65 2034 0 0 0 0 28 72 2035 0 0 0 0 21 79 2036 0 0 0 0 14 86 2037 0 0 0 0 7 93 2038 0 0 0 0 0 100

9-23Table 9.23. EPS Representative Product Class F, Dynamic Natural Progression, Standard at CSL3, Roll-Up Response

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 0 60 15 9 5 11 2008 0 50 23 10 6 12 2009 0 40 30 11 6 13 2010 0 30 38 12 7 14 2011 0 23 40 15 8 14 2012 0 15 43 18 8 15 2013 0 8 46 22 9 16 2014 0 0 0 74 10 17 2015 0 0 0 67 15 18 2016 0 0 0 61 20 19 2017 0 0 0 55 26 19 2018 0 0 0 49 31 20 2019 0 0 0 43 36 21 2020 0 0 0 37 42 22 2021 0 0 0 32 44 24 2022 0 0 0 28 46 27 2023 0 0 0 23 48 30 2024 0 0 0 18 50 32 2025 0 0 0 14 52 35 2026 0 0 0 9 54 37 2027 0 0 0 5 56 40 2028 0 0 0 0 58 43 2029 0 0 0 0 52 48 2030 0 0 0 0 46 54 2031 0 0 0 0 40 60 2032 0 0 0 0 35 66 2033 0 0 0 0 29 71 2034 0 0 0 0 23 77 2035 0 0 0 0 17 83 2036 0 0 0 0 12 89 2037 0 0 0 0 6 94 2038 0 0 0 0 0 100

9-24Table 9.24. EPS Representative Product Class F, Dynamic Natural Progression, Standard at CSL3, Shift Response

Year Percent of Market at Each Efficiency Level CSL0 CSL1 CSL2 CSL3 CSL4 CSL5 2007 0 60 15 9 5 11 2008 0 50 23 10 6 12 2009 0 40 30 11 6 13 2010 0 30 38 12 7 14 2011 0 23 40 15 8 14 2012 0 15 43 18 8 15 2013 0 8 46 22 9 16 2014 0 0 0 8 46 47 2015 0 0 0 7 43 50 2016 0 0 0 6 40 54 2017 0 0 0 6 36 58 2018 0 0 0 5 33 62 2019 0 0 0 4 30 66 2020 0 0 0 4 27 70 2021 0 0 0 3 26 71 2022 0 0 0 3 24 73 2023 0 0 0 2 23 75 2024 0 0 0 2 22 76 2025 0 0 0 1 21 78 2026 0 0 0 1 20 80 2027 0 0 0 0 18 81 2028 0 0 0 0 17 83 2029 0 0 0 0 15 85 2030 0 0 0 0 14 86 2031 0 0 0 0 12 88 2032 0 0 0 0 10 90 2033 0 0 0 0 9 91 2034 0 0 0 0 7 93 2035 0 0 0 0 5 95 2036 0 0 0 0 3 97 2037 0 0 0 0 2 98 2038 0 0 0 0 0 100

References

1 Blosser, J., H. Ka meth, et al. (2006). Battery Charger Laboratory Test Data File

. California Energy Commission Public Interest Energy Research Funding.
2 TIAX LLC. “Assessment of Analyses Performed for the California Energy Efficiency Regulations for Consumer Electronics Pr oducts.” Prepared by TIAX for California Energy Commission. 2 February 2006. TIAX LLC: Cambridge, MA. Distributions used were updates to the distribution created by the Darnell Group in 2005 (cited elsewhere in this document). 3 Darnell Group. External AC-DC Power Supplies: Global Market Forecasts and Competitive Environment . 2 nd Edition. 2005. Darnell Group : Corona, California.

9-254 Pacific Gas and Electric. Comments from the Scoping Workshop on Battery Chargers and External Power Supplies. . June 29, 2007. 5 Fernstrom, Gary . Codes and Standards Enhancement Initiative For PY2004: Title 20 Standards Development Analysis of Standards Options For Single-Voltage External AC to DC Power Supplies. May 2004. Prepared by Ecos Consulti ng et al. for Pacific Gas and Electric.
6 Environmental Protection Agency. Qualified Product (QP) List for ENERGY STAR® Ac-Dc Qualified External Power Supplies. http://www.energystar.gov/ia/products /prod_lists/eps_ac_dc_prod_list.pdf . Last accessed December 17, 2007.
7 United States Census Bureau. U.S. Interim Projections by Age, Sex, Race, and Hispanic Origin. . March 2004.

