[BILLING CODE] 

DEPARTMENT OF ENERGY 

10 CFR Part 430 

[Docket Number EERE–2008–BT–STD–0005] 

RIN: 1904–AB57 

Energy Conservation Program: Energy Conservation Standards for Battery 

Chargers and External Power Supplies 

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

ACTION: Notice of proposed rulemaking (NOPR) and public meeting. 

SUMMARY: The Energy Policy and Conservation Act (EPCA) prescribes energy 

conservation standards for various consumer products and commercial and industrial 

equipment, including battery chargers and external power supplies (EPSs). EPCA also 

requires the U.S. Department of Energy (DOE) to determine whether more stringent, 

amended standards for these products are technologically feasible, economically justified, 

and would save a significant amount of energy. In this notice, DOE proposes amended 

energy conservation standards for Class A EPSs and new energy conservation standards 

for non-Class A EPSs and battery chargers. The notice also announces a public meeting 

to receive comment on these proposed standards and associated analyses and results. 

1 
DATES: DOE will hold a public meeting on [Day of week, Month, Day, Year], from 9 

a.m. to 5 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See 

section VII, “Public Participation,” for webinar registration information, participant 

instructions, and information about the capabilities available to webinar participants. 

DOE will accept comments, data, and information regarding this notice of 

proposed rulemaking (NOPR) before and after the public meeting, but no later than 

[INSERT DATE 60 DAYS AFTER FEDERAL REGISTER PUBLICATION]. See 

section VII, “Public Participation,” for details. 

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

Forrestal Building, Room [NUMBER], 1000 Independence Avenue, SW., Washington, 

DC 20585. To attend, please notify Ms. Brenda Edwards at (202) 586–2945. Please note 

that foreign nationals visiting DOE Headquarters are subject to advance security 

screening procedures. Any foreign national wishing to participate in the meeting should 

advise DOE as soon as possible by contacting Ms. Edwards to initiate the necessary 

procedures. Please also note that those wishing to bring laptops into the Forrestal 

Building will be required to obtain a property pass. Visitors should avoid bringing 

laptops, or allow an extra 45 minutes. 

Any comments submitted must identify the NOPR for Energy Conservation 

Standards for Battery Chargers and External Power Supplies, and provide docket number 

2 
 

EE-2008–BT–STD–0005 and/or regulatory information number (RIN) number 1904­

AB57. Comments may be submitted using any of the following methods: 

1. Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions 

for submitting comments. 

2. E-mail: BC&EPS_ECS@ee.doe.gov. Include the docket number and/or RIN in 

the subject line of the message. 

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

Program, Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC, 

20585-0121. If possible, please submit all items on a CD. It is not necessary to 

include printed copies. 

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

Building Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, 

Washington, DC, 20024. Telephone: (202) 586-2945. If possible, please submit 

all items on a CD. It is not necessary to include printed copies. 

Written comments regarding the burden-hour estimates or other aspects of the 

collection-of-information requirements contained in this proposed rule may be submitted 

to Office of Energy Efficiency and Renewable Energy through the methods listed above 

and by e-mail to Chad_S_Whiteman@omb.eop.gov. 

For detailed instructions on submitting comments and additional information on 

the rulemaking process, see section VII of this document (Public Participation). 

3 
Docket: The docket is available for review at regulations.gov, including Federal 

Register notices, framework documents, public meeting attendee lists and transcripts, 

comments, and other supporting documents/materials. All documents in the docket are 

listed in the regulations.gov index. However, not all documents listed in the index may be 

publicly available, such as information that is exempt from public disclosure. 

A link to the docket web page can be found at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external. 

html. This web page will contain a link to the docket for this notice on the 

regulations.gov site. The regulations.gov web page will contain simple instructions on 

how to access all documents, including public comments, in the docket. See section VII 

for information on how to submit comments through regulations.gov. 

For further information on how to submit or review public comments or 

participate in the public meeting, contact Ms. Brenda Edwards at (202) 586-2945 or 

email: Brenda.Edwards@ee.doe.gov. 

FOR FURTHER INFORMATION CONTACT: 

Mr. Victor Petrolati, U.S. Department of Energy, Office of Energy Efficiency and 

Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, 

SW., Washington, DC, 20585-0121. Telephone: (202) 586-4549. E-mail: 

Victor.Petrolati@ee.doe.gov. 

4 
 

Mr. Michael Kido, U.S. Department of Energy, Office of the General Counsel, 

GC-71, 1000 Independence Avenue, SW., Washington, DC, 20585-0121. Telephone: 

(202) 586-8145. E-mail: michael.kido@hq.doe.gov. 

5 
SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Summary of the Proposed Rule ................................................................................. 1716 

A. Benefits and Costs to Consumers ........................................................................ 2019 

B. Impact on Manufacturers ..................................................................................... 2221 

C. National Benefits ................................................................................................. 2322 

II. Introduction .............................................................................................................. 3735 

A. Authority ............................................................................................................. 3735 

B. Background ......................................................................................................... 4341 

1. Current Standards ............................................................................................ 4341 

2. History of Standards Rulemaking for Battery Chargers and External Power 

Supplies ............................................................................................................... 4442 

III. General Discussion ................................................................................................. 5452 

A. Test Procedures ................................................................................................... 5452 

1. External Power Supply Test Procedures ......................................................... 5452 

2. Battery Charger Test Procedures ..................................................................... 5553 

B. Technological Feasibility .................................................................................... 5755 

1. General ............................................................................................................ 5755 

2. Maximum Technologically Feasible Levels ................................................... 5856 

a. External Power Supply Max-Tech Levels .................................................... 5957 

b. Battery Charger Max-Tech Levels ................................................................ 6159 

C. Energy Savings .................................................................................................... 6361 

1. Determination of Savings ................................................................................ 6462 

2. Significance of Savings ................................................................................... 6562 

D. Economic Justification ........................................................................................ 6563 

1. Specific Criteria ............................................................................................... 6563 

a. Economic Impact on Manufacturers and Consumers ................................... 6663 

b. Life-Cycle Costs ........................................................................................... 6764 

c. Energy Savings .............................................................................................. 6866 

d. Lessening of Utility or Performance of Products ......................................... 6866 

e. Impact of Any Lessening of Competition..................................................... 6967 

f. Need for National Energy Conservation ....................................................... 7067 

2. Rebuttable Presumption .................................................................................. 7068 

IV. Methodology and Discussion ................................................................................. 7169 

A. Market and Technology Assessment................................................................... 7270 

1. Products Included in this Rulemaking ............................................................ 7371 

a. External Power Supplies ............................................................................... 7371 

b. Battery Chargers ........................................................................................... 8785 

c. Wireless Power .............................................................................................. 9189 

d. Unique Products ............................................................................................ 9492 

2. Market Assessment ......................................................................................... 9593 

a. Market Survey............................................................................................... 9593 

b. Non-Class A External Power Supplies ......................................................... 9896 

c. Application Shipments .................................................................................. 9997 

6 
d. Efficiency Distributions .............................................................................. 10098 

3. Product Classes ........................................................................................... 102102 

a. External Power Supply Product Classes ................................................... 105103 

b. Battery Charger Product Classes .............................................................. 112110 

4. Technology Assessment.............................................................................. 124122 

a. EPS Efficiency Metrics ............................................................................. 125123 

b. EPS Technology Options .......................................................................... 128126 

c. High-Power EPSs ...................................................................................... 130128 

d. Power Factor ............................................................................................. 131129 

e. Battery Charger Modes of Operation and Performance Parameters ......... 132130 

f. Battery Charger Technology Options ........................................................ 134132 

B. Screening Analysis .......................................................................................... 135133 

C. Engineering Analysis ...................................................................................... 136134 

1. Engineering Analysis for External Power Supplies .................................... 137135 

a. Representative Product Classes and Representative Units ....................... 137135 

b. EPS Candidate Standard Levels (CSLs) ................................................... 139137 

c. EPS Engineering Analysis Methodology.................................................. 143141 

d. EPS Engineering Results .......................................................................... 147145 

e. EPS Equation Scaling ............................................................................... 150148 

2. Engineering Analysis for Battery Chargers ................................................ 155153 

a. Representative Units ................................................................................. 156154 

b. Battery Charger Efficiency Metrics .......................................................... 157155 

c. Calculation of Unit Energy Consumption ................................................. 160158 

d. Battery Charger Candidate Standard Levels (CSLs) ................................ 167165 

e. Test and Teardowns .................................................................................. 173171 

f. Manufacturer Interviews ............................................................................ 175173 

g. Design Options.......................................................................................... 179177 

h. Cost Model ................................................................................................ 182180 

i. Battery Charger Engineering Results ........................................................ 182180 

j. Scaling of Battery Charger Candidate Standard Levels ............................ 192190 

D. Markups to Determine Product Price .............................................................. 197195 

E. Energy Use Analysis ....................................................................................... 200198 

F. Life-Cycle Cost and Payback Period Analyses ............................................... 208206 

1. Manufacturer Selling Price .......................................................................... 211209 

2. Markups .......................................................... Error! Bookmark not defined.211 

3. Sales Tax ..................................................................................................... 214212 

4. Installation Cost ........................................................................................... 214212 

5. Maintenance Cost ........................................................................................ 215213 

6. Product Price Forecast ................................................................................. 216214 

7. Unit Energy Consumption........................................................................... 216214 

8. Electricity Prices ......................................................................................... 216214 

9. Electricity Price Trends ............................................................................... 217215 

10. Lifetime ..................................................................................................... 218216 

11. Discount Rate ............................................................................................ 220216 

12. Sectors Analyzed....................................................................................... 222218 

13. Base Case Market Efficiency Distribution................................................ 222219 

7 
 

 

14. Compliance Date ....................................................................................... 224220 

15. Payback Period Inputs ............................................................................... 224220 

G. National Impact Analysis ................................................................................ 226222 

1. Shipments .................................................................................................... 228224 

2. Shipment Growth Rate ................................................................................ 231227 

3. Product Class Lifetime ................................................................................ 232228 

4. Forecasted Efficiency in the Base Case and Standards Cases .................... 232228 

5. Product Price Forecast ................................................................................. 239231 

6. Unit Energy Consumption and Savings ...................................................... 240231 

7. Unit Costs.................................................................................................... 241232 

8. Repair and Maintenance Cost per Unit ....................................................... 241233 

9. Energy Prices ............................................................................................... 242233 

10. Site-to-Source Energy Conversion............................................................ 243234 

11. Discount Rates ........................................................................................... 246237 

12. Benefits from Effects of Standards on Energy Prices ............................... 247238 

H. Consumer Subgroup Analysis ......................................................................... 248239 

I. Manufacturer Impact Analysis.......................................................................... 252243 

1. Overview ..................................................................................................... 252243 

2. EPS MIA ..................................................................................................... 253244 

a. EPS GRIM Key Inputs .............................................................................. 254245 

b. Comments from Interested Parties Related to EPSs ................................. 264255 

c. High-Power EPS Manufacturer Interviews ............................................... 267258 

3. Battery Charger MIA .................................................................................. 267259 

a. Battery Charger GRIM Key Inputs........................................................... 271262 

b. Battery Charger Comments from Interested Parties ................................. 282273 

4. Comments from Interested Parties Related to EPSs and Battery Chargers 287279 

a. Cumulative Burden ................................................................................... 288279 

b. Competition............................................................................................... 290282 

5. Manufacturer Interviews ............................................................................. 291283 

a. Product Groupings .................................................................................... 292283 

b. Competition from Substitutes ................................................................... 293285 

c. Test Procedure Concerns........................................................................... 294286 

d. Multiple Regulation of EPSs and Battery Chargers ................................. 295286 

e. Profitability Impacts .................................................................................. 295287 

f. Potential Changes to Product Utility ......................................................... 296288 

J. Employment Impact Analysis .......................................................................... 297289 

K. Utility Impact Analysis ................................................................................... 300291 

L. Emissions Analysis .......................................................................................... 302292 

M. Monetizing Carbon Dioxide and Other Emissions Impacts ........................... 306295 

1. Social Cost of Carbon ................................................................................. 306296 

a. Monetizing Carbon Dioxide Emissions .................................................... 307297 

b. Social Cost of Carbon Values Used in Past Regulatory Analyses ............ 310299 

c. Current Approach and Key Assumptions ................................................. 312302 

d. Valuation of Other Emissions Reductions ................................................ 315305 

N. Discussion of Other Comments....................................................................... 316306 

O. Marking Requirements .................................................................................... 318307 

8 
 

 

P. Reporting Requirements .................................................................................. 325314 

V. Analytical Results ................................................................................................ 326314 

A. Trial Standard Levels ...................................................................................... 326314 

1. External Power Supply TSLs ...................................................................... 326315 

2. Battery Charger TSLs .................................................................................. 328316 

B. Economic Justification and Energy Savings ................................................... 331319 

1. Economic Impacts on Individual Consumers .............................................. 332320 

a. Life-Cycle Cost and Payback Period ........................................................ 332320 

b. Consumer Subgroup Analysis................................................................... 336324 

c. Rebuttable Presumption Payback .............................................................. 344332 

2. Economic Impacts on Manufacturers .......................................................... 345333 

a. Cash-Flow Analysis Results ..................................................................... 345333 

b. Impacts on Employment ........................................................................... 374361 

c. Impacts on Manufacturing Capacity ......................................................... 377363 

d. Impacts on Sub-Group of Manufacturers ................................................. 377364 

e. Cumulative Regulatory Burden................................................................. 378364 

3. National Impact Analysis ............................................................................ 380366 

a. Significance of Energy Savings ................................................................ 380366 

b. Net Present Value of Consumer Costs and Benefits ................................. 381368 

c. Indirect Impacts on Employment .............................................................. 383369 

4. Impact on Utility or Performance of Products ............................................ 385370 

5. Impact of Any Lessening of Competition ................................................... 385370 

6. Need of the Nation to Conserve Energy...................................................... 386371 

7. Other Factors ............................................................................................... 406389 

C. Proposed Standards ......................................................................................... 406390 

1. External Power Supplies ............................................................................. 411393 

a. Product Class B -- Direct Operation External Power Supplies ................. 411393 

b. Product Class X -- Multiple-Voltage External Power Supplies ................ 418400 

c. Product Class H – High-Power External Power Supplies ......................... 423404 

d. Product Class N -- Indirect-Operation External Power Supplies .............. 429409 

2. Battery Chargers .......................................................................................... 433414 

a. Low-Energy, Inductive Charging Battery Chargers, Product Class 1 ...... 433414 

b. Low-Energy, Non-Inductive Charging Battery Chargers, Product Classes 2, 3, 

and 4 ..................................................... Error! Bookmark not defined.418 

c. Medium-Energy Battery Chargers, Product Classes 5 and 6 .................... 449426 

d. High-Energy Battery Chargers, Product Class 7 ...................................... 455431 

e. Battery Chargers with a DC Input of Less than 9 V, Product Class 8 ...... 460435 

f. Battery Chargers with a DC Input Greater than 9 V, Product Class 9 ...... 467441 

g. AC Output Battery Chargers, Product Class 10........................................ 467441 

3. Summary of Benefits and Costs (Annualized) of Proposed Standards for External 

Power Supplies ................................................................................................ 470444 

4. Summary of Benefits and Costs (Annualized) of Proposed Standards for Battery 

Chargers .......................................................................................................... 474448 

VI. Procedural Issues and Regulatory Review ......................................................... 478452 

A. Review Under Executive Order 12866 and 13563.......................................... 478452 

B. Review Under the Regulatory Flexibility Act ................................................. 481455 

9 
 

1. Description and Estimated Number of Small Entities Regulated ............... 482456 

a. Methodology for Estimating the Number of Small Entities ..................... 482456 

b. Manufacturer Participation ....................................................................... 485459 

c. Battery Charger Industry Structure ........................................................... 485459 

d. Comparison Between Large and Small Entities ....................................... 487461 

2. Description and Estimate of Compliance Requirements ............................. 487461 

a. Capital Conversion Costs .......................................................................... 489462 

b. Product Conversion Costs ......................................................................... 490463 

c. Summary of Compliance Impacts ............................................................. 491464 

3. Duplication, Overlap, and Conflict with Other Rules and Regulations ...... 492465 

4. Significant Alternatives to the Proposed Rule ............................................ 492465 

C. Review Under the Paperwork Reduction Act ................................................. 493466 

D. Review Under the National Environmental Policy Act of 1969 ..................... 495468 

E. Review Under Executive Order 13132 ............................................................ 496468 

F. Review Under Executive Order 12988............................................................ 496469 

G. Review Under the Unfunded Mandates Reform Act of 1995 ......................... 497470 

H. Review Under the Treasury and General Government Appropriations Act, 1999

 .............................................................................................................................. 499472 

I. Review Under Executive Order 12630 ............................................................. 500472 

J. Review Under the Treasury and General Government Appropriations Act, 2001

 .............................................................................................................................. 500473 

K. Review Under Executive Order 13211 ........................................................... 500473 

L. Review Under the Information Quality Bulletin for Peer Review .................. 501474 

VII. Public Participation ........................................................................................... 502475 

A. Attendance at Public Meeting ......................................................................... 502475 

B. Procedure for Submitting Prepared General Statements For Distribution ...... 503476 

C. Conduct of Public Meeting.............................................................................. 503476 

D. Submission of Comments ............................................................................... 505478 

E. Issues on Which DOE Seeks Comment .......................................................... 508481 

VIII. Approval of the Office of the Secretary........................................................... 516488 

List of Tables 

Table I-1. Proposed Energy Conservation Standards for Direct Operation External Power 

Supplies ......................................................................................................................... 1817 

Table I-6 Annualized Benefits and Costs of Proposed Standards for External Power 

Table I-8 Annualized Benefits and Costs of Proposed Standards for Battery Chargers 

Table II-1 Federal Active Mode Energy Efficiency Standards for Class A External Power 

Table I-2. Proposed Energy Conservation Standards for Battery Chargers ................. 2019 

Table I-3 Impacts of Proposed Standards on Consumers of External Power Supplies 2120 

Table I-4 Impacts of Proposed Standards on Consumers of Battery Chargers ............. 2221 

Table I-5. External Power Supply Product Classes ...................................................... 2322 

Supplies Shipped in 2013-2042 .................................................................................... 2826 

Table I-7. Battery Charger Product Classes .................................................................. 3128 

Shipped in 2013-2042 ................................................................................................... 3532 

Supplies ......................................................................................................................... 4340 

10 
Table II-2 Stakeholders Providing Comments on the Preliminary Analysis ................ 5350 

Table IV-1 Preliminary Analysis Product Classes .................................................... 110105 

Table IV-2 External Power Supply Product Classes Used in the NOPR ................. 112106 

Table IV-3 Battery Charger Product Classes ............................................................ 115109 

Table IV-4 Summary of EPS CSLs for Product Classes B, C, D, and E.................. 139134 

Table IV-5 Summary of EPS CSLs for Product Class X.......................................... 142137 

Table IV-6 Summary of EPS CSLs for Product Class H.......................................... 143138 

Table IV-7 2.5W EPS Engineering Analysis Results ............................................... 148142 

Table IV-8 18W EPS Engineering Analysis Results ................................................ 148143 

Table IV-9 60W EPS Engineering Analysis Results ................................................ 148143 

Table IV-10 120W EPS Engineering Analysis Results ............................................ 148143 

Table IV-11 203W EPS Engineering Analysis Results ............................................ 149144 

Table IV-12 345W EPS Engineering Analysis Results ............................................ 150145 

Table IV-13 The Battery Charger Representative Units for each Product Class ..... 157151 

Table IV-14 CSLs Equivalent to California Proposed Standards ............................. 170165 

Table IV-15 Supplemental Values for Product Classes 10a and 10b ....................... 179174 

Table IV-16 Product Class 1 (Inductive Chargers) Engineering Analysis Results .. 183177 

Table IV-17 Product Class 2 (Low-Energy, Low-Voltage) Engineering Analysis Results 

................................................................................................................................... 184178 

Table IV-18 Product Class 3 (Low-Energy, Medium-Voltage) Engineering Analysis 

Results ....................................................................................................................... 184179 

Table IV-19 Product Class 4 (Low-Energy, High-Voltage) Engineering Analysis Results 

................................................................................................................................... 185179 

Table IV-20 Product Class 5 (Medium-Energy, Low-Voltage) Engineering Analysis 

Results ....................................................................................................................... 185180 

Table IV-21 Product Class 6 (Medium-Energy, High-Voltage) Engineering Analysis 

Results ....................................................................................................................... 186180 

Table IV-22 Product Class 7 (High-Energy) Engineering Analysis Results ............ 188183 

Table IV-23 Product Class 8 (Low-Voltage DC Input) Engineering Analysis Results 

................................................................................................................................... 189183 

Table IV-24 Product Class 9 (High-Voltage DC Input) Engineering Analysis Results 

................................................................................................................................... 190184 

Table IV-25 Product Class 10 (AC Input, AC Output) Engineering Analysis Results 

................................................................................................................................... 191185 

Table IV-26 Summary of Inputs and Key Assumptions Used in the Preliminary Analysis 

and NOPR LCC Analyses ......................................................................................... 210204 

Table IV-27 EPS Life-Cycle Cost Savings with 4-Year Lifteime Assumptions ...... 220214 

Table IV-28 EPS Life-Cycle Cost Savings with Alternative (2-year) Lifetime 

Assumptions .............................................................................................................. 220214 

Table IV-29 Summary of Inputs, Sources and Key Assumptions for the National Impact 

Analysis..................................................................................................................... 228223 

Table IV-30 Changes to Base Case Efficiency Distributions to Account for CEC 

Standards ................................................................................................................... 236231 

Table IV-31 Social Cost of CO2, 2010–2050 (in 2007 dollars per metric ton) ........ 314306 

Table IV-32 Proposed Efficiency Marking Protocol for Battery Chargers .............. 322314 

Table III-1. Reduction in Energy Consumption at Max-Tech for Battery Chargers .... 6360 

11 
 

Table IV-33 Proposed Location for Battery Charger Marking ................................. 323315 

Table V-3 LCC Savings and Payback Period for DC Output, Basic-Voltage External 

Table V-4 LCC Savings and Payback Period for Non-Class A External Power Supplies 

Table V-6 DC Output, Basic-Voltage External Power Supplies: Low-Income Consumer 

Table V-7 Non-Class A External Power Supplies: Low-Income Consumer Subgroup 

Table V-9 DC Output, Basic-Voltage External Power Supplies: Small Business 

Table V-11 DC Output, Basic-Voltage External Power Supplies: Top Tier Marginal 

Table V-12 Non-Class A External Power Supplies: Top Tier Marginal Electricity Price 

Table V-13 Battery Chargers: Top Tier Marginal Electricity Price Consumer Subgroup 

Table V-14 Manufacturer Impact Analysis for Product Classes B, C, D, and E – Flat 

Table V-15 Manufacturer Impact Analysis for Product Classes B, C, D, and E – 

Table V-16 Manufacturer Impact Analysis for Product Class X EPS – Flat Markup 

Table V-17 Manufacturer Impact Analysis for Product Class X EPS – Preservation of 

Table V-18 Manufacturer Impact Analysis for Product Class H EPS – Flat Markup 

Table V-19 Manufacturer Impact Analysis for Product Class H EPS – Preservation of 

Table V-22 Cash Flow Results – Product Class 1 – Pass Through Markup Scenario 

Table V-23 Cash Flow Results – Product Class 1 – Constant Price Markup Scenario 

Table V-25 Cash Flow Results – Product Classes 2, 3, and 4 – Flat Markup Scenario 

Table V-26 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup 

Table V-1 Trial Standard Levels for External Power Supplies ................................ 327318 

Table V-2 Trial Standard Levels for Battery Chargers ............................................. 329320 

Power Supplies.......................................................................................................... 334325 

................................................................................................................................... 334325 

Table V-5 LCC Savings and Payback Period for Battery Chargers ......................... 335326 

Subgroup ................................................................................................................... 337328 

................................................................................................................................... 337328 

Table V-8 Battery Chargers: Low-Income Consumer Subgroup ............................. 338329 

Consumer Subgroup.................................................................................................. 339330 

Table V-10 Battery Chargers: Small Business Consumer Subgroup ....................... 340331 

Electricity Price Consumer Subgroup....................................................................... 341332 

Consumer Subgroup.................................................................................................. 341332 

................................................................................................................................... 342333 

Markup Scenario....................................................................................................... 347337 

Preservation of Operating Profit Markup Scenario .................................................. 347338 

Scenario..................................................................................................................... 351342 

Operating Scenario.................................................................................................... 351342 

Scenario..................................................................................................................... 353344 

Operating Profit Markup Scenario............................................................................ 354344 

Table V-20 Applications in Product Class 1............................................................. 358349 

Table V-21 Cash Flow Results – Product Class 1 – Flat Markup Scenario ............. 358349 

................................................................................................................................... 359349 

................................................................................................................................... 359349 

Table V-24 Applications in Product Classes 2, 3, and 4 .......................................... 361351 

................................................................................................................................... 361351 

Scenario..................................................................................................................... 362352 

12 
 

 

Table V-27 Cash Flow Results – Product Classes 2, 3, and 4 – Constant Price Markup 

Scenario..................................................................................................................... 362352 

Table V-28 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup 

Table V-29 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup 

Table V-30 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup 

Table V-33 Cash Flow Results – Product Classes 5 and 6 – Pass Through Markup 

Table V-34 Cash Flow Results – Product Classes 5 and 6 – Constant Price Markup 

Table V-37 Cash Flow Results – Product Class 7 – Pass Through Markup Scenario 

Table V-38 Cash Flow Results – Product Class 7 – Constant Price Markup Scenario 

Table V-41 Cash Flow Results – Product Class 8 – Pass Through Markup Scenario 

Table V-42 Cash Flow Results – Product Class 8 – Constant Price Markup Scenario 

Table V-46 Cash Flow Results – Product Class 10 – Pass Through Markup Scenario 

Table V-47 Cash Flow Results – Product Class 10 – Constant Price Markup Scenario 

Table V-48 – Base Case Manufacturer Impact Analysis for All Battery Charger Product 

Table V-49 External Power Supplies: Cumulative National Energy Savings in Quads 

Table V-51 Cumulative Net Present Value of Consumer Benefits for External Power 

Table V-52 Cumulative Net Present Value of Consumer Benefits for External Power 

Table V-53 Cumulative Net Present Value of Consumer Benefits for Battery Chargers, 3­

Table V-54 Cumulative Net Present Value of Consumer Benefits for Battery Chargers, 7­

Scenario – Consumer Electronics ............................................................................. 365355 

Scenario - Power Tools ............................................................................................. 365355 

Scenario – Small Appliances .................................................................................... 366355 

Table V-31 Applications in Product Classes 5 and 6 ............................................... 366356 

Table V-32 Cash Flow Results – Product Classes 5 and 6 – Flat Markup Scenario 367356 

Scenario..................................................................................................................... 367357 

Scenario..................................................................................................................... 367357 

Table V-35 Applications in Product Class 7............................................................. 369358 

Table V-36 Cash Flow Results – Product Class 7 – Flat Markup Scenario ............. 369358 

................................................................................................................................... 369359 

................................................................................................................................... 369359 

Table V-39 Applications in Product Class 8............................................................. 370360 

Table V-40 Cash Flow Results – Product Class 8 – Flat Markup Scenario ............. 371360 

................................................................................................................................... 371360 

................................................................................................................................... 371361 

Table V-43 Applications in Product Class 9............................................................. 372361 

Table V-44 Applications in Product Class 10........................................................... 372362 

Table V-45 Cash Flow Results – Product Class 10 – Flat Markup Scenario ........... 373362 

................................................................................................................................... 373362 

................................................................................................................................... 373363 

Classes Due to the CEC Standard............................................................................. 379368 

................................................................................................................................... 380369 

Table V-50 Battery Chargers: Cumulative National Energy Savings in Quads ....... 380369 

Supplies, 3-Percent Discount Rate (2010$ millions) ................................................ 381370 

Supplies, 7-Percent Discount Rate (2010$ millions) ................................................ 382370 

Percent Discount Rate (2010$ millions)................................................................... 382371 

Percent Discount Rate (2010$ millions)................................................................... 382371 

13 
Table V-55 Cumulative Emissions Reduction for 2013- 2042 Under External Power 

Supply TSLs.............................................................................................................. 387374 

Table V-56 Cumulative Emissions Reduction for 2013- 2042 Under Battery Charger 

Table V-57 External Power Supply Product Class B: Estimates of Global Present Value 

Table V-58 External Power Supply Product Classes B, C, D, and E: Estimates of Global 

Table V-59 External Power Supply Product Class X: Estimates of Global Present Value 

Table V-60 External Power Supply Product Class H: Estimates of Global Present Value 

Table V-67 External Power Supply Product Class B: Estimates of Domestic Present 

Table V-68 External Power Supply Product Classes B, C, D, E: Estimates of Domestic 

Table V-69 External Power Supply Product Class X: Estimates of Domestic Present 

Table V-70 External Power Supply Product Class H: Estimates of Domestic Present 

Table V-77 Estimates of Present Value of NOX Emissions Reduction Under External 

TSLs .......................................................................................................................... 388374 

of CO2 Emissions Reduction Under TSLs................................................................ 390376 

Present Value of CO2 Emissions Reduction Under TSLs ........................................ 390376 

of CO2 Emissions Reduction Under TSLs................................................................ 390377 

of CO2 Emissions Reduction Under TSLs................................................................ 391377 

Table V-61 Battery Charger Product Class 1: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs ............................................................................ 391377 

Table V-62 Battery Chargers Product Classes 2, 3, 4: Estimates of Global Present Value 

of CO2 Emissions Reduction Under TSLs................................................................ 391377 

Table V-63 Battery Chargers Product Classes 5, 6: Estimates of Global Present Value of 

CO2 Emissions Reduction Under TSLs .................................................................... 392378 

Table V-64 Battery Chargers Product Class 7: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs ............................................................................ 392378 

Table V-65 Battery Chargers Product Class 8: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs ............................................................................ 393378 

Table V-66 Battery Chargers Product Class 10: Estimates of Global Present Value of 

CO2 Emissions Reduction Under TSLs .................................................................... 393379 

Value of CO2 Emissions Reduction Under TSLs ..................................................... 393379 

Present Value of CO2 Emissions Reduction Under TSLs ........................................ 394379 

Value of CO2 Emissions Reduction Under TSLs ..................................................... 394380 

Value of CO2 Emissions Reduction Under TSLs ..................................................... 394380 

Table V-71 Battery Charger Product Class 1: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs .................................................................... 395380 

Table V-72 Battery Charger Product Classes 2, 3, 4: Estimates of Domestic Present 

Value of CO2 Emissions Reduction Under TSLs ..................................................... 395380 

Table V-73 Battery Charger Product Classes 5, 6: Estimates of Domestic Present Value 

of CO2 Emissions Reduction Under TSLs................................................................ 396381 

Table V-74 Battery Charger Product Class 7: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs .................................................................... 396381 

Table V-75 Battery Charger Product Class 8: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs .................................................................... 396381 

Table V-76 Battery Charger Product Class 10: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs .................................................................... 397382 

Power Supply TSLs .................................................................................................. 398383 

14 
Table V-78 Estimates of Present Value of NOX Emissions Reduction Under Battery 

Charger TSLs ............................................................................................................ 399384 

Table V-79 Adding Net Present Value of Consumer Savings to Present Value of 

Monetized Benefits from CO2 and NOX Emissions Reductions Under TSL 1 for Battery 

Table V-80 Results of Adding Net Present Value of Consumer Savings (at 7% Discount 

Rate) to Net Present Value of Monetized Benefits from CO2 and NOX Emissions 

Table V-81 Results of Adding Net Present Value of Consumer Savings (at 3% Discount 

Rate) to Net Present Value of Monetized Benefits from CO2 and NOX Emissions 

Table V-82 Results of Adding Net Present Value of Consumer Savings (at 7% Discount 

Rate) to Net Present Value of Monetized Benefits from CO2 and NOX Emissions 

Table V-83 Results of Adding Net Present Value of Consumer Savings (at 3% Discount 

Rate) to Net Present Value of Monetized Benefits from CO2 and NOX Emissions 

Table V-84 Selected National Impacts of Aligning Federal Standards with California 

Table V-105 Annualized Benefits and Costs of Proposed Standards for Battery Chargers 

Table VI-1 Estimated Capital Conservation Costs for a Typical Small Business (2010$ 

Table VI-2 Estimated Product Conversion Costs for a Typical Small Business (2010$ 

Chargers Product Classes 2, 3, 4 ............................................................................... 401385 

Reductions Under External Power Supply TSLs ...................................................... 402386 

Reductions External Power Supply TSLs................................................................. 403387 

Reductions Under Battery Charger TSLs ................................................................. 403388 

Reductions Under Battery Charger TSLs ................................................................. 405389 

Standards ................................................................................................................... 407391 

Table V-85 Summary of Results for Product Class B External Power Supplies ...... 411395 

Table V-86 Proposed Standards for EPSs in Product Classes B, C, D, and E ......... 417400 

Table V-87 Proposed Standards for Product Class X External Power Supplies ...... 419402 

Table V-88 Proposed Standards for Multiple-Voltage External Power Supplies ..... 423405 

Table V-89 Proposed Standards for High-Power External Power Supplies ............. 424406 

Table V-90 Proposed Standards for High-Power External Power Supplies ............. 429411 

Table V-91 Applications of Indirect Operation External Power Supplies ............... 430412 

Table V-92 Summary of Results for Battery Charger Product Class 1 .................... 434416 

Table V-93 Proposed Standard for Product Class 1 ................................................. 438419 

Table V-94 Summary of Results for Battery Charger Product Classes 2, 3, and 4 .. 439420 

Table V-95 Proposed Standard for Product Classes 2, 3, and 4 ............................... 448427 

Table V-96 Summary of Results for Battery Charger Product Classes 5 and 6 ....... 450428 

Table V-97 Proposed Standard for Product Classes 5 and 6 .................................... 454432 

Table V-98 Summary of Results for Battery Charger Product Class 7 .................... 456433 

Table V-99 Proposed Standard for Product Class 7 ................................................. 460436 

Table V-100 Summary of Results for Battery Charger Product Class 8 .................. 461437 

Table V-101 Proposed Standard for Product Class 8 ............................................... 466441 

Table V-102 Summary of Results for Battery Charger Product Class 10 ................ 468443 

Table V-103 Proposed Standard for Product Class 10 ............................................. 470445 

Table V-104 Annualized Benefits and Costs of Proposed Standards for EPSs........ 473448 

................................................................................................................................... 477452 

million) ...................................................................................................................... 490464 

million) ...................................................................................................................... 490464 

15 
 

Table VI-3 Estimated Total Conversion Costs for a Typical Small Business (2010$ 

million) ...................................................................................................................... 491465 

16 
 

I. Summary of the Proposed Rule 

Title III, Part B1 of the Energy Policy and Conservation Act of 1975 (EPCA or the 

Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified), established the Energy 

Conservation Program for Consumer Products Other Than Automobiles. Pursuant to 

EPCA, any new or amended energy conservation standard that DOE prescribes for 

certain products, such as battery chargers and external power supplies (EPSs), shall be 

designed to achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)). 

Furthermore, the new or amended standard must result in a significant conservation of 

energy. (42 U.S.C. 6295(o)(3)(B)). In accordance with these and other statutory 

provisions discussed in this notice, DOE proposes amended energy conservation 

standards for Class A EPSs and new energy conservation standards for non-Class A EPSs 

and battery chargers. The proposed standards for direct operation EPSs, which are the 

minimum average efficiency in active mode and the maximum power consumption in noload mode expressed as a function of the nameplate output power, are shown in Table I.1. 

The proposed standards for battery chargers, which consist of a set of maximum annual 

energy consumption levels expressed as a function of battery energy, are shown in Table 

I-2Table I.2. These proposed standards, if adopted, would apply to all products listed in 

Table I.1 and Table I-2Table I.2 and manufactured in, or imported into, the United States 

on or after July 1, 2013. In addition to being technologically feasible and economically 

justified, DOE’s proposed standards were also designed to maximize the net monetized 

benefits, as explained further below in this notice. 

1 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A. 

Comment [A1]: Change recommended by OIRA. 

17 
Table I-1. Proposed Energy Conservation Standards for Direct Operation External 

Power Supplies 

AC-DC, Basic-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.100 

> 49 watts to ≤ 250 

watts ≥ 0.880 ≤ 0.210 

> 250 watts 0.875 ≤ 0.500 

AC-DC, Low-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.100 

> 49 watts to ≤ 250 

watts ≥ 0.870 ≤ 0.210 

> 250 watts 0.875 ≤ 0.500 

AC-AC, Basic-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.210 

> 49 watts to ≤ 250 

watts ≥ 0.880 ≤ 0.210 

> 250 watts 0.875 ≤ 0.500 

AC-AC, Low-voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.210 

18 
> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.210 

> 49 watts to ≤ 250 

watts ≥ 0.870 ≤ 0.210 

> 250 watts 0.875 ≤ 0.500 

Multiple-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.497 × Pout + 0.067 ≤ 0.300 

> 1 to ≤ 49 watts ≥ 0.075 × ln (Pout) + 0.561 ≤ 0.300 

> 49 watts ≥ 0.860 ≤ 0.300 

19 
Table I-2. Proposed Energy Conservation Standards for Battery Chargers 

Product 

Class 

Product Class Description Proposed Standard as a 

Function of Battery 

Energy (kWh/yr) 

1 Low-Energy, Inductive 3.04 

2 Low-Energy, Low-Voltage = 0.2095(Ebatt*) + 5.87 

3 

4 

5 

6 

Low-Energy, Medium-Voltage 

Low-Energy, High-Voltage 

Medium-Energy, Low-Voltage 

Medium-Energy, High-Voltage 

For Ebatt < 9.74 Wh, 

= 4.68 

For Ebatt ≥ 9.74 Wh, 

= 0.0933(Ebatt) + 3.77 

For Ebatt < 9.71 Wh, 

= 9.03 

For Ebatt ≥ 9.71 Wh, 

= 0.2411(Ebatt) + 6.69 

For Ebatt < 355.18 Wh, 

= 20.06 

For Ebatt ≥ 355.18 Wh, 

= 0.0219(Ebatt) + 12.28 

For Ebatt < 239.48 Wh 

= 30.37 

For Ebatt ≥ 239.48 Wh 

= 0.0495(Ebatt) + 18.51 

7 High-Energy = 0.502(Ebatt) + 4.53 

8 Low-Voltage DC Input 0.66 

9 High-Voltage DC Input No Standard. 

1010a 

10b 

AC Output, 

Basic (i.e. no Automatic Voltage Regulation) 

AC Output, 

Contains Automatic Voltage Regulation 

1.50For Ebatt < 37.2 Wh, = 2.54 

For Ebatt ≥ 37.2 Wh, = 

0.0733(Ebatt) – 0.18 

For Ebatt < 37.2 Wh, = 6.18 

For Ebatt ≥ 37.2 Wh, = 

0.0733(Ebatt) + 3.45 

A. Benefits and Costs to Consumers 

Table I-3Table I-3 presents DOE’s evaluation of the economic impacts of the 

proposed standards on consumers of EPSs, as measured by the average life-cycle cost 

(LCC) savings and the median payback period. The projected economic impacts of the 

proposed standards on individual consumers are generally positive. For example, the 

estimated average life-cycle cost (LCC) savings are from -$0.45 to $0.69 for product 

Formatted Table 

20 
 

 

 

 

 

 

class B, depending on the representative unit, $2.07 for product class X, and $129.08 for 

product class H.2 

Table I-3 Impacts of Proposed Standards on Consumers of External Power Supplies 

Product 

Class Rep. Unit 

Weighted Average LCC 

Savings 

[2010$] 

Median Payback Period3 

[yrs] 

B 2.5W AC-DC, Basic V 0.04 4.3 

B 18W AC-DC, Basic V 0.69 3.1 

B 60W AC-DC, Basic V (0.45) 5.4 

B 120W AC-DC, Basic 

V 

0.61 1.9 

X 203W MultipleVoltage 2.07 4.7 

H 345W High-Power 129.08 0.2 

Comment [A2]: Footnote recommended by 

OIRA. 

Table I-4Table I.4 presents DOE’s evaluation of the economic impacts of the 

proposed standards on consumers of battery chargers, as measured by the average lifecycle cost (LCC) savings and the median payback period. The projected economic 

impacts of the proposed standards on individual consumers are generally positive. For 

example, the estimated average life-cycle cost (LCC) savings are $1.52 for product class 

1, $0.1816 for product class 2, $0.4035 for product class3class 3, $0.4143 for product 

class 4, $39.1533.79 for product class 5, $46.9940.78 for product class 6, $43.9238.26 for 

product class 7, $3.0504 for product class 8, and $8.5230 for product class 10.4 

2

 The LCC is the total consumer expense over the life of a product, consisting of purchase and installation 

costs plus operating costs (expenses for energy use, maintenance and repair). To compute the operating 

costs, DOE discounts future operating costs to the time of purchase and sums them over the lifetime of the 

product. 

3

 As explained in V.B.1.a, DOE uses the median payback period rather than the mean payback period to 

dampen the effect of outliers on the data.

4

 The LCC is the total consumer expense over the life of a product, consisting of purchase and installation 

costs plus operating costs (expenses for energy use, maintenance and repair). To compute the operating 

costs, DOE discounts future operating costs to the time of purchase and sums them over the lifetime of the 

product. 

21 
 

 

 

Table I-4 Impacts of Proposed Standards on Consumers of Battery Chargers 

Rep. Unit Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

PC1 - Low E, 

Inductive 1.52 1.7 

PC2 - Low E, LowVoltage 0.1816 0.5 

PC3 - Low E, 

Medium-Voltage 0.4035 3.69 

PC4 - Low E, 

High-Voltage 0.4143 2.93.0 

PC5 - Medium E, 

Low-Voltage 39.1533.79 0.0 

PC6 - Medium E, 

High-Voltage 46.9940.78 0.0 

PC7 - High E 43.9238.26 0.0 

PC8 - DC-DC, <9V 

Input 3.0504 0.0 

PC10 - Low E, AC 

Out 8.5230 1.5 

B. Impact on Manufacturers 

The industry net present value (INPV) is the sum of the discounted cash flows to 

the industry from the base year through the end of the analysis period (20132011 to 

20432042). Using a real discount rate of 7.01 percent, DOE estimates that the industry 

net present value (INPV) for manufacturers of EPSs is $0.262 million276 billion in 

2010$. Under the proposed standards, DOE expects that manufacturers may lose up to 

33.634.1 percent of their INPV, which is approximately $0.088094 billion. Additionally, 

in 2010$. Based on DOE’s interviews with the manufacturers of EPSs and because DOE 

did not identify any domestic EPS production, DOE does not expect any domestic plant 

closings or any significant loss ofchange in employment, since the vast majority, if not all 

EPS production occurs abroad. 

For battery chargers, DOE estimates that the INPV for manufacturers of 

applications that include battery chargers is $55.784between $53.918 and $53.205 billion 

Comment [A3]: Changes recommended by 

OIRA. 

22 
 

in 2010$ using a real discount rate of 9.1 percent. Under the proposed standards, DOE 

expects that manufacturers may lose up to 7.110.2 percent of their INPV, which is 

approximately $3.9845.428 billion. Additionally, in 2010$. Based on DOE’s interviews 

with the manufacturers of battery chargers, DOE does not expect any domestic plant 

closings or significant loss ofchange in employment, since DOE only identified one 

domestic battery charger manufacturer. 

C. National Benefits 

External Power Supplies 

DOE’s analyses indicate that the proposed standards would save a significant 

amount of energy over 30 years (2013–2042) ― an estimated 0.9599 quads of cumulative 

energy for EPSs. In addition, DOE expects the energy savings from the proposed 

standards to eliminate the need for approximately 0.53 gigawatts (GW) of generating 

capacity by 2042. 

The product classes at issue are comprised of the following groupings of EPS 

products listed below. 

Table I-5. External Power Supply Product Classes 

Comment [A4]: Changes recommended by 

OIRA. 

Comment [A5]: Deletion recommended by 

OIRA. 

Product Class Product Class Description 

B DC Output, Basic-Voltage 

2.5 W (0-10.25 W) 

18 W (10.25-39 W) 

60 W (39-90 W) 

23 
 

 

 

120 W (91-250 W) 

C DC Output, Low-Voltage 

D AC Output, Basic-Voltage 

E AC Output, Low-Voltage 

X Multiple-Voltage 

H High-Power 

N Indirect Operation 

The cumulative national net present value (NPV) of total consumer costs and 

savings of the proposed standards in 2010$ ranges from $0.6779 billion (at a 7-percent 

discount rate) to $1.6387 (at a 3-percent discount rate) for EPSs. This NPV expresses the 

estimated total value of future operating-cost savings minus the estimated increased 

product costs for products purchased in 2013–2042, discounted to 2011. 

In addition, the proposed standards would have significant environmental 

benefits. The energy saved is in the form of electricity, and DOE expects the energy 

savings from the proposed standards to eliminate the need for approximately 0.53 

gigawatts (GW) of generating capacity by 2042. The savings would result in cumulative 

greenhouse gas emission reductions of 44.8446.5 million metric tons (Mt)5 of carbon 

dioxide (CO2) in 2013–2042. During this period, the proposed standards would result in 

emissions reductions of 3738 thousand tons of nitrogen oxides (NOX) and 0.2425 tons (t) 

5 A metric ton is equivalent to 1.1 short tons. Results for NOX and Hg are given in short tons. 

Comment [A6]: Deletion recommended by 

OIRA. 

24 
 

 

 

 

 

 

 

 

 

of mercury (Hg).6

DOE estimates the net present monetary value of the CO2 emissions 

reduction is between $0.1920 and $2.8495 billion, expressed in 2010$ and discounted to 

2011. DOE also estimates the net present monetary value of the NOX emissions 

reduction, expressed in 2010$ and discounted to 2011, is between $5.906.11 and 

$60.6162.79 million at a 7-percent discount rate, and between $10.5897 and 

$108.74112.73 million at a 3-percent discount rate.7 

The benefits and costs of today’s proposed standards, for products sold in 2013­

2042, can also be expressed in terms of annualized values. The annualized monetary 

values are the sum of (1) the annualized national economic value of the benefits from 

consumer operation of products that meet the proposed standards (consisting primarily of 

operating cost savings from using less energy, minus increases in equipment purchase 

and installation costs, which is another way of representing consumer NPV), and (2) the 

annualized monetary value of the benefits of emission reductions, including CO2 

emission reductions.8

 The value of the CO2 reductions, otherwise known as the Social 

6

 DOE calculates emissions reductions relative to the most recent version of the Annual Energy Outlook 

(AEO) Reference case forecast. This forecast accounts for regulatory emissions reductions through 

2008from in-place regulations, including the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 

2005)), but not the Clean Air Mercury Rule (CAMR, 70 FR 28606 (May 18, 2005)). Subsequent 

regulations, including the currently proposed CAIR replacement rule, the Clean Air Transport Rule (75 FR 

45210 (August 2, 2010)), do not appear in the forecast.finalized CAIR replacement rule, the Cross-State 

Air Pollution rule issued on July 6, 2011, do not appear in the forecast. On December 30, 2011, the D.C. 

Circuit stayed CSAPR while ordering EPA to continue administering the also remanded 2005 Clean Air 

Interstate Rule (CAIR, which has a similar structure, but with less stringent budgets and less restrictive 

trading provisions) and tentatively set a briefing schedule to allow the case to be heard by April 2012.

7

 DOE is aware of multiple agency efforts to determine the appropriate range of values used in evaluating 

the potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg in its 

rulemakings.

8

 The process that DOE used to convert the time-series of costs and benefits into annualized values is 

explained in section V.C.3 of this notice.” 

25 
Cost of Carbon (SCC), is calculated using a range of values per metric ton of CO2 

developed by a recent interagency process. The derivation of the SCC values is discussed 

in section IV.M. 

Although combining the values of operating savings and CO2 reductions provides 

a useful perspective, two issues should be considered. First, the national operating 

savings are domestic U.S. consumer monetary savings that occur as a result of market 

transactions while the value of CO2 reductions is based on a global value. Second, the 

assessments of operating cost savings and CO2 savings are performed with different 

methods that use quite different time frames for analysis. The national operating cost 

savings is measured for the lifetime of EPSs shipped in 2013 –2042. The SCC values, on 

the other hand, reflect the present value of all future climate-related impacts resulting 

from the emission of one ton of carbon dioxide in each year. These impacts continue well 

beyond 2100. 

Table I-6Table I.6 shows the annualized values for today’s proposed standards for 

EPSs. (All monetary values below are expressed in 2010$.) The results under the primary 

estimate are as follows. Using a 7-percent discount rate for benefits and costs other than 

CO2 reduction, for which DOE used a 3-percent discount rate along with the SCC series 

corresponding to a value of $22.3/ton in 2010, the cost of the standards proposed in 

today’s rule is $220.0251.9 million per year in increased equipment costs, while the 

annualized benefits are $$274.0$325.2 million per year in reduced equipment operating 

costs, $47.552.3 million in CO2 reductions, and $3.2.7 million in reduced NOX emissions. 

26 
In this case, the net benefit amounts to $104.2128.7 million per year. Using a 3-percent 

discount rate for all benefits and costs and the SCC series corresponding to a value of 

$22.3/ton in 2010, the cost of the standards proposed in today’s rule is $233.1247.3 

million per year in increased equipment costs, while the benefits are $316.5348.2 million 

per year in reduced operating costs, $47.552.3 million in CO2 reductions, and $3.03 

million in reduced NOX emissions. In this case, the net benefit amounts to $134.0156.6 

million per year. 

27 
 

 

 

 

 

 

Table I-6 Annualized Benefits and Costs of Proposed Standards for External Power 

Supplies Shipped in 2013-2042 

Discount Rate 

Primary 

Estimate* 

Low Net 

Benefits 

Estimate* 

High Net 

Benefits 

Estimate* 

Monetized (million 2010$/year) 

Benefits 

Operating Cost Savings 

7% 274.0325.2 260.4309.1 287.4341.1 

3% 316.5348.2 299.4329.5 333.8367.3 

CO2 Reduction at $4.9/t** 5% 12.314.1 12.314.1 12.314.1 

CO2 Reduction at $22.3/t** 3% 47.552.3 47.552.3 47.552.3 

CO2 Reduction at $36.5/t** 2.5% 74.781.4 74.781.4 74.781.4 

CO2 Reduction at $67.6/t** 3% 145.1159.6 145.1159.6 145.1159.6 

NOX Reduction at 

$2,537/t** 

7% 3.2.7 3.2.7 3.2.7 

3% 3.03 3.03 3.03 

Total (Operating Cost 

Savings, CO2 Reduction 

and NOx 

Reduction)†Total† 

7% plus CO2 

range 

289.0342.5 to 

421.8488.0 

275326.4 to 

408.2471.9 

302.5358.4 to 

435.2503.9 

7% 324.2380.7 310364.6 337.7396.6 

3% 367.1403.9 350.0385.1 384.4422.9 

3% plus CO2 

range 

331.9365.7 to 

464.6511.2 

314.8346.9 to 

447.6492.5 

349.2384.7 to 

481.9530.3 

Costs 

Incremental Product Costs‡ 

7% 220.0251.9 220.0251.9 220.0251.9 

3% 233.1247.3 233.1247.3 233.1247.3 

Total Net Benefits/Costs 

Total (Operating Cost 

Savings, CO2 Reduction 

and NOx Reduction, minus 

Incremental Product 

Costs)†Total † 

7% plus CO2 

range 

69.090.5 to 

201.8236.1 

5574.4 to 

188.2220.0 

82.4106.5 to 

215.2252.0 

7% 104.2128.7 90112.6 117.6144.7 

3% 134.0156.6 116137.9 151.3175.7 

3% plus CO2 

range 

98.8118.4 to 

231.6264.0 

8199.7 to 

214.5245.2 

116.1137.5 to 

248.9283.0 

* The difference betweenresults include benefits to consumers which accrue after 2042 from the products 

purchased from 2013 through 2042. Costs incurred by manufacturers, some of which may be incurred prior 

to 2013 in preparation for the rule, are indirectly included as part of incremental equipment costs. The 

Primary, Low Benefits, and High Benefits Estimates is the utilization ofutilize forecasts of energy prices 

from the AEO2010 Reference case, Low Economic Growth caseEstimate, and High Economic Growth 

caseEstimate, respectively. 

Formatted Table 

Formatted Table 

28 
 

 

 

 

 

 

 

 

 

** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 

2010 under several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC 

distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value 

of $67.6 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount 

rate. The value for NOX (in 2010$) is the average of the low and high values used in DOE’s analysis. 

‡ Incremental Product Costs represent the total present value (in 2010$) of costs borne by consumers due to 

increased manufacturing costs from efficiency improvements. 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 

3-percent discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as “7% plus CO2 range” 

and “3% plus CO2 range,” the operating cost and NOX benefits are calculated using the labeled discount 

rate, and those values are added to the full range of CO2 values. 

DOE has tentatively concluded that the proposed standards represent the 

maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in the significant conservation of energy. DOE 

further notes that products achieving these standard levels are already commercially 

available for all product classes covered by today’s proposal for EPSs, other than product 

class H (high-power EPSs). Based on the analyses described above, DOE has tentatively 

concluded that the benefits of the proposed standards to the Nation (energy savings, 

positive NPV of consumer benefits, consumer LCC savings, and emission reductions) 

would outweigh the burdens (loss of INPV for manufacturers and LCC increases for 

some consumers). 

DOE also considered more-stringent and less stringent energy use levels as trial 

standard levels, and is still considering them in this rulemaking. However, DOE has 

tentatively concluded that the potential burdens of the more-stringent energy use levels 

would outweigh the projected benefits. Based on consideration of the public comments 

DOE receives in response to this notice and related information collected and analyzed 

during the course of this rulemaking effort, DOE may adopt energy use levels presented 

Comment [A7]: Changes recommended by 

OIRA. 

29 
in this notice that are either higher or lower than the proposed standards, or some 

combination of level(s) that incorporate the proposed standards in part. 

Battery Chargers 

DOE’s analyses for battery chargers indicate that the proposed standards would 

save a significant amount of energy over 30 years (2013–2042) ― an estimated 1.5336 

quads of cumulative energy for battery chargers. In addition, DOE expects the energy 

savings from the proposed standards to eliminate the need for approximately 0.83 

gigawatts (GW) of generating capacity by 2042. 

The product classes at issue are comprised of the groupings of battery chargers 

listed in Table I-7Table I.7. Each product class grouping was established based on the 

battery charger’s input/output type, and further divided into product classes according to 

battery energy and voltage. 

Comment [A8]: Deletion recommended by 

OIRA. 

30 
 

 

Table I-7. Battery Charger Product Classes 

Product 

Class # 

Input / 

Output Type 

Battery 

Energy 

(Wh) 

Special 

Characteristic or 

Battery Voltage 

Product Class 

Description 

1 

AC In, 

DC Out 

< 100 

Inductive 

Connection 

Low-Energy, 

 Inductive 

2 < 4 V Low-Energy, 

Low-Voltage 

3 4 – 10 V Low-Energy, 

Medium-Voltage 

4 > 10 V Low-Energy, 

High-Voltage 

5 

100–3000 

< 20 V Medium-Energy, 

Low-Voltage 

6 ≥ 20 V Medium-Energy, 

High-Voltage 

7 > 3000 - High-Energy 

8 DC In, 

DC Out 

- < 9 V Input Low-Voltage 

DC Input 

9 - ≥ 9 V Input High-Voltage 

DC Input 

10a AC In, 

AC Out 

-

Basic (i.e. no 

Automatic Voltage 

Regulation) 

10a 

10b - Contains Automatic 

Voltage Regulation 10b 

The cumulative national net present value (NPV) of total consumer costs and 

savings of the proposed standards in 2010$ ranges from $6.6004 billion (at a 7-percent 

discount rate) to $12.0010.96 billion (at a 3-percent discount rate) for battery chargers. 

This NPV expresses the estimated total value of future operating-cost savings minus the 

estimated increased product costs for products purchased in 2013–2042, discounted to 

2011. 

31 
 

 

 

 

 

 

 

 

In addition, the proposed standards would have significant environmental 

benefits. The energy saved is in the form of electricity, and DOE expects the energy 

savings from the proposed standards to eliminate the need for approximately 0.83 

gigawatts (GW) of generating capacity by 2042.The savings would result in cumulative 

greenhouse gas emission reductions of 70.69 million metric tons (62.9 Mt)

9

 of CO2 in 

2013–2042. During this period, the proposed standards would result in emissions 

reductions of 58.2752 thousand tons of NOX and 0.3935 tons of mercury (Hg).10. DOE 

estimates the net present monetary value of the CO2 emissions reduction is between 

$0.3027 and $4.5404 billion, expressed in 2010$ and discounted to 2011. DOE also 

estimates the net present monetary value of the NOX emissions reduction, expressed in 

2010$ and discounted to 2011, is between $9.208.19 and $94.5284.14 million at a 7­

percent discount rate, and between $16.7314.88 and $172.02153.05 million at a 3-percent 

discount rate.11 

The benefits and costs of today’s proposed standards, for products sold in 2013­

2042, can also be expressed in terms of annualized values. The annualized monetary 

values are the sum of (1) the annualized national economic value of the benefits from 

consumer operation of products that meet the proposed standards (consisting primarily of 

9 A metric ton is equivalent to 1.1 short tons. Results for NOX and Hg are presented in short tons. 10 DOE calculates emissions reductions relative to the most recent version of the Annual Energy Outlook 

(AEO) Reference case forecast. This forecast accounts for regulatory emissions reductions through 2008, 

including the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), but not the Clean Air 

Mercury Rule (CAMR, 70 FR 28606 (May 18, 2005)). Subsequent regulations, including the currently 

proposed CAIR replacement rule, the Clean Air Transport Rule (75 FR 45210 (August 2, 2010)), do not 

appear in the forecast. 

11 DOE is aware of multiple agency efforts to determine the appropriate range of values used in evaluating 

the potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg in its 

rulemakings. 

Comment [A9]: Deletion recommended by 

OIRA. 

32 
operating cost savings from using less energy, minus increases in equipment purchase 

and installation costs, which is another way of representing consumer NPV), and (2) the 

annualized monetary value of the benefits of emission reductions, including CO2 

emission reductions. The value of the CO2 reductions is calculated using a range of 

values per metric ton of CO2 developed by a recent interagency process. The derivation 

of the SCC values is discussed in section IV.M. 

Although combining the values of operating savings and CO2 reductions provides 

a useful perspective, two issues should be considered. First, the national operating 

savings are domestic U.S. consumer monetary savings that occur as a result of market 

transactions while the value of CO2 reductions is based on a global value. Second, the 

assessments of operating cost savings and CO2 savings are performed with different 

methods that use quite different time frames for analysis. The national operating cost 

savings is measured for the lifetime of battery chargers shipped in 2013–2042. The SCC 

values, on the other hand, reflect the present value of all future climate-related impacts 

resulting from the emission of one ton of carbon dioxide in each year. These impacts 

continue well beyond 2100. 

Table I-8Table I.8 shows the annualized values for today’s proposed standards for 

battery chargers. (All monetary values below are expressed in 2010$.) The results under 

the primary estimate are as follows. Using a 7-percent discount rate for benefits and costs 

other than CO2 reduction, for which DOE used a 3-percent discount rate along with the 

SCC series corresponding to a value of $22.3/ton in 2010, the standards proposed in 

33 
 

today’s rule result in $92.8110.0 million per year in equipment costs savings, and the 

annualized benefits are 439.0447.2 million per year in reduced equipment operating 

costs, $75.971.6 million in CO2 reductions, and $4.23 million in reduced NOX emissions. 

In this case, the benefit amounts to $611.9633.0 million per year. Using a 3-percent 

discount rate for all benefits and costs and the SCC series corresponding to a value of 

$22.3/ton in 2010, the standards proposed in today’s rule result in $98.3$107.9 million 

per year in equipment costs savings, and the benefits are $514485.2 million per year in 

reduced operating costs, $75.971.6 million in CO2 reductions, and $4.85 million in 

reduced NOX emissions. In this case, the net benefit amounts to to $693$669.3 million 

per year. 

34 
 

 

 

 

 

 

 

 

 

Table I-8 Annualized Benefits and Costs of Proposed Standards for Battery 

Chargers Shipped in 2013-2042 

Discount Rate 

Primary 

Estimate* 

Low Net 

Benefits 

Estimate* 

High Net 

Benefits 

Estimate* 

Monetized (million 2010$/year) 

Benefits 

Operating Cost Savings 

7% 439.0447.2 417.8425.6 460.3468.8 

3% 514485.2 487.2459.7 541.9511.2 

CO2 Reduction at $4.9/t** 5% 19.63 19.63 19.63 

CO2 Reduction at $22.3/t** 3% 75.971.6 75.971.6 75.971.6 

CO2 Reduction at $36.5/t** 2.5% 119.3111.5 119.3111.5 119.3111.5 

CO2 Reduction at $67.6/t** 3% 231.6218.5 231.6218.5 231.6218.5 

NOX Reduction at 

$2,537/t** 

7% 4.23 4.23 4.23 

3% 4.85 4.85 4.85 

Total (Operating Cost 

Savings, CO2 Reduction 

and NOx Reduction)†Total 

† 

7% plus CO2 

range 

462.9470.7 to 

674.8670.0 

441.6449.1 to 

653.6648.4 

484.1492.4 to 

696.0691.6 

7% 519523.1 497.9501.5 540.3544.7 

3% 594.9561.3 567.9535.8 622.6587.4 

3% plus CO2 

range 

538.7509.0 to 

750.6708.2 

511.7483.5 to 

723.6682.7 

566.3535.0 to 

778734.3 

Costs 

Incremental Product 

Costs‡12 

7% (92.8110.0) (92.8110.0) (92.8110.0) 

3% (98.3107.9) (98.3)107.9) (98.3)107.9) 

Total Net Benefits/Costs 

Total (Operating Cost 

Savings, CO2 Reduction 

and NOx Reduction, minus 

Incremental Product 

Costs)†Total † 

7% plus CO2 

range 

555580.7 to 

767.6780.0 

534.5559.1 to 

746.4758.3 

576.9602.3 to 

788.8801.6 

7% 611.9633.0 590.7611.4 633.2654.7 

3% 693669.3 666.3643.8 720.9695.3 

3% plus CO2 

range 

637.0616.9 to 

849.0816.2 

610.0591.4 to 

821.9790.7 

664.7643.0 to 

876.6842.2 

Formatted Table 

Comment [A10]: Footnote recommended by 

OIRA. 

Formatted Table 

* The difference betweenresults include benefits to consumers which accrue after 2042 from the products 

purchased from 2013 through 2042. Costs incurred by manufacturers, some of which may be incurred prior 

to 2013 in preparation for the rule, are indirectly included as part of incremental equipment costs. The 

Primary, Low Benefits, and High Benefits Estimates is the utilization ofutilize forecasts of energy prices 

from the AEO2010 Reference case, Low Economic Growth caseEstimate, and High Economic Growth 

caseEstimate, respectively. 

12 The incremental product costs for battery chargers are negative because of a shift in technology from 

linear power supplies to switch mode power for the larger battery chargers in product classes 5, 6, and 7. 

35 
 

 

 

 

 

 

 

 

 

 

 

** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 

2010 under several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC 

distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value 

of $67.6 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount 

rate. The value for NOX (in 2010$) is the average of the low and high values used in DOE’s analysis. 

‡ Incremental Product Costs represent the total present value (in 2010$) of costs borne by consumers due to 

increased manufacturing costs from efficiency improvements.In this case, the incremental equipment costs 

are negative and represent savings. 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 

3-percent discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as “7% plus CO2 range” 

and “3% plus CO2 range,” the operating cost and NOX benefits are calculated using the labeled discount 

rate, and those values are added to the full range of CO2 values. 

DOE has tentatively concluded that the proposed standards represent the 

maximum improvement in energy efficiency that is technologically feasible and 

economically justified, and would result in the significant conservation of energy. DOE 

further notes that products achieving these standard levels are already commercially 

available for all product classes covered by today’s proposal for battery chargers, other 

than product class 10 (AC output). Based on the analyses described above, DOE has 

tentatively concluded that the benefits of the proposed standards to the Nation (energy 

savings, positive NPV of consumer benefits, consumer LCC savings, and emission 

reductions) would outweigh the burdens (loss of INPV for manufacturers and LCC 

increases for some consumers). 

DOE also considered more-stringent and less-stringent energy use levels as trial 

standard levels, and is still considering them in this rulemaking. However, DOE has 

tentatively concluded that the potential burdens of the more-stringent energy use levels 

would outweigh the projected benefits. Based on consideration of the public comments 

DOE receives in response to this notice and related information collected and analyzed 

during the course of this rulemaking effort, DOE may adopt energy use levels presented 

Comment [A11]: Changes recommended by 

OIRA. 

36 
 

in this notice that are either higher or lower than the proposed standards, or some 

combination of level(s) that incorporate the proposed standards in part. 

II. Introduction 

The following section briefly discusses the statutory authority underlying today’s 

proposal, as well as some of the relevant historical background related to the 

establishment of standards for battery chargers and EPSs. 

A. Authority 

Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA or the 

Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified) established the Energy 

Conservation Program for Consumer Products Other Than Automobiles,13 a program 

covering most major household appliances (collectively referred to as “covered 

products”), which includes battery chargers and EPSs. (42 U.S.C. 6295(u)) (DOE notes 

that under 42 U.S.C. 6295(m), the agency must periodically review its already established 

energy conservation standards for a covered product. Under this requirement, the next 

review that DOE would need to conduct must occur no later than six years from the 

issuance of a final rule establishing or amending a standard for a covered product.) 

Pursuant to EPCA, DOE’s energy conservation program for covered products 

consists essentially of four parts: (1) testing; (2) labeling; (3) the establishment of Federal 

energy conservation standards; and (4) certification and enforcement procedures. The 

13 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A. 

37 
 

Federal Trade Commission (FTC) is primarily responsible for labeling, and DOE 

implements the remainder of the program. Subject to certain criteria and conditions, DOE 

is required to develop test procedures to measure the energy efficiency, energy use, or 

estimated annual operating cost of each covered product. (42 U.S.C. 6293) Manufacturers 

of covered products must use the prescribed DOE test procedure as the basis for 

certifying to DOE that their products comply with the applicable energy conservation 

standards adopted under EPCA and when making representations to the public regarding 

the energy use or efficiency of those products. (42 U.S.C. 6293(c)) Similarly, DOE must 

use these test procedures to determine whether the products comply with standards 

adopted pursuant to EPCA. See 42 U.S.C. 6295(s). As stated below in Section II.B.2 the 

DOE test procedures for battery chargers and EPSs currently appear at title 10, Code of 

Federal Regulations (CFR), part 430, subpart B, appendices Y and Z, respectively. 

DOE must follow specific statutory criteria when prescribing amended standards 

for covered products. As indicated above, any amended standard for a covered product 

must be designed to achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) 

Furthermore, EPCA precludes DOE from adopting any standard that would not result in 

the significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not 

prescribe a standard: (1) for certain products, including battery chargers and EPSs, if no 

test procedure has been established for the product, or (2) if DOE determines by rule that 

the proposed standard is not technologically feasible or economically justified. (42 

U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is economically 

38 
justified, DOE must determine whether the benefits of the standard exceed its burdens. 

(42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving 

comments on the proposed standard, and by considering, to the greatest extent 

practicable, the following seven factors: 

1. The economic impact of the standard on manufacturers and consumers of the 

products subject to the standard; 

2. The savings in operating costs throughout the estimated average life of the 

covered products in the type (or class) compared to any increase in the price, initial 

charges, or maintenance expenses for the covered products that are likely to result from 

the imposition of the standard; 

3. The total projected amount of energy, or as applicable, water, savings likely to 

result directly from the imposition of the standard; 

4. Any lessening of the utility or the performance of the covered products likely to 

result from the imposition of the standard; 

5. The impact of any lessening of competition, as determined in writing by the 

Attorney General, that is likely to result from the imposition of the standard; 

6. The need for national energy and water conservation; and 

7. Other factors the Secretary of Energy (Secretary) considers relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(I)–( VII)) 

EPCA, as codified, also contains what is known as an “anti-backsliding” 

provision, which prevents the Secretary from prescribing any amended standard that 

39 
 

 

 

either increases the maximum allowable energy use or decreases the minimum required 

energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may 

not prescribe an amended or new standard if interested persons have established by a 

preponderance of the evidence that the standard is likely to result in the unavailability in 

the United States of any covered product type (or class) of performance characteristics 

(including reliability), features, sizes, capacities, and volumes that are substantially the 

same as those generally available in the United States. (42 U.S.C. 6295(o)(4)) 

Further, EPCA, as codified, establishes a rebuttable presumption that a standard is 

economically justified if the Secretary finds that the additional cost to the consumer of 

purchasing a product complying with an energy conservation standard level will be less 

than three times the value of the energy savings during the first year that the consumer 

will receive as a result of the standard, as calculated under the applicable test procedure. 

See 42 U.S.C. 6295(o)(2)(B)(iii). 

Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating a 

standard for a type or class of covered product that has two or more subcategories. DOE 

must specify a different standard level than that which applies generally to such type or 

class of products for any group of covered products that have the same function or 

intended use if DOE determines that covered products within such group (A) consume a 

different kind of energy from that consumed by other covered products within such type 

(or class) or (B) have a capacity or other performance-related feature which other 

products within such type (or class) do not have and such feature justifies a higher or 

40 
 

lower standard . (42 U.S.C. 6294(q)(1)). In determining whether a performance-related 

feature justifies a different standard for a group of products, DOE must consider such 

factors as the utility of the feature to the consumer and other factors DOE deems 

appropriate. Id. Any rule prescribing such a standard must include an explanation of the 

basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2)) 

Federal energy conservation requirements generally supersede State laws or 

regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 

6297(a)–(c)) DOE may, however, grant waivers of Federal preemption for particular 

State laws or regulations, in accordance with the procedures and other provisions set forth 

under 42 U.S.C. 6297(d). 

Finally, pursuant to the amendments contained in section 310(3) of EISA 2007, 

any final rule for new or amended energy conservation standards promulgated after July 

1, 2010, are required to address standby mode and off mode energy use. (42 U.S.C. 

6295(gg)(3)) Specifically, when DOE adopts a standard for a covered product after that 

date, it must, if justified by the criteria for adoption of standards in under EPCA (42 

U.S.C. 6295(o)), incorporate standby mode and off mode energy use into the standard, or, 

if that is not feasible, adopt a separate standard for such energy use for that product. (42 

U.S.C. 6295(gg)(3)(A)-(B)) DOE’s current test procedures for battery chargers and EPSs 

already address standby-mode and off-mode energy use. The standards for EPSs also 

address this energy use; currently there are no standards for battery chargers. In this 

41 
 

 

rulemaking, DOE intends to incorporate such energy use into any new or amended 

energy conservation standards it adopts in the final rule. 

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued 

on January 18, 2011 (76 FR 3281 (Jan. 21, 2011)). EO 13563 is supplemental to and 

explicitly reaffirms the principles, structures, and definitions governing regulatory review 

established in Executive Order 12866. To the extent permitted by law, agencies are 

required by Executive Order 13563 to: (1) propose or adopt a regulation only upon a 

reasoned determination that its benefits justify its costs (recognizing that some benefits 

and costs are difficult to quantify); (2) tailor regulations to impose the least burden on 

society, consistent with obtaining regulatory objectives, taking into account, among other 

things, and to the extent practicable, the costs of cumulative regulations; (3) select, in 

choosing among alternative regulatory approaches, those approaches that maximize net 

benefits (including potential economic, environmental, public health and safety, and other 

advantages; distributive impacts; and equity); (4) to the extent feasible, specify 

performance objectives, rather than specifying the behavior or manner of compliance that 

regulated entities must adopt; and (5) identify and assess available alternatives to direct 

regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can 

be made by the public. 

DOE emphasizes as well that Executive Order 13563 requires agencies “to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

42 
accurately as possible.” In its guidance, the Office of Information and Regulatory Affairs 

has emphasized that such techniques may include “identifying changing future 

compliance costs that might result from technological innovation or anticipated 

behavioral changes.” For the reasons stated in the preamble, DOE believes that today’s 

NOPR is consistent with these principles, including the requirement that, to the extent 

permitted by law, benefits justify costs and that net benefits are maximized. 

Consistent with EO 13563, and the range of impacts analyzed in this rulemaking, 

the energy efficiency standards proposed herein by DOE achieves maximum net benefits. 

B. Background 

1. Current Standards 

Section 301 of EISA 2007 established minimum energy conservation standards 

for Class A EPSs, which became effective on July 1, 2008. (42 U.S.C. 6295(u)(3)(A)) 

These standards provided an active mode efficiency level and a no-load power 

consumption rate. The current standards are set forth in Table II.1 and Table II.2, 

respectively. 

Table II-1 Federal Active Mode Energy Efficiency Standards for Class A External 

Power Supplies 

Nameplate Output Power Active Mode Minimum Efficiency 

(decimal equivalent of a percentage) 

< 1 Watt 0.5*(nameplate_output) 

1 – 51 Watts 0.5+ 0.09*ln(nameplate_output) 

> 51 Watts 0.85 

43 
 

Table II-2 Federal No-Load Mode Energy Efficiency Standards for Class A 

External Power Supplies 

Nameplate Output Power No-Load Mode Maximum Power 

Consumption 

≤ 250 Watts 0.5 Watts 

Currently, no Federal energy conservation standards apply to non-Class A EPSs 

or battery chargers. 

2. History of Standards Rulemaking for Battery Chargers and External Power Supplies 

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

(Aug. 8, 2005), amended sections 321 and 325 of EPCA by defining the terms “battery 

charger” and “external power supply.” That provision also directed DOE to prescribe 

definitions and test procedures related to the energy consumption of battery chargers and 

external power supplies and to issue a final rule that determines whether energy 

conservation standards shall be issued 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 test procedures for a variety of products. 71 FR 

71340, 71365-71375. That rule, which was codified in multiple sections of the Code of 

Federal Regulations (CFR), included definitions and test procedures for battery chargers 

and EPSs. As stated above, the test procedures for these products 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 

44 
 

 

(“Uniform Test Method for Measuring the Energy Consumption of External Power 

Supplies”). 

On December 19, 2007, Congress enacted EISA 2007, which, among other things, 

amended sections 321, 323, and 325 of EPCA. As part of these amendments, EISA 2007 

altered the EPS definition. Under the definition previously set by EPACT 2005, the 

statute defined an EPS as an external power supply circuit “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)) Section 301 of EISA 2007 amended that definition by 

creating a subset of EPSs called “Class A External Power Supplies.” This new subset of 

products consisted of those EPSs that can convert to only 1 AC or DC output voltage at a 

time and have a nameplate output power of no more than 250 watts (W). The definition 

excludes any device requiring Federal Food and Drug Administration (FDA) 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 one that 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)) Section 301 of EISA 2007 also established energy conservation 

standards for Class A EPSs that became effective on July 1, 2008, and directed DOE to 

conduct an energy conservation standards rulemaking to review those standards. 

Additionally, section 309 of EISA 2007 amended section 325(u)(1)(E) of EPCA 

(42 U.S.C. 6295(u)(1)(E)) by directing DOE to issue a final rule that prescribes energy 

conservation standards for battery chargers or classes of battery chargers or to determine 

45 
 

 

 

that no energy conservation standard is technologically feasible and economically 

justified. DOE is bundling this battery charger rulemaking proceeding with the 

requirement to review and consider amending the energy conservation standards for 

Class A EPSs. The new rulemaking requirements contained in sections 301 and 309 of 

EISA 2007 effectively superseded the prior determination analysis that EPACT 2005 

required DOE to conduct. 

Section 309 of EISA 2007 also instructed DOE to issue a final rule to determine 

whether DOE should issue energy conservation standards for external power supplies or 

classes of external power supplies no later than two years after EISA 2007’s enactment. 

(42 U.S.C. 6295(u)(1)(E)(i)(I)) Because Congress already set standards for Class A 

devices, DOE interpreted this determination requirement as applying solely to assessing 

whether energy conservation standards are warranted for EPSs that fall outside of the 

Class A definition (i.e. non-Class A EPSs). Non-Class A EPSs include those devices that 

have a nameplate output power greater than 250 watts, are able to convert to more than 

one AC or DC output voltage simultaneously, and are specifically excluded from 

coverage under the Class A EPS definition in EISA 2007 by virtue of their application -- 

e.g., EPSs used with medical devices.14 DOE determined that standards are warranted for 

non-Class A EPSs. See 75 FR 27170 (May 14, 2010). Given the similarities between 

battery chargers and non-Class A and Class A EPSs, DOE is handling all three product 

groups in a single standards rulemaking. 

14 To help ensure that the standards Congress set were not applied in an overly broad fashion, DOE applied 

the statutory exclusion not only to those EPSs that require FDA listing and approval but also to any EPS 

that provides power to a medical device. 

46 
Finally, section 310 of EISA 2007 established definitions for active, standby, and 

off modes, and directed DOE to amend its existing test procedures for battery chargers 

and EPSs to measure the energy consumed in standby mode and off mode. (42 U.S.C. 

6295(gg)(2)(B)(i)) Consequently, DOE published a final rule incorporating standby- and 

off-mode measurements into the DOE test procedure. 74 FR 13318, 13334-13336 (March 

27, 2009) Additionally, DOE amended the test procedure for battery chargers to include 

an active mode measurement for battery chargers and made certain amendments to the 

test procedure for EPSs. 76 FR 31750 (June 1, 2011). 

DOE initiated its current rulemaking effort for these products by issuing the 

Energy Conservation Standards Rulemaking Framework Document for Battery Chargers 

and External Power Supplies (the framework document). See 

https://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/bceps_fram 

eworkdocument.pdf. The framework document explained the issues, analyses, and 

process DOE anticipated using to develop energy efficiency standards for those products. 

DOE also published a notice announcing the availability of the framework document, 

announcing a public meeting to discuss the proposed analytical framework, and inviting 

written comments concerning the development of standards for battery chargers and 

EPSs. 74 FR 26816 (June 4, 2009) 

DOE held a public meeting on July 16, 2009, to discuss the analyses and issues 

identified in the framework document. At the meeting, DOE described the different 

47 
analyses it would conduct, the methods proposed for conducting them, and the 

relationships among the various analyses. Manufacturers, trade associations, 

environmental advocates, regulators, and other interested parties attended the meeting. 

The comments received at the public meeting and during the subsequent comment period 

helped DOE identify and resolve issues involved in this rulemaking. 

Following the framework document public meeting, DOE published on 

November 3, 2009, a Notice of Proposed Determination to examine the feasibility and 

related economic costs and benefits of setting energy conservation standards for nonClass A EPSs. 74 FR 56928. This notice was followed by a final determination published 

on May 14, 2010, 75 FR 27170, which concluded that energy conservation standards for 

non-Class A EPSs appear to be technologically feasible and economically justified, and 

would be likely to result in significant energy savings. Consequently, DOE decided to 

include non-Class A EPSs in the present energy conservation standards rulemaking for 

battery chargers and EPSs. 

DOE then gathered additional information and performed preliminary analyses 

for the purpose of developing potential amended energy conservation standards for 

Class A EPSs and new energy conservation standards for battery chargers and nonClass A EPSs. This process culminated in DOE’s announcement in the Federal Register 

on September 15, 2010, of the preliminary analysis public meeting, at which DOE 

discussed and received comments on the following matters: the product classes DOE 

analyzed; the analytical framework, models, and tools that DOE was using to evaluate 

48 
 

 

potential standards; the results of the preliminary analyses performed by DOE; and 

potential standard levels under consideration. 75 FR 56021 (the September 2010 notice). 

DOE also invited written comments on these subjects and announced the availability on 

its website of a preliminary technical support document (preliminary TSD) it had 

prepared to inform interested parties and enable them to provide comments.15 Id. Finally, 

DOE stated its interest in receiving views concerning other relevant issues that 

participants believed would affect energy conservation standards for battery chargers and 

EPSs, or that DOE should address in this NOPR. Id. at 56024. 

The preliminary TSD provides an overview of the activities DOE undertook in 

developing standards for battery chargers and EPSs, and discusses the comments DOE 

received in response to the framework document. It also describes the analytical 

framework that DOE used (and continues to use) in this rulemaking, including a 

description of the methodology, the analytical tools, and the relationships among the 

various analyses that are part of the rulemaking. The preliminary TSD presents and 

describes in detail each analysis DOE had performed up to that point, including 

descriptions of inputs, sources, methodologies, and results. These analyses were as 

follows: 

• A market and technology assessment addressed the scope of this rulemaking, 

identified the potential classes for battery chargers and EPSs, characterized the markets 

15 The preliminary TSD is available at: 

<http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external_preliminaryanaly 

sis_tsd.html> 

49 
 

for these products, and reviewed techniques and approaches for improving their 

efficiency; 

• A screening analysis reviewed technology options to improve the efficiency of 

battery chargers and EPSs, and weighed these options against DOE’s four prescribed 

screening criteria: (1) technological feasibility, (2) practicability to manufacture, install, 

and service, (3) impacts on equipment utility or equipment availability, (4) adverse 

impacts on health or safety; 

• An engineering analysis estimated the increases in manufacturer selling prices 

(MSPs) associated with more energy-efficient battery chargers and EPSs; 

• An energy use analysis estimated the annual energy use in the field of battery 

chargers and EPSs as a function of efficiency levels; 

• A markups analysis converted estimated manufacturer selling price (MSP) 

increases derived from the engineering analysis to consumer prices; 

• A life-cycle cost analysis calculated, at the consumer level, the discounted 

savings in operating costs throughout the estimated average life of the product, compared 

to any increase in installed costs likely to result directly from the imposition of a given 

standard; 

50 
 

• A payback period (PBP) analysis estimated the amount of time it would take 

consumers to recover the higher expense of purchasing more energy efficient products 

through lower operating costs; 

• A shipments analysis estimated shipments of battery chargers and EPSs over the 

30-year analysis period (2013-2042), which were used in performing the national impact 

analysis (NIA); 

• A national impact analysis assessed the national energy savings (NES), and the 

national net present value of total consumer costs and savings, expected to result from 

specific, potential energy conservation standards for battery chargers and EPSs; and 

• A preliminary manufacturer impact analysis took the initial steps in evaluating 

the effects new or amended efficiency standards may have on manufacturers. 

In the September 2010 notice, DOE summarized the nature and function of the 

following analyses: (1) engineering, (2) energy use analysis, (3) markups to determine 

installed prices, (4) LCC and PBP analyses, and (5) national impact analysis. Id. at 

56023-56024. 

DOE held a public meeting on October 13, 2010, to discuss its preliminary 

analysis. At this meeting, DOE presented the methodologies and results of the analyses 

set forth in the preliminary TSD. Major topics discussed at the meeting included, among 

51 
 

others, the regulation of EPSs for motorized applications and applications with 

detachable batteries (MADB EPSs), criteria for establishing separate product classes, and 

assumptions made by DOE on the usage of certain products. The comments received 

since publication of the September 2010 notice, including those received at the 

preliminary analysis public meeting, have contributed to DOE’s proposed resolution of 

the issues noted by interested parties. This NOPR quotes and summarizes many of these 

comments, and responds to the issues they raised.16 

DOE received written comments on the preliminary analysis from four industry 

groups (the Association of Home Appliance Manufacturers (AHAM, No. 42); the 

Consumer Electronics Association (CEA, No. 46), the Power Tool Institute, Inc. (PTI, 

No. 45); and the Wireless Power Consortium (WPC, No. 40)), six manufacturers (Cobra 

Electronics Corp. (Cobra, No. 51); Lester Electrical of Nebraska, Inc. (Lester) (Lester, 

No. 50); Motorola, Inc. (Motorola, No. 48); Philips Electronics North America Corp. 

(Philips, No. 41); Stanley Black & Decker (SBD, No. 44); and Wahl Clipper Corporation 

(Wahl, No. 53)), and several energy efficiency advocates, including a number of utilities 

(Pacific Gas and Electric Company, San Diego Gas and Electric Company, Southern 

California Gas Company, and Southern California Edison, collectively organized as the 

California Investor Owned Utilities (California IOUs, No. 43); Northeast Energy 

Efficiency Partnerships (NEEP, No. 49); and a joint comment from Pacific Gas and 

Electric Company, Southern California Gas Company, San Diego Gas and Electric 

Company, Southern California Edison, Appliance Standards Awareness Project, 

16 A parenthetical reference at the end of a quotation or paraphrase provides the location of the item in the 

public record. 

52 
 

 

 

 

 

 

 

 

 

Northeast Energy Efficiency Partnerships, Northwest Energy Efficiency Alliance, 

American Council for an Energy-Efficient Economy, and Natural Resources Defense 

Council (PG&E, et al., No. 47)). These commenters, along with those that provided oral 

comments at the preliminary analysis public meeting, are summarized in Table II-2Table 

II.2. 

Table II-2 Stakeholders Providing Comments on the Preliminary Analysis 

Name Abbreviation Type* Oral 

Comments 

Written 

Comments 

Association of Home Appliance 

Manufacturers AHAM IR  

California Investor-Owned Utilities California IOUs U 

Cobra Electronics Corp. Cobra M 

Consumer Electronics Association CEA IR 

Earthjustice EarthJustice EA 

Ecos Consulting on behalf of Pacific Gas 

and Electric ECOS EA 

Fulton Innovation Fulton Innovation M 

Lester Electrical Lester M 

Motorola Motorola M 

Northeast Energy Efficiency 

Partnerships NEEP EA 

Pacific Gas and Electric and others PG&E, et al. U 

Philips Electronics North America Philips M  

Power Tool Institute PTI IR 

Stanley Black & Decker SBD M  

Wahl Clipper Wahl Clipper M 

Wireless Power Consortium WPC IR 

*IR: Industry Representative; M: Manufacturer; EA: Efficiency/Environmental Advocate; CA: Consumer 

Advocate; CS: Component Supplier: TE: Technical Expert: I: Individual; U: Utility; UA: Utility Advocate; 

FG: Foreign Government Agency 

Following the close of the formal public comment period, DOE also received a 

clarification statement regarding an earlier submission to which ASAP joined with other 

commenters (ASAP, No. 55) and a proposal for DOE to adopt an efficiency marking 

protocol for battery chargers from the Natural Resources Defense Council (NRDC, No. 

56). 

53 
 

 

 

III. General Discussion 

The following section discusses various technical aspects related to this proposed 

rulemaking. In particular, it addresses aspects involving the test procedures for battery 

chargers and EPSs, the technological feasibility of potential standards to assign to these 

products, and the potential energy savings and economic justification for prescribing the 

proposed amended standards for battery chargers and EPSs. 

A. Test Procedures 

To help analyze the proposal for the products covered under today’s rulemaking, 

DOE applied the recently amended test procedures for EPSs and battery chargers. The 

following sections explain how DOE applied these procedures in evaluating the standards 

that are being proposed. 

1. External Power Supply Test Procedures 

DOE used its recently modified EPS test procedure as the basis for evaluating 

EPS efficiency in the NOPR. This procedure, which was recently codified in appendix Z 

to subpart B of 10 CFR Part 430 (“Uniform Test Method for Measuring the Energy 

Consumption of EPSs”), includes a means to account for the energy consumption from 

multiple-voltage EPSs and clarifies the manner in which to test those devices that 

communicate with their loads. See 76 FR 31750, 31782-31783 (June 1, 2011). The term 

“load communication” refers to the ability of an EPS to identify whether a given load is 

compatible with the product that is being powered. See id. at 31752-31753. 

54 
 

The amended test procedure produces two key outputs relevant to today’s 

proposal. In particular, the procedure provides measurements for active mode efficiency 

and no-load mode power consumption. For single output voltage EPSs, active-mode 

conversion efficiency is the ratio of output power to input power. DOE averages the 

efficiency at four loading conditions—25, 50, 75, and 100 percent of maximum rated 

output current. For multiple-voltage EPSs, the test procedure produces these same four 

efficiency measurements, but does not average them. For both single-voltage and 

multiple-voltage EPSs, DOE measures the power consumption of the EPS when 

disconnected from the consumer product, which is termed no-load power consumption. If 

the EPS has an on-off switch, the switch is placed in the “on” position when making this 

measurement. 

2. Battery Charger Test Procedures 

The initial battery charger test procedure, 71 FR 71340, 71368 (Dec. 8, 2006), 

included a means to measure battery charger energy consumption in “maintenance” and 

“no-battery” modes. These are non-active modes of operation for a battery charger and 

neither mode is the primary (i.e. active) mode of operation for a battery charger. A 

battery charger is in maintenance mode when the battery it is designed to charge is fully 

charged, but is still plugged into the charger -- i.e. the charger is maintaining the charge 

in the battery. Standby mode, also known as no-battery mode, occurs when a battery 

charger is plugged into the wall (or power source), but the battery has been removed. The 

test procedure was amended to include measurements (or metrics) to account for the 

energy consumption that takes place in a battery charger during all modes of operation -- 

55 
 

 

 

active (i.e. the energy consumed by a battery charger while charging a battery), 

maintenance (i.e. the energy consumed to maintain the charge of a battery that has 

already been fully charged), standby (the energy consumed when a battery charger is 

plugged in, but the battery is removed from the device), and off (i.e. the energy consumed 

while a charger is plugged in but is switched off) modes. 76 FR 31750. 

In analyzing the various products in preparation of the preliminary analysis, DOE 

relied on a test procedure that was largely based on a procedure that had been developed 

by the California Energy Commission (CEC). That procedure also served as the basis for 

DOE’s 2010 proposal to amend the procedure to account for active mode energy 

consumption during testing. 75 FR 16958 (April 2, 2010). 

The proposed procedure DOE employed had two key differences from the CEC 

procedure. First, it employed a shortened test procedure for battery chargers whose output 

power to the battery stabilizes within 24 hours. Second, the procedure employed a 

reversed charge/discharge testing order from that specified in the CEC procedure. DOE 

proposed switching the order such that the proposal used a preparatory charge, followed 

by a measured discharge, followed by a measured charge. The final rule dropped this 

approach in favor of the order prescribed in the CEC procedure -- i.e. preparatory 

discharge, a measured charge, and a measured discharge. DOE applied this amended test 

procedure when analyzing the potential energy efficiency levels for battery chargers. 

56 
B. Technological Feasibility 

The following sections address the manner in which DOE assessed the 

technological feasibility of potential standard levels. Energy conservation standards 

promulgated by DOE must be technologically feasible. Separate analyses were conducted 

for EPSs and battery chargers. 

1. General 

In each standards rulemaking, DOE conducts a screening analysis based on 

information gathered on all current technology options and prototype designs that have 

the potential to improve product or equipment efficiency. To conduct the analysis, DOE 

develops a list of design options for consideration in consultation with manufacturers, 

design engineers, and other interested parties. DOE then determines which of these 

means for improving efficiency are technologically feasible. DOE considers a design 

option to be technologically feasible if it is currently in use by the relevant industry, or if 

a working prototype exists. See 10 CFR part 430, subpart C, appendix A, section 

4(a)(4)(i), which provides that “[t]echnologies incorporated in commercially available 

products or in working prototypes will be considered technologically feasible.” 

Once DOE has determined that particular design options are technologically 

feasible, it evaluates each of these design options using the following additional 

screening criteria: (1) practicability to manufacture, install, or service; (2) adverse 

impacts on product utility or availability; and (3) adverse impacts on health or safety. (10 

CFR part 430, subpart C, appendix A, section 4(a)(4)). Section IV.B of this notice 

57 
 

 

 

 

 

discusses the results of the screening analysis for battery chargers and EPSs, particularly 

the designs DOE considered, those it screened out, and those that are the basis for the 

trial standard levels (TSLs) in this rulemaking. 

For further details on the screening analysis for this rulemaking, see chapter 4 of 

the TSD. 

Additionally, DOE notes that it has received no interested party comments 

regarding patented technologies and proprietary designs that would prohibit all 

manufacturers from achieving the energy conservation standards proposed in today’s 

rule. At this time, DOE believes that the proposed standards for the products covered as 

part of this rulemaking will not mandate the use of any such technologies, but requests 

additional information regarding proprietary designs and patented technologies. 

2. Maximum Technologically Feasible Levels 

When proposing an amended standard for a type or class of covered product, 

DOE must ‘‘determine the maximum improvement in energy efficiency or maximum 

reduction in energy use that is technologically feasible’’ for such product. (42 U.S.C. 

6295(p)(1)). DOE determined the maximum technologically feasible (“max-tech”) 

efficiency level, as required by section 325(o) of EPCA, by interviewing manufacturers, 

vetting their data with subject matter experts, and presenting the results for public 

comment. (42 U.S.C. § 6295(o)). 

Comment [A12]: Change recommended by 

OIRA. 

58 
 

 

 

 

a. External Power Supply Max-Tech Levels 

DOE conducted several rounds of interviews with manufacturers of EPSs, 

integrated circuits for EPSs, and applications using EPSs. All of the manufacturers 

interviewed identified ways that EPSs could be modified to achieve efficiencies higher 

than those available with current products. These manufacturers also described the costs 

of achieving those efficiency improvements, which DOE examines in detail in chapter 5 

of the TSD. DOE independently verified the accuracy of the information described by 

manufacturers.17 Verifying this information required examining and testing products at 

the best-in-market efficiency level and determining what design options could still be 

added to improve their efficiency. By comparing the improved best-in-market designs 

(using predicted performance and cost) to the estimates provided by manufacturers, DOE 

was able to assess the reasonableness of the max-tech levels developed. 

DOE solicited comment on its review of the max-tech CSLs prepared for the 

preliminary analysis – particularly with respect to its initial view that 2.5W EPSs may be 

able to achieve a max-tech efficiency of 80% rather than the lower efficiency suggested 

by manufacturers (See Chapter 5 of the TSD for details on how DOE aggregated 

manufacturer data). During interviews conducted in preparation for the NOPR, 

manufacturers confirmed that an 80% efficiency level is achievable for 2.5W EPSs, but 

not without a decrease in utility. Manufacturers stated that reaching that efficiency level 

17 In confirming this information, DOE obtained technical assistance from two subject matter experts -­

Robert Gourlay of RDG Engineering in Northridge, CA. and Jon Wexler, an independent and solo 

consultant in Los Angeles, CA. These two experts were selected after having been found through the 

Institute of Electrical and Electronics Engineers (IEEE). Together, they have over 30 years of combined 

experience with power supply design. The experts relied on their years of experience to evaluate the 

validity of both the design and the general cost of the max-tech efficiency levels provided by 

manufacturers. 

59 
would require an increase in the form factor (i.e. the geometry of the design), which 

would make these devices larger. The increased size of the EPS would, in the 

manufacturers’ views, constitute a decreased utility that would be undesirable to 

consumers because of demands for smaller and lighter products. In light of this 

possibility, DOE used a max-tech efficiency value of 74.8%, which represents the 

average max-tech efficiency level predicted by manufacturers, to characterize CSL 4. The 

aggregated responses from manufacturers are discussed in chapter 5 of the TSD. 

DOE created the max-tech (CSL 4) equations for average efficiency and no-load 

power using curve-fits (i.e. creating a continuous mathematical expression to represent 

the trend of the data as accurately as possible) of the aggregated manufacturer data (see 

chapter 5 of the TSD for details on curve fits). DOE created the equations for no-load 

power based on a curve fit of the no-load power among the four representative units. For 

both the average efficiency and no-load power CSL equations, DOE used equations 

similar to those for CSL 1, involving linear and logarithmic terms in the nameplate output 

power. DOE chose the divisions at 1 watt and 49 watts in the CSL 4 equations to ensure 

consistency with the nameplate output power divisions between the equations for CSL 1. 

In the determination for non-Class A EPSs, DOE created CSLs based on test and 

teardown data as well as manufacturer interview data consistent with the Class A EPS 

methodology. See 75 FR 27170, 27174-27175. DOE also stated in Chapter 5 of the 

preliminary analysis TSD that it might further evaluate additional CSLs should that 

60 
become necessary pending later analysis, including revising the max-tech CSLs for all 

the representative units. 

For the NOPR, DOE has chosen to add a new max-tech CSL for high-power EPSs 

while the max-tech for multiple-voltage EPSs remains unchanged from the preliminary 

analysis. Based on its analysis, DOE ascertained that 345W EPSs are able to achieve 

comparable efficiencies to 120W EPSs because efficiency tends to improve with higher 

nameplate output power before leveling off regardless of output power. Because of the 

diminishing returns of this trend, there would be no appreciable difference in the 

achievable efficiency of a 120W EPS and a 345W EPS. Therefore, DOE scaled its 120W 

EPS cost-efficiency curve using its voltage scaling method, outlined in Chapter 5 of the 

TSD, to generate the max-tech CSL for 345W EPSs. The max-tech no-load metric was 

chosen by assuming that three 120W EPSs could theoretically be connected to deliver 

345 watts to a load (i.e. three 120W EPSs yield a 360W load). Consequently, in 

analyzing the potential cost-efficiency curves for these products, the no-load metric DOE 

created for CSL 4 is three times greater than the no load used for the 120W equivalent 

CSL. 

b. Battery Charger Max-Tech Levels 

The preliminary analysis did not include max-tech efficiency levels for five of the 

ten product classes that are being addressed today. DOE omitted levels for these product 

classes because manufacturers did not provide information on levels of performance that 

would be technologically feasible and more efficient than the current best-in-market 

61 
 

 

 

devices. DOE’s preliminary analyses typically rely heavily on manufacturer input in 

framing potential max-tech levels for discussion and comment. 

In preparing today’s NOPR, which includes max-tech levels for the ten classes 

initially addressed in DOE’s preliminary analysis, DOE developed a means to create 

max-tech levels for those classes that were previously not assigned max-tech levels. For 

the product classes that DOE was previously unable to generate max-tech efficiency 

levels, DOE used multiple approaches to develop levels for these classes. DOE once 

again solicited manufacturers for information and extrapolated performance parameters 

from its best-in-market efficiency levels. Extrapolating from the best-in-market 

performance efficiency levels required an examination of the devices. From this 

examination, DOE determined which design options could be applied and what affects 

they would likely have on the various battery charger performance parameters. The table 

below shows the reduction in energy consumption when increasing efficiency from the 

baseline to the max-tech efficiency level. 

62 
Table III-1. Reduction in Energy Consumption at Max-Tech for Battery Chargers 

Product Class 

Max-Tech Unit Energy 

Consumption 

(kWh/yr) 

Reduction of Energy 

Consumption Relative to 

the Baseline (Percentage) 

1 

(Low-Energy, Inductive) 1.29 85 

2 

(Low-Energy, Low-Voltage) 0.81 91 

3 

(Low-Energy, Medium-Voltage) 0.75 94 

4 

(Low-Energy, High-Voltage) 3.01 92 

5 

(Medium-Energy, Low-Voltage) 15.35 82 

6 

(Medium-Energy, High-Voltage) 16.79 86 

7 

(High-Energy) 131.44 46 

8 

(DC to DC, < 9V Input) 0.19 79 

9 

(DC to DC, ≥ 9V Input) 0.13 83 

10a 

(AC Output, No AVR) 4.95 92 

10b 

(AC Output, AVR) 8.58 92 

Additional discussion of DOE’s max-tech efficiency levels and comments 

received in response to the preliminary analysis can be found in the discussion of 

candidate standard levels in section IV.C.2.d. Specific details regarding which design 

options were considered for the max-tech efficiency levels (and all other CSLs) can be 

found in Chapter 5 of the accompanying TSD. 

C. Energy Savings 

The following discussion addresses the various steps DOE used to assess the 

potential energy savings that DOE projects will likely accrue from the various standard 

levels that were examined. 

63 
 

1. Determination of Savings 

DOE used its NIA spreadsheet model to estimate energy savings from amended 

standards for the battery chargers and EPS products that are the subject of this 

rulemaking.18 For each TSL, DOE forecasted energy savings beginning in 2013, the year 

that manufacturers would be required to comply with amended standards, and ending in 

the last year products shipped in 2042 would be retired. DOE quantified the energy 

savings attributable to each TSL as the difference in energy consumption between the 

standards case and the base case. The base case represents the forecast of energy 

consumption in the absence of amended mandatory efficiency standards and considers 

market demand for more-efficient products. 

The NIA spreadsheet model calculates the electricity savings in “site energy” 

expressed in kilowatt-hours (kWh). Site energy is the energy directly consumed by 

battery chargers and EPSs at the locations where they are used. DOE reports national 

energy savings on an annual basis in terms of the aggregated source (primary) energy 

savings, which is the savings in the energy that is used to generate and transmit the site 

energy. (See chapter 10 of the TSD.) To convert site energy to source energy, DOE 

derived annual conversion factors from the model used to prepare the Energy Information 

Administration’s (EIA) Annual Energy Outlook 2010 (AEO2010). 

18 The NIA spreadsheet model is described in section IV.G of this notice. 

64 
2. Significance of Savings 

As noted above, 42 U.S.C. 6295(o)(3)(B) any standard that DOE sets must result 

in “significant” energy savings. While the term “significant” is not defined in the Act, the 

U.S. Court of Appeals, in Natural Resources Defense Council v. Herrington, 768 F.2d 

1355, 1373 (D.C. Cir. 1985), indicated that Congress intended “significant” energy 

savings in this context to be savings that were not “genuinely trivial.” The energy savings 

for all of the TSLs considered in this rulemaking are nontrivial, and, therefore, DOE 

considers them “significant” within the meaning of section 325 of EPCA. 

D. Economic Justification 

This section summarizes the manner in which DOE estimated the economic 

impacts for the various potential standards that it evaluated. Among the aspects 

considered by DOE were the economic impacts on both manufacturers and consumers, 

life cycle costs, the amount of projected energy savings, product utility and performance, 

impacts on competition, and the general need to conserve energy. 

1. Specific Criteria 

As noted in section II.B, EPCA provides seven factors to be evaluated in 

determining whether a potential energy conservation standard is economically justified. 

(42 U.S.C. 6295(o)(2)(B)(i)) The following sections discuss how DOE has addressed 

each of those seven factors in this rulemaking. 

65 
 

a. Economic Impact on Manufacturers and Consumers 

In determining the impacts of new and amended standards on manufacturers, 

DOE first determines the quantitative impacts using an annual cash-flow approach. This 

step includes both a short-term assessment—based on the cost and capital requirements 

during the period between the issuance of a regulation and when entities must comply 

with the regulation—and a long-term assessment over a 30-year analysis period. The 

industry-wide impacts analyzed include INPV (which values the industry on the basis of 

expected future cash flows), cash flows by year, changes in revenue and income, and 

other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts 

on different types of manufacturers, including impacts on small manufacturers. Third, 

DOE considers the impact of standards on domestic manufacturer employment and 

manufacturing capacity, as well as the potential for standards to result in plant closures 

and loss of capital investment. Finally, DOE takes into account cumulative impacts of 

different DOE regulations and other regulatory requirements on manufacturers. 

For individual consumers, measures of economic impact include the changes in 

LCC and the PBP associated with new or amended standards. The LCC, specified 

separately in EPCA as one of the seven factors to be considered in determining the 

economic justification for a new or amended standard, 42 U.S.C. 6295(o)(2)(B)(i)(II), is 

discussed in the following section. For consumers in the aggregate, DOE also calculates 

the national net present value of the economic impacts on consumers over the forecast 

period used in a particular rulemaking. 

66 
 

b. Life-Cycle Costs 

The LCC is the sum of the purchase price of a product (including its installation) 

and the operating expense (including energy and maintenance expenditures) discounted 

over the lifetime of the product. For each battery charger product class and EPS 

representative unit, DOE calculated both LCC and LCC savings for various efficiency 

levels. The LCC analysis required a variety of inputs, such as product prices, electricity 

prices, product lifetimes, base case efficiency distributions, annual unit energy 

consumption, and discount rates. 

To characterize variability in electricity pricing, DOE established regional 

differences in electricity prices. To account for uncertainty and variability in other inputs, 

such as discount rates, DOE used a distribution of values with probabilities assigned to 

each value. DOE then sampled the values of these inputs from the probability 

distributions for each consumer. The analysis produced a range of LCCs. A distinct 

advantage of this approach is that DOE can identify the percentage of consumers 

achieving LCC savings due to an increased energy conservation standard, in addition to 

the average LCC savings. DOE presents only average LCC savings in this NOPR; 

however, additional details showing the distribution of results can be found in chapter 8 

and appendix 8B of the TSD. 

In the LCC analysis, DOE determined the input values for a wide array of end-use 

applications that are powered by battery chargers or EPSs. There are typically multiple 

applications within every representative unit and product class that DOE analyzed. As 

67 
 

 

 

such, DOE considered a wide array of input values for each unit analyzed. The lifetime, 

markups, base case market efficiency distribution, and unit energy consumption all vary 

based on the application. In the analysis, DOE sampled an application based on its 

shipment-weighting within the representative unit or product class. When an application 

was sampled, its unique inputs were selected for calculating the LCC and PBP. For 

further detail regarding application sampling, see appendix 8C of the TSD. 

In its written comments, AHAM stated that the MIA and LCC calculations should 

be the most important considerations when determining where to set the standard level. 

(AHAM, No. 42 at p. 15) DOE considered many criteria when selecting the proposed 

standard level, including impacts on manufacturers, consumers, the Nation, and 

environmental impacts. DOE weighed the impacts from each of these analyses in 

determining the proposed standard level. 

c. Energy Savings 

While significant conservation of energy is a separate statutory requirement for 

imposing an energy conservation standard, EPCA requires DOE, in determining the 

economic justification of a standard, to consider the total projected energy savings that 

are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) DOE 

uses the NIA spreadsheet results in its consideration of total projected energy savings. 

d. Lessening of Utility or Performance of Products 

In establishing classes of products, and in evaluating design options and the impact of 

potential standard levels, DOE sought to develop standards for EPSs and battery chargers that 

68 
 

 

 

 

would not lessen the utility or performance of these products. None of the TSLs presented in 

today’s NOPR would substantially reduce the utility or performance of the products under 

consideration in the rulemaking. DOE received no comments that standards for battery 

chargers and EPSs would increase their size and reduce their convenience, increase the length 

of time to charge a product, shorten the intervals between chargers, or any other significant 

adverse impacts on consumer utility. However, based on DOE’s preliminary examination of 

the information before it, including interviews with manufacturers, manufacturers may 

reduce the availability of features that increase energy use, such as LED indicator lights, in 

an effort to meet any standard levels promulgated as a result of this rulemaking. (42 U.S.C. 

6295(o)(2)(B)(i)(IV)) Manufacturers indicated that these changes would only be made if their 

customers would not be averse to the change in utility. DOE requests interested party 

feedback, including any substantive data, regarding today’s proposed standard levels and the 

potential for lessening of utility or performance related features. 

e. Impact of Any Lessening of Competition 

EPCA directs DOE to consider any lessening of competition that is likely to result 

from standards. It also directs the Attorney General of the United States (Attorney 

General) to determine the impact, if any, of any lessening of competition likely to result 

from a proposed standard and to transmit such determination to the Secretary within 60 

days of the publication of a proposed rule, together with an analysis of the nature and 

extent of the impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) DOE has transmitted a 

copy of today’s proposed rule to the Attorney General and has requested that the 

Department of Justice (DOJ) provide its determination on this issue. DOE will address 

the Attorney General’s determination, if any, in the final rule. 

Comment [A13]: Change recommended by 

OIRA. 

69 
 

 

 

 

 

f. Need for National Energy Conservation 

Certain benefits of the proposed standards are likely to be reflected in 

improvements to the security and reliability of the Nation’s energy system. Reductions in 

the demand for electricity may also result in reduced costs for maintaining the reliability 

of the Nation’s electricity system. DOE conducts a utility impact analysis to estimate how 

standards may affect the Nation’s needed power generation capacity. 

Energy savings from the proposed standards are also likely to result in 

environmental benefits in the form of reduced emissions of air pollutants and greenhouse 

gases associated with energy production. DOE reports the environmental effects from the 

proposed standards for battery chargers and EPSs, and from each TSL it considered, in 

the environmental assessment contained in chapter 15 of the TSD. DOE also reports 

estimates of the economic value of emissions reductions resulting from the considered 

TSLs in chapter 16 of the TSD. 

2. Rebuttable Presumption 

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable 

presumption that an energy conservation standard is economically justified if the 

additional cost to the consumer of a product that meets the standard is less than three 

times the value of the first year of energy savings resulting from the standard, as 

calculated under the applicable DOE test procedure. DOE’s LCC and PBP analyses 

generate values used to calculate the payback period of potential standards for 

70 
consumers. These analyses include, but are not limited to, the 3-year payback period 

contemplated under the rebuttable presumption test. However, DOE routinely conducts 

an economic analysis that considers the full range of impacts to the consumer, 

manufacturer, Nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). 

The results of this analysis serve as the basis for DOE to definitively evaluate the 

economic justification for a potential standard level, thereby supporting or rebutting the 

results of any preliminary determination of economic justification. The rebuttable 

presumption payback calculation is discussed in section V.B.1.cV.B.1.c of this NOPR 

and chapter 8 of the TSD. 

IV. Methodology and Discussion 

DOE used three spreadsheet tools to estimate the impact of today’s proposed 

standards. The first spreadsheet calculates LCCs and payback periods of potential 

standards. The second provides shipments forecasts, and then calculates national energy 

savings and net present value impacts of potential standards. Finally, DOE assessed 

manufacturer impacts, largely through use of the Government Regulatory Impact Model 

(GRIM). All three spreadsheet tools will be made available online at the rulemaking 

website: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external. 

html. 

Additionally, DOE estimated the impacts on utilities and the environment that 

would be likely to result from the setting of standards for battery chargers and EPSs. 

Formatted: Font color: Black 

71 
 

 

 

DOE used a version of EIA’s National Energy Modeling System (NEMS) for the utility 

and environmental analyses. The NEMS model simulates the energy sector of the U.S. 

economy. EIA uses NEMS to prepare its Annual Energy Outlook, a widely known 

energy forecast for the United States. The version of NEMS used for appliance standards 

analysis is called NEMS-BT19, and is based on the AEO version with minor 

modifications.20 NEMS-BT offers a sophisticated picture of the effect of standards 

because it accounts for the interactions between the various energy supply and demand 

sectors and the economy as a whole. 

A. Market and Technology Assessment 

When beginning an energy conservation standards rulemaking, DOE develops 

information that provides an overall picture of the market for the products concerned, 

including the purpose of the products, the industry structure, and market characteristics. 

This activity includes both quantitative and qualitative assessments, based primarily on 

publicly available information. The subjects addressed in the market and technology 

assessment for this rulemaking include a determination of the scope of this rulemaking; 

product classes and manufacturers; quantities and types of products sold and offered for 

sale; retail market trends; regulatory and non-regulatory programs; and technologies or 

19 BT stands for DOE’s Building Technologies Program. 20 The EIA allows the use of the name “NEMS” to describe only an AEO version of the model without any 

modification to code or data. Because the present analysis entails some minor code modifications and runs 

the model under various policy scenarios that deviate from AEO assumptions, the name “NEMS-BT” refers 

to the model as used here. For more information on NEMS, refer to The National Energy Modeling 

System: An Overview, DOE/EIA–0581 (98) (Feb.1998), available at: 

http://tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf. 

72 
 

design options that could improve the energy efficiency of the product(s) under 

examination. See chapter 3 of the TSD for further detail. 

1. Products Included in this Rulemaking 

This section addresses the scope of coverage for today’s proposal, stating which 

products would be subject to new or amended standards. The numerous comments DOE 

received on the scope of today’s proposal are also summarized and addressed in this 

section. 

a. External Power Supplies 

The term “external power supply” refers to 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)) EPCA, as amended by EISA 

2007, also prescribes the criteria for a subcategory of EPSs—those classified as Class A 

EPSs (or in context, “Class A”). A Class A EPS is a device that: 

1.	 is designed to convert line voltage 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 separate end-use product that 

constitutes the primary load; 

4.	 is contained in a separate physical enclosure from the end-use product; 

5.	 is connected to the end-use product via a removable or hard-wired 

male/female electrical connection, cable, cord, or other wiring; and 

73 
 

6. has nameplate output power that is less than or equal to 250 watts. 

See 42 U.S.C. 6291(36)(C)(i). 

The Class A definition excludes any device that either (a) 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 (b) powers 

the charger of a detachable battery pack or charges the battery of a product that is fully or 

primarily motor operated. See 42 U.S.C. 6291(36)(C)(ii). 

Based on DOE’s examination of product information, all EPSs appear to share 

four of the six criteria under the Class A definition in that all are: 

 designed to convert line voltage AC input into lower voltage AC or DC 

output; 

 sold with, or intended to be used with, a separate end-use product that 

constitutes the primary load; 

 contained in a separate physical enclosure from the end-use product; and 

 connected to the end-use product via a removable or hard-wired male/female 

electrical connection, cable, cord, or other wiring. 

DOE refers to an EPS that falls outside of Class A as a non-Class A EPS (or, in 

context, “non-Class A”). Examples of such devices include EPSs that can convert power 

to more than one output voltage at a time (multiple voltage), EPSs that have nameplate 

output power exceeding 250 watts (high-power), EPSs used to power medical devices, 

74 
and EPSs that provide power to the battery chargers of motorized applications and 

detachable battery packs (MADB). After examining the potential for energy savings that 

could result from standards for non-Class A devices, DOE concluded that standards for 

these devices would be likely to result in significant energy savings and be 

technologically feasible and economically justified. 75 FR 27170 (May 14, 2010). Thus, 

DOE is examining the possibility of setting standards for all types of EPSs within the 

scope of today’s notice. 

In the preliminary analysis, DOE treated only those wall adapters that lacked 

charge control as EPSs; those with charge control were not considered to be EPSs. 

(Charge control relates to regulating the amount of current being delivered to a battery.) 

Under that approach, a given wall adapter without charge control capability could be 

considered both as an EPS and as a part of a battery charger. If that approach were 

adopted, such a wall adapter would be subject to whatever EPS standard that DOE may 

set and would also, indirectly, help the battery charger of which it is a part to meet 

whatever battery charger standard that DOE may set. In essence, the EPS would need to 

satisfy a prescribed level of efficiency, which could create certain design restrictions on 

manufacturers seeking to optimize the overall efficiency of the battery charger. 

In the following paragraphs, DOE summarizes and addresses the comments it 

received on (1) whether to set EPS standards for wall adapters that are part of battery 

chargers, (2) whether the absence of charge control circuitry should be the basis for 

regulating such wall adapters, and (3) if so, appropriate methods for determining whether 

75 
 

 

 

 

a given wall adapter contains charge control. DOE received a few comments urging DOE 

to regulate these types of EPSs -- which are part of a battery charger system -- as part of 

the overall battery charger and also as an EPS to help ensure that whatever EPS is used in 

such a charger system meets a minimum level of efficiency. Several other parties, 

however, objected to requiring that these EPSs also meet separate EPS standards. 

Comments focused mainly on MADB EPSs, but some pertained to EPSs generally. In 

response to these comments, DOE is proposing a new approach, namely, to evaluate 

whether an EPS can directly operate an end-use consumer product and to create a new 

product class for those EPSs that cannot directly operate an end-use consumer product. 

DOE is considering this approach in light of the substantial resistance by the industry to 

the initial approach presented during the preliminary analysis phase. 

Energy efficiency advocates favored requiring certain EPSs that are part of 

battery chargers to also meet separate EPS standards—in particular, for those EPSs that 

do not perform charge control functions. PG&E, et al. expressed their strong support for 

this approach and cited research showing that improving the efficiency of a power supply 

helps improve the efficiency of a battery charger. In addition, PG&E commented that a 

single EPS definition (rather than one for Class A and another for non-Class A) would 

reduce the complexity of compliance and enforcement as well as the potential for 

loopholes. (PG&E, et al., No. 47 at p. 3-4) NEEP also expressed its support for this 

approach and added that DOE's initial research shows that there are a limited number of 

cases where EPSs would be regulated under both standards. (NEEP, No. 49 at pp. 1-2) 

The California IOUs and PG&E, et al. expressed their support for using the ENERGY 

76 
STAR EPS definition to determine whether a wall adapter is an EPS. (California IOUs, 

No. 43 at p. 9; PG&E, et al., No. 47 at p. 4) 

AHAM, PTI, and Wahl Clipper agreed with DOE and the efficiency advocates 

that MADB wall adapters should be regulated, but not under multiple efficiency 

requirements. Instead, they urged DOE to regulate these items as battery charger 

components but not as EPSs. (AHAM, No. 42 at pp. 2, 3, 13; PTI, No. 45 at p. 4; Wahl, 

No. 53 at p. 1) PTI argued that a MADB wall adapter cannot be an EPS because it is not 

used "to operate a consumer product." According to PTI, a MADB wall adapter operates 

a battery charger, but a battery charger is not a consumer product because battery 

chargers are not themselves "distributed in commerce for personal use or consumption by 

individuals." Thus, in its view, MADB wall adapters are not EPSs. (PTI, No. 45 at pp. 3­

4; Pub. Mtg. Tr., No. 57 at p. 74) AHAM argued that subjecting a product to multiple 

energy efficiency requirements (1) “makes no sense,” (2) could cause manufacturers to 

be in "constant redesign mode" if EPS and battery charger standards change at different 

times, and (3) would be an undue burden. (AHAM, No. 42 at pp. 4-5) AHAM contended 

further that the EPS active mode test is inappropriate and inaccurate for MADB wall 

adapters, as they are never used in the manner tested under that procedure. Consequently, 

in AHAM's view, requiring that these types of wall adapters be tested under the EPS test 

procedure would not enable DOE to meet its obligation to test products in a manner 

representative of their actual use. (AHAM, No. 42 at p. 6) Wahl Clipper echoed AHAM's 

concerns that the EPS test procedure is inappropriate for MADB wall adapters and noted 

that unsynchronized battery charger and EPS standards would force manufacturers to 

77 
 

 

 

constantly redesign their products. Wahl Clipper added that manufacturers "do not know 

if future standards levels will make it impossible to meet both regulations at the same 

time since there is no correlation between the two regulations." (Wahl, No. 53 at p. 1) 

Others had similar concerns about setting standards for Class A devices that are 

part of battery chargers. CEA, Cobra Electronics, and Motorola objected to regulating 

any wall adapter as both an EPS and a component of a battery charger. These parties 

drew attention to the burden that multiple energy efficiency requirements would impose 

on manufacturers—small businesses in particular. CEA commented that its "foremost 

concern is DOE's contemplation of a 'double jeopardy' regulatory situation whereby a 

single charging device would be subject to two different test procedures and two different 

sets of regulatory requirements," and added that such a situation would be "unreasonable 

and unnecessary—and would be particularly onerous for small businesses." (CEA, No. 

46 at pp. 1-2) Cobra Electronics, which markets and sells two-way radios and mobile 

navigation devices, commented that “having to be regulated under two standards for a 

product which is infrequently used is an unreasonable burden for small companies when 

added to the burden of other recent regulations." (Cobra, No. 51 at p. 1) Motorola also 

agreed with CEA that the energy efficiency of EPSs should not be regulated in two 

different product categories (battery chargers and EPSs) and added that “given the likely 

high performance standards that will be set for battery chargers, it would be nearly 

impossible for an external power supply to comprise part of a [standards-compliant] 

battery charger if it were not itself highly efficient.” (Motorola, No. 48 at pp. 1-2) 

78 
 

AHAM also asserted that DOE risks overestimating energy savings if it does not 

determine how to remove the overlap between battery charger and EPS energy savings. 

AHAM emphasized the importance of accurately quantifying the extent to which energy 

savings from battery charger and EPS standards might overlap so that DOE can 

accurately project the potential energy savings from potential standards. (AHAM, Pub. 

Mtg. Tr., No. 57 at p. 112) 

After carefully considering all of these comments, DOE has tentatively decided to 

adopt a broad scope and to propose an approach in which EPS standards could apply to 

all devices that meet the EPS definition prescribed by EPCA. See 42 U.S.C. 6291(36)(A). 

Those standards prescribed by Congress, namely, those for Class A devices, will remain 

in effect, and DOE, despite the objections raised by CEA and others, has no authority to 

remove these standards, although these standards could be amended to increase their 

stringency. With regard to non-Class A EPSs that are components of battery chargers, 

DOE has the option to propose new efficiency standards for these devices, including 

those devices that perform charge control functions. 

To help it ascertain whether a given wall adapter performs charge control 

functions, DOE sought comment during the preliminary analysis phase on seven methods 

it presented to determine whether charge control is present in a wall adapter. See 

Preliminary TSD, appendix 3-C (detailing the methods DOE considered for determining 

whether a wall adapter contains charge control). In the preliminary analysis, DOE used a 

method it called "Energy Star Inspection," which is based on parts (f) and (g) of the 

79 
 

 

ENERGY STAR program’s definition of an EPS. ("ENERGY STAR Program 

Requirements for Single Voltage External Ac-Dc and Ac-Ac Power Supplies, Eligibility 

Criteria (Version 2.0)"21) This method considers certain easily observable physical 

characteristics of the wall adapter. Under this approach, a wall adapter that meets either 

of the following two criteria would be exempt from having to satisfy separate EPS 

standards and would instead be treated simply as a battery charger component: (1) the 

wall adapter has batteries or battery packs that physically attach directly (including those 

that are removable) to the power supply unit; OR (2) the wall adapter has a battery 

chemistry or type selector switch AND an indicator light or state of charge meter. 

As noted above, DOE received comments from the California IOUs and PG&E 

that supported using this method. PTI contended that DOE neglected to include MADB 

wall adapters in its preliminary assessment of the seven methods and requested that DOE 

include these products in any future analysis of possible charge control criteria. (PTI, No. 

45 at p. 4) AHAM viewed the presence of charge control in a wall adapter as irrelevant. 

In its view, DOE should ask whether a given wall adapter is a MADB device, as all 

MADB wall adapters should be excluded from any EPS standards. (AHAM, No. 42 at p. 

12) DOE received no other comments on the appropriateness of the Energy Star 

Inspection method or any of the six other methods it considered for identifying charge 

control in wall adapters. 

21 http://www.energystar.gov/ia/partners/product_specs/program_reqs/eps_prog_req.pdf 

80 
 

 

 

At this time, DOE does not believe that such an exclusion from the EPS scope of 

coverage is warranted. It is DOE’s understanding that most, if not all, of the MADB wall 

adapters that DOE proposes to add to the EPS scope of coverage are already subject to, 

and satisfy, the EPS standards currently in place in California. The California standard 

applies the same efficiency level that already applies to Class A EPSs nationwide. See 

California Energy Commission, "2009 Appliance Efficiency Regulations," August 2009, 

CEC-400-2009-013, Table U-1 on p. 134. This efficiency level is referred to as Level IV 

in the International Efficiency Marking Protocol for External Power Supplies.22 

Comments from manufacturers and the California IOUs also support this finding. 

(California IOUs, No. 43 at p. 9) DOE is not aware of any products powered by battery 

chargers and EPSs that are not designed, manufactured, and packaged for distribution 

throughout the country. 

It is DOE’s understanding that products that use EPSs are designed, manufactured 

and packaged for distribution throughout the United States. Assuming that this 

understanding is correct, that fact indicates it is highly unlikely that manufacturers are 

producing one set of products for California and another set for the remaining states. 

Notably, California's EPS standards apply only to devices that meet the ENERGY 

STAR definition of an EPS,23 but do not meet the Class A definition established by EISA 

22 U.S. EPA, "International Efficiency Marking Protocol for External Power Supplies," October 2008, 

available at Docket No. 62. 

23 For the purposes of EPA's ENERGY STAR specification, an external power supply: (a) is designed to 

convert line voltage ac input into lower voltage ac or dc output; (b) is able to convert to only one output 

voltage at a time; (c) is sold with, or intended to be used with, a separate end-use product that constitutes 

81 
 

 

 

 

 

 

 

 

2007. (California Energy Commission, "2009 Appliance Efficiency Regulations," August 

2009, CEC-400-2009-013) This situation stems in large part from California’s adoption 

of the ENERGY STAR definition of an EPS when it first established energy conservation 

standards for these devices. Once Congress subsequently established standards for Class 

A EPSs, these Class A devices were removed from the scope of the California standards, 

leaving behind a set of devices California now refers to as "state-regulated EPSs." As a 

result, these state-regulated EPSs are those devices that meet the ENERGY STAR 

definition of an EPS but do not fall under the Class A definition -- specifically medical 

and MADB EPSs. (Multiple-voltage and high-power EPSs do not meet the ENERGY 

STAR definition but satisfy the Federal definition of an EPS.) 

Due to differences between the ENERGY STAR and Federal statutory definitions 

of an EPS, there could be MADB devices that meet the Federal statutory definition that 

are not state-regulated. For example, a MADB EPS that has a battery type selector switch 

and an indicator light, and thus does not meet the ENERGY STAR definition of an EPS, 

would not be covered either by the current Federal or California standards. However, as a 

practical matter, DOE has not identified any MADB products that meet the Federal 

statutory definition of an EPS but do not also meet the ENERGY STAR definition. Thus, 

DOE is unaware of any MADB products that are not already subject to California energy 

the primary load; (d) is contained in a separate physical enclosure1 from the end-use product; (e) is 

connected to the end-use product via a removable or hard-wired male/female electrical connection, cable, 

cord or other wiring; (f) does not have batteries or battery packs that physically attach directly (including 

those that are removable) to the power supply unit; (g) does not have a battery chemistry or type selector 

switch AND an indicator light or state of charge meter (e.g., a product with a type selector switch AND a 

state of charge meter is excluded from this specification; a product with only an indicator light is still 

covered by this specification); and (h) has nameplate output power less than or equal to 250 watts. (See 

http://www.energystar.gov/ia/partners/product_specs/program_reqs/eps_prog_req.pdf.) 

82 
efficiency standards that are within the EPS scope of coverage being contemplated today. 

DOE seeks comment on the accuracy of this belief and specific examples of such 

products, if they exist. 

As noted above, some parties commented that requiring wall adapters that are part 

of battery chargers to be tested according to the EPS test procedure would impose an 

undue burden on manufacturers and would be inappropriate and result in inaccurate 

projections of estimated energy savings. In response to these comments, DOE notes that 

Congress prescribed the definitions of what constitutes an EPS. It did not provide for any 

exceptions that would exclude those EPSs that are components of another product. Given 

this situation, DOE must assume that Congress was aware of the fact that some battery 

chargers use EPSs and that it structured these statutory provisions to allow for the 

possibility that all EPSs would be required to meet some minimum level of efficiency 

that would also improve the efficiency of those products that used these more efficient 

devices. 

As to how to measure the energy performance of these devices, DOE believes that 

these wall adapters can be evaluated using the existing EPS test procedure. See 10 CFR 

part 430, subpart B, appendix Z (detailing the procedure to follow when measuring the 

energy consumption of an EPS). In fact, this test procedure already is used to demonstrate 

compliance with existing Federal standards, in the case of Class A EPSs, and California 

83 
 

 

 

 

standards, in the case of most MADB EPSs.24 The test procedure is designed to assess the 

energy performance of an EPS while in active mode by measuring its active-mode 

efficiency at 25, 50, 75, and 100 percent of nameplate output current and then computing 

the simple arithmetic average of these four values. DOE believes that this test procedure 

yields a meaningful and representative measure of an EPS's active-mode efficiency 

because, along with the no-load mode power measurement, it covers the full range of 

outputs the device may be called on to provide in the field. This is true of EPSs that are 

not part of battery chargers as well as those that are. Thus, the EPS test procedure is 

appropriately applied to all EPSs, including those that are part of battery chargers. 

Regarding PTI's argument that MADB wall adapters cannot, by definition, be 

EPSs because they operate battery chargers (which, in its view, are not consumer 

products), DOE disagrees. First, a battery charger is a consumer product by virtue of its 

inclusion by Congress under Part A of EPCA, 42 U.S.C. 6291(32), which addresses the 

regulation of consumer products. A consumer product is any article of a type that 

consumes or is designed to consume energy and which, to any significant extent, is 

distributed in commerce for personal use or consumption by individuals. See 42 U.S.C. 

6291(1). The fact that a battery charger is a device that charges batteries for consumer 

products does not imply that chargers are not themselves consumer products, particularly 

since the definition contemplates the inclusion of those devices “in other consumer 

products, “ which indicates that Congress viewed battery chargers as a separate, and 

individual, consumer product. 

24 California has adopted the Federal EPS test procedure as part of its regulatory requirements. (California 

Code of Regulations, Title 20, Section 1604) 

84 
 

Second, EPSs are also consumer products for similar reasons. 

Third, a MADB wall adapter satisfies the EPS definition since it “convert[s] 

household electric current... to operate a consumer product." See 42 U.S.C. 6291(36)(A) 

(emphasis added). Whether the MADB wall adapter is considered to operate a battery 

charger, which is a consumer product, or is considered to enable the end-use consumer 

product to operate (by supplying energy to the battery, which in turn operates the end-use 

product), a MADB wall adapter falls squarely within the EPS definition because it is 

taking household electric current to operate a consumer product. Accordingly, in DOE’s 

view, MADB wall adapters are EPSs. 

However, in view of the concerns raised by industry commenters, DOE believes 

there may be merit in distinguishing between a direct operation EPS and an indirect 

operation EPS. In particular, some EPSs are able to directly power an end-use consumer 

product (e.g., a wireless Internet router), while others cannot. This distinction may be 

necessary because DOE believes that less stringent EPS standards may be appropriate for 

indirect operation EPSs, which cannot directly operate an end-use consumer product. As 

explained later, DOE is proposing a means to differentiate between these two types of 

EPSs and to set different efficiency standards for them. DOE's proposed approach to 

regulating these products is described in more detail in sections 0IV.A.3 and V.C below. 

85 
DOE notes that while Congress amended EPCA to exempt certain EPSs used in 

security and life safety alarms and surveillance systems from the no-load mode power 

requirements that apply generally to Class A EPSs manufactured prior to July 1, 2017, 

see Pub. L. 111-360 (Jan. 4, 2011), such systems would be subject to the proposed active 

mode standards under consideration in this NOPR. See 42 U.S.C. 6295(u)(3)(E)(ii) 

(exempting security and life safety alarms and surveillance systems solely from no-load 

requirements). 

DOE further notes that it has recently identified an important emerging EPS 

application: solid-state lighting (SSL). SSL technology is used in both the residential and 

commercial sectors for desk lamps, under-cabinet lighting, accent lighting, and many 

other purposes. Most of the SSL luminaires (fixtures) DOE has identified have integral 

power supplies, but some use power supplies that appear to meet the EPS definition. 

Some of these EPSs plug into an outlet, while others are hard wired into the electrical 

system. DOE has not yet identified any relevant technical differences between these EPSs 

and those for laptops, cell phones, and other electronic equipment that it has analyzed in 

detail as part of today’s notice. DOE did not include SSL technology in its NOPR 

analysis because so few SSL products with EPSs were sold in 2009, the base year for 

shipments. However, because of the rapid proliferation of these products, DOE may 

consider revising its analysis to include SSL products in determining the final standards 

for EPSs. DOE invites comment on SSL EPSs, specifically on whether there are any 

differences between SSL EPSs and other EPSs that might warrant treating them as a 

separate product class. 

86 
 

b. Battery Chargers 

A battery charger is a device that charges batteries for consumer products, 

including battery chargers embedded in other consumer products. (42 U.S.C. 6291(32)) 

All devices that meet this definition are within the scope of this rulemaking. 

Like EPSs, battery chargers are used in conjunction with other end-use consumer 

products, such as cell phones and digital cameras. However, unlike EPSs, the battery 

charger definition prescribed by Congress is not limited solely to products powered from 

AC mains, i.e., those products that are plugged into a wall outlet. Further, battery 

chargers may be wholly embedded in another consumer product, wholly separate from 

another consumer product, or partially inside and partially outside another consumer 

product. 

The California IOUs commented that they "agree with DOE's wide-reaching 

consumer battery charger scope proposed in the preliminary [TSD]," as they believe "it 

will ultimately enable DOE to identify more cost-effective savings opportunities." 

(California IOUs, No. 43 at p. 2) Several other parties requested that DOE exclude golf 

car chargers and in-vehicle chargers from potential battery charger regulations. 

Lester argued that "golf cars do not meet the definition of a consumer product" 

because they are primarily purchased by businesses rather than individuals, adding that 

the leading golf car manufacturer in the United States sells the vast majority of its golf 

87 
 

 

 

 

 

cars to businesses rather than individuals -- specifically 96 percent in 2009 and 97.5 

percent in 2010. (Lester, No. 50 at p. 1) 

As indicated above, the statutory definition of “consumer product” is a broad one. 

The extent of that breadth indicates that Congress had contemplated that this definition 

would encompass a wide variety of products. DOE’s research indicates that 

approximately 10.6 percent of all new battery-powered golf cars sold each year in the 

United States are sold to individuals.25 While DOE has no reason to question Lester's 

claim that the leading golf car manufacturer sells almost all of its golf cars to businesses, 

there are clearly manufacturers that sell a significant number of golf cars to individuals. 

Further, there is no identifiable difference between battery chargers for golf cars sold to 

individuals and those for golf cars sold to golf courses and other businesses. Thus, DOE 

continues to believe that golf cars are a type of consumer product. The distinction 

between consumer products and industrial equipment has been previously addressed by 

DOE. See http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/cce_faq.pdf 

Lester also commented that in certain industrial applications the benefits of less 

energy-efficient, transformer-based battery chargers outweigh those of more energyefficient, switch mode battery chargers and that business managers are skilled in making 

the proper choice of battery charger based on a consideration of all the relevant factors. 

(Lester, No. 50 at pp. 2-3) In this context, Lester argued that businesses that purchase 

25 International Market Solutions, Golf Car-Type Vehicles and the Emerging Market for Small, TaskOriented Vehicles in the United States; Trends 2000-2006, Forecasts to 2012, December 2007. For more 

information about this report or to purchase a copy, email icaworld@optonline.net. 

88 
 

 

 

 

golf cars should be allowed to make their own decisions regarding the energy 

performance of the battery chargers they purchase, implying that there is no need for 

energy conservation standards for this product. 

DOE notes that, in general, the energy conservation standards that it sets must 

satisfy a series of criteria. See generally 42 U.S.C. 6295(o). Among these criteria is the 

need to ensure the continued utility of the regulated product. Consistent with this 

requirement, DOE will take this factor into account when setting standards for battery 

chargers. 

CEA commented that because in-vehicle chargers do not consume energy from 

the utility grid, they should not be covered by DOE. (CEA, No. 46 at p. 3) Motorola 

made similar statements and concluded that electronics that do not connect to the utility 

grid should be excluded from coverage. Motorola added that since DOE could not 

demonstrate cost savings associated with the potential efficiency standards that were 

under consideration for these products, these devices should not be regulated. (Motorola, 

No. 48 at pp. 2, 3) Cobra also expressed concerns over this product class and stated that 

quantifying the effect of battery chargers that obtain energy from 12V car batteries seems 

inaccurate and urged DOE to drop this product class from consideration. Cobra added 

that it was too difficult to accurately assess the economic impact of standards on 12V invehicle chargers because of difficulties inherent in accurately estimating gasoline 

savings. (Cobra, No. 51 at p. 3) 

89 
 

 

DOE is aware that consumer products "designed solely for use in recreational 

vehicles and other mobile equipment" are, by law, specifically excluded from coverage as 

consumer products. (42 U.S.C. 6292) Thus, a battery charger designed solely for use in 

recreational vehicles (RVs) and other mobile equipment would not be subject to battery 

charger standards. DOE has identified several consumer products—most prominently 

portable GPS navigators—that are commonly sold with 12V power adapters. However, 

DOE is not aware of any battery-operated consumer products that operate within a 

vehicle that cannot also be charged by alternate means, specifically from a 5V USB 

power source or from mains through a wall adapter. (For example, a GPS device may be 

plugged into a home computer via a USB port to receive power and to download data 

updates to the device’s memory.) In other words, these products are not designed solely 

for use in recreational vehicles and other mobile equipment. DOE seeks comment on 

whether any products exist that can only be operated on 12V. DOE also seeks comment 

on whether a device that can be powered only from a 12V power outlet can be assumed 

to be designed solely for use in recreational vehicles (RVs) and other mobile equipment, 

or whether other 12V power sources exist that could power battery chargers. Lastly, DOE 

seeks comment on whether there are battery chargers with DC inputs other than 5V and 

12V. 

DOE also considered whether the above exclusion also applies to battery chargers 

that charge mobile equipment such as golf cars, wheelchairs, and electric scooters. DOE 

has preliminarily determined that this exclusion does not apply to those types of battery 

chargers, for two reasons. First, the statute, by specifying that a device be “designed 

90 
solely for use in” a recreational vehicle or mobile equipment, appears to exclude only 

those devices that obtain power from recreational vehicles and other mobile equipment, 

not those that provide power to recreational vehicles and other mobile equipment. For 

example, a refrigerator designed solely for use in an RV obtains its power from the RV 

and, thus, is not a covered product, whereas a battery charger that is designed solely to 

charge the batteries of an electric bicycle obtains its power from another power source 

external to the bicycle (e.g., AC mains) and, thus, is a covered product. Second, EPCA 

excludes from coverage those consumer products "designed solely for use in recreational 

vehicles and other mobile equipment." DOE has found that many battery chargers that 

charge mobile equipment are not contained entirely within that equipment, but rather 

operate only partly within, or entirely outside of, that equipment. (Examples of such 

chargers include those for many wheelchairs and lawn mowers.) In DOE’s view, such a 

device is not operated solely in the mobile equipment and, thus, is not excluded from 

coverage. DOE welcomes comment on whether its understanding of how these devices 

operate is accurate. 

As to the general concern regarding the calculation of potential benefits and 

savings from standards for in-vehicle chargers, DOE notes that it is no longer considering 

these savings in order to avoid any potential conflict with the exclusions set out in EPCA. 

c. Wireless Power 

The Wireless Power Consortium (WPC), which represents companies engaged in 

the emerging technology of wireless transfer of energy to both power and charge 

consumer products, commented that it does not believe that a “wireless power transducer 

91 
 

 

is either an EPS or a battery charger” and recommended that a new category of inductive 

power supply be introduced for power supplies having inductive output. WPC explained 

that it is possible for the various components needed for these products, such as the 

transmitter transducers and receiver transducers, to be manufactured by different 

companies and sold separately. WPC further noted that it has not yet been determined 

how to address the independence of transmitter and receiver transducers in regards to 

overall system efficiency. As a result, “requirements for efficiency should be deferred 

until the technology is better understood and methods for accurately measuring the 

efficiency are developed.” (WPC, No. 42 at p. 2) Similarly, CEA requested that DOE 

categorize wireless power systems independently of battery chargers or EPSs to avoid 

regulatory mandates that could harm innovation in the emerging area of wireless power. 

CEA cited the technology's ability to charge or interact with multiple devices for multiple 

purposes simultaneously and to provide real-time power to appliances without batteries at 

a variety of power levels and transmitting efficiencies. (CEA, No. 46 at pp. 2-3) Philips, 

in reference to wireless power, expressed concern that DOE “might inadvertently take 

regulatory action that could have the unintended effect of stifling this new technology.” 

(Philips, No. 41 at p. 3) 

DOE has observed that a number of new products have entered the marketplace in 

recent years that use wireless power technology in order to charge small consumer 

electronics products such as digital music players and mobile phones. Some of these 

products transfer power using induction while others use conduction or a galvanic (i.e., 

current-carrying) connection. Products are also sold in a variety of different 

92 
configurations, as noted in WPC's comment, with some transmitters and receivers sold 

separately, while others are sold together as a system. 

There are a number of different types of products under the broad umbrella of 

"wireless power," including both battery chargers and EPSs. DOE analyzed one type, 

namely inductive battery chargers for wet environments (product class 1), and is 

proposing standards for these products today. In the preliminary analysis, DOE did not 

differentiate any other wireless power battery chargers from their conventional wired 

counterparts. DOE continues to believe that wireless power products that meet the 

definition of a battery charger, whether inductive or galvanic, are covered products. 

However, DOE also agrees with CEA that the ability to charge multiple devices 

simultaneously and wirelessly offers a unique utility to consumers that could adversely 

and inadvertently be affected by standards. Because of this fact, and the immaturity of the 

technology, which collectively explain the absence of energy efficiency performance data 

on these products, DOE is not proposing standards for these types of products. Instead, 

DOE is proposing to create a separate product class for these products and to defer 

analysis of these products to a later standards rulemaking. Therefore, in today’s 

rulemaking, DOE has reserved a section in the CFR for an 11th battery charger product 

class for products that use wireless power, in a dry environment, to charge consumer 

products. 

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With regard to the applicability of EPS standards to wireless power products, 

DOE reiterates that, by definition, an EPS "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)) Some wireless power transmitter pads are sold by themselves and, thus, are 

consumer products in their own right. Other wireless power transmitter pads are sold 

along with a power receiver. Such a product constitutes a battery charger or a large 

portion of a battery charger, which also is a consumer product. Hence, in both cases, a 

wall adapter that provides power to the wireless power transmitter pad is an EPS. 

d. Unique Products 

Through additional market study of battery chargers and external power supplies 

since the preliminary analysis, DOE has found certain “unique” products that exhibit 

characteristics spanning several of the proposed BCEPS product classes, which make 

them difficult to classify within the scope of this rulemaking. These products possess 

traits inherent to both battery chargers and external power supplies and/or were designed 

for multiple simultaneous end-use consumer applications. In one example, a product 

DOE examined supplied power to an answering machine equipped with two charging 

stations for a wireless headset and a cordless handset. The power converter itself 

provided two separate outputs at the same nameplate output voltage, but with different 

current limits on each. One output was dedicated to charging the wireless headset and one 

output was used to power the answering machine and charge the cordless handset. Under 

the definitions DOE has used to classify battery chargers and EPSs to this point, this 

product could be considered a multiple-voltage EPS, a multi-port battery charger, or even 

94 
 

 

a distinct single-voltage EPS and a battery charger depending on how the terms are 

applied. 

DOE has invested considerable effort in properly analyzing the design tendencies 

of battery chargers and EPSs and believes that the vast majority of these products can be 

classified under the definitions of this proposed rule. DOE also believes that 

manufacturers, who are most familiar with how their products function and their intended 

use, should be able to appropriately determine what type of product they are selling and 

therefore which standard is appropriate based on DOE’s proposed definitions. DOE 

requests any interested party information regarding products that may seem to fall into 

multiple product classes. 

2. Market Assessment 

a. Market Survey 

To characterize the market for battery chargers and EPSs, DOE gathered 

information on the products that use them. DOE refers to these products as end-use 

consumer products or battery charger and EPS “applications.” This method was chosen 

for two reasons. First, battery chargers and EPSs are nearly always integrated into, 

bundled with, or otherwise intended to be used with a given application; therefore, the 

demand for applications drives the demand for battery chargers and EPSs. Second, 

because most battery chargers and EPSs are not stand-alone products, their usage 

profiles, energy consumption, and power requirements are all determined by the 

associated application. 

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DOE began the development of the preliminary analysis by analyzing online and 

brick-and-mortar retail outlets to determine which applications use battery chargers and 

EPSs and which battery charger and EPS technologies are most prevalent. Because the 

market for battery charger and EPS applications continues evolving, DOE updated the 

market survey to identify new applications and determine whether any relevant attributes 

of existing applications had changed significantly between the preliminary analysis and 

NOPR phases of the rulemaking. 

In order to more accurately characterize the market for battery chargers and EPSs, 

DOE analyzed the following new applications: media tablets, mobile internet hotspots, 

smartphones, and wireless charging stations. To simplify the analysis, DOE removed 

external media drives, radio-controlled cars (hobby grade), and electronic pest repellents, 

all of which had low or unsupported shipments estimates. Battery chargers and EPSs for 

such applications and any other applications not explicitly analyzed in the market 

assessment would still be subject to the standards proposed in today’s notice as long as 

they meet the definition of a covered product outlined in sections A.1.a and A.1.b, above. 

DOE also combined Wi-Fi access points with LAN equipment and merged weed 

trimmers and hedge trimmers into a single application (rechargeable garden care 

products). Finally, DOE identified EPS applications that now also commonly contain 

rechargeable batteries and use battery chargers, including LAN equipment and video 

game consoles. Chapter 3 of the TSD discusses all of these market assessment updates in 

further detail. 

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As noted in section IV.A.1.a above, DOE is considering including EPSs for SSL 

luminaires when it updates its analysis prior to issuing a final rule. DOE welcomes 

comment on the size of the market for these products, what proportion of SSL luminaires 

use EPSs, the efficiency of those EPSs, and usage patterns. 

The California IOUs suggested that DOE consider two additional products for 

inclusion in battery charger product class 10 (AC output): emergency uninterruptible 

power supplies (UPSs) for cordless phones and emergency backup for security systems. 

(California IOUs, No. 43 at p. 7) Battery charger product class 10 is reserved for products 

that output AC power from the battery. UPSs were the only applications that met this 

criterion. Due to the small number of UPSs for cordless phones shipped annually, DOE 

did not include this application in its quantitative analysis for product class 10, despite its 

inclusion in this class. DOE recognizes that many home security systems contain 

rechargeable emergency backup batteries; however, because those backup batteries 

output DC power in order to operate the electronics in the security system, DOE placed 

these chargers in product class 2. Although DOE recognizes that there are battery charger 

and EPS applications that it did not analyze, it tentatively believes that it has included 

within its analysis all major applications and, thus, has accurately characterized battery 

charger and EPS energy consumption and savings potential for each product class. 

97 
b. Non-Class A External Power Supplies 

In addition, DOE expanded its analysis of applications that use non-Class A EPSs, 

including multiple-voltage and high-power EPSs, those EPSs that are used with medical 

devices, and EPSs used with (1) motor-operated battery charger applications and (2) the 

chargers of detachable batteries (i.e. collectively, MADB devices). In the preliminary 

analysis, DOE relied upon market information it had collected prior to publishing the 

notice of proposed determination for non-Class A EPSs in November 2009. Because 

updated information was available following the preliminary analysis, DOE revisited 

non-Class A EPSs while conducting its NOPR-phase market survey. 

DOE found that multiple-voltage EPSs are used in fewer applications today than 

they were at the time of the first survey. Specifically, DOE removed inkjet imaging 

equipment from the multiple-voltage EPS product class, leaving the Xbox 360 (a video 

game console) as the only application for these devices. 

DOE also reclassified medical EPSs based on the power requirements stated on 

retailer websites and updated lifetime and shipments estimates for medical devices. 

Philips commented that medical devices are expected to last longer than other consumer 

products and suggested using expected lifetimes of six to ten years for these products. 

(Philips, No. 41 at pp. 2-3) In the preliminary analysis, DOE estimated the product 

lifetimes for all medical devices analyzed to be greater than six years based on input from 

medical EPS manufacturers. Philips’ comment, combined with independent market 

research, helped DOE to confirm its preliminary estimates for the NOPR. All of DOE's 

98 
 

 

 

shipment and lifetime assumptions are documented in the market workbook that 

accompanies chapter 3 of the TSD. 

c. Application Shipments 

DOE relied on published market research to estimate base-year shipments for all 

applications. The base-year was changed from 2008 to 2009 for the NOPR, and 

application shipments were updated wherever supporting data were available. DOE 

estimated that in 2009 a total of 345 million EPSs and 437 million battery chargers 

shipped for final sale in the United States. Philips commented that DOE understated the 

shipments estimate for products in battery charger product class 1—inductive chargers 

for use in wet environments. In the preliminary analysis DOE assumed annual shipments 

of 5.35 million units, but Philips recommended using an estimate that is “closer to 15 

million” units. (Philips, No. 41 at p. 2) Philips later explained how it derived this estimate 

from proprietary market data and its knowledge of the toothbrush market. In the NOPRstage analysis, DOE used the shipments estimate recommended by Philips. 

One significant update to the market assessment methodology was to estimate the 

proportion of battery chargers and EPSs used exclusively in the commercial sector. 

Commercial users pay commercial electricity rates, which are lower than residential 

electricity rates, and, therefore, the cost savings they would enjoy from an energy 

conservation standard would be lower. DOE identified applications that were likely to be 

used in office buildings, restaurants, or commercial construction sites, for example, in 

order to more accurately estimate energy cost savings in the life-cycle cost (LCC) 

99 
 

 

 

 

analysis and national impact analysis. Data on commercial shipments were not readily 

available for most applications; therefore, DOE assumed similar commercial market 

shares among similar office and telecommunications applications. In the case of power 

tools, DOE assumed that commercial and residential spaces have similar repair and 

maintenance needs and, thus, used the ratio of commercial to residential floor space in the 

United States as a proxy for each sector's share of total power tool shipments. DOE seeks 

comment on which battery charger and EPS applications are used in the commercial 

sector, what fraction of shipments are to the commercial sector, and how product 

lifetimes and usage may differ between residential and commercial settings. (See Issue 2 

under “Issues on Which DOE Seeks Comment” in section VII.E of this notice.) See 

chapter 3 of the TSD for more information on DOE’s commercial sector market share 

estimates. 

d. Efficiency Distributions 

In the preliminary analysis, DOE estimated separate base-case market efficiency 

distributions for each battery charger product class and a single efficiency distribution for 

all Class A EPSs analyzed in the LCC and national impact analyses. AHAM commented 

that there are currently more EPSs in the market with efficiencies at levels higher than the 

EISA standard than what DOE estimated in the preliminary analysis; however, AHAM 

did not provide any specific data to support its claim. (AHAM, Pub. Mtg. Tr., No. 57 at 

p. 121) On the other hand, Cobra Electronics commented that most manufacturers of 

lower cost products use linear EPSs that just meet the current Federal standard rather than 

more efficient switch mode power supplies because of the higher costs involved with 

100 
using that more efficient technology. (Cobra, No. 51 at p. 3) DOE incorporated these 

stakeholder comments into its updated efficiency distribution estimates but largely relied 

upon product testing and other market research to estimate base-case efficiency 

distributions. Further detail is contained in TSD chapter 3 and the accompanying 

analytical spreadsheet models. 

In preparing today’s NOPR, DOE revised its methodology for calculating 

efficiency distributions from test data. Instead of weighting results for each individual 

tested unit based on the shipments of the associated application, DOE gave equal weight 

to the results for each unit. For battery chargers and EPSs, DOE compared each test result 

to the proposed compliance curves for each candidate standard level (CSL). DOE then 

divided the number of units at a given CSL by the total number of tested units to estimate 

the percentage of units in the market. For select applications, DOE adjusted these 

distributions to reflect additional data or other market research about these applications. 

For EPSs, DOE also calculated the distribution of tested units within the ranges of 

nameplate output power corresponding to the representative units of analysis. Finally, 

DOE continued to calculate the distribution of tested units within each battery charger 

product class. DOE assigned an efficiency distribution profile to each EPS and battery 

charger application based on application-specific data where possible. For applications 

that DOE did not test, DOE relied on product class (for battery chargers) or 

representative unit (for EPSs) distributions for use in the energy use analysis and LCC 

analysis. DOE calculated a shipment-weighted average efficiency distribution for each 

product class for use in the national impact analysis. For more detail, see sections IV.E, 

101 
 

 

IV.F, and IV.G below, which discuss the energy use, life-cycle cost, and national impact 

analyses, respectively. 

DOE received two comments regarding the effect of European Union (EU) 

energy efficiency standards on the efficiency of battery chargers and EPSs in the U.S. 

market. AHAM commented that the EU is planning to begin a series of battery charger 

efficiency standards in 2011 that could have an effect on some non-wall-adapter battery 

chargers. (AHAM, No. 42 at p. 15) Similarly, Cobra Electronics commented that the 

EU’s most recent energy efficiency standard for EPSs was established at international 

efficiency marking protocol level V. (Cobra, No. 51 at p. 3) 

DOE agrees that standards established by the EU will affect the U.S. market, due 

to the global nature of EPS design, production, and distribution, and it has accounted for 

them in the market assessment. EU standards published on April 7, 2009 require that 

EPSs manufactured after April 27, 2010 comply with International Marking Protocol 

Level IV and those manufactured after April 27, 2011 comply with Level V.26 (Level V 

represents the efficiency level in version 2.0 of the ENERGY STAR EPS specification, 

which took effect on November 1, 2008.) Though the EU included battery chargers in a 

preparatory study on eco-design requirements that it published in January 2007, it does 

not plan to set standards for such products in 2011 and has not announced plans to 

regulate battery chargers at a later date. In the preliminary analysis, DOE assumed that 50 

percent of Class A EPSs at CSL 0 (Level IV) in 2009 will move up to CSL 1 (Level V) 

26 U.S. EPA, "International Efficiency Marking Protocol for External Power Supplies," October 2008, 

available at Docket No. 62; European Commission, OL L 93/3, 7.4.2009, available at Docket No. 61. 

102 
 

 

 

by the compliance date in 2013. DOE made this assumption with the understanding that 

the efficiency of Class A EPSs will likely improve for a number of reasons before 2013, 

including the implementation of standards in Europe (which comprises a third of the 

global market) and the adoption of the “GSMA Universal Charging Solution” agreement 

by the European mobile phone industry. The GSMA Universal Charging Solution 

agreement incorporates a no-load (“standby”) power consumption requirement that is 

stricter than both the current Federal standard and ENERGY STAR version 2.0 criteria. 

DOE did not receive comment on its assumption about improvement in the efficiency of 

Class A EPSs but seeks comment from interested parties on whether its assumption is 

reasonable. 

It is also likely that current EPS standards and potential battery charger standards 

in Europe will have some effect on the efficiency of battery chargers sold in the United 

States. However, because the EU has not specified a battery charger standard level and 

EPS standard levels cannot be compared directly to the battery charger standard levels 

analyzed by DOE, the size of this effect cannot be accurately estimated. Thus, DOE did 

not adjust the efficiency distributions that it calculated for battery chargers between the 

present-day and the compliance date in 2013. 

DOE also recognizes that California may enact standards for battery chargers sold 

in that state that would come into effect prior to the promulgation of a Federal standard. 

DOE cannot determine the national impact of this potential standard, and therefore did 

not assume any improvement in market efficiency as a result of this potential standard. 

103 
DOE seeks comment on its assumption that battery charger efficiency will not 

improve between today and the compliance date in 2013. In addition, DOE seeks 

comment on its assumptions about EPS efficiency, specifically that EPSs within product 

classes B (DC output, basic-voltage), C (DC output, low-voltage), D (AC output, basicvoltage) and E (AC output, low-voltage) will improve in efficiency slightly prior to 2013, 

but then no longer improve in the absence of standards, and that EPSs within product 

classes X (multiple-voltage) and H (high-power) will not improve in efficiency in the 

absence of standards. (See issues 10 and 11 under “Issues on Which DOE Seeks 

Comment” in section VII.E of this notice.) 

3. Product Classes 

When necessary, DOE divides covered products into classes by the type of 

energy used, the capacity of the product, and any other performance-related feature that 

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 provide separate standard levels for each product class. 

At the preliminary analysis public meeting, DOE presented its rationale for 

creating 15 product classes for EPSs and 10 product classes for battery chargers. The 

product classes established for EPSs and battery chargers were based on various electrical 

characteristics shared by particular groups of products. As these electrical characteristics 

change, so does the utility and efficiency of the devices. 

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a. External Power Supply Product Classes 

In the preliminary analysis, DOE raised the possibility of creating product 

classes based on nameplate output power and nameplate output voltage. This approach 

was based on the framework set by EISA 2007 and ENERGY STAR 2.0, which, 

collectively, grouped EPSs in this manner. DOE also divided EPS product classes 

based on whether a device met the Class A definition, its application type (motorized or 

medical), its output power, its output current type, its output voltages, and the battery 

type (detachable) of the associated application. 

For Class A EPSs, the preliminary analysis divided these products into product 

classes A1, A2, A3, and A4 based on ENERGY STAR 2.0 criteria, which classify EPSs 

based on the type of power conversion (i.e., AC to DC or AC to AC) used and 

nameplate output voltage (i.e., low-voltage or basic-voltage). Each of these four 

product classes (A1-A4) from the preliminary analysis was created using these same 

criteria. The Class A EPS product classes were defined using the identical power 

conversion type and nameplate output voltage parameters as the ENERGY STAR 

program for EPSs. 

Consistent with this initial approach, DOE is proposing to adopt the ENERGY 

STAR definition for low-voltage EPSs. DOE received no comments on these class 

structures when it first raised them during the preliminary analysis phase. As a result, 

DOE is proposing to adopt these class structures as part of today’s proposal. 

Particularly, if a device has a nameplate output voltage of less than 6 volts and its 

105 
 

 

 

 

nameplate output current is greater than or equal to 550 milliamps, DOE is proposing to 

classify that device as a low-voltage EPS. Additionally, a product that does not meet the 

criteria for being a low-voltage EPS would be classified as a basic-voltage EPS. DOE is 

also proposing definitions for AC to DC and AC to AC EPSs. If an EPS converts 

household electrical current to a lower voltage DC, DOE is proposing to classify that 

product as an AC to DC EPS. Similarly, DOE is proposing to classify a device that 

converts household electrical current to a lower voltage AC output as an AC to AC 

EPS. 

DOE’s preliminary analysis also explained how DOE was planning to organize 

non-Class A EPSs, which include medical, MADB, multiple-voltage, and high-power 

(nameplate output power > 250 Watts) EPSs, into product classes. In the preliminary 

analysis, DOE created product classes M1, M2, M3, and M4 for medical EPSs and B1, 

B2, B3, and B4 for MADB EPSs. As with Class A EPSs, DOE considered four product 

classes for these two groups of devices based on combinations of power conversion 

type and voltage level. Additionally, for MADB products, DOE determined whether a 

wall adapter for a MADB application lacked charge control, as defined in appendix 3C 

of the preliminary TSD, and therefore was a MADB EPS. For multiple-voltage EPSs, 

DOE considered the creation of two product classes – X1 and X2 – and for high-power 

EPSs, it considered only one, H1. In response to the preliminary analysis, DOE 

received comments on the product class definitions presented for MADB and multiplevoltage EPSs. The issues raised are discussed below. 

106 
Indirect Versus Direct Operation External Power Supplies 

As noted in section IV.A.1, interested parties raised concerns with DOE’s 

proposed approach in the preliminary analysis regarding MADB EPSs. Based on these 

comments, DOE revised its approach and is no longer using the charge control method it 

had considered using during the preliminary analysis. Instead, DOE is proposing a 

simpler approach, which would require a manufacturer to determine whether an EPS can 

only “indirectly operate” an application. 

DOE is proposing to define an indirect operation EPS as an EPS that cannot 

power a consumer product (other than a battery charger) without the assistance of a 

battery. In other words, if an end-use product only functions when drawing power from a 

battery, the EPS associated with that product is classified as an indirect operation EPS. 

Because the EPS must first deliver power and charge the battery before the end-use 

product can function as intended, DOE considers this device an indirect operation EPS 

and has defined a separate product class, N, for all such devices. Conversely, if the 

battery’s charge status does not impact the end-use product’s ability to operate as 

intended and the end-use product can function using only power from the EPS, DOE is 

proposing to treat that wall adapter as a direct operation EPS. 

DOE’s initial approach for determining whether a given EPS has direct operation 

capability involved removing the battery from the application and attempting to operate 

the application using only power from the EPS. While this approach gave the most 

definitive EPS classifications, this procedure had the potential of creating complications 

107 
 

 

 

during testing since it can frequently necessitate the removal of integral batteries prior to 

testing. The removal of such batteries can often require access to internal circuitry via 

sealed moldings capable of shattering and damaging the application. 

DOE then developed a new method of testing to help minimize both the risk of 

damage to the application and the accompanying complexity associated with the removal 

of the internal batteries while ensuring testing accuracy. This approach would require 

product testers to determine whether an EPS can operate an end-use product once the 

associated battery has been fully discharged. Based on product testing results, DOE 

believes that direct operation EPSs will be able to power the application regardless of the 

state of the battery while indirect-operation EPSs will need to charge the battery before 

the application can be used as intended. Comparing the time required for an application 

to operate once power is applied during fully discharged and fully charged battery 

conditions would provide a reliable indication of whether a given EPS is an indirect or 

direct operation device. Recording the time for the application to reach its intended 

functionality is necessary because certain applications, such as smartphones, contain 

firmware that can delay the EPS from operating the end-use product as expected. If the 

application takes significantly longer to operate once the battery has been fully 

discharged, DOE would view this EPS as one that indirectly operates the end-use 

consumer product and classify it as part of product class N. Using this methodology, 

DOE was also able to evaluate a given product’s EPS as it was intended to be used while 

limiting the burden of the test. The full procedure is detailed in Appendix 3C of the TSD 

and in the rule language section of today’s notice. 

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Product class N that DOE is proposing in today’s notice contains both Class A 

and non-Class A EPSs. DOE believes that these two groups of devices are technically 

equivalent, i.e., there is no difference in performance-related features between the two 

groups that would justify different standard levels for the two groups. (42 U.S.C. 

6295(q)) Because of this technical equivalency, DOE grouped these EPSs into one 

product class for analysis. DOE seeks comment on whether there are any performancerelated features characteristic of either Class A or non-Class A devices (but not both) in 

product class N that would help justify analyzing the two groups separately. 

If a product is capable of directly operating its end-use consumer product, other 

characteristics must be examined to determine the appropriate product class. In its 

preliminary analysis, DOE separated product classes based on combinations of their 

power conversion type and voltage level. DOE is proposing to use these class definitions 

based on those combinations but with one change. As shown in Table IV-1, DOE used 

four product classes for each combination of power conversion type and voltage level in 

the preliminary analysis for Class A EPSs, MADB EPSs, and medical EPSs. DOE also 

considered applying the results of the Class A engineering analysis directly to medical 

and MADB EPSs, meaning there would be no difference in the cost-efficiency curves or 

the product class divisions for Class A, medical, or MADB EPSs. DOE believed this was 

a valid approach because the costs associated with improving the efficiency of a medical 

or MADB EPS were identical to those associated with the same improvements in a 

comparable Class A EPS as all three types are technically equivalent. Due to these 

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similarities, DOE believed that Class A, medical, and MADB EPSs should be evaluated 

identically. Interested parties did not comment on this simplified approach after it was 

presented during the preliminary analysis public meeting. 

Today’s NOPR proposes eliminating the disaggregation of Class A, medical, and 

MADB EPSs in its product class definitions. This consolidation would reduce the number 

of product classes covering these products from 12 in the preliminary analysis to five (B, 

C, D, E, and N) in the NOPR. Under this consolidated approach, product class B includes 

direct operation EPSs that are AC/DC and basic-voltage (i.e. do not qualify as lowvoltage); product class C includes direct operation EPSs that are AC/DC and low-voltage 

(i.e. nameplate output voltage less than 6 volts and nameplate output current greater than 

or equal to 550 milliamps.); product class D includes direct operation EPSs that are 

AC/AC and basic-voltage; product class E includes direct operation EPSs that are AC/AC 

and low-voltage; and product class N includes all indirect operation EPSs. 

Table IV-1 Preliminary Analysis Product Classes 

Voltage Level 

Basic (Not LowVoltage) Low (<6V, ≥550mA 

outputs) 

Power 

Conversion 

Type 

AC input, 

DC output A1, B1, M1 (now B) A2, B2, M2 (now C) 

AC input, 

AC output A3, B3, M3 (now D) A4, B4, M4 (now E) 

Multiple-Voltage External Power Supplies 

In the preliminary analysis, DOE considered combining product classes X1 (< 

100 Watts) and X2 (≥ 100 Watts) into one product class for all multiple-voltage EPSs. 

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DOE is proposing to define multiple-voltage EPS as devices that convert household 

electric current into multiple simultaneous output currents. The California IOUs were in 

favor of creating a single product class for multiple-voltage EPSs because "the types of 

products that may occupy this category in the future are unknown." (California IOUs, 

No. 43 at p. 9). DOE’s initial approach was based on the view that these product classes 

corresponded to the two main products already in the market in 2008: multi-function 

devices in X1 and video game consoles in X2. As of 2010, multi-function devices no 

longer use multiple-voltage EPSs, leaving only one main product category and the need 

for only one product class. Therefore, DOE has consolidated product classes X1 and X2 

into product class X for all multiple-voltage EPSs, which are EPSs that can directly 

operate a consumer product and simultaneously produce multiple output voltages. 

High-Power External Power Supplies 

DOE examined only one product class for high-power EPSs during the 

preliminary analysis because only one relevant consumer application existed at the time 

the analysis was prepared. DOE received no comments on this proposal from interested 

parties and, therefore, maintained one product class for high-power EPSs in the NOPR. 

This product class includes EPSs that can directly operate a consumer product and have a 

nameplate output power greater than 250 watts. To maintain consistency in the naming 

convention for the NOPR, product class H1 is now product class H. All product classes 

developed for the NOPR are shown in Table IV-2Table IV.2. 

. 

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Table IV-2 External Power Supply Product Classes Used in the NOPR 

Product Class Description 

Preliminary Analysis 

External Power Supply 

Product Classes 

NOPR 

External Power Supply Product 

Classes 

AC/DC Basic-Voltage A1, M1, B1 (some) B 

AC/DC Low-Voltage A2, M2, B2 (some) C 

AC/AC Basic-Voltage A3, M3, B3 (some) D 

AC/AC Low-Voltage A4, M4, B4 (some) E 

Multiple Voltage X1, X2 X 

High-Power H1 H 

Indirect Operation B1, B2, B3, B4 (most) N 

b. Battery Charger Product Classes 

In the preliminary analysis, DOE used five electrical characteristics to 

disaggregate product classes -- battery voltage, battery energy, input and output 

characteristics (e.g. inductive charging capabilities),27 input voltage type (line AC or lowvoltage DC), and AC output. DOE explained its reasoning for using this approach in the 

preliminary analysis. This reasoning is also detailed in chapter 3 of the TSD. 

First, DOE explained that battery voltage greatly affects consumer utility because 

the electronics of a portable consumer product are designed to require a particular battery 

voltage. If a change occurs in battery voltage, it is possible that the end-use application 

will be rendered inoperable. Furthermore, battery chargers that charge lower-voltage 

(voltage equals the product of current (I) and resistance (R)) batteries tend to be less 

27 Inductive charging is a utility-related characteristic designed to promote cleanliness and guarantee 

uninterrupted operation of the battery charger in a wet environment. In wet environments, such as a 

bathroom where an electric toothbrush is used, these chargers ensure that the user is isolated from mains 

current by transferring power to the battery through magnetic induction rather than using a galvanic (i.e. 

current carrying) connection. 

112 
 

 

 

 

 

 

efficient because they use higher currents, which increase I2

R losses for the same given 

output power. (I2

R, the product of current and voltage, equates to power and refers to 

losses directly related to current flow.) These devices could be disproportionately 

affected by an equally stringent standard level across all voltages. Consequently, DOE 

opted to use battery voltage as a characteristic for setting product classes. See preliminary 

analysis TSD Chapter 3. 

Second, while battery voltage specifies which consumer product applications can 

be used with a particular battery (and its corresponding battery charger), battery energy 

describes the total amount of work that the battery can perform, regardless of the 

application, and is also a measure of utility. Furthermore, because a battery charger must 

provide enough output power to replenish the energy discharged during use, the capacity 

and physical size of the battery charger depend on the amount of battery energy.28 By 

using battery energy as a proxy for output power, only a single criterion, rather than two, 

is required for classifying battery chargers. This approach has the benefit of simplifying 

any energy conservation standards that DOE may set while sufficiently accounting for 

any differences in battery charger capacity or utility in the standards analysis. Additional 

details on this approach can be found in TSD chapter 3. 

Third, input and output characteristics are important because input voltage can 

have an impact on efficiency and dictate where a battery charger may be used, this impact 

28 The minimum output power is a product of battery energy and charge rate. However, while charge rates 

rarely fall outside the range of 1 °C to 10 °C, the battery energy of consumer battery chargers can span over 

5 orders of magnitude from 1 watt-hour to over 10,000 watt-hours. Therefore, the output power is more 

dependent on battery energy than charge rates. 

113 
may affect end user utility. With respect to inductive chargers, the utility offered by this 

characteristic is providing reliable and safe electrical power to a device during operation. 

In wet environments, such as a bathroom where an electric toothbrush is used, these 

chargers ensure that the user is isolated from mains current by transferring power to the 

battery through magnetic induction rather than using a galvanic (i.e. current carrying) 

connection. DOE also identified numerous battery chargers that do not include a wall 

adapter, connecting instead to a personal computer’s USB port or a car’s cigarette lighter 

receptacle. Because input voltage can impact battery charger performance and determine 

where the battery charger can be used, which affects the utility of the product, DOE 

defined product classes using this criterion in the preliminary TSD. In response to the 

preliminary analysis and during manufacturer interviews, DOE received numerous 

comments regarding these product classes, discussed below, and the results of which are 

summarized in Table IV-3Table IV.3. 

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Table IV-3 Battery Charger Product Classes 

Product Class # Input / Output 

Type 

Battery Energy 

(Wh) 

Special Characteristic 

or Battery Voltage 

1 

AC In, 

DC Out 

< 100 

Inductive Connection 

2 < 4 V 

3 4 – 10 V 

4 > 10 V 

5 

100–3000 

< 20 V 

6 ≥ 20 V 

7 > 3000 -

8 DC In, 

DC Out 

- < 9 V Input 

9 - ≥ 9 V Input 

10a AC In, 

AC Out 

- Basic (i.e. no Automatic 

Voltage Regulation) 

10b - Contains Automatic 

Voltage Regulation 

During the preliminary analysis public meeting, Philips questioned whether DOE 

could consider product classes based on usage, topology (i.e., the general circuit layout), 

or price. (Philips, Pub. Mtg. Tr., No. 37 at pp. 126-130) Philips and AHAM stated that 

they believed DOE could disaggregate infrequently used products into a separate product 

class and urged DOE to do so. (Philips, No. 43 at p. 3; AHAM, Pub. Mtg. Tr., No. 37 at 

pp 154-156) AHAM added that, in its view, DOE has always established new product 

classes based on characteristics, designs, or functions that affect energy use. (AHAM, 

No. 44 at p. 6) CEA expressed similar concerns as Philips and AHAM, suggesting that 

DOE did not adequately deal with infrequently charged battery chargers. (CEA, No. 48 at 

p. 2) Earthjustice disagreed with AHAM’s suggestion and stated that usage is not a 

feature of a battery charger, but rather a characteristic of the end user of the application 

that the battery charger accompanies. (Earthjustice, Pub. Mtg. Tr., No. , No. 37 at p. 131) 

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Fulton Innovation inquired whether topology is considered as part of the utility of a 

product and, hence, a factor for setting product classes. (Fulton Innovation, Pub. Mtg. Tr., 

No., 37 at pp. 134-135) Finally, Stanley Black and Decker asked whether pricing could 

be considered a utility-related feature to use in defining product classes. (SBD, Pub. Mtg. 

Tr., No., 37 at pp. 133-134) 

DOE does not consider usage, topology, and pricing as utility-related features for 

determining separate product classes. These factors were considered separately, however, 

in setting potential energy efficiency levels for these products. Usage defines how a 

battery charger is used, which is inherently tied to the end-use product with which the 

battery charger is packaged. While changes in usage will affect the energy use of a 

battery charger, they do not affect the actual performance of the battery charger, which is 

the relevant factor DOE must consider when establishing a separate class for these 

products. See 42 U.S.C. 6295(q). Product usage is fundamental to the analyses that DOE 

performs for battery chargers, particularly for the LCC and NIA. For each application, 

DOE estimates the time spent in each mode of operation in order to estimate unit energy 

consumption. Further details on usage and DOE’s assumptions are presented in the 

energy usage section, IV.E, of today’s notice. 

Although DOE does not explicitly define product classes for battery chargers 

based on topology, it considered topologies when it presented its initial product classes. 

Primarily, DOE uses battery energy as a defining characteristic for battery charger 

product classes. Because of the extremely wide range of different battery energies, DOE 

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needed to establish meaningful ranges of battery energies for each product class. As 

outlined in the preliminary analysis TSD (Chapter 3), when battery energy changes, the 

topologies, or general circuit designs that are most appropriate also change. Therefore, as 

part of today’s NOPR, DOE examined the potential impacts on topologies when it 

defined the ranges of battery energies that were considered. 

Finally, price was also not included in the definitions of DOE’s battery charger 

product class because it is not a utility-related feature for the purposes of EPCA. DOE 

understands commenters concerns that some products are marketed at various price 

points and that energy efficiency standards have the potential to raise those price points 

or eliminate some all together. However, price does not directly affect device 

performance. DOE acknowledges that price is an important consideration for consumers 

and although price is not considered when setting product classes, DOE does account for 

such consumer impacts in the LCC and PBP analyses conducted in support of this 

rulemaking. 

Medical and Single-Cell Battery Chargers 

Interested parties also advocated separating out particular products into their own 

classes. Philips suggested that DOE consider creating a separate product class for medical 

battery chargers, as is done for EPSs. (Philips, No. 43 at p. 2) They mentioned that 

medical battery chargers cannot use off the shelf consumer grade battery chargers and 

must undergo a special regulatory process that adds testing requirements and costs. 

(Philips, No. 43 at p. 3) At the public meeting, Wahl Clipper suggested that DOE should 

117 
 

 

 

 

have an additional product class for applications that use single-cell batteries. (Wahl 

Clipper, Pub. Mtg. Tr., No. 37 at p. 158) Neither commenter provided any data 

supporting their views. 

While DOE appreciates the suggestions from Philips and Wahl about segregating 

out additional product classes from DOE’s current definitions, DOE is not inclined to 

adopt them at this time based on the current information before it. As with EPSs, DOE 

believes that even though medical battery chargers must adhere to more stringent 

requirements than other battery chargers, the cost-efficiency relationship will not be 

appreciably different to merit separate standards and product classes. In the preliminary 

analysis, DOE found that there was virtually no difference in the cost effectiveness of 

improving medical EPS efficiency versus improving Class A EPS efficiency. Moreover, 

DOE is unaware of any capacity or performance-related feature present in medical 

battery chargers that would permit the creation of a special class for these devices for 

purposes of setting separate energy conservation standards. As a result, despite the 

additional safety testing that medical EPSs may have to go through for certification, DOE 

has tentatively consolidated the two groups and no longer distinguishes between them in 

its product class definitions for today’s proposal. Based on the information that DOE 

receives during the course of the comment period, it may reconsider this approach for the 

final rule. 

As for the single-cell batteries that Wahl Clipper referenced, DOE believes that its 

proposed scaling methodology sufficiently addresses Wahl Clipper’s concerns and allows 

118 
chargers that use single-cell batteries to remain in product class 2 (low-energy, lowvoltage). As discussed in section IV.C.2.j, when battery energy approaches zero, DOE 

levels off unit energy consumption (UEC) requirements to prevent the adoption of overly 

stringent requirements that could eliminate such products. (UEC is a relevant factor 

because it is the metric which DOE is proposing to regulate for these devices.) 

Motorized Application Detachable Battery (MADB) Battery Chargers 

PTI also submitted comments in which it recommended that DOE revise its 10 

battery charger product classes presented in the preliminary analysis. PTI stated that 

because the statute provides language for DOE to separate MADB's when referring to 

EPS’s, DOE should extend this distinction to battery chargers and separate MADB 

battery chargers from consumer electronics battery chargers. PTI claimed that even 

though MADB and consumer electronics battery chargers share a common range of 

battery voltages and energies, the two are vastly different in other ways and urged DOE 

to create different classes for MADB and non-MADB products across the same battery 

voltages and energies. PTI added that part of the problem with grouping the two product 

types together is that consumer electronics promote features such as smaller size and 

weight and longer run-time -- all of which are added benefits related to improving a 

product’s energy efficiency. (PTI, No. 47 at p. 13) In other words, in their view, 

consumer electronics have already begun to move towards more efficient battery chargers 

and manufacturers have been able to pass along the additional costs to consumers 

because the use of more efficient chargers has led to the addition of desirable features, 

such as reduced notebook computer weight. (PTI, No. 47 at pp. 13) 

119 
PTI also disagreed with DOE’s initial plan to group power tools with consumer 

electronics because shipments of consumer electronics, such as laptops, greatly 

outnumber MADB product shipments. Because a shipment-weighted average is 

employed by DOE in its analysis, the calculated effects would be dominated by the 

effects of the products that have the greatest number of shipments. (PTI, No. 47 at p. 6) 

Since the shipment quantities of consumer electronic products far outnumber those for 

MADB products, PTI asserted that the calculations derived by DOE would be dominated 

by the inclusion of consumer electronics products and skew the overall effects projected 

to occur with a given standard for these products. (PTI, No. 47 at pp. 6 and 13) 

In addition, in PTI’s view, the incremental cost estimates to achieve higher 

efficiencies which have been included in the life cycle cost analysis, are a much smaller 

percentage of the higher-priced products than they would be for many do-it-yourself 

power tools. (PTI, No. 47 at p. 13) As a result, PTI asserted that do-it-yourself power tool 

users are likely to be more sensitive to price changes even though the incremental change 

may be similar to higher priced products, such as consumer electronics. PTI added that 

manufacturers, and ultimately consumers, would be better served by a class that included 

only appliances or, alternatively, have appliances more fairly represented in the averages. 

In its view, making this change would generate CSLs that more appropriately address the 

realizable efficiency improvements and strike a better balance between the realities of 

power tool manufacturers and the energy savings gained by the consumer. (PTI, No. 47 at 

p. 13) Therefore, PTI recommended that DOE should calculate CSL and LCC 

120 
 

 

information based on sub-classifications of product classes 3 (AC in/DC out, < 100 Wh, 

4-10 V battery chargers) and 4 (AC in/DC out, < 100Wh, > 10V battery chargers) for 

MADB and non-MADB devices. (PTI, No. 47 at p. 7) 

Conversely, the California IOUs supported DOE’s decision to group both power 

tools (i.e. MADB battery chargers) and laptops (i.e. consumer electronics battery 

chargers) in the same product classes for the purposes of this analysis (California IOUs, 

No. 45 at p. 6) They also expressed support for DOE's proposal in the preliminary 

analysis that usage profiles should not be used when creating product classes. (California 

IOUs, No. 45 at p. 8) In separate comments, Pacific Gas and Electric and others urged 

DOE to reduce the number of product classes from 10 to 4, and reorganize product 

classes 2 through 7 (AC in/DC out battery chargers) into one new product class. (PG&E, 

et al., No. 49 at pp. 2-3) 

After considering these comments, DOE re-examined the UEC data from its 

engineering analysis for product classes 3 and 4. DOE found that when MADB 

applications were removed from product classes 3 and 4, the UECs generated for the 

removed group of MADB applications were not significantly different (< 10 percent) 

than those DOE had presented for the product class as a whole. Relative to the reductions 

in UEC when incrementing CSLs, DOE considered these differences much less 

significant than it initially suspected. Furthermore, for the NOPR analysis, DOE altered 

some of its assumptions for the LCC analysis. In the preliminary analysis, DOE assumed 

the same efficiency distribution for all applications within a product class. For example, 

121 
in product class 4, laptops were assumed to have the same percentage of their shipments 

at CSL 0, 1, and 2 as power tools and all other applications in that product class. As 

mentioned by manufacturers and determined by DOE’s testing program for battery 

chargers, some products, mainly consumer electronics, have already begun increasing the 

efficiency of their products because doing so is desirable to the end user. As a result, 

DOE has altered its assumption that all applications within a product class have the same 

distribution of efficiency. Instead, DOE now makes more tailored assumptions about 

efficiency distributions for different applications based on information provided by 

manufacturers, publicly available data, and DOE’s own test results. 

This new assumption will alter the economics of DOE’s standards analysis and 

more accurately illustrate the effects on consumers for the varying consumer types in 

each product class. Additionally, the individual LCC results for each application are 

available in appendix 8B of the TSD. Similarly, just as DOE is not persuaded to 

disaggregate certain product classes, DOE is also not persuaded to aggregate any 

additional product classes, as suggested by PG&E. DOE initially considered using 

separate product classes in the preliminary analysis because the different battery voltage 

and energy ratings that define these classes imply a certain utility and deviation from 

those ratings will likely lead to different cost-efficiency relationships and efficiency 

levels. These differences will also lead to different effects on consumers, which will 

likely support different energy conservation standard levels. 

Uninterruptible Power Supply (UPS) Battery Chargers 

122 
 

 

Uninterruptible power supplies are used only for emergency situations when 

power is lost and users need time to safely shut down their electronic devices. 

Consequently, these devices generally do not fully charge a completely depleted battery. 

Additionally, these devices typically use integral batteries and generally remain on 

continuously. Because of its role in providing power in emergency situations, the battery 

chargers within these devices primarily remain in maintenance mode, which constitutes 

the most relevant portion of its energy consumption. 

During manufacturer interviews with UPS producers, DOE discussed additional 

functionality as it pertains to these devices. Manufacturers suggested that DOE classify 

UPSs into three different categories: basic UPSs, UPSs that have automatic voltage 

regulation (AVR), and UPSs that are extended-run capable (i.e., the ability to attach a 

second battery to increase battery capacity within the UPS). After further investigation, 

DOE decided that two of these categories were appropriate and warranted separate 

standards, but the third category (extended-run UPSs), as it was simply representative of 

a change in battery capacity, could be accounted for through its scaling methodology. 

AVR UPSs use circuitry that monitors input voltage from the wall and ensures 

that all products plugged into the UPS see a steady flow of voltage despite any 

fluctuations at the wall. This circuitry provides added utility to the consumer by 

preventing any spikes or dips in voltage, but it comes at the expense of additional power 

consumption by the UPS. This additional power consumption of the UPS is always on 

123 
 

when the device is plugged in and it is indistinguishable from the power consumption due 

to the battery charger within the UPS. 

To account for these characteristics, DOE is proposing to divide preliminary 

analysis product class 10 into two product classes, one for basic UPSs and one for UPSs 

that contain AVR circuitry. Even though DOE is proposing two product classes for these 

categories of UPSs, DOE believes that the underlying engineering analysis and other 

downstream analyses for both product classes is the same. DOE believes that this is an 

appropriate assumption because the addition of AVR is irrelevant to UPS battery charger 

power consumption, yet it cannot be disaggregated from UPS battery charger power 

consumption due to the integrated nature of the circuitry components within a UPS. In 

other words, there is no technical reason why the battery charger within a basic UPS 

should be different from the battery charger within a UPS with AVR functionality. 

However, when the latter is tested via DOE’s battery charger test procedure, it will 

demonstrate a higher maintenance mode power consumption and will not be able to meet 

as stringent an energy efficiency standard as a basic UPS. Consequently, for all of DOE’s 

analyses in today’s NOPR, battery chargers for UPSs are examined as an aggregated 

product class, product class 10, rather than separately, however the proposed standard for 

each product class is different. DOE seeks comment on its analytical approach and 

whether separate classes are appropriate in this context. 

4. Technology Assessment 

In the technology assessment, DOE identifies technology options that appear to be 

feasible to improve product efficiency. This assessment provides the technical 

124 
background and structure on which DOE bases its screening and engineering analyses. 

The following discussion provides an overview of the technology assessment for EPSs 

and battery chargers. Chapter 3 of the TSD provides additional detail and descriptions of 

the basic construction and operation of EPSs and battery chargers, followed by a 

discussion of technology options to improve their efficiency and power consumption in 

various modes. 

a. EPS Efficiency Metrics 

On December 8, 2006, DOE codified a test procedure final rule for single outputvoltage EPSs in Appendix Z to Subpart B of 10 CFR Part 430 (“Uniform Test Method for 

Measuring the Energy Consumption of External Power Supplies.”) See 71 FR 71340. On 

June 1, 2011, DOE added a test procedure to cover multiple output-voltage EPSs in 

Appendix Z to Subpart B of 10 CFR Part 430 (“Uniform Test Method for Measuring the 

Energy Consumption of External Power Supplies.”) 76 FR 31750. DOE’s test procedure, 

based on the CEC EPS test procedure, yields two measurements: active mode efficiency 

and no-load mode (standby mode) power consumption. 

Active-mode efficiency is the ratio of output power to input power. For singlevoltage EPSs, the DOE test procedure 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. For multiple-voltage EPSs, the test 

procedure provides those four metrics individually, which DOE is considering averaging 

when setting the efficiency level measurements for these types of devices. The test 

125 
 

 

procedure also specifies how to measure the power consumption of the EPS when 

disconnected from the consumer product, which is termed “no-load” power consumption 

because the EPS outputs zero percent of the maximum rated output current to the 

application. 

To develop the analysis and to help establish a framework for setting EPS 

standards, DOE considered both combining average active-mode efficiency and no-load 

power into a single metric, such as unit energy consumption (i.e. UEC), and maintaining 

separate metrics for each. For the preliminary analysis, DOE chose to evaluate EPSs 

using the two metrics separately. Today’s NOPR proposes continuing to use this method 

when setting standards for these products. Using a single metric that combines activemode efficiency and no-load power consumption to determine the standard may 

inadvertently permit the “backsliding” of the standards established by EISA 2007. 

Specifically, because a combined metric would regulate the overall energy consumption 

of the EPS as the aggregation of active-mode efficiency and no-load power, that approach 

could permit the performance of one metric to drop below the EISA 2007 level if it is 

sufficiently offset by an improvement in the other metric. Such a result would, in DOE’s 

view, constitute a backsliding of the standards and would violate EPCA’s prohibition 

from setting such a level. DOE’s proposed approach seeks to avoid this result. 

The DOE test procedure for multiple-voltage EPSs yields five values: no-load 

power consumption as well as efficiency at 25, 50, 75, and 100 percent of maximum 

load. See 76 FR 31750 (June 1, 2011)(noting DOE’s recently added procedures for 

126 
 

 

 

multiple voltage EPSs codified at section 4.2 of appendix Z of subpart B to part 430 of 

the CFR). In the preliminary analysis, DOE examined the possibility of averaging the 

four efficiency values to create an average efficiency metric for multiple-voltage EPSs, 

similar to the approach followed for single-voltage EPSs. Alternatively, DOE introduced 

the idea of averaging the efficiency measurements at 50 percent and 75 percent of 

maximum load because the only known application that currently uses a multiple voltage 

EPS, a video game console, operates most often between those loading conditions. DOE 

sought comment from interested parties on these two approaches. 

The California IOUs commented that the test metric should be an "average of 

25%, 50%, 75%, and 100% of rated output power, similar to the approach taken for 

single voltage EPSs." The California IOUs viewed this approach as best rather than 

basing the multiple-voltage test procedure on the loading profile of a single application 

which could decrease the applicability of any standard since “the types of products that 

may occupy this category in the future are unknown”. (California IOUs, No. 43 at p. 9) 

Though it is aware of only one consumer product using multiple-voltage EPSs, 

DOE believes that evaluating multiple-voltage EPSs using an average-efficiency metric 

(based on the efficiencies at 25%, 50%, 75%, and 100% of each output’s normalized 

maximum nameplate output power) would allow a future standard to be applicable to a 

diverse range of products as it would not be based solely on the loading profile of a single 

EPS application. Therefore, DOE evaluated multiple-voltage EPSs using no-load mode 

power consumption and an average active-mode efficiency metric based on the measured 

127 
 

 

efficiencies at 25%, 50%, 75%, and 100% of rated output power in developing the 

proposed energy conservation standards for these products. DOE requests feedback on 

this proposed approach to determining the average efficiency for multiple-voltage EPSs. 

b. EPS Technology Options 

DOE considered seven technology options, fully detailed in Chapter 3 of the TSD, 

which may improve the efficiency of EPSs: (1) Improved Transformers, (2) SwitchedMode Power Supplies, (3) Low-Power Integrated Circuits, (4) Schottky Diodes and 

Synchronous Rectification, (5) Low-Loss Transistors, (6) Resonant Switching, and (7) 

Resonant ("Lossless") Snubbers. 

AHAM and PTI commented during the preliminary analysis that "[DOE] has not 

justified the value of decreasing the no-load levels at each [initially considered] CSL" 

(AHAM, No. 42 at p. 7; PTI, No. 45 at p. 5). NEEP suggested that DOE should consider 

whether technology options are applicable across product classes (NEEP, No. 49 at 2). 

During its analysis, DOE found that some technology options affect both 

efficiency and no-load performance and that the individual contributions from these 

options cannot be separated from each other in a cost analysis. Given this trend, DOE 

generated a “matched pairs” approach for creating the EPS CSLs where select test units 

were used in characterizing the relationship of average active-mode efficiency and noload power dissipation. In the matched pairs approach, EPS energy consumption 

improves either through higher active mode efficiency, lower no-load mode power 

consumption, or both. If DOE allowed one metric to decrease in stringency between 

128 
 

CSLs, then the cost-efficiency results might have shown cost reductions at higher CSLs 

and skew the true costs associated with increasing the efficiency of EPSs. To avoid this 

result, DOE is using an approach that increases the stringency of both metrics for each 

CSL considered in today’s NOPR. 

Regarding NEEP’s suggestion, DOE notes that in developing the engineering 

analysis, DOE considered all technology options when developing CSLs for all four EPS 

representative units. DOE considered the same efficiency improvements during its 

analysis for non-Class A EPSs as it did for Class A EPSs. Where representative units 

were not explicitly analyzed (i.e. product classes C, D, and E), DOE extended its analysis 

from a directly analyzed class. As a result, all design options that could apply to these 

products were implicitly considered because the proposed efficiency levels of the 

analyzed product class will be scaled to other product classes, an approach supported by 

interested parties. The equations were structured based on the relationship of the other 

Class A product classes to the representative product class such that the technology 

options not implemented by the other classes were accounted for in the proposed 

efficiency equations. For example, AC-AC EPSs (product classes A2 and A4 in the 

preliminary analysis) tend to have higher no load power dissipation because they do not 

use switched-mode methods (see Chapter 3 of the TSD for a full technical description). 

Therefore, DOE used higher no load power metrics when generating CSLs for these 

product classes than the CSLs from the representative product class A1. DOE will 

continue to examine all technology options and apply them wherever possible across all 

product classes as part of the NOPR analysis. 

129 
c. High-Power EPSs 

In the non-Class A determination analysis TSD, DOE examined the specific 

design options of high-power EPSs as they relate to ham radios, the sole consumer 

application for these EPSs. DOE found that high-power EPSs are unique because both 

linear and switched-mode versions are available as cost-effective options, but the linear 

EPSs are more expensive and inherently limited in their achievable efficiency despite 

sharing some of the same possible efficiency improvements as EPSs in other product 

classes. Interested parties have expressed concern that setting an efficiency standard 

higher than a linear EPS can achieve would reduce the utility of these devices because 

ham radios are sensitive to the electromagnetic interference (EMI) generated by 

switched-mode EPSs. 

However, DOE believes there is no reduction in utility because EPSs used in 

telecommunication applications are required to meet the EMI regulations of the Federal 

Communications Commission (47 CFR 15, subpart B) regardless of the underlying 

technology. DOE used this assumption when constructing its engineering analysis for the 

NOPR but seeks comment on possible issues with EMI and/or radio frequency 

interference associated with switch-mode power supplies (SMPS) used with amateur 

radios, including design options for reducing or eliminating interference. 

130 
 

 

d. Power Factor 

Power factor is a relative measure of transmission losses between the power plant 

and a consumer product. DOE examined the issue of power factor in section 3.6 of the 

framework document for the BCEPS rulemaking and noted that certain ENERGY STAR 

specifications limit power factor. DOE also noted in that same section the role of power 

factor in higher-power EPSs -- namely, that at higher powers, problems associated with 

power factor (e.g. power dissipation in the wiring) become more pronounced. 

PTI commented that DOE should preempt other jurisdictions from regulating 

power factor by addressing power factor as a metric, but not to specify a limit in the 

energy-efficiency standard. (PTI, No. 45 at p. 12) PTI stated that regulating power factor 

will add cost to the product because of the need for additional power factor correction 

circuitry. It also explained that losses due to power factor are a consequence of the power 

cables used by the local utility, which are beyond the control of the manufacturer. (PTI, 

No. 45 at pp. 10-11) 

DOE notes that regulating power factor includes substantial challenges, such as 

quantifying transmission losses that depend on the length of the transmission wires, 

which differ for each residential consumer. Further, DOE has not yet conclusively 

analyzed the benefits and burdens from regulating power factor. While DOE plans to 

continue analyzing power factor and the merits of its inclusion as part of a future 

rulemaking, it is DOE’s view that the above factors weigh in favor of not setting a power 

factor-based standard at this time. 

131 
 

 

 

e. Battery Charger Modes of Operation and Performance Parameters 

For the preliminary analysis, DOE found that there are five modes of operation in 

which a battery charger can operate at any given time. These modes of operation are: 

active (or charge) mode, maintenance mode, no-battery (or standby) mode, off mode, and 

unplugged mode. These five modes are briefly described below29: 

Active (or charge) mode: During active mode, a battery charger is charging a 

depleted battery, equalizing its cells, or performing functions necessary for bringing the 

battery to the fully charged state. 

Maintenance mode: In maintenance mode, the battery is plugged into the charger, 

has reached full charge, and the charger is performing functions intended to keep the 

battery fully charged while protecting it from overcharge. 

No-Battery (or standby) mode: In no-battery mode, the battery is not connected to 

the charger but the battery charger itself is still plugged into mains. 

Off mode: In off mode, the charger remains connected to mains power but the 

battery is removed and all manual on-off switches are turned off. 

29 Active mode, maintenance mode, standby mode, and off mode are all explicitly defined by DOE in 

Appendix Y to Subpart B of Part 430 – Uniform Test Method for Measuring the Energy Consumption of 

Battery Chargers. 

132 
 

 

Unplugged mode: In unplugged mode, the battery charger is disconnected from 

mains and not consuming any electrical power. 

For each battery charger mode of operation, DOE’s battery charger test procedure 

has a corresponding test that is performed that outputs a metric for energy consumption in 

that mode. The tests to obtain these metrics are described in greater detail in DOE’s 

battery charger test procedure. (76 FR 31750) The following items are pertinent 

performance parameters from those tests. 

24-Hour Energy: This quantity is defined as the power consumption integrated 

with respect to time of a full metered charge test that starts with a fully depleted battery. 

In other words, this is the energy consumed to fully charge and maintain at full charge a 

depleted battery over a period that lasts 24 hours or the length of time needed to charge 

the tested battery plus 5 hours, whichever is longer. 

Maintenance Mode Power: This is a measurement of the average power 

consumed while a battery charger is known to be in maintenance mode. 

No-Battery (or standby) Mode Power: This is a measurement of the average 

power consumed while a battery charger is in no-battery or standby mode (only if 

applicable). 

133 
Off-Mode Power: This is a measurement of the average power consumed while an 

on-off switch-equipped battery charger is in off mode (i.e. with the on-off switch set to 

the “off” position). 

Unplugged Mode Power: This quantity is always 0. 

Additional discussion on how these parameters are derived and subsequently 

combined with assumptions about usage in each mode of operation to obtain a value for 

the UEC is discussed below in section IV.C.2.b. 

f. Battery Charger Technology Options 

Since most consumer battery chargers contain an AC to DC power conversion 

stage, similar to that found in an EPS, all of the technology options discussed in section 

IV.A.4.b also apply to battery chargers. The technology options used to decrease EPS noload power will impact battery charger energy consumption in no-battery and 

maintenance modes (and off mode, if applicable), while those options used to increase 

EPS conversion efficiency will impact energy consumption in active and maintenance 

modes. 

Technology options that DOE considered for battery chargers in the preliminary 

analysis and again for the NOPR include: improved transformer cores, termination, 

elimination/limitation of maintenance mode current, elimination of no-battery mode 

current, switched-mode power supplies, low-power integrated circuits, Schottky diodes 

134 
and synchronous rectification, phase control to limit input power. An in-depth discussion 

of these technology options can be found in TSD chapter 3. 

B. Screening Analysis 

DOE uses the following four screening criteria to determine which design options 

are suitable for further consideration in a standards rulemaking: 

1. Technological feasibility. DOE considers technologies incorporated in 

commercial products or in working prototypes to be technologically feasible. 

2. Practicability to manufacture, install, and service. If mass production and 

reliable installation and servicing of a technology in commercial products could be 

achieved on the scale necessary to serve the relevant market at the time the standard 

comes into effect, then DOE considers that technology practicable to manufacture, install, 

and service. 

3. Adverse impacts on product utility or product availability. If DOE determines a 

technology would have significant adverse impact on the utility of the product to 

significant subgroups of consumers, or would result in the unavailability of any covered 

product type with performance characteristics (including reliability), features, sizes, 

capacities, and volumes that are substantially the same as products generally available in 

the United States at the time, it will not consider this technology further. 

135 
 

4. Adverse impacts on health or safety. If DOE determines that a technology will 

have significant adverse impacts on health or safety, it will not consider this technology 

further. 

See 10 CFR part 430, subpart C, appendix A, (4)(a)(4) and (5)(b). 

For EPSs, DOE did not screen out any technology options after considering the 

four criteria. For battery chargers, DOE screened out: 

1.	 Non-inductive chargers for use in wet environments because of adverse 

impacts on safety; 

2.	 Capacitive reactance because of adverse impacts on safety; and 

3.	 Lowering charging current or increasing battery voltage because of 

adverse impacts on product utility to consumers. 

DOE received no comments in response to its preliminary screening analysis. 

Therefore, DOE is using the same screening analysis for the NOPR. 

For additional details, please see chapter 4 of the TSD. 

C. Engineering Analysis 

In the engineering analysis (detailed in chapter 5 of the TSD), DOE presents a 

relationship between the manufacturer selling price (MSP) and increases in battery 

charger and EPS efficiency. The efficiency values range from that of an inefficient 

battery charger or EPS sold today (i.e., the baseline) to the maximum technologically 

136 
 

feasible efficiency level. For each efficiency level examined, DOE determines the MSP; 

this relationship is referred to as a cost-efficiency curve. 

DOE structured its engineering analysis around two methodologies: (1) test and 

teardowns, which involves testing products for efficiency and determining cost from a 

detailed bill of materials derived from tear-downs and (2) the efficiency-level approach, 

where the cost of achieving increases in energy efficiency at discrete levels of efficiency 

are estimated using information gathered in manufacturer interviews that was 

supplemented and verified through technology reviews and subject matter experts 

(SMEs). When analyzing the cost of each CSL—whether based on existing or theoretical 

designs—DOE differentiates the cost of the battery charger or EPS from the cost of the 

associated end-use product. 

1. Engineering Analysis for External Power Supplies 

a. Representative Product Classes and Representative Units 

DOE is applying the same methodology in the NOPR as it used in the preliminary 

analysis to identify representative product classes and representative units. In the 

preliminary analysis, DOE selected product class A1 (AC to DC conversion, basicvoltage EPSs) for further analysis as the representative product class because it 

constituted the majority of EPS shipments and national energy consumption related to 

EPSs. Within product class A1, DOE focused on four representative units with output 

power levels at 2.5 watts, 18 watts, 60 watts, and 120 watts because most consumer 

applications use EPSs with these, or similar, nameplate output power ratings. In the 

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NOPR, DOE is choosing to focus on representative product class B (AC to DC 

conversion, basic-voltage EPSs), which contains certain product classes from the 

preliminary analysis -- most Class A EPSs from product class A1, most medical EPSs 

from product class M1, and some MADB EPSs from product class B1 (which are EPSs 

that can directly power an application). The NOPR analysis also focuses on the same four 

representative units as the preliminary analysis with output powers at 2.5 watts, 18 watts, 

60 watts, and 120 watts in product class B and scales those results to product classes C, 

D, and E as suggested by interested parties. 

Interested parties supported DOE’s approach in creating and analyzing 

representative product classes and representative units in the preliminary analysis. The 

California IOUs agreed with using product class A1 as the representative product class 

and scaling to other product classes because of the inherent similarities of the A1 devices 

to those in the other product classes (California IOUs, No. 43 at p. 8). Although no 

specific data were provided, the California IOUs also commented in support of the four 

representative units within the product class noting that their own research30 into the 

power supply market corroborates DOE’s selections (California IOUs, No. 43 at p. 8). 

DOE did not receive comments disputing its selections for the four representative units. 

DOE is proposing to continue using the same representative product class and 

representative unit methodology, and will scale results for the other EPS product classes. 

As noted previously, DOE has incorporated EPSs from product class A1 into product 

30http://www.energy.ca.gov/appliances/archive/2004rulemaking/documents/case_studies/CASE_Power_Su 

pplies.pdf 

138 
 

 

class B. Within product class B (preliminary analysis product class A1) DOE will focus 

on the four representative units with output powers at 2.5 watts, 18 watts, 60 watts, and 

120 watts because products with these ratings constitute a significant portion of 

shipments and energy consumption. Interested parties also supported this approach. 

b. EPS Candidate Standard Levels (CSLs) 

DOE is applying the same methodology to establish CSLs in the NOPR as it used 

in the preliminary analysis. DOE created CSLs as pairs of EPS efficiency metrics for 

each representative unit with increasingly stringent standards having higher-numbered 

CSLs. The CSLs were generally based on (1) voluntary (e.g. ENERGY STAR) 

specifications or mandatory (i.e. those established by EISA 2007) standards that either 

require or encourage manufacturers to develop products at particular efficiency levels; (2) 

the most efficient products available in the market; and (3) the maximum technologically 

feasible (“max tech”) level. These CSLs are summarized for each representative unit in 

Table IV-4Table IV.4. In section IV.C.1.e, DOE discusses how it developed equations to 

apply the CSLs from the representative units to all EPSs. 

Table IV-4 Summary of EPS CSLs for Product Classes B, C, D, and E 

CSL Reference Basis 

0 EISA 2007 EISA 2007 equations for efficiency and no-load power 

1 ENERGY STAR 

2.0 

ENERGY STAR 2.0 equations for efficiency and no-load 

power 

2 Intermediate Interpolation between test data points 

3 Best in Market Most efficient test data points 

4 Max Tech Maximum technologically feasible efficiency 

139 
 

 

 

 

DOE evaluated EPSs using the two EPS efficiency metrics, no-load power 

consumption and active-mode average efficiency, which it grouped into “matched pairs.” 

Under the matched pairs approach, each CSL would increase in stringency in at least one 

of the metrics and no metric would ever be lowered in moving to a higher CSL. DOE’s 

goal in using this approach was to ensure that when it associated costs with the CSLs, 

that the costs would reflect the complete costs of increased efficiency. If DOE followed 

an approach that permitted a decrease in stringency for a given metric, the result might be 

a projected reduction in EPS cost, which would mask the full cost of increasing EPS 

efficiency. 

DOE received considerable support from interested parties on its matched pairs 

approach for EPS CSLs. However, interested parties, including the California IOUs, also 

cautioned DOE to avoid setting levels for no-load power that were too stringent when 

compared to active-mode efficiency improvements. (California IOUs, No. 43 at p. 8). 

The California IOUs added that “PG&E research suggests that improvements in active 

mode yield much higher energy savings than small, incremental improvements in no-load 

mode.” Id. PG&E added that DOE should verify that the no-load levels for the EPS CSLs 

are not too stringent, which could lead to higher costs since the majority of the projected 

savings for EPSs would likely come from improving active-mode efficiency (PG&E, 

Pub. Mtg. Tr., No. 57 at pp. 198-199). 

DOE received two additional comments regarding its CSLs. The California IOUs 

supported DOE's CSL selections, particularly those that were developed based on test 

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data. (California IOUs, No. 43 at p. 8). Additionally, AHAM stated that DOE should 

"consider whether the CSLs also apply to units that are less than 2.5W," in particular 

2.4W and 1.2W EPSs because they believe that “the CSL for this class does not apply to 

these smaller wattage products” (AHAM, No. 42 at p. 13). 

DOE considered interested party comments when revising the CSLs for the 

NOPR. DOE’s approach maintains the same efficiency levels for all CSLs but alters the 

max-tech efficiency level based on new data gleaned from manufacturer interviews, 

which indicated that manufacturers could achieve higher max-tech levels than were 

previously considered during the preliminary analysis. No load requirements were 

carefully considered consistent with commenter suggestions to not aggressively increase 

these levels. 

Further, DOE has tentatively decided to maintain its best-in-market CSL based on 

test data and also considered whether the CSLs for the 2.5W EPS should apply to lowerpower EPSs. DOE continues to believe that the CSLs apply to these lower power devices 

because the scaling equations developed by DOE incorporate the test results and data of 

EPSs with nameplate output power ratings less than 2.5W. For both metrics and at each 

CSL, DOE has developed standards equations that are functions of nameplate output 

power. To accommodate the design trend of decreasing efficiency with decreasing output 

power, the 2.5W CSLs are used as lower power reference points for the standard 

equations. All of the direct operation CSLs were created using a combination of existing 

standards and were corroborated with test data. In cases where DOE tested EPSs with 

141 
 

 

 

 

nameplate output powers less than 2.5 watts, it scaled the results to the representative unit 

(2.5 W) and adjusted the efficiency accordingly. Hence, the 2.5W CSLs are supported by 

data from EPSs with output powers equal to 2.5 watts and scaled EPSs with output power 

ranges below 2.5 watts. DOE used this methodology in generating the CSLs for all of the 

other direct operation representative units where the CSLs were not only based on units 

tested at the nominal output power rating but also on scaled results of EPSs with 

nameplate output powers slightly above and slightly below the representative unit value. 

For additional detail regarding DOE’s scaling methodology see chapter 5 of the TSD. 

DOE maintained the same CSLs for multiple-voltage EPSs in product class X as 

it proposed in the preliminary analysis because it received no comments and has no new 

information that would otherwise merit a change in the CSLs for this product class. The 

CSLs are shown in Table IV-5Table IV.5. 

Table IV-5 Summary of EPS CSLs for Product Class X 

CSL Reference Basis 

0 Market Bottom Test data of the least efficient unit in the market 

1 Mid Market Test data of the typical unit in the market 

2 Best-in-Market Manufacturer’s data 

3 Max Tech Maximum technologically feasible efficiency 

DOE structured the CSLs for high-power EPSs based on products available in the 

market and by scaling CSLs for 120-watt EPSs. The two least efficient CSLs are based on 

units DOE tested for the non-Class A EPS determination analysis. CSL 0 corresponds to 

test results from a linear EPS for amateur radio equipment while CSL 1 corresponds to 

test results from a switched-mode EPS for the same application. During interviews for the 

determination analysis, high-power EPS manufacturers indicated that CSL 2 was what 

142 
 

they believed to be the max-tech efficiency for high-power EPSs. As outlined in section 

III.B.2.a, DOE believes that the efficiencies of the 120W EPSs indicate a potential for 

345W EPSs to achieve higher efficiencies than CSL 2 since achievable efficiency tends 

to remain the same for EPSs with a nameplate output power above 49 watts. DOE 

characterized these higher efficiencies by modeling a 360W EPS composed of three 

120W EPSs connected in parallel. This theoretical EPS would have the same average 

efficiency as a 120W EPS, scaled for nameplate output voltage, and three times the noload power consumption. DOE developed CSL 3 and CSL 4 for the 345W representative 

EPSs based on the efficiency of the theoretical 360W EPS. DOE received no comments 

concerning the CSLs for high-power EPSs during the preliminary analysis (CSL 0, CSL 1 

and CSL 2). DOE seeks comment on its proposed methodology for establishing higherefficiency CSLs (CSL 3 and CSL 4). The CSLs for product class H are listed in Table 

IV-6Table IV.6. 

Table IV-6 Summary of EPS CSLs for Product Class H 

CSL Reference Basis 

0 Line Frequency Test data of a low-efficiency unit in the market 

1 Switched-Mode Low 

Level Test data of a high-efficiency unit in the market 

2 Switched-Mode High 

Level Manufacturers’ theoretical maximum efficiency 

3 Scaled Best-in-Market Scaled from 120W EPS CSL 3 

4 Scaled Max Tech Scaled from 120W EPS CSL 4 

c. EPS Engineering Analysis Methodology 

In the preliminary analysis, DOE presented two sets of cost-efficiency curves: one 

based on manufacturer data that showed an increasing trend between cost and efficiency 

143 
 

and a second set based on test and teardown data that, while inconclusive, generally 

showed a decreasing relationship between cost and efficiency. DOE sought interested 

party comment on this discrepancy. 

Commenters had mixed opinions on which results DOE should use as the basis 

for its analysis. AHAM commented that "based on what was presented that the 

Department should use the manufacturer’s data" rather than the test and teardown data 

that DOE developed stating that “there is no incentive for manufacturers to not give out 

all necessary information to the Department”. (AHAM, No. 42 at p. 13) However, IOUs 

encouraged DOE to continue to pursue teardowns because the test and teardown results 

in the preliminary analysis, in their view, may be as accurate as manufacturer data since 

"costs are rapidly declining for highly efficient power supplies." (California IOUs, No. 43 

at p. 9). NEEP stated that DOE should "corroborate the cost-efficiency curve data 

provided to them by manufacturers." In other words, DOE should re-evaluate the 

manufacturer's results and consider consulting independent sources to establish a more 

direct relationship between efficiency and cost. (NEEP, No. 49 at p. 4). DOE considered 

these opinions and sought additional information. 

In preparing the NOPR analysis, DOE conducted an additional round of 

manufacturer interviews to address the differences between the two cost-efficiency 

curves in the preliminary analysis. Based on the interviews, DOE believes that the 

discrepancy between the preliminary analysis curves was due to an ongoing shift in the 

market that was not reflected in the data. Specifically, the manufacturers stated during 

144 
 

 

 

these interviews that the EPS market has a trend of increasing efficiency and decreasing 

cost with each design cycle and the DOE-tested units may have been from different 

design cycles.31 By contrast, the manufacturers’ data on which DOE had initially relied 

reflected the cost-efficiency relationship during a single design cycle. In general, 

manufacturers agreed that, in their current design cycle, EPSs are designed to be more 

efficient than the ENERGY STAR level. Thus, DOE’s revised cost-efficiency curves 

reflect this improved understanding across all the representative units using updated data 

obtained from interviews with EPS manufacturers and component suppliers. 

In the preliminary analysis, DOE evaluated switched-mode power supplies (i.e. 

power supplies that use controlled switching of a power source to regulate the flow of 

current to a load), but not linear power supplies. Linear power supplies are power 

supplies that use a transformer and a linear regulator to provide power to a load. These 

devices are typically less cost effective as a method to improve energy efficiency and 

inherently limited in their achievable efficiencies -- these limitations stem from 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. Switched-mode power supplies do not 

have the same limitations with respect to the level of efficiency they can achieve because 

the design relies on transferring power through the controlled modulation of energy 

stored in the magnetic and electric fields of passive components. As a result, there are 

31 Original design dates are difficult to determine because the date of release is not often publicized with 

EPS product data. 

145 
 

 

fewer resistive losses in the conversion stage and the voltage is regulated using controlled 

switching instead of intentionally dissipating excess voltage in the form of heat, Cobra 

Electronics noted this omission. (Cobra, No. 51 at p. 3) DOE has since re-evaluated the 

analysis and found that linear power supplies are a cost-effective option for 2.5 W EPSs 

at the lower stringency CSLs, but not in meeting other CSLs or in satisfying CSLs for 

other representative units. As a result, the NOPR cost-efficiency curves for the 2.5W 

representative unit include linear supplies as part of the analysis. 

Today’s proposed rule is based on a slightly revised version of the initial 

methodology DOE considered when aggregating manufacturer results for the 2.5W and 

18W representative units. In the preliminary analysis, DOE used a 3D-aggregation 

method32 based on cost, efficiency, and no-load power to generate cost-efficiency curves 

for all representative units. The same 3D-aggregation methodology was applied to the 

NOPR analysis with the exception of the 2.5W and 18W representative units, for which 

DOE used a 2D aggregation approach.33 DOE used a 2D aggregation method because 

that method more accurately captures the cost-efficiency relationship for these EPSs. 

Generally, DOE believes that 3D aggregation typically yields the best curve fit for the 

dataset, so long as there are sufficient data. However, for the 2.5W and 18W EPSs, DOE 

had less data for which it could generate curve fits. DOE initially ran a 3D regression for 

the 2.5W and 18W representative units, but found that variations in the data for no-load 

32 DOE’s 3D-aggregation method is an approach to developing an equation that describes how MSP for an 

EPS changes with respect to both average efficiency and no-load power. That is, MSP is a function of both 

metrics simultaneously. 

33 DOE’s 2D-aggregation method is an approach to developing an equation that describes how MSP for an 

EPS changes with respect to average efficiency only. 

146 
 

 

power caused the correlation of the resulting curve to be low. Upon further inspection, 

DOE believes that the 2D curve fit more accurately reflects the less-robust underlying 

dataset for these two EPSs because the costs represent incremental improvements to meet 

specific CSLs and, thus, the large variations in the no-load power data provided by 

manufacturers do not degrade the correlation of the curve fit. Therefore, DOE switched to 

a 2D aggregation that described efficiency and cost, which generated a curve with higher 

correlation and more appropriate results for these representative units. For the remaining 

EPSs, DOE continued to apply the 3D-aggregation method because it generated a 

satisfactory curve fit. For additional details, please see chapter 5 of the TSD. 

d. EPS Engineering Results 

DOE characterized the cost-efficiency relationship of the four representative units 

in product class B as shown in Table IV-7Table IV.7, Table IV-8Table IV.8, Table 

IV-9Table IV.9, and Table IV-10Table IV.10. During interviews, manufacturers 

indicated that their switched-mode EPSs currently meet CSL1, the ENERGY STAR 2.0 

specification. This factor is reflected in the analysis by setting the incremental MSP for 

the 18W, 60W, and 120W EPSs at $0 at CSL 1, which means that there is no incremental 

cost above the baseline to achieve CSL 1. Costs for the 2.5W EPS, however, are 

estimated at $0.15 for CSL 1. This result occurs because of DOE’s assumption (based on 

available information) that the lowest cost solution for improving the efficiency of the 

2.5W EPS is through the use of linear EPSs, which are manufactured both at the EISA 

2007 level as well as at ENERGY STAR 2.0. Specifically, as commenters suggested, 

DOE examined linear EPSs and found that they might be a cost-effective solution at CSL 

147 
 

 

 

 

 

0 and CSL 1 for 2.5W EPSs. Thus, $0.15 indicates the incremental cost for a 2.5W EPS 

to achieve higher efficiency. For all four representative units, the more stringent CSLs, 

CSL 2, CSL 3, and CSL 4, correspond to switched-mode EPSs designed during the same 

design cycle, which would cause their costs to increase with increased efficiency. 

Table IV-7 2.5W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 58.3 67.9 71.0 73.5 74.8 

No-Load Power [W]: 0.500 0.300 0.130 0.100 0.039 

CSL Description: EISA ENERGY 

STAR 2.0 Intermediate Best-inMarket Max Tech 

Incremental MSP[$]: 0.00 0.15 0.33 0.45 0.52 

Table IV-8 18W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 76.0 80.3 83.0 85.4 91.1 

No-Load Power [W]: 0.500 0.300 0.2 0.1 0.039 

CSL Description: EISA ENERGY 

STAR 2.0 Intermediate Best-inMarket Max Tech 

Incremental MSP[$]: 0.00 0.00 0.17 0.64 2.89 

Table IV-9 60W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 85.0 87.0 87.0 88.0 92.2 

No-Load Power [W]: 0.5 0.5 0.2 0.073 0.05 

CSL Description: EISA ENERGY 

STAR 2.0 Intermediate Best-inMarket Max Tech 

Incremental MSP[$]: 0.00 0.00 0.82 1.29 2.73 

Table IV-10 120W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 85.0 87.0 88.0 88.4 93.5 

No-Load Power [W]: 0.5 0.5 0.23 0.21 0.089 

CSL Description: EISA ENERGY 

STAR 2.0 Intermediate Best-inMarket Max Tech 

Incremental MSP[$]: 0.00 0.00 0.31 0.45 6.41 

Unlike product class B, DOE analyzed a single 203W representative unit for 

multiple-voltage EPSs. These devices are exclusively used with home video-game 

148 
consoles, which use one output to power the device and another for standby controls. In 

Chapter 5 of the preliminary analysis TSD, DOE indicated that, for the NOPR, it was 

considering using the cost-efficiency relationship for 203W multiple-voltage EPSs that it 

developed as part of the non-Class A EPS determination analysis. In the determination 

analysis, DOE derived costs for CSL 0 and CSL 1 from test and teardown data but costs 

for CSL 2 and CSL 3 came from manufacturer and component supplier interviews. DOE 

received no comments on this approach, which was detailed in the preliminary analysis 

TSD. Hence, DOE is continuing to rely on its determination analysis results to help 

characterize the cost-efficiency relationship for 203W multiple voltage EPSs, shown in 

Table IV-11Table IV.11. 

Table IV-11 203W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

Efficiency [%]: 82.4 86.4 86.4 88.5 

No-Load Power [W]: 12.3 0.4 0.3 0.3 

CSL Description: Market 

Baseline 

MidMarket Best-in-Market Max Tech 

Incremental MSP[$]: 0.00 2.45 2.66 7.71 

Similar to the analysis of multiple-voltage EPSs, DOE analyzed one 345W 

representative unit for high-power EPSs. In Chapter 5 of the preliminary analysis TSD, 

DOE indicated that it was considering applying the cost-efficiency relationship for 345W 

high-power single-voltage EPSs that it developed as part of the non-Class A EPS 

determination analysis to high-power EPSs. In the determination analysis, DOE derived 

costs for CSL 0 and CSL 1 from test and teardown data, whereas costs for CSL 2 and 

CSL 3 came from manufacturer and component supplier interviews. DOE did not receive 

comments on this aspect of its approach in the preliminary analysis TSD. Hence, DOE 

149 
 

used the results from the determination analysis to characterize the costs of the lessefficient CSLs for 345W high-power EPSs in today’s NOPR (CSL 0 and CSL 1). 

However, as noted previously in section IV.C.1.b, DOE also believes that a 345W 

EPS could achieve higher efficiencies based on its theoretical model of a 360W EPS that 

exhibits the properties of three 120W EPSs connected in parallel. These higher output 

devices are typically used with amateur radio equipment, which often transmit at power 

levels between 100 and 200 watts while simultaneously providing power to other 

components. DOE developed its costs for the higher-efficiency CSLs (CSL 2, CSL 3, and 

CSL 4) based on 120W EPS analysis. The complete cost-efficiency relationship for the 

345W EPS is shown in Table IV-12Table IV.12. 

Table IV-12 345W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 62.4 81.3 84.6 87.5 92.0 

No-Load Power [W]: 15.43 6.01 0.5 0.5 0.266 

CSL Description: Market 

Baseline 

Low 

Market Mid-Market 

Scaled 

Best-inMarket 

Scaled 

Max Tech 

Absolute MSP[$]: 132.68 104.52 104.52 107.30 143.92 

e. EPS Equation Scaling 

During the preliminary analysis phase, DOE presented an approach to derive the 

average efficiency and no-load efficiency requirements for each CSL over the full range 

of output power for Class B EPSs. Mathematical equations define each CSL as a pair of 

relationships – 1) average active-mode efficiency to nameplate output power and 2) noload mode power consumption to nameplate output power. These equations allow DOE 

150 
 

 

to describe a CSL for any nameplate output power and are the basis of its proposed 

standards. A complete description of the equations can be found in chapter 5 of the TSD. 

For the baseline CSL and CSL1, DOE relied on equations from EISA 2007 and 

ENERGY STAR 2.0, respectively, rather than developing new equations. Both equations 

are defined over ranges of output power, although the divisions between ranges are 

slightly different. EISA 2007 created divisions by establishing separate efficiency 

equations at the 1 watt and 51 watt levels -- ENERGY STAR 2.0 creates a similar 

dividing line at 1 watt and 49 watts. See 42 U.S.C. 6295(u)(3)(A) (denoting nameplate 

output divisions at under 1 watt, 1 watt to not more than 51 watts, and over 51 watts) and 

“ENERGY STAR Program Requirements for Single Voltage External Ac-Dc and Ac-Ac 

Power Supplies” (denoting nameplate output divisions at less than or equal to 1 watt, 1 

watt to not more than 49 watts, and over 49 watts). DOE developed equations for all 

other CSLs and for consistency and simplicity used the ENERGY STAR 2.0 divisions at 

1 watt and 49 watts for all CSLs. These divisions were created in conjunction with the 

EPS product classes discussed in section IV.A.3.a as part of a complete analysis by the 

EPA. Given that it is considering adopting those product classes for direct operation 

EPSs, DOE believes that utilizing the ENERGY STAR output power divisions for its 

proposed standards is the most appropriate course of action. Consequently, the proposed 

standards are structured around these divisions rather than those created by the EISA 

2007 standard or the CEC standards for EPSs. Comment [A14]: Changes recommended by 

OIRA. 

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DOE derived CSL 2, CSL 3, and CSL 4 by fitting equations to the efficiency 

values of their respective data points for each representative unit. DOE used an equation 

of the form Y=a*ln(Pout) + b*Pout+c, for each of the nameplate output power ranges, 

where Y indicates the efficiency requirement; Pout indicates the nameplate output power; 

and a, b, and c indicate the specific parameters defined in the respective CSLs. DOE 

ensured that the equations met three conditions: 

(1) The distance to each point was minimized. 

(2) The equation did not exceed the tested efficiencies. 

(3) DOE further restricted the parameter choice in order to ensure that the 

CSL curves adhered to a matched pairs approach fully detailed in chapter 

5 of the TSD. 

Among the CSLs for product class B, DOE only revised the efficiencies of the 

max-tech data points at CSL 4. Thus, the remaining CSL equations, other than max-tech, 

remain unchanged from the equations DOE developed for the preliminary analysis. For 

the NOPR, DOE derived a revised max-tech scaling equation using the new max-tech 

data points it developed after obtaining additional data during manufacturer interviews 

following the preliminary analysis. 

As in the preliminary analysis, DOE scaled the CSL equations from product class 

B to product classes with low-voltage and AC-AC EPSs, which comprise product classes 

C, D, and E. The scaling for these equations was based on ENERGY STAR 2.0, which 

separates AC-DC conversion and AC-AC conversion into “basic-voltage” and “lowvoltage” categories. ENERGY STAR 2.0 sets less stringent efficiency levels for low152 
voltage EPSs because they cannot typically achieve the same efficiencies as basic-voltage 

EPSs due to inherent design limitations. Similarly, ENERGY STAR 2.0 sets less 

stringent no-load standards for AC-AC EPSs because they do not use the overhead 

circuitry found in AC-DC EPSs to limit no-load power dissipation. The power consumed 

by the additional AC-AC EPS circuitry would actually increase their no-load power 

metric. DOE used this approach to develop CSLs other than the baseline CSL 0 for 

product classes C, D, and E. Because the baseline is the EISA 2007 standard that applies 

to all Class A EPSs, which comprise most of product classes B, C, D, and E, CSL 0 is the 

same for all product classes. 

As described in the preliminary analysis and continued in today’s proposal, DOE 

created less stringent CSLs for product classes C, D, and E. For CSL 1, the equations 

come directly from the ENERGY STAR 2.0 low-voltage equation. The low-voltage 

curves for CSL 2, CSL 3, and CSL 4 were created by using their respective CSL 2, CSL 

3, and CSL 4 basic-voltage efficiency curves, and altering all equation parameters by the 

difference in the coefficients between the CSL 1 basic-voltage and low-voltage equations. 

This approach had the effect of shifting the CSL 2, CSL 3, and CSL 4 low -voltage 

curves downward from their corresponding basic-voltage CSL 2, CSL 3, and CSL 4 

curves, by a similar amount as the shift between the CSL basic-voltage and low-voltage 

curves. 

In the executive summary of the preliminary analysis TSD, DOE asked for 

comment regarding the various scaling relationships it developed to analyze EPS 

representative units and generate CSLs for the scaled product classes. The California 

153 
 

IOUs commented that they agreed "with [scaling EPS] CSLs on the basis of nameplate 

output power" but added that the standard equation should be based on power alone, not 

on voltage or cord length because this approach would allow DOE to create a potential 

standard more transparently than one based on voltage or cord length. In their view, an 

approach based on either or both of these factors would unnecessarily complicate the 

analysis without yielding an appreciable benefit with respect to determining an EPS’s 

achievable efficiency. (California IOUs, No. 43 at p. 8). 

DOE is proposing to apply the output power scaling method detailed in chapter 5 

of the TSD to set the standards for the scaled product classes. 

During the preliminary analysis, DOE analyzed the impacts of setting a discrete 

standard for product class X (multiple-voltage EPSs) as there was only one existing 

product on the market at that time. Since then, DOE has re-evaluated its data and now 

believes that the ENERGY STAR 2.0 low-voltage standard equation for AC-DC 

conversion is a preferable approach to setting standards for multiple-voltage EPSs 

because lower power EPSs tend to be less efficient. Under this approach, DOE would 

take into account that trend and any low-power multiple-voltage EPSs that appear on the 

market would not be relegated to a single efficiency level that was established based on 

the performance of a 203W unit. As detailed in chapter 5 of the TSD, the ENERGY 

STAR 2.0 low-voltage equation matches the CSL DOE is proposing for the standard at 

the representative unit’s output power of 203 watts, but also sets less stringent efficiency 

standards for lower power EPSs. Therefore, the proposed equation accounts for future 

products requiring multiple-voltage EPSs by setting a continuous standard versus output 

154 
 

 

power while also supporting DOE’s analysis of the 203W representative unit in product 

class X. DOE applied the same constraints when fitting the equation to the test data as it 

did for product classes B, C, D, and E. DOE seeks comment on this proposed approach in 

setting a standard for multiple-voltage EPSs. 

For product class H (high-power EPSs), DOE proposes to set a discrete standard 

for all EPSs greater than 250 watts. DOE believes this is appropriate for two main 

reasons: (1) DOE is aware of only one application for high-power EPSs (i.e. amateur 

radios) and (2) this approach is consistent with the standard for product class B, which is 

a discrete level for all EPSs with nameplate output powers greater than 49 watts. In light 

of these facts, setting a single efficiency level as the standard for all EPSs with output 

powers greater than 250 watts (i.e. high-power EPSs) appears to be a reasonable 

approach to ensure a minimal level of energy efficiency while minimizing the overall 

level of burden on manufacturers. DOE seeks comment on this approach. 

2. Engineering Analysis for Battery Chargers 

When developing the engineering analysis for battery chargers, DOE selected 

representative units for each product class. For each representative unit, DOE tested a 

number of different products. After examining the test results, DOE selected CSLs that 

set discrete levels of improved battery charger performance in terms of energy 

consumption. Subsequently, for each CSL, DOE used either teardown data or information 

gained from manufacturer interviews to generate costs corresponding to each CSL for 

each representative unit. Finally, for each product class, DOE developed scaling 

155 
relationships using additional test results and generated UEC equations based on battery 

energy. 

a. Representative Units 

For each product class, DOE selected a representative unit upon which it 

conducted its engineering analysis and developed a cost-efficiency curve. The 

representative unit is meant to be an idealized battery charger typical of those used with 

high-volume applications in its product class. Because results from the analysis of these 

representative units would later be extended to additional battery chargers, DOE selected 

high-volume and/or high-energy-consumption applications that use batteries that are 

typically found across battery chargers in the given product class. The analysis of these 

battery chargers is pertinent to all the applications in the product class under the 

assumption that all battery chargers with the same battery voltage and energy provide 

similar utility to the user, regardless of the actual end-use product with which they work. 

The table below shows the representative units for each product class that DOE analyzed. 

156 
 

 

 

Table IV-13 The Battery Charger Representative Units for each Product Class 

Product 

Class # 

Input / 

Output 

Type 

Battery 

Energy 

(Wh) 

Special 

Characteristic or 

Battery Voltage 

Rep. Unit 

Battery 

Voltage 

(V) 

Rep. Unit 

Battery 

Energy 

(Wh) 

1 

AC In, 

DC Out 

< 100 

Inductive 

Connection 3.6 1.5 

2 < 4 V 3.6 3 

3 4–10 V 7.2 10 

4 > 10 V 12 20 

5 

100–3000 

< 20 V 12 800 

6 ≥ 20 V 24 400 

7 > 3000 - 48 3,750 

8 DC In, 

DC Out 

- < 9 V Input 3.6 2 

9 - ≥ 9 V Input 5 3.6 

10 AC In, 

AC Out - - 12 70 

Additional details on the battery charger representative units can be found in 

chapter 5 of the TSD. 

b. Battery Charger Efficiency Metrics 

In the preliminary analysis, DOE considered using a single metric (i.e. UEC) to 

illustrate the improved performance of battery chargers. DOE designed the calculation of 

UEC to represent an annualized amount of the non-useful energy consumed by a battery 

charger in all modes of operation. Non-useful energy is the total amount of energy 

consumed by a battery charger that is not transferred and stored in a battery as a result of 

charging (i.e. losses). In order to calculate UEC, DOE must have the performance data, 

which comes directly from its battery charger test procedure (see section 

IV.A.4.eIV.A.4.e.). DOE must also make assumptions about the amount of time spent in 

157 
 

 

 

 

each mode of operation. The collective assumption about the amount of time spent in 

each mode of operation is referred to as a usage profile and is addressed in section 

IV.EIV.E and further detail in TSD chapter 7. 

The possible use of a UEC metric generated numerous comments. NEEP and 

PG&E stated that they believed UEC to be an inappropriate metric because of the 

uncertainties around the usage profiles. (NEEP, No. 51 at p. 3; PG&E, et al., No. 49 at p. 

1) NEEP suggested that DOE should regulate 24-hour energy and standby mode power 

individually rather than use UEC. (NEEP, No. 51 at p. 4) For product classes 1 through 9, 

PG&E proposed that DOE should have separate standards for 24-hour charge and 

maintenance energy and no-battery mode power, while for product class 10, DOE should 

regulate only maintenance mode power. (PG&E, et al., No. 49 at p. 2) PG&E also 

suggested another alternative in which DOE could use UEC, but that alternative involved 

giving equal weight to each mode of operation. (PG&E, et al., No. 49 at p. 2) While the 

ENERGY STAR specification for battery chargers (i.e. a nonactive energy ratio) does not 

consider active (or charge) mode, the California IOUs agreed with DOE’s approach to 

consider active mode as a component of UEC. (California IOUs, No. 43 at p. 1) Details 

on UEC are included in the next section of today’s notice (IV.C.2.c). 

DOE recognizes that a wide range of consumers may use the same product in 

different ways, which may cause some uncertainty about usage profiles. Notwithstanding 

that possibility, DOE believes that its assumptions are accurate and appropriate gauges of 

product use because calculated weighted averages of usage profiles based on a 

158 
 

 

 

 

distribution of user types were used to represent each product class. These assumptions 

also rely on a variety of sources including information from manufacturers and utilities. 

Details on DOE’s new usage profile assumptions and how they have changed since the 

preliminary analysis can be found in section IV.E of today’s notice and TSD chapter 7. 

DOE also appreciates suggestions to regulate only product class 10 (AC in/AC 

out) on the basis of maintenance mode power. DOE’s proposal follows that suggestion. 

DOE assumes that UPSs, which comprise all of product class 10 units, are always in 

maintenance mode and undergo zero charges per year. By following this approach, the 

calculated energy per year for these devices is simply an allowance of maintenance mode 

power over a 365-day year. However, by converting maintenance mode power to a UEC, 

DOE can ensure consistency across all battery charger classes and avoid any potential 

confusion.34 

Finally, DOE believes that by aggregating the performance parameters of battery 

chargers into one metric and applying a usage profile, it will allow manufacturers more 

flexibility to improve performance in the modes of operation that will be the most 

beneficial to their consumers rather than being required to improve the performance in 

each mode of operation, some of which may not provide any appreciable benefit. For 

example, a battery charger used with a mobile phone is likely to spend more time per day 

in no-battery mode than a battery charger used for a house phone, which is likely to 

34 If DOE were to establish an energy conservation standard for UPSs in terms of maintenance mode 

power, manufacturers of other products could be confused and believe that their product is also subject to a 

maintenance mode power standard, when in fact, it is a combination of all of their product’s performance 

characteristics. 

159 
 

 

 

 

spend a significant portion of everyday in maintenance mode. Consequently, it would be 

more beneficial to consumers of mobile phones if manufacturers improved no-battery 

mode and house phone battery charger manufacturers improved maintenance mode. 

Therefore, DOE plans to continue to use UEC as the metric for battery chargers. 

c. Calculation of Unit Energy Consumption 

As discussed in IV.C.2.b, UEC is based on a calculation designed to give the total 

annual amount of energy lost by a battery charger from the time spent in each mode of 

operation. For the preliminary analysis, the various performance parameters were 

combined with the usage profile parameters and used to calculate UEC with the 

following equation: 

Where 

E24 = 24 hour energy 

Ebatt = Measured battery energy 

Pm = Maintenance mode power 

Psb = Standby mode power 

Poff = Off mode power 

tc = Time to completely charge a fully discharged battery 

n = Number of charges per day 

ta&m = Time per day spent in active and maintenance mode 

tsb = Time per day spent in standby mode 

toff = Time per day spent in off mode35 

When separated and examined in segments, it becomes evident how this equation 

gives a value for energy consumed in each mode of operation per day and ultimately, 

35 Those values shown in italics are parameters assumed in the usage profile and change for each product 

class. Further discussion of them and their derivation is found in IV.E. The other values should be 

determined according to section 5 of Appendix Y to Subpart B of Part 430. 

ܷܥܧ ൌ 365 ൬݊ሺܧଶସ െ ܲ௠ሺ24 െ ݐ௖ሻ െ ܧ௔௕௧௧ሻ ൅ ቀܲ௠൫ݐ ௠&௔െ ሺݐ௖݊ሻ൯ቁ ൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯൰

160 
 

 

/݀ܽݕ 	ൌ	 ܧ௖஺௧௜௩௘	ெ௢ௗ௘ ሻ െ ܧ௔௕௧௧ ሻ 24 െ ݐ ௖െ ܲ௠ሺ ܧଶସ ݊ሺ

energy consumption per year. These segments are discussed individually below. DOE 

seeks comment on all of these equations and its proposed approach. 

Active (or Charge) Mode Energy per Day 

In the first portion of the equation, shown above, DOE combines the assumed 

number of charges per day, 24-hour energy, maintenance mode power, charge time, and 

measured battery energy to calculate the active mode energy losses per day. To calculate 

this value, 24-hour energy (E24) is reduced by the measured battery energy (the useful 

energy inherently included in a 24-hour energy measurement) and the product of the 

value of the maintenance mode power multiplied by the quantity of 24 minus charge 

time. This latter value (24 minus charge time) corresponds to the amount of time spent in 

maintenance mode, which, when multiplied by maintenance mode power, yields the 

amount of maintenance mode energy consumed by the tested product. Thus, maintenance 

mode energy and the value of the energy transferred to the battery during charging are 

both subtracted from 24-hour energy, leaving a quantity theoretically equivalent to the 

amount of energy required to fully charge a depleted battery. This number is then 

multiplied by the assumed number of charges per day (n) resulting in a value for active 

mode energy per day. Details on DOE’s usage profile assumptions can be found in 

section IV.E of today’s notice and TSD chapter 7. 

161 
 

 

 

Maintenance Mode Energy per Day 

ݕ/݀ܽ ܽ݅ܯ݁݊ܽ݊ݐ݀݁ܿ݊݋ܯ	݁ ܧ ൌ ሻ൯ቁܿ݊ݐሺ െ& ݉ܽ ݐ൫ܲ݉ቀ

In the second segment of DOE’s equation, shown above, maintenance mode 

power, time spent in active and maintenance mode per day, charge time, and the assumed 

number of charges per day are combined to obtain maintenance mode energy per day. 

Time spent in active and maintenance mode is subtracted by the product of the charge 

time multiplied by the number of charges per day. The resulting quantity is an estimate of 

time spent in maintenance mode per day, which, when multiplied by the measured value 

of maintenance mode power, yields the energy consumed per day in maintenance mode. 

Standby (or No-Battery) Mode Energy per Day 

ݕ/݀ܽ ݋ܯ݁݀ ݕ ܽݐܾ݀݊ܵ ܧ 	ൌ ሻܾݏݐܾݏܲሺ

In the third part of DOE’s UEC equation, shown above, the measured value of 

standby mode power is multiplied by the estimated time in standby mode per day, which 

results in a value of energy consumed per day in standby mode. 

Off-Mode Energy per Day 

ݕ/݀ܽ ݀݁݁݋ܯ	ݕݎ ݐݐ _݋ܰܤܽ ܧ ൌ ൯ ݂݋݂ ݐ݂݂݋ܲ൫

In the final part of DOE’s UEC equation, shown above, the measured value of 

off-mode power is multiplied by the estimated time in off-mode per day, which results in 

a value of energy consumed per day in off-mode. 

162 
 

 

 

 

 

 

Finally, to obtain UEC, the values found through the above calculations are added 

together. The resulting sum is equivalent to an estimate of the average amount of energy 

consumed by a battery charger per day. That value is then multiplied by 365, the number 

of days in a year, and the end result is a value of energy consumed per year. 

Modifications to Equation for Unit Energy Consumption 

On April 2, 2010, DOE published its NOPR on active mode test procedures for 

battery chargers and EPSs. 75 FR 16958. In that notice, DOE proposed shortening the 

active mode test procedure in scenarios where a technician could determine that a battery 

charger had entered maintenance mode. 75 FR 16970. However, during its testing of 

battery chargers, DOE observed complications arising when attempting to determine the 

charge time for some devices, which, in turn, could affect the accuracy of the UEC 

calculation. DOE also received comments opposed to the proposed shortened test 

procedure. DOE ultimately decided that the duration of the charge test must not be 

shortened and be a minimum of 24 hours. See 76 FR 31750 (final rule establishing 

amended test procedure for battery chargers and EPSs). The test that DOE adopted is 

longer if it is known (e.g. because of an indicator light on the battery charger) or it can be 

determined from manufacturer information that fully charging the associated battery will 

take longer than 19 hours.36 

36 The charge mode test must include at least a five-hour period where the unit being tested is known to be 

in maintenance mode. Thus, if a device takes longer than 19 hours to charge, or is expected to take longer 

than 19 hours to charge, the entire duration of the charge mode test will exceed 24 hours in total time after 

the five-hour period of maintenance mode time is added. 76 FR 31750, 31766-67, and 31780. 

163 
 

 

This revision to the test procedure is important because it underscores the 

potential issues with trying to determine exactly when a battery charger has entered 

maintenance mode, which creates difficulty in determining charge time. To address this 

situation, DOE modified its initial UEC equation. The new equation, which was 

presented to manufacturers during interviews, is mathematically equivalent to the 

equation presented in the preliminary analysis. When the terms in the preliminary 

analysis UEC equation are multiplied, those terms containing a factor of charge time 

cancel each other out and drop out of the equation. What is left can be factored and 

rewritten as done below. This means that even though the new equation looks different 

from the equation presented for the preliminary analysis, the value that is obtained is 

exactly the same and represents the exact same value of unit energy consumption. 

ܷܥܧ ൌ 365 ൬݊ሺܧଶସ െ ܧ௔௕௧௧ሻ ൅ ቀܲ௠൫ݐ ௠&௔െ ሺ24݊ሻ൯ቁ ൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯൰

In addition to initially considering a shortened battery charger active mode test 

procedure, DOE considered capping the measurement of 24-hour energy at the 24-hour 

mark of the test. However, following this approach could result in inaccuracies because 

that measurement would exclude the full amount of energy used to charge a battery if the 

charge time is longer than 24 hours in duration. To account for this possibility, DOE 

altered this initial approach in the test procedure final rule by requiring the measurement 

of energy for the entire duration of the charge and maintenance mode test, which includes 

a minimum of 5 hours in maintenance mode. 76 FR 31750, 31780. 

164 
 

 

 

 

 

 

 

The modifications to the UEC calculation do not alter the value obtained when the 

charge and maintenance mode test is completed within 24 hours. However, if the test 

exceeds 24 hours, the energy lost during charging is scaled back to a 24-hour, or per day, 

cycle by multiplying that energy by the ratio of 24 to the duration of the charge and 

maintenance mode test. In the equation below, tcd, represents the duration of the charge 

and maintenance mode test and is a value that the test procedure requires technicians to 

determine. DOE also modified the equation for the NOPR by inserting a provision to 

subtract 5 hours of maintenance mode energy from the 24-hour energy measurement. 

This change was made because the charge and maintenance mode test includes a 

minimum of 5 hours of maintenance mode time. Consequently, in the second portion of 

the equation below, DOE would reduce the amount of time subtracted from the assumed 

time in active and maintenance mode time per day. 

In other words, the second portion of the equation, which is an approximation of 

maintenance mode energy, is reduced by 5 hours. This alteration is needed in those 

instances when the charge and maintenance mode test exceeds 24 hours, because the 

duration of the test minus 5 hours is an approximation of charge time. This information, 

tcd, can then be used to approximate the portion of time that a device is assumed to spend 

in active and maintenance mode per day (ta&m) is solely dedicated to maintenance mode.37 

The primary equation that manufacturers will use to determine their product’s unit energy 

consumption and whether or not their device complies with DOE’s standards is below. 

37 For a test exceeding 24 hours, the duration of the test less 5 hours is equal to the time it took the battery 

being tested to become fully charged (tcd – 5). That value, multiplied by the assumed number of charges per 

day, gives an estimate of charge (or active) time per day, which can then be subtracted from DOE’s other 

assumption for ta&m. That difference is an approximation for maintenance mode time per day. 

165 
 

24 ሻ ܧଶସ െ 5ܲ௠ െ ܧ௔௕௧௧ ܷܥܧ ൌ 365ሺ݊ሺ ݐ௖ௗ

൅ ൫ܲ௢௙௙ݐ௙௙௢൯ሻ

ሻ ܲ௦௕ݐ௦௕ െ 5ሻ݊ሻ൯ ൅ ሺ ݐ௖ௗ െ ሺ ൅ ൫ܲ௠ሺݐ௠&௔

Secondary Calculation of UEC 

For some battery chargers, the equation described above is not appropriate and an 

alternative calculation is necessary. Specifically, in those cases where the charge test 

duration (as determined according to section 5.2 of Appendix Y to Subpart B of Part 430) 

minus 5 hours is multiplied by the number of charges per day (n) is greater than the time 

assumed in active and maintenance mode (ta&m), an alternative equation must be used. A 

different equation must be used because if the number of charges per day multiplied by 

the time it takes to charge (charge test duration minus 5 hours -- or the charge time per 

day) is longer than the assumption for the amount of time spent in charge mode and 

maintenance mode per day, that difference creates an inconsistency between the 

measurements for the test product and DOE’s assumptions. This problem can be 

corrected by using an alternative equation, which is shown below. 

ሻ ܧଶସ െ 5ܲ௠ െ ܧ௔௕௧௧ ܷܥܧ ൌ 365ሺ݊ሺ ൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯ሻ െ 5ሻ

24

ሺݐ௖ௗ

This alternative equation resolves this inconsistency by prorating the energy used 

for charging the battery. 

166 
 

 

 

 

d. Battery Charger Candidate Standard Levels (CSLs) 

After selecting its representative units for battery chargers, DOE examined the 

impacts on the cost of improving the efficiency of each of the representative units to 

evaluate the impact and assess the viability of potential energy efficiency standards. As 

described in the technology assessment and screening analysis, there are numerous design 

options available for improving efficiency and each incremental technology improvement 

increases the battery charger efficiency along a continuum. The engineering analysis 

develops cost estimates for several CSLs along that continuum. 

CSLs are often based on (1) efficiencies available in the market; (2) voluntary 

specifications or mandatory standards that cause manufacturers to develop products at 

particular efficiency levels; and (3) the maximum technologically feasible level.38 

Currently, there are no energy conservation standards for battery chargers. DOE 

does not believe the ENERGY STAR efficiency level to be widely applicable, primarily 

because these levels are limited to chargers used for motor-operated applications and 

contain no provisions to cover active mode energy consumption. Because of this 

situation, DOE based the CSLs for its battery charger engineering analysis on the 

efficiencies obtainable through the design options presented previously (see IV.A.4.f). 

These options are readily seen in various commercially available units. DOE selected 

commercially available battery chargers at the representative-unit battery voltage and 

38 The “max-tech” level 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 constrained 

by economic justification, and typically is the most expensive design option considered in the engineering 

analysis. 

167 
 

energy levels from the high-volume applications identified in the market survey. DOE 

then tested these units in accordance with the DOE battery charger test procedure. For 

each representative unit, DOE then selected CSLs to correspond to the efficiency of 

battery charger models that were comparable to each other in most respects, but differed 

significantly in UEC (i.e. efficiency). 

In general, for each representative unit, DOE chose the baseline (CSL 0) unit to 

be the one with the highest calculated unit energy consumption, and the best-in-market 

(CSL 2) to be the one with the lowest. Where possible, the energy consumption of an 

intermediate model was selected as the basis for CSL 1 to provide additional resolution to 

the analysis. 

Unlike the previous three CSLs, CSL 3 was not based on an evaluation of the 

efficiency of battery charger units in the market, since battery chargers with maximum 

technologically feasible efficiency levels are not commercially available due to their high 

cost. Where possible, DOE analyzed manufacturer estimates of max-tech costs and 

efficiencies. In some cases, manufacturers were unable to offer any insight into 

efficiencies beyond the best currently available in the market. Therefore, DOE projected 

the efficiency of a max-tech unit by estimating through extrapolation from its analysis of 

the analyzed CSL 2 unit the impacts of adding any remaining energy efficiency design 

options. 

168 
 

 

DOE received a number of comments from interested parties regarding the CSLs 

developed for the preliminary analysis. The California IOUs suggested that DOE 

consider CSLs between the best-in-market and max-tech levels. (California IOUs, No. 43 

at pp. 3, 5) NEEP made a similar suggestion, stating that DOE should have an additional 

CSL between the intermediate and max-tech CSLs. (NEEP, No. 51 at p. 4) The California 

IOUs added that DOE should consider the efficiency levels proposed at a standardsrelated workshop held in California on October 11, 2010.39 (California IOUs, No. 43 at p. 

2) 

In response to these suggestions on the preliminary analysis, DOE considered the 

levels proposed at the California workshop. At that workshop, California proposed using 

separate metrics for 24-hour energy, maintenance mode power, and standby mode power. 

Subsequently, California modified its approach to battery charger standards and 

combined the requirements for maintenance mode power and standby mode power into 

one metric. Using its usage profiles to translate these standards into a value of UEC, DOE 

compared its CSLs with the levels adopted by California. DOE found that, in most cases, 

when California’s proposed standard was calculated into a value of UEC (using DOE’s 

usage profile assumptions), it generally corresponded closely with one of DOE’s CSLs 

for each product class. Therefore, in most instances, little valuable resolution could be 

added to DOE’s cost-efficiency curves. 

39PG&E, Analysis of Standards Options for Battery Charger Systems, October 1, 2010 

(http://www.energy.ca.gov/appliances/battery_chargers/documents/2010-10-11_workshop/2010-10­

11_Battery_Charger_Title_20_CASE_Report_v2-2-2.pdf). 

169 
 

 

 

 

Although this was the case for most product classes, it was not the case for all of 

them. For product class 2, DOE adopted the suggestion from the California IOUs and 

added a level between CSL 1 and CSL 2 because the magnitude of the gap between UEC 

values was large enough to permit an additional CSL that could provide more cost 

effective savings. Please see TSD chapter 5 for product class 2 test results that illustrate 

this gap. 

Table IV-14Table IV.14 below shows which CSL aligns most closely with the 

California proposal for each product class. 

Table IV-14 CSLs Equivalent to California Proposed Standards40 

Product Class CSL Equivalent to CEC Standard 

1 (Low-Energy, Inductive) CSL 20 

2 (Low-Energy, Low-Voltage) CSL 2 

3 (Low-Energy, Medium-Voltage) CSL 2 

4 (Low-Energy, High-Voltage) CSL 2 

5 (Medium-Energy, Low-Voltage) CSL 2- 3 

6 (Medium-Energy, High-Voltage) CSL 23 

7 (High-Energy) CSL 01 

8 (DC Input < 9 V) CSL 0 

10 (AC Output) CSL 23 

In addition, DOE received comments on specific CSLs for specific product 

classes. For product class 1(low-energy, inductive) in particular, the California IOUs 

encouraged DOE to consider a CSL higher than CSL 3 because, in their view, CSL 3 was 

shown to be cost effective, leaving a possibility of additional cost-effective savings at 

40 Product classes 8 and 9 were omitted because the California Energy Comission did not propose separate 

standards for DC input devices in their rule. 

170 
 

higher efficiencies. (California IOUs, No. 43 at p. 5) For product class 2 (low-energy, 

low-voltage), the California IOUs asserted that DOE’s baseline CSL should be lower 

because the test results presented in the preliminary analysis TSD showed products with 

UEC levels higher than the baseline value selected by DOE. (California IOUs, No. 43 at 

p. 6) PTI expressed concern over the max-tech level for product class 4, stating that it 

would be achievable only by using a lithium-based (i.e. Lithium-ion or “Li-ion”) battery 

technology, which is currently used in laptop computer applications. (PTI, No. 47 at p. 8) 

Finally, when developing a max-tech level for product classes 2, 3 (low-energy, medium 

voltage), 4 (low-energy, high-voltage), 8 (low-energy, low DC input), and 9(low-energy, 

high DC input), the California IOUs suggested that DOE speak to integrated circuit 

component suppliers. (California IOUs, No. 43 at p. 5) 

Based on all of these comments, DOE conducted further analysis and review. For 

product class 1, DOE conducted additional interviews with manufacturers of these 

products and has revised its engineering analysis accordingly. DOE believes that the new 

MSPs, which are shown in section IV.C.2.i, more accurately depict the relationship 

between cost and efficiency for electric toothbrushes, which is the predominant 

application in that class. 

For product class 2, DOE understands the concerns about creating an accurate 

baseline UEC for these devices. However, the baseline level that DOE has developed for 

today’s NOPR is representative of the worst performing products tested by DOE. All of 

the units that showed higher values of energy consumption were products that Ecos, an 

171 
 

independent consulting firm and test lab that assisted the CEC when developing a battery 

charger test procedure, tested and provided to DOE. DOE believes that this factor may be 

partially explained by timing. Since many of the units tested by Ecos that performed 

poorly were older test units, it is likely that these devices did not incorporate EPSs that 

meet the EISA 2007 regulations that went into effect in 2008. Therefore, DOE believes 

that its current CSL 0 for product class 2 is appropriate and provides a reasonable picture 

of the current battery charger market. 

In response to PTI’s comment, DOE clarifies that its preliminary analysis did not 

include an analysis for CSL 3 in product class 4. DOE obtained results only up to CSL 2 

for product class 4. DOE notes that one of the units tested and torn down for that CSL 

was a power tool. For the NOPR, DOE has developed an analysis for CSL 3 in product 

class 4, which corresponds to that class’s maximum technology level. 

Finally, in developing the max-tech levels in the NOPR engineering analysis, 

DOE relied on input from manufacturers of battery chargers and original equipment 

manufacturers (OEMs) of products that use battery chargers. Manufacturers were able to 

provide DOE with sufficient information to enable the agency to ascertain what level of 

technology is feasible and is capable of surpassing the efficiency levels of incumbent 

technology currently available at the high end of the market today. Based on this 

information, DOE tentatively concluded that based on these discussions with 

manufacturers and OEMs there was sufficient information to define max-tech levels 

without interviewing integrated circuit suppliers. 

172 
 

e. Test and Teardowns 

As mentioned above, the CSLs used in the battery charger engineering analysis 

were based on the efficiencies of battery chargers available in the market. Following 

testing, the units corresponding to each commercially available CSL were disassembled 

to (1) evaluate the presence of energy efficiency design options and (2) estimate the 

materials cost. The disassemblies included an examination of the general design of the 

battery charger and helped confirm the presence of any of the technology options 

discussed in section IV.A.4.f. 

After the battery charger units corresponding to the CSLs were evaluated, they 

were torn down by iSuppli, a DOE contractor and industry expert. An in-depth teardown 

and cost analysis was performed for each of these units. For some products, like 

camcorders and notebook computers, the battery charger constitutes a small portion of 

the circuitry. In evaluating the related costs, iSuppli identified the subset of components 

in each product enclosure responsible for battery charging. The results of these teardowns 

were then used as the primary source for the MSPs. 

Interested parties offered some feedback regarding DOE’s test and teardowns 

after the preliminary analysis. Stanley Black and Decker suggested that DOE should 

validate iSuppli’s results by having them teardown products whose true costs are known ­

- i.e. those instances where a manufacturer may have supplied data under a nondisclosure agreement. (B&D, Pub. Mtg. Tr., No. 37 at p. 234) AHAM recommended that 

173 
 

 

 

DOE look at low cost products in product class 4 (e.g. notebook computers and large 

power tools). Wahl Clipper recommended that DOE estimate costs at lower volume 

levels than those used in the preliminary analysis -- it offered 20,000 units per year as one 

alternative -- because the effects on cost might be greater when components are 

purchased in lower volumes. (Wahl Clipper, Pub. Mtg. Tr., No. 37 at p. 206) The 

California IOUs made a number of recommendations to DOE. First, they suggested that 

DOE use PG&E’s battery charger test data and that DOE gather more teardown data. 

(California IOUs, No. 43 at p. 2) Second, they supported DOE’s decision to leave out 

packaging costs from the teardown results. In particular, for product class 2 (e.g. mobile 

and cordless phones), they recommended that DOE conduct teardown analyses of units 

with slightly higher and lower battery energies. Third, the California IOUs urged DOE to 

test and tear down a wider array of battery chargers from product classes 5 (e.g. marine 

chargers) and 7 (e.g. golf cars). They suggested this approach because they claimed that 

their own test data showed a wider range of efficiencies among battery chargers 

belonging to these classes. (California IOUs, No. 43 at pp. 4, 6) 

For the NOPR, DOE has adopted most of the recommendations raised by 

commenters and has expanded its test program. DOE has performed additional tests using 

a variety of products from a number of product classes, including product classes 2, 4, 5, 

and 7. Further, DOE has performed additional teardown analyses on products from all ten 

proposed product classes. In total, over 100 new test results have been incorporated into 

the NOPR analysis. Packaging costs have continued to be excluded because they do not 

represent costs associated with improving the efficiency of a product. Regarding Wahl 

174 
 

 

Clipper’s suggestion to modify the volume assumption to 20,000 in order to determine 

how costs may change for a lower volume manufacturer, DOE believes that the large 

number of applications in each product class make it too difficult to select an appropriate 

low volume level. Additionally, DOE believes that the change in volume that results in 

higher costs for a manufacturer is likely to have little effect on consumers because the 

incremental costs from CSL to CSL are likely to be the same regardless of volume. 

Finally, DOE verified the accuracy of the iSuppli results by confirming those 

results with individual manufacturers during interviews. As will be discussed in the 

following section, DOE performed additional manufacturer interviews for the NOPR and 

during these interviews, the initial iSuppli results were vetted with manufacturers. DOE 

believes that it has sufficiently verified the accuracy of its teardown results and believes 

that all of the engineering costs gleaned from iSuppli are appropriate. 

f. Manufacturer Interviews 

The preliminary analysis had, in part, relied on information obtained through 

interviews with several battery charger manufacturers. These manufacturers consisted of 

companies that manufacture battery chargers and OEMs of battery-operated products 

who package battery chargers with their end-use products. DOE followed this approach 

to obtain data on the possible efficiencies and resultant costs of consumer battery 

chargers. 

175 
 

DOE received two comments regarding manufacturer interviews. First, PTI 

recommended that DOE speak with power tool manufacturers individually to obtain 

detailed information that would otherwise be unavailable through PTI as a trade 

association. (PTI, No. 47 at p. 12) Second, AHAM requested that the manufacturer 

interviews also involve discussions about testing costs and non-recurring capital 

expenditures. (AHAM, No. 44 at p. 13) 

In preparing the NOPR, additional interviews were conducted, including those 

with manufacturers who were previously interviewed and new ones who were not. These 

interviews served two purposes. First, it gave manufacturers the opportunity to provide 

feedback on the preliminary analysis engineering analysis results. Aggregated 

information from these results is provided in TSD chapter 5. Second, these interviews 

also provided manufacturer inputs and comments in preparing the manufacturer impact 

analysis, which is discussed in detail in section IV.I. 

DOE attempted to obtain teardown results for all of its product classes but 

encountered difficulties in obtaining useful and accurate teardown results for two of its 

products classes -- namely, product class 1 (e.g. electric toothbrushes) and product class 

10 (e.g. uninterruptible power supplies). For these two classes, DOE relied heavily on 

information obtained from manufacturer interviews. DOE found that when it attempted to 

teardown product class 1 devices, most contained potting (i.e. material used to waterproof 

internal electronics). Removal of the potting also removed the identifying markings that 

176 
 

 

iSuppli needed to estimate a cost for the components. As a result, manufacturer interview 

data helped furnish the necessary information to assist DOE in estimating these costs. 

In the case of UPSs, DOE found that it was difficult to accurately compare 

product costs because of the varying functionality of these devices. For example, DOE 

examined multiple UPSs, some of which provided additional utility to end users, such as 

AVR. As discussed earlier, AVR involves circuitry that monitors input voltage from the 

wall and ensures that all products plugged into the UPS see a steady flow of voltage 

despite any fluctuations. This added circuitry was impossible to distinguish from the 

standard UPS battery charging circuitry, which made it difficult to compare the costs of 

products that did not provide the same level of utility to the end-user. Furthermore, 

because the cost versus efficiency data provided by manufacturers showed economically 

justifiable levels through the max-tech level developed in the preliminary analysis, DOE 

believed that these data were sufficient to set out the proposed levels without resorting to 

a more time-consuming tear-down analysis. However, after a second round of interviews 

with UPS manufacturers for the NOPR and conducting additional analysis (including 

testing), DOE found that it needed to make a modification to its approach for dealing 

with battery chargers within UPSs. 

When DOE tested UPSs according to the battery charger test procedure, it was 

unable to obtain maintenance mode power measurements as low (i.e. as good in terms of 

energy consumption) as those that manufacturers indicated were possible. DOE believes 

that the discrepancies between its test measurements and the data provided by 

177 
 

manufacturers stems from the manner in which the test procedure measures energy 

consumption. TP measures consumption of unit as a whole -- the entire UPS. BC only is 

using from mfr data. In particular, the DOE test procedure measures the energy 

consumption of the unit -- in this case, the UPS -- as a whole. Measuring the energy 

consumption of the battery charger alone in this instance would involve destructive 

testing. As a result, the data that DOE derived following its current test procedure for 

battery chargers includes the energy consumption from other UPS components other than 

the battery charger itself. For this reason, in this instance, DOE believes that the 

manufacturer-supplied data is more likely to accurately reflect the actual energy 

consumption of the battery charger alone. Because manufacturers would be unlikely to 

over-estimate the potential energy consumption of their products, DOE believes that their 

estimates of power consumption from the UPS’s battery charger are still appropriate 

estimates. However, DOE still needs to account for the discrepancies between the 

manufacturer data and the measurements from its test procedure. 

For the NOPR, DOE conducted additional testing of UPSs in which it attempted 

to describe the differences between its test procedure measurement and the values 

provided by manufacturers. During this round of testing, DOE performed the DOE test 

procedure, but added another measurement. As mentioned previously, while it is 

extremely difficult to isolate the power consumption due to battery charging from any 

other UPS functionality, the input power to the battery itself can be measured. With this 

measurement, DOE obtained two useful pieces of information. First, it allowed DOE to 

isolate a portion of battery charging power consumption from all other functions within a 

178 
 

UPS and develop a trend line that describes how maintenance mode power will vary as 

battery energy changes. Second, this measurement, combined with the data from the 

tested units that corresponded to DOE’s best-in-market test results (in terms of 

maintenance mode power as measured in the DOE test procedure), allowed DOE to 

develop supplemental values that it could use to increment the data provided by 

manufacturer such that it correlated to DOE test results. These values essentially operate 

as a means to account for the additional energy consumption used by a device when 

providing additional functionality. DOE developed two values, shown in Table 

IV-15Table IV.15 below, one for basic UPSs and one for UPSs that incorporate AVR. 

See TSD Chapter 5 for additional details. DOE is proposing to use these two values to 

develop an appropriate standard for basic UPSs and UPSs with AVR, after DOE proposes 

selecting an appropriate TSL for product 10. 

Table IV-15 Supplemental Values for Product Classes 10a and 10b 

Product Class 

Maintenance Mode 

Supplemental Value for 

Proposed Standard (W) 

UEC Supplemental Value 

for Proposed Standard 

(kWh/yr) 

10a (UPSs without AVR) 0.4 3.45 

10b (UPSs with AVR) 0.8 7.08 

g. Design Options 

Design options are technology options that remain viable for use in the 

engineering analysis after applying the screening analysis as discussed above in section 

IV.B. 

179 
 

In response to the preliminary analysis, DOE received comments regarding design 

options and their application to the overall analysis. The California IOUs indicated that, 

with respect to the larger battery charger product classes where lead-acid batteries are 

most common, DOE should apply technologies more common in smaller units, such as 

switch-mode power supplies, to these devices in the analysis. (California IOUs, No. 43 at 

p. 5) NEEP made similar suggestions and stated that DOE should examine whether 

technologies can be applied across multiple product classes. (NEEP, No. 51 at p. 2) 

However, CEA urged DOE to account for the differences in battery chemistries and 

determine the appropriateness of given technologies for certain applications. CEA added 

that DOE must consider how battery technologies could be impacted by new efficiency 

requirements. (CEA, No. 48 at p. 2) Motorola expressed similar concerns and noted that 

although certain battery chemistries are less efficient, those chemistries may have other 

inherently important features like wider temperature range operations and improved 

cycle-life. Motorola insisted that these things should be considered when DOE conducts 

its technical and economic analyses. (Motorola, No. 50 at p. 2) Stanley Black and Decker 

added that DOE should not assume that additional utility is desirable as it will likely 

cause an increase in cost to the consumer. (SBD, Pub. Mtg. Tr., No, 37 at pp. 147-148) 

Finally, Lester commented that transformer-based chargers are more reliable, durable and 

provide batteries with a much longer life expectancy. Lester added that these chargers are 

often preferable to more efficient switch-mode chargers in industrial applications. 

(Lester, No. 52 at p. 2) Lester did not include any additional data to corroborate their 

statements regarding increased durability for battery chargers that are transformer-based 

and the life expectancy for batteries that use such chargers. 

180 
 

DOE clarifies that all technology options that are not eliminated in the screening 

analysis (section IV.B) become design options that are considered in the engineering 

analysis. As most CSLs are based on actual teardowns of units manufactured and sold in 

today’s battery charger market, DOE did not control which design options were used at 

each CSL. No technology options were preemptively eliminated from use with a 

particular product class. Similarly, if products are being manufactured and sold, DOE 

believes that fact indicates the absence of any significant loss in utility, such as an 

extremely limited operating temperature range or shortened cycle-life. Therefore, DOE 

believes that all CSLs can be met with technologies that are feasible and that fit the 

intended application. 

For the max-tech designs, which are not commercially available, DOE developed 

these levels in part with a focus on maintaining product utility as projected energy 

efficiency improved. Although some features, such as decreased charge time, were 

considered as added utilities, DOE did not assign any monetary value to such features. 

Additionally, DOE did not assume that such features were undesirable, particularly if the 

incremental improvement in performance causes a significant savings in energy costs. 

Finally, DOE appreciates the need to consider durability, reliability, and other 

performance and utility related features that affect consumer behavior. On these issues, 

DOE seeks information, including substantive data, to help it assess these factors in 

consumer products. 

181 
 

h. Cost Model 

Today’s NOPR continues to apply the same approach used in the preliminary 

analysis to generate the manufacturer selling prices (MSPs) for the engineering analysis. 

For those product classes other than product classes 1 and 10, DOE’s MSPs rely on the 

teardown results obtained from iSuppli. The bills of materials provided by iSuppli were 

multiplied by a markup that depended on product class. For those product classes for 

which DOE could not estimate MSPs using the iSuppli teardowns -- product classes 1 

and 10 -- DOE relied on aggregate manufacturer interview data, which projected that 

economic savings would accrue through the max-tech level in the preliminary analysis. 

Additional details regarding the cost model and the markups assumed for each 

product class are presented in TSD chapter 5. 

i. Battery Charger Engineering Results 

The results of the engineering analysis are reported as cost-efficiency data (or 

“curves”) in the form of MSP (in dollars) versus unit energy consumption (in kWh/yr). 

These data form the basis for the NOPR analyses. This section illustrates the results that 

DOE obtained for all 10 product classes in its NOPR engineering analysis. 

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Table IV-16 Product Class 1 (Inductive Chargers) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy 

(Wh) 26.7 19.3 10.8 5.9 

Maintenance Mode 

Power (W) 1.2 0.8 0.4 0.2 

No-Battery Mode 

Power (W) 0.5 0.4 0.2 0.1 

Off-Mode Power 

(W) 0.0 0.0 0.0 0.0 

Unit Energy 

Consumption 

(kWh/yr) 

8.73 6.10 3.04 1.29 

MSP [$] $2.05 $2.30 $2.80 $6.80 

In response to the engineering results that DOE provided in the preliminary 

analysis for product class 1, DOE received one comment from Philips. Philips publicly 

submitted estimates of “what the consumer pays,” for CSLs 0, 1, 2, and 3 for product 

class 1. Philips suggested that those values would be $8, $10, $15, and $24, respectively. 

(Philips, No. 43 at p. 2) In its preliminary analysis, DOE proposed MSPs for product 

class 1 to be: $2.05, $2.22, $2.45, $2.60, for CSLs 0 through 3 respectively. Although 

DOE appreciates the feedback provided by Philips, it is vastly different from the 

information gathered on manufacturer interviews. DOE believes this discrepancy is 

partially due to a misinterpretation of the term MSP. The values that Philips provided, as 

it has described them, would correspond to what DOE considers a retail price and not an 

MSP. DOE has revised its MSPs for product class 1 according to the data obtained from 

manufacturers on interviews for the NOPR. 

183 
 

 

 

 

 

 

 

Table IV-17 Product Class 2 (Low-Energy, Low-Voltage) Engineering Analysis 

Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

CSL 

Description Baseline Intermediate 2nd Intermediate Best in Market Max Tech 

24 Hour 

Energy (Wh) 46.5 36.9 19.7 8.2 6.9 

Maintenance 

Mode Power 

(W) 

1.8 1.4 0.5 0.1 0.04 

No-Battery 

Mode Power 

(W) 

0.70 0.30 0.08 0.08 0.05 

Off-Mode 

Power (W) 0.0 0.0 0.0 0.0 0.0 

Unit Energy 

Consumption 

(kWh/yr) 

8.66 6.47 2.86 1.03 0.81 

MSP [$] $0.62 $0.71 $2.13 $3.84 $5.72 

DOE did not receive any specific comments on its product class 2 engineering 

results in the preliminary analysis, but its revised results are presented in Table IV-17. 

Table IV-18 Product Class 3 (Low-Energy, Medium-Voltage) Engineering Analysis 

Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 123.0 53.6 17.0 15.9 

Maintenance Mode 

Power (W) 4.5 1.8 0.3 0.3 

No-Battery Mode 

Power (W) 3.5 1.0 0.2 0.2 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy 

Consumption (kWh/yr) 11.90 4.68 0.79 0.75 

MSP [$] $0.77 $1.98 $5.47 $5.51 

DOE did not receive any specific comments on its product class 3 engineering 

results in the preliminary analysis, but its revised results are presented in Table IV-18. 

184 
 

 

 

 

 

 

Table IV-19 Product Class 4 (Low-Energy, High-Voltage) Engineering Analysis 

Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 167.5 52.6 39.1 27.2 

Maintenance Mode Power 

(W) 5.9 1.4 0.5 0.4 

No-Battery Mode Power 

(W) 2.2 1.4 0.3 0.3 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 37.73 9.91 4.57 3.01 

MSP [$] $3.79 $6.76 $12.71 $18.34 

DOE did not receive any specific comments on its product class 4 engineering 

results in the preliminary analysis, but its revised results are presented in Table IV-19. 

Table IV-20 Product Class 5 (Medium-Energy, Low-Voltage) Engineering Analysis 

Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 2036.9 1647.3 1195.5 1180.0 

Maintenance Mode Power 

(W) 21.2 11.9 8.0 0.0 

No-Battery Mode Power 

(W) 20.1 11.6 4.2 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 84.60 56.09 29.26 15.35 

Incremental MSP [$] $18.48 $21.71 $15.69 $127.00 

185 
 

 

 

DOE did not receive any specific comments on its product class 5 engineering 

results in the preliminary analysis, but its revised results are presented in Table IV-20. 

Table IV-21 Product Class 6 (Medium-Energy, High-Voltage) Engineering Analysis 

Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 891.6 786.1 561.0 536.4 

Maintenance Mode Power 

(W) 10.6 6.0 4.0 0.0 

No-Battery Mode Power 

(W) 10.0 5.8 2.1 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 120.60 81.72 38.33 16.79 

Incremental MSP [$] $18.48 $21.71 $15.69 $127.00 

For product class 6, DOE performed additional product testing for the NOPR, but 

did not obtain a complete data set upon which to base its engineering analysis. This 

situation was due in large part to DOE’s inability to locate products with sufficiently 

similar battery energies and the fact that the products tested did not span a significant 

range of performance. DOE’s test data for this product class are available in chapter 5 of 

the accompanying TSD. In order to develop an engineering analysis for this product 

class, DOE relied on, among other things, the results gleaned from product class 5, 

interviews with manufacturers, and its limited test data from product class 6. 

The difference between product class 5 and product class 6 is the range of 

voltages that are covered. Product class 5 covers low-voltage (less than 20 V) and 

186 
 

medium energy (100 Wh to 3,000 Wh) products, while product class 6 covers highvoltage (greater than or equal to 20 V) and medium energy (100 Wh to 3,000 Wh) 

products. The representative unit examined for product class 5 is a 12 V, 800 Wh battery 

charger, while the representative unit analyzed for product class 6 is a 24 V, 400 Wh 

battery charger. Despite the change in voltage, DOE believes that similar technology 

options and battery charging strategies are available in both classes. Both chargers are 

used with relatively large sealed-lead acid batteries in products like wheelchairs, electric 

scooters, and electric lawn mowers. However, since the battery chargers in product class 

6 work with higher voltages, current can be reduced for the same output power, which 

creates the potential for making these devices slightly more efficient because I2

R losses41 

will be reduced. 

For the NOPR, DOE examined its product class 5 results and analyzed how the 

performance may be impacted if similar technologies are used. The resulting performance 

parameters are shown in Table IV-21Table IV.21. To account for the projected variation 

in energy consumption, DOE used information on charge time and maintenance mode 

power to adjust the corresponding values for 24-hour energy. Additionally, DOE 

discussed with manufacturers about how costs may differ in manufacturing a 12 V 

(product class 5) charger versus a 24 V (product class 6) charger. Manufacturers 

indicated that, holding constant all other factors, there would likely be minimal change, if 

any, in the cost. Therefore, because DOE scaled performance assuming that the designs 

for corresponding CSLs in each product class used the same design options and only 

41 In electrical circuits, I2

R losses manifests themselves as heat and are the result of high levels of current 

flow through a device. 

187 
 

 

 

differed in voltage, DOE did not scale costs from product class 5. Rather than scaling the 

product class 5 costs, DOE used the same MSP’s for product class 6 that were developed 

from iSuppli tear down data for product class 5. DOE believes these costs are an accurate 

representation of the MSPs and seeks comment on its methodology in scaling the results 

of product class 5 to product class 6, including the decision to hold MSPs constant. 

Table IV-22 Product Class 7 (High-Energy) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 

CSL Description Baseline Intermediate Max Tech 

24 Hour Energy (Wh) 5884.2 5311.1 4860.0 

Maintenance Mode 

Power (W) 10.0 3.3 2.6 

No-Battery Mode Power 

(W) 0.0 1.5 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 

Unit Energy 

Consumption (kWh/yr) 255.05 191.74 131.44 

Incremental MSP [$] $88.07 $60.86 $164.14 

DOE did not receive any specific comments on its product class 7 results in the 

preliminary analysis, but its revised results are presented in Table IV-22. 

188 
 

 

 

 

Table IV-23 Product Class 8 (Low-Voltage DC Input) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 10.4 8.4 3.7 3.1 

Maintenance Mode Power 

(W) 0.3 0.2 0.1 0.04 

No-Battery Mode Power 

(W) 0.0 0.0 0.0 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 0.90 0.66 0.24 0.19 

MSP [$] $5.90 $3.26 $5.77 $5.95 

Product class 8 (e.g. MP3 players and smartphones) consists of devices that 

charge with a DC input of less than 9 V, which is mostly those products that charge via 

USB connections. When DOE analyzed this product class it tested and tore down 3 

devices, one for CSL 0, 1, and 2; and all of which were MP3 players. 

DOE’s analysis projects a significant drop in MSP from CSL 0 to CSL 1. See 

Table IV-23Table IV.23. Because of this drop, DOE tentatively believes that at least one 

of its trial standard levels for this product class meets DOE’s criteria for being 

economically justified and technologically feasible. However, the baseline unit MSP for 

this analysis may be inflated due to the cost of the particular integrated circuit used in that 

unit. The integrated circuit used in this device performs additional functions besides 

battery charging and constitutes a significant portion of the bill of materials generated by 

iSuppli. DOE was unable to determine what portion of the integrated circuit was 

dedicated to battery charging and therefore, kept the entire cost of the component in its 

bill of materials. Because of this factor and the minimal differences in energy 

189 
 

 

consumption between each CSL for product class 8, DOE is considering an alternative 

approach in addition to its proposed standard. Both the proposed standard and the 

alternative approach are outlined in 0I.C and, as with all other product class data, DOE 

seeks comment on its MSP projections for product class data. 

Table IV-24 Product Class 9 (High-Voltage DC Input) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 

CSL Description Baseline Intermediate Best in Market 

24 Hour Energy (Wh) 48.1 13.5 8.1 

Maintenance Mode 

Power (W) 1.8 0.2 0.2 

No-Battery Mode Power 

(W) 0.0 0.1 0.1 

Off-Mode Power (W) 0.0 0.0 0.0 

Unit Energy 

Consumption (kWh/yr) 0.79 0.26 0.13 

MSP [$] $1.94 $2.77 $3.02 

For the preliminary analysis, DOE scaled the results of other product classes to 

obtain results for product class 9. The results of DOE’s revised analysis, based on test 

and teardown results, are shown in Table IV-24. 

190 
 

 

 

Table IV-25 Product Class 10 (AC Input, AC Output) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy 

(Wh) - - - -

Maintenance Mode 

Power (W) 2.2 0.7 0.5 0.2 

No-Battery Mode 

Power (W) 0.0 0.0 0.0 0.0 

Off-Mode Power 

(W) 0.0 0.0 0.0 0.0 

Unit Energy 

Consumption 

(kWh/yr) 

19.27 6.13 4.00 1.50 

Incremental Unit 

Energy 

Consumption 

(kWh/yr) 

- 13.14 2.13 2.50 

MSP [$] $2.76 $3.93 $4.25 $4.64 

As discussed previously, DOE believes that the engineering analysis results it 

developed in the preliminary analysis using manufacturer-supplied data provide an 

appropriate estimate of the cost-versus-UEC (or maintenance mode power) relationship 

for the battery charger embedded within a UPS. Also as discussed previously, DOE 

believes that this relationship is appropriate for UPSs, regardless of whether they have 

AVR. Consequently, DOE has used one set of engineering data, presented in Table IV-25 

above, in all of the subsequent analyses (e.g. the LCC and NIA). DOE contends that this 

is an accurate approach because the technologies available in designing a battery charger 

used within a UPS are the same whether or not that UPS has AVR. The corresponding 

costs for these technologies would also result in the same MSP for the battery charger as 

a component of the UPS. 

Finally, in the preliminary analysis, DOE developed cost-efficiency curves based 

on both manufacturer interviews and when possible, test and teardown results. As a result 

191 
 

 

 

of some differences in these curves, NEEP suggested that DOE should reconcile 

differences in the results obtained from manufacturer data and from teardowns. (NEEP, 

No. 51 at p. 4) 

The data obtained from teardowns that was available at the time of manufacturer 

interviews was included in the interview guide and discussed at those meetings. DOE 

continued to conduct teardowns after those meetings and has added data that will be 

available for public comment. Through that process, DOE seeks to continue to refine its 

analysis and to mitigate any differences between the teardown and manufacturer data. 

j. Scaling of Battery Charger Candidate Standard Levels 

To establish its proposed energy conservation standards for products with all 

battery energies and battery voltages within a product class, DOE developed a UEC 

scaling approach. After developing the engineering analysis results for the representative 

units, DOE had to determine a methodology for extending the UEC at each CSL to all 

other ratings not directly analyzed for a given product class. DOE had initially raised the 

possibility of using UEC as a function of battery energy. DOE also indicated that it might 

base this UEC function on the test data that had been obtained up through the preliminary 

analysis.42 

42 At the preliminary analysis public meeting, DOE handed out a supplemental slide deck, which outlined 

preliminary ideas to scaling UEC based on test data and with respect to battery energy. See these slides 

available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external_preliminaryanalys 

is_public_mtg.html 

192 
 

 

 

 

Numerous interested parties submitted comments regarding the potential scaling 

methodology. AHAM generally supported DOE’s proposed approach in which the UEC 

was scaled with regards to battery energy but suggested that DOE hold UEC constant 

below a certain value of battery energy because the fixed losses in these low-energy, 

lower power units begin to dominate and more stringent standards risk becoming overly 

restrictive on the ability of manufacturers to design useful products for consumers. 

AHAM also suggested that DOE consider UEC as a function of battery voltage. (AHAM, 

No. 44 at p. 9) PTI made similar suggestions and commented that it may be appropriate 

for UEC to remain constant for battery energies below the representative unit value. (PTI, 

No. 47 at p. 9) 

The California IOUs suggested applying a single scaling relationship for active 

mode energy for product classes 2 through 7. For battery chargers with very high battery 

energies, such as those used in golf cars, the California IOUs believed that a flat or 

constant standard might be appropriate. (California IOUs, No. 43 at pp. 3-4) The 

California IOUs also argued that a potential scaling approach based on the test results of 

multi-capacity battery chargers would be inaccurate and argued that it should be dropped. 

They indicated that a scaling relationship based on such products would be demonstrative 

of products that are capable of using multiple batteries rather than products representative 

of the bulk of battery chargers, which are designed for a single specific battery. 

(California IOUs, No. 43 at p. 6) Finally, these commenters asserted that maintenance 

mode power and no-battery mode power should be regulated independently of battery 

energy, as many of the same design options are applicable to small and large energy 

193 
 

battery chargers. Because of these similarities, the California IOUs asserted that all 

battery chargers, regardless of battery size, should be capable of the same level of 

performance in those modes of operation and DOE should assume this value is constant 

irrespective of battery energy. (California IOUs, No. 43, at p. 7) 

DOE considered the comments it received and refined its scaling approach for the 

NOPR. In particular, DOE evaluated scaling approaches based on the battery voltage and 

the battery energy and found that the latter is a more appropriate way to model its scaling 

methodology. When DOE examined its test results, it noted a much weaker correlation 

between battery voltage and UEC than between battery energy and UEC. See TSD, 

appendix 5C. DOE also noticed from its test results that the individual performance 

parameters, such as maintenance mode power, no-battery mode power, and 24-hour 

energy, could be formulated as functions of battery energy. See TSD, Chapter 5. For this 

reason, DOE did not follow the recommendation of the California IOUs to leave some 

performance parameters constant. 

Additionally, DOE is proposing to scale UEC as a function of battery energy for 

golf cars. The TSD shows that, as battery energy increases, so too does the UEC because 

more energy is needed to charge the larger battery. See TSD, chapter 5 (discussing test 

results related to product classes 5, 6, and 7 that demonstrate the linear relationship 

between increasing battery energy and UEC). DOE also found that this trend was true for 

product class 10 devices (UPSs), which incorporate lead-acid batteries. The details on the 

scaling methodology for these products are also available in TSD chapter 5. 

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In contrast, for product classes 1 and 8 DOE is proposing that all devices within 

those product classes be required to meet one nominal standard. For these product 

classes, battery energy appeared to have little impact on the UEC’s that were calculated. 

Accordingly, to account for these differences, DOE is tentatively proposing two separate 

approaches for scaling UEC based on these test results -- i.e. one that scales with battery 

energy and another that remains at a single, nominal level. 

DOE’s scaling approach for the NOPR relies heavily on the test data that it has 

gathered throughout the rulemaking process. DOE examined each performance parameter 

individually and, when possible, looked at groups of product class test results. For 

example, product classes 2, 3, and 4 are similar products that use similar technologies and 

span the same battery energy ratings. In these cases, DOE examined all of these test 

results together. DOE also developed regression equations for each of the performance 

parameters needed to calculate UEC and ultimately, aggregated those equations with 

assumptions about usage profiles for each product class. That is, DOE examined test 

results for maintenance mode power, no-battery mode power, and 24-hour energy 

individually and relative to battery energy. From these data, DOE derived equations for 

each parameter as it relates to battery energy. Because each equation was a function of 

the same parameter, battery energy, each one could be combined with assumptions about 

product usage to develop a single UEC equation that was also a function of battery 

energy. 

195 
 

For product classes other than product classes 1, 8, and 10, DOE developed 

equations that use different slopes for different CSLs. For higher CSL equations in a 

given product class, the slope of the UEC line becomes smaller, which means that the 

line describing UEC versus battery energy becomes flatter. DOE found that when it 

filtered its test results and examined products with similar technologies (e.g. lithium-ion 

chemistry batteries) spanning a range of battery energy levels, the slope of the line 

generated for 24-hour energy correlated to the inverse of 24-hour efficiency, which is the 

ratio of measured battery energy to 24-hour energy, expressed as a percentage. Thus, as 

products became more efficient, the slope of the equation used to describe UEC versus 

battery energy became flatter. 

Finally, DOE adopted the suggestions offered by AHAM and PTI regarding the 

treatment of small battery energies. When DOE was developing its CSL equations for 

UEC, it found during testing that the correlation between points at low battery energies 

was much worse than for the rest of the range of battery energy, which indicated that the 

initial equations DOE had initially planned to use did not match the test results. To 

address this situation, DOE generated a boundary condition for its CSL equations, which 

essentially flattens the UEC below a certain threshold of battery energy to recognize that 

below certain values, fixed power components of UEC, such as maintenance mode 

power, dominate UEC. Making this change helped DOE to create a better-fitting equation 

to account for these types of conditions to ensure that any standards that are set better 

reflect the particular characteristics of a given product. 

196 
 

 

For additional details and the exact CSL equations developed for each product 

class, please see TSD chapter 5. 

D. Markups to Determine Product Price 

The markups analysis develops appropriate markups in the distribution chain to 

convert the MSP estimates derived in the engineering analysis to consumer prices. At 

each step in the distribution chain, companies mark up the price of the product to cover 

business costs and profit margin. Given the variety of products that use battery chargers 

and EPSs, distribution varies depending on the product class and application. As such, 

DOE assumed that the dominant path to market establishes the retail price and, thus, the 

composite markup for a given application. The markups applied to end-use products that 

use battery chargers and EPSs are approximations of the battery charger and EPS 

markups. 

In the case of battery chargers and EPSs, the dominant path to market typically 

involves an end-use product manufacturer (i.e. OEM) and retailer. DOE developed OEM 

and retailer markups by examining annual financial filings, such as Securities and 

Exchange Commission (SEC) 10-K reports, from more than 80 publicly traded OEMs, 

retailers, and distributors engaged in the manufacturing and/or sales of consumer 

applications that use battery chargers or EPSs. 

Retail prices for EPSs in product class H (e.g. EPSs for amateur radios) were 

readily available, as these devices are not typically bundled with a consumer application. 

197 
 

Thus, using these retail prices and the component costs determined in its teardown 

analysis, DOE was able to derive markups for EPSs in product class H. 

DOE typically calculates two markups for each product in the markups analysis. 

These are: a markup applied to the baseline component of a product’s cost (referred to as 

a baseline markup) and a markup applied to the incremental cost increase that results 

from standards (referred to as an incremental markup). The incremental markup relates 

the change in the MSP of higher-efficiency models (the incremental cost increase) to the 

change in the retailer’s selling price. 

In the preliminary analysis public meeting, PTI commented that DOE neglected to 

take into account situations in which an EPS is purchased by a battery charger 

manufacturer to be integrated into a battery charger. In these cases, the completed battery 

charger (with integrated EPS) is sold to an OEM to be packaged with an end-use 

application. Philips explained that three markups would be applied to the MSP of these 

EPSs: one by the battery charger manufacturer, one by the OEM, and one by the retailer. 

(PTI, Pub. Mtg. Tr., No. 57 at p. 316) 

DOE agrees that, for situations in which this additional step occurs, the battery 

charger manufacturer would need to cover its costs and profit margin with a markup. 

However, given DOE’s assumption that the dominant path to market sets the final 

product price, it is only for those classes of EPS for which this is the most common path 

to market that the final product price would be affected. DOE believes that this situation 

198 
 

would primarily apply to EPSs that exclusively provide power to a stand-alone battery 

charger, such as EPSs for power tools, garden-care equipment, and other applications 

with detachable batteries. As explained in section IV.A.1 above, DOE did not quantify 

savings for EPSs that cannot directly power an end-use consumer product (i.e., EPSs that 

only provide power to a battery charger), and, therefore, DOE did not quantify markups 

for these "indirect operation" EPSs. The remaining EPSs that power battery chargers can 

also power an application directly, meaning that the EPS is not exclusively a component 

of the battery charger. Instead, it is a component of the application itself, e.g., a notebook 

computer. In those cases, DOE assumes that it is more common that the OEM, rather than 

the battery charger manufacturer, sources the EPS, making a third markup unnecessary. 

AHAM commented that engineering costs to integrate a battery charger into an 

end-use consumer product are typically higher than those for an EPS, and it may be 

inappropriate to apply an incremental markup to battery chargers at the OEM stage that is 

lower than the baseline markup. (AHAM, Pub. Mtg. Tr., No. 57 at p. 325) 

To calculate incremental markups, DOE subtracted “selling, general, and 

administrative expenses” (SG&A) from net profit to yield operating profit. Dividing this 

amount by the revenue value yields an incremental markup. By subtracting SG&A from 

net profit, DOE assumes that indirect costs (such as indirect labor and overhead) remain 

constant when a product becomes more efficient and, therefore, do not need to be 

accounted for in the incremental markup. Given that SG&A does not include research 

and development (R&D) or engineering costs, any direct labor, R&D, engineering, and 

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other direct expenses that OEMs incur when integrating a more efficient battery charger 

into an application are assumed to be recovered through the incremental markup. 

Chapter 6 of the TSD provides additional detail on the markups analysis. 

E. Energy Use Analysis 

DOE estimated the annual energy use of products in the field as they are used by 

consumers. The energy use analysis provides the basis for other analyses, particularly 

assessments of the energy savings and the savings in consumer operating costs that could 

result from DOE’s adoption of new or amended standards. While the DOE test procedure 

provides standardized results that can serve as the basis for comparing the performance of 

different products used under the same conditions, the energy use analysis seeks to 

capture the range of operating conditions for battery chargers and EPSs in the United 

States. 

Battery chargers and EPSs are power conversion devices that transform input 

voltage to a suitable voltage for the end-use application or battery they are powering. A 

portion of the energy that flows into a battery charger or EPS flows out to a battery or 

end-use product and, thus, cannot be considered to be consumed by the battery charger or 

EPS. However, to provide the necessary output power, other factors contribute to battery 

charger and EPS energy consumption -- e.g. internal losses and overhead circuitry.43 

Therefore, the traditional method for calculating energy consumption -- by measuring the 

43 Internal losses are energy losses that occur during the power conversion process. Overhead circuitry 

refers to circuits and other components of the EPS, such as monitoring circuits, logic circuits, and LED 

indicator lights, that consume power but do not directly contribute power to the end-use application. 

200 
 

energy a product draws from mains while performing its intended function(s) -- is not 

appropriate for battery chargers and EPSs. Instead, DOE considered energy consumption 

to be the energy dissipated by the battery charger or EPS (losses) and not delivered to the 

end-use product or battery as a more accurate means to determine the energy 

consumption of these products. Once the energy and power requirements of those enduse products and batteries were determined, DOE considered them fixed, and DOE 

analyzed only how standards would affect the energy consumption of the battery chargers 

and EPSs themselves. 

DOE applied a single usage profile for each application to calculate the unit 

energy consumption for battery chargers and EPSs. However, usage varies by application 

and among users. DOE examined the usage profiles of multiple user types for 

applications where usage varies widely (for example, a light user and a heavy user or an 

amateur user and professional user). AHAM suggested that DOE revisit, and possibly 

revise, its usage profile assumptions for the NOPR stage analyses. (AHAM, No. 42 at p. 

8) As new information became available and analytical methodologies were altered, DOE 

revisited its usage profile assumptions to ensure the accuracy of its NOPR analyses. As 

part of its NOPR analysis, DOE re-examined its initial usage profiles in the following 

ways: 

 New applications were added or existing applications were combined; 

 Existing applications were divided into applications used in a commercial 

setting and applications used in a residential setting; 

201 
 New sources (such as published studies or data from stakeholders) were made 

available or new data were provided to DOE; and/or 

 Tested charge times indicated that DOE’s usage profiles were in need of 

revision. 

DOE also explored high- and low-savings scenarios in an LCC sensitivity 

analysis. Values that varied in this sensitivity analysis included battery charger and EPS 

usage profiles and EPS loading points. Varying these values allowed DOE to account for 

uncertainty in the average usage profiles and explore the effect that usage variations 

might have on energy consumption, life-cycle cost, and payback. Additional information 

on this sensitivity analysis is contained in appendix 8B to the TSD. 

DOE does not assume the existence of a rebound effect, in which consumers 

would increase use in response to an increase in energy efficiency and resulting decrease 

in operating costs. For BCs and EPSs, DOE expects that, in light of the small amount of 

savings expected over the course of the year, the rebound effect is likely to be negligible 

because consumers are unlikely to notice the decrease in operating costs that would result 

from new standards for these products. 

At the preliminary analysis public meeting, PG&E, through its consultant Ecos, 

commented that DOE should adopt the simplified approach to battery charger usage 

profiles being pursued by California. It claimed that the wide variety of end-use 

applications and end users makes it infeasible to accurately characterize usage for battery 

Comment [A15]: Change recommended by 

OIRA. 

202 
 

 

 

chargers. It recommended instead that DOE assign all applications to one of two 

categories: those that are charged rarely (such as battery chargers for uninterruptible 

power supplies and other backup batteries) and those that are charged sometimes (all 

other battery chargers). (Ecos/PG&E, Pub. Mtg. Tr., No. 57 at p. 30) In a joint letter 

submitted to DOE, energy efficiency advocates echoed these sentiments and suggested 

that DOE group products into one of two possible general duty cycles: ‘charged some of 

the time’ and ‘almost always in maintenance mode.’” (PG&E, et al., No. 47 at p. 2) In the 

preliminary analysis public meeting, PTI commented that taking into account usage 

profiles to analyze annual energy consumption is the correct approach because it is the 

only way to express meaningful savings to the public. PTI reiterated its support for 

DOE’s proposed approach in its written comments, claiming that increased detail allows 

for a more accurate understanding of variations in use and a basis for estimating actual 

energy consumption. PTI also stated that it “believe[s] that the subsequent UEC 

calculation based upon usage patterns provides a meaningful measure of energy use.” 

(PTI, Pub. Mtg. Tr., No. 57 at p. 378 and No. 45 at pp. 7-8) AHAM supported the 

continued use of usage profiles in estimating unit energy consumption and emphasized 

that, because of their critical nature, usage profiles should be more exact, not simplified. 

(AHAM, Pub. Mtg. Tr., No. 57 at p. 376 and No. 42 at p. 8) 

In developing its usage profiles, DOE relied on empirical data for more than 40 

applications. These data primarily consisted of user surveys, metering studies, and 

stakeholder input. Collectively, the analyzed applications for which DOE has empirical 

usage data accounted for more than 80 percent of annual aggregate battery charger 

203 
energy use, because the available data focused mainly on the more common, highpowered, and high-use applications. Usage profiles for the remaining applications were 

derived from these known usage profiles. DOE recognizes that the calculation of usage 

profiles is not an exact science, but is confident that energy use and potential savings can 

be more accurately estimated if application-specific use is taken into account. Therefore, 

based on data and arguments presented to DOE to date, DOE is proposing to continue to 

use the same basic approach to battery charger usage profiles that it used in the 

preliminary analysis. 

Philips questioned DOE’s initial assumption during the preliminary analysis 

phase that seldom-used applications, such as beard and mustache trimmers, are plugged 

in, on average, one hour per day. Instead, Philips stated that such products are rarely 

charged and the potential energy savings from regulating battery chargers and EPSs that 

power these products would be very small. (Philips, Pub. Mtg. Tr., No. 57 at pp. 130­

131) AHAM commented that many of the products that DOE assumes to be charged for 

one hour per week, such as personal care products and other portable appliances, are 

typically charged less frequently. (AHAM, No. 42 at p. 6) 

DOE’s usage profiles are intended to represent an average usage scenario across 

all users, rather than any particular type of user. DOE recognizes that while many users 

likely have these products plugged in for less than one hour per day, others (specifically 

those with cradle chargers) tend to leave these products plugged in for more than one 

hour per day. Some users may rarely, if ever, unplug their chargers. Given these possible 

204 
 

 

variations in usage, DOE revisited its assumed usage profiles for personal care products 

and other infrequently charged products. DOE opted to leave its usage profiles for beard 

and mustache trimmers and hair clippers unchanged in the reference case, but also to 

explore high- and low-use scenarios in the LCC sensitivity analyses. Upon further 

analysis, DOE agrees with AHAM and Philips that some small, portable applications are 

charged, on average, less frequently than indicated in the preliminary analysis (1 hour per 

week). Thus, DOE reduced the amount of time in active and maintenance modes to 0.5 

hours per week for air mattress pumps, mixers, blenders, handheld GPSs, and residential 

portable printers. DOE also explored the effects of lower use for other applications in the 

LCC sensitivity analysis. 

Philips also suggested the following usage profile for battery chargers in product 

class 1 (inductive chargers for use in wet environments): 

1. Active + Maintenance = 17.25 hr/day 

2. Unplugged = 6.48 hr/day 

3. No Battery = 0.11 hr/day 

4. Off = 0 hr day 

5. Charges per day = 0.048 (Philips, No. 41 at p. 2) 

DOE’s usage profile from its preliminary analysis, which was provided by PG&E 

(Ecos Consulting, No. 30), assumed that all products in product class 1 are cradlecharged and, thus, are never unplugged. While DOE tentatively agrees with Philips that 

some users unplug their chargers once the product is charged, PG&E’s research suggests 

205 
 

 

 

that Philips overestimated the number of users who unplug between charges (and by 

extension, the amount of time the average unit spends unplugged). Thus, for the NOPR, 

DOE used an average of the usage profiles provided by PG&E and Philips for its 

reference case usage profile. This resulted in a usage profile that assumed those products 

spend some time in unplugged mode, but less than the time suggested by Philips. Highand low-use scenarios for the applications in product class 1 were explored in the LCC 

sensitivity analysis. 

Stanley Black & Decker commented that outdoor gardening appliances are 

typically used seasonally, and that the initial unit energy consumption values for these 

products that DOE had considered during the preliminary analysis phase should be 

reduced by half. It added, though, that DOE should maintain its lifetime assumptions 

from the preliminary analysis. (SBD, No. 44 at p. 1) DOE agrees that these products are 

typically used seasonally and notes that it had already accounted for seasonal use, as 

suggested by Stanley Black & Decker, when it created the usage profiles in the 

preliminary analysis. The usage profile that DOE used in the NOPR-stage analysis 

continues to apply a seasonal use assumption for these products. 

Cobra Electronics claimed that the typical residential two-way radio is charged 

less than once per week, since residential consumers tend to use these products a few 

times per year. (Cobra, No. 51 at p. 2) DOE agrees that residential use of two-way radios 

is likely to be infrequent, but also recognizes that many of the two-way radios used by 

residential users are also available to commercial users, who charge these products far 

206 
more frequently. In preparation of the NOPR analysis, DOE analyzed the energy use of 

the two-way radio application separately for those products charged in a residential 

setting and those products charged in a commercial setting. DOE assumed that two-way 

radios charged in a residential setting are charged infrequently, as was suggested by 

Cobra, while those charged in a commercial setting are charged more frequently. 

Lester commented that “the reduction in energy loss as estimated is overstated for 

golf cars due to mistaken assumptions about the duty cycle and corresponding energy 

use.” (Lester, No. 53 at p. 2) DOE remains confident in its assumptions for golf car use, 

which are derived from manufacturer input. As it did for two-way radios, DOE divided 

the golf car application into two distinct applications: golf cars charged in the residential 

sector, and golf cars charged in the commercial sector. DOE’s residential usage profile 

assumes less time in active use and, therefore, fewer charges per day, while DOE’s 

commercial usage profile assumes heavier use. Given this heavier use, DOE assumed that 

commercial golf cars spend less time in maintenance mode, as they are typically used 

more frequently, and for longer durations, than are residential golf cars. 

In response to comments from manufacturers that battery chargers in product 

class 2 that meet the baseline efficiency level may be slow chargers and designed for less 

frequent use or increased time in maintenance mode, the California IOUs commented that 

these products may not always be used infrequently, but rather can be used by some 

segments of the population on a daily basis. (California IOUs, No. 43 at p. 6) 

207 
 

DOE’s usage profiles are designed to take into account the average use of all 

users, subject to the constraints of a given battery charger, such as a slow charge rate or 

quick discharge rate. DOE believes that it has accurately estimated the usage profiles of 

handheld vacuum cleaners (which are in no battery mode, on average, six minutes per 

day), cordless phones (which are in no battery mode, on average, more than two hours 

per day), and the usage profiles for the remaining applications in its analysis. These usage 

profiles reflect average use, and, therefore, account for infrequent and frequent users of 

these applications. 

DOE recognizes that there is considerable variation in how individual consumers 

use battery chargers and EPSs for specific applications. This leads to some uncertainty 

and disagreement over what an appropriate usage profile is for specific applications, such 

as power tools, personal care products, and other applications. In all cases, DOE used the 

best available data to derive reference case usage profiles for each application. For 

applications with highly variable use, DOE explored high- and low-use scenarios in an 

LCC sensitivity analysis. DOE continues to seek data and substantiated recommendations 

that will allow it to further refine its reference case usage profiles. (See Issue 12 under 

“Issues on Which DOE Seeks Comment” in section VII.E of this notice.) 

Chapter 7 of the TSD provides additional detail on the energy use analysis. 

F. Life-Cycle Cost and Payback Period Analyses 

This section describes the LCC and payback period analyses and the spreadsheet 

model DOE used for analyzing the economic impacts of possible standards on individual 

208 
 

 

 

consumers. Details of the spreadsheet model, and of all the inputs to the LCC and PBP 

analyses, are contained in chapter 8 and appendix 8A of the TSD. DOE conducted the 

LCC and PBP analyses using a spreadsheet model developed in Microsoft Excel. When 

combined with Crystal Ball (a commercially-available software program), the LCC and 

PBP model generates a Monte Carlo simulation44 to perform the analysis by 

incorporating uncertainty and variability considerations. 

The LCC analysis estimates the impact of a standard on consumers by calculating 

the net cost of a battery charger or EPS under a base-case scenario (in which no new 

energy conservation standard is in effect) and under a standards-case scenario (in which 

the proposed energy conservation standard is applied). The base-case scenario is 

determined by the efficiency level that a sampled consumer currently purchases, which 

may be above the baseline efficiency level. The life-cycle cost of a particular battery 

charger or EPS is composed of the total installed cost (which includes manufacturer 

selling price, distribution chain markups, sales taxes, and any installation cost), operating 

expenses (energy and any maintenance costs), product lifetime, and discount rate. As 

noted in the preliminary analysis, DOE considers installation costs to be zero for battery 

chargers and EPSs. 

The payback period is the change in purchase expense due to a more stringent 

energy conservation standard, divided by the change in annual operating cost that results 

from the standard. Stated more simply, the payback period is the time period it takes to 

44 Monte Carlo simulations model uncertainty by utilizing probability distributions instead of single values 

for certain inputs and variables. 

209 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

recoup the increased purchase cost of a more-efficient product through energy savings. 

DOE expresses this period in years. 

Table IV-26Table IV.26 summarizes the approach and data that DOE used to 

derive the inputs to the LCC and PBP calculations for the preliminary analysis and the 

changes made for today’s proposed rule. The following sections discuss these inputs and 

comments DOE received regarding its presentation of the LCC and PBP analyses in the 

preliminary analysis, as well as DOE’s responses thereto. 

Table IV-26 Summary of Inputs and Key Assumptions Used in the Preliminary 

Analysis and NOPR LCC Analyses 

Inputs September 2010 Preliminary Analysis Changes for the Proposed Rule 

Manufacturer 

Selling Price 

Derived from the Engineering Analysis 

through manufacturer interviews (battery 

chargers and EPSs) and test/teardown results 

(battery chargers only). 

Used same methodology, but 

conducted additional test/teardowns 

and interviews. 

Markups Considered various distribution channel 

pathways for different applications. Applied a 

reduced “incremental” markup to the portion 

of the product price exceeding the baseline 

price. 

Used same methodology with 

additional data sources. See chapter 

6 of the TSD for details. 

Sales Tax Derived weighted-average tax values for each 

Census division and large State from data 

provided by the Sales Tax Clearinghouse.1 

Updated the sales tax using the latest 

information from the Sales Tax 

Clearinghouse.2 

Installation Cost Assumed to be zero. No change. 

Maintenance Cost Assumed to be zero. Included the cost of repurchasing a 

battery that fails within the 

application lifetime. Accounted for 

the incremental cost of a lithium ion 

battery over a nickel chemistry 

battery, only for CSL 2 or higher. 

Unit Energy