9-26CHAPTER 10. NATIONAL IMPACT ANALYSIS

10.1 Introduction

.................................................................................................... 10-2 10.2 Unit Energy Savings

...................................................................................... 10-2 10.3 National Inventory

......................................................................................... 10-3 10.4 National Energy Savings

................................................................................ 10-5 10.5 National Net Present Value

............................................................................ 10-5

LIST OF FIGURES

Figure 10.1. Flow Diagram of th e Calculation of UES

................................................. 10-3 Figure 10.2. Flow Chart of the Calcul ation of National Inventory

................................ 10-4 Figure 10.3. Flow Chart of the Calculation of NES

...................................................... 10-5 Figure 10.4. Flow Chart of the Calculation of NPV

...................................................... 10-6

LIST OF TABLES

Table 10.1 Sample National Inventory Table

................................................................ 10-4

10-110.1 Introduction For the determination analysis, DOE intended to use the national impact analysis to measure the affects of Federal energy c onservation standards by comparing projected U.S. energy consumption with and wit hout new energy conservation standards. Aggregate impacts combined projections of unit energy consumption of new battery chargers and external power supplies, annua l equipment shipments, and the price of purchased equipment. Approaches to determ ining unit energy consumption are described in chapter 6, methods for deriving base case shipment forecasts are discussed in chapter 9, and approaches to determining re tail prices for produc ts are described in chapter 7.

The national impact analysis c onsisted of four calculations:

• Unit energy savings (UES), which measured the change in unit energy consumption due to the impact of the standard (section 10.2);

• National inventory , which measured the total number of units affected by the standard (section 10.3);

• National energy savings (NES), which combined unit energy savings and the national inventory to obtain the aggreg ate energy savings generated by the standard (section 10.4); and

• Net present value , which calculated the net pres ent savings and costs of a standard by comparing the present va lue of energy savings from national energy savings with the present value of the increased consumer purchase costs associated with th e standard (section 10.5).

10.2 Unit Energy Savings The unit energy savings is the differen ce between the unit energy consumption (UEC) in the standard case a nd the UEC in the base case. Thus, the UES represents the reduced energy consumption of a single unit due to the higher efficiency generated by a standard. Once calculated, the UES would then be multiplied by the national inventory of units to calculate national energy savings.

For each representative product class, DOE calculated the shipment-weighted average UEC of products in that class sold in a given year. Chapter 6 provides the UEC of products at each candidate standard leve l (CSL); chapter 9 pr ovides the proportion of total shipments at each CSL. DOE calculated weighted-average UECs for each year in the evaluation period in both the standards cas e and the base case. DOE then calculated UES by taking the difference betw een the two cases (Figure 10.1).

10-2

### Calculation of Unit Energy Savings

Inputs

Unit Energy Consumption by Efficiency Level

Base Case Distribution of Shipments Across Efficiency Levels

Standard Case Distribution of Shipments Across Efficiency Levels Standard Case Unit Energy Consumption

Base Case Unit Energy Consumption

Unit Energy Savings

Figure 10.1. Flow Diagram of the Calculation of UES

10.3 National Inventory DOE used the national inventory to repres ent the installed base of BCs and EPSs that a standard would affect. Because the BCs and EPSs remain in use for several years, the national inventory represents the stock of BCs or EPSs in service for any given year of the analysis period. It is important to tr ack the date of manufacture, or vintage, of products in the installed base because the en ergy efficiency and price of products sold changes over time. DOE used the following i nputs to calculate the national inventory for the determination analysis:

• Start-Year Shipments The values for start-year shipments by representative product class, estimated in chapter 9 of the dr aft technical report.

• Shipment Growth Rate The values for shipment growth rate by representative product class, estimated in chapter 9 of the dr aft technical report.

• Lifetime by Representative Product Class The values for lifetime by product class, drawn from chapter 8 of the draft technical report.

10-3Table 10.1 shows how the national inventor y model tracks the number of products by vintage in the installed base for a given year. In 2014, 100 units are sold and enter the installed base. In this example, the product ha s an average lifetime of 3 years. Therefore, the units sold in 2014 are retired in 2017. The shipment growth rate is 5 percent, so 105 units are sold in 2015. These units are added to the 100 units that remain in the installed base from the year before. In 2015, 205 units are in the installed base. This process of adding to and subtracting from the instal led base is carried forward throughout the analysis period (Figure 10.2). Table 10.1 Sample National Inventory Table

Vintage Year of Analysis 2014 2015 2016 2017 2018 2019 2020 2014 100 100 100

- - - - 2015

- 105 105 105

- - - 2016

- - 110 110 110

- - 2017

- - - 116 116 116

- 2018

- - - - 122 122 122 2019

- - - - - 128 128 2020

- - - - - - 134 Total 100 205 315 331 348 366 384



### Calculation of National Inventor y

Inputs

Shipment Growth Rate Start Year Shipments

Product Lifetimes N ational Inventor y

Figure 10.2. Flow Chart of the Calc ulation of National Inventory

10-410.4 National Energy Savings Using the calculated national inventory and unit energy savings for each year of the analysis, DOE then calculated national en ergy savings by multiplying the two inputs together, depicted in Figure 10.3.



### Calculation of National Energy Savings

Inputs

National Inventory

Unit Energy Savings National Energy Savings

Figure 10.3. Flow Chart of the Calculation of NES

10.5 National Net Present Value The national NPV of energy conservation st andards for the determination analysis is the difference between electricity cost savings and equipment cost increases. DOE calculated electricity cost savings for each year by multiplying energy savings by forecasted electricity prices. DOE assumed th at consumers paying residential electricity rates would receive 80 percent of the total energy savings, and that the commercial sector would receive the remainder. DOE calculated equipment cost increases for each year by taking the incremental price in crease per unit (from chapter 8) between a base case and a standards case scenario and multiplying the difference by the national inventory. For each year, DOE took the difference between the savi ngs and cost to calculate the net savings (if positive) or net cost (if negative).

After calculating the net savings and cost s, DOE discounted these annual values to the present time and summed them to obtain the national net present value, displayed in Figure 10.4.

10-5

### Calculation of Net Present Value

Discount Rate Net Present Value

Figure 10.4. Flow Chart of the Calculation of NPV Electricity Price

Unit Energy Savings National Energy Savings ($)

National Energy Savings (kWh)

National Inventory

Unit Improvement Cost National Improvement Costs

10-6EERE Information Center Search Help More Search Options

Printable Version 

### Battery Chargers and External Power Supplies Framework Document Public Meeting

The U.S. Department of Energy (DOE) will hold a public meeting on July 16, 2009 to discuss the analyses presented and issues identified in the framework document. At the public meeting, DOE will make a number of presentations; invite discussion on the rulemaking process as it applies to battery chargers and external power supplies; and solicit comments, data, and information from participants. DOE will also invite comment on its preliminary analyses of battery chargers and external power supplies as described in the draft technical report. Meeting Materials All materials related to the public meeting, including the agenda, presentations, and any supplemental documents, will be posted here. DOE will notify interested parties as these documents become available.
Notice of Public Meeting and Availability of the Framework Document ( PDF 48 KB ) Agenda ( PDF 16 KB ) Presentation (Available after the meeting) Transcript: A transcript from the public meeting will be available on this Web site after the meeting. A transcript will also be available for public inspection in the Building Technologies Program Reading Room, between 9:00 a.m. and 4:00 p.m., Monday through Friday, except Federal Holidays. To schedule an DATE: July 16, 2009

TIME: 9:00 a.m. – 5:00 p.m. EDT

LOCATION: U.S. Department of Energy 1000 Independence Ave. SW Forrestal Building Room 1E-245 Washington, D.C. 20585 Appliances and Commercial Equipment Standards: Battery Chargers and ... http://www1.eere.energy.gov/buildings/appliance_standard s/residential/b...

1 of 3 6/4/2009 9:01 A Mappointment or to purchase this transcript, contact: Brenda Edwards U.S. Department of Energy Building Technologies Program 950 L'Enfant Plaza, 6th Floor Washington, DC 20024 Telephone: (202) 586-2945
Request to Speak at the Public Meeting Interested parties are welcome to give a prepared statement at the public meeting. The Department must receive a request to speak before 4:00 p.m. EDT on July 2, 2009. Please submit a signed original and an electronic copy of the statement to be given at the public meeting no later than 4:00 p.m. EDT July 9, 2009.

Comments DOE welcomes comments from interested parties during the designated comment periods for this rulemaking. The comment period is open for 45 days after publication in the Federal Register

. Interested parties may submit comments through the Federal rulemaking portal, electronically, by mail, or by courier. Whenever possible, comments in the electronic format should carry the electronic signature of the author. Absent an electronic signature, comments submitted electronically must be authenticated by submitting the signed original paper document.
All comments submitted must clearly identify the BCEPS rulemaking, the docket number, and the regulatory information number (RIN).
Battery Charger and External Power Supply Rulemaking: Docket Number EERE-2008-BT-STD-0005 and Regulatory Information Number (RIN) 1904-AB57.

Comments may be submitted using any of the following methods:
Federal e-Rulemaking Portal: http://www.regulations.gov/ Follow the instructions for submitting comments.

E-mail: Include docket number EERE-2008- BT-STD-0005 and/or RIN 1904-AB57 in the subject line of your message and send to BC&EPS_ECS@ee.doe.gov.

Postal Mail: Brenda Edwards U.S. Department of Energy Building Technologies Program 1000 Independence Avenue, SW Appliances and Commercial Equipment Standards: Battery Chargers and ... http://www1.eere.energy.gov/buildings/appliance_standard s/residential/b...

2 of 3 6/4/2009 9:01 A MMailstop EE-2J Washington, DC, 20585
Please include one signed original.
Hand Delivery or Courier: Brenda Edwards U.S. Department of Energy Building Technologies Program 950 L'Enfant Plaza, 6th Floor Washington, DC 20224 Telephone: (202) 586-2945
Please include one signed original.

Contact Information Victor Petrolati Project Manager (202) 586-4549

Printable Version

Building Technologies Program Home | EERE Home | U.S. Department of Energy Webmaster | Web Site Policies | Security & Privacy | USA.gov Content Last Updated: 05/28/2009 Appliances and Commercial Equipment Standards: Battery Chargers and ... http://www1.eere.energy.gov/buildings/appliance_standard s/residential/b...

3 of 3 6/4/2009 9:01 A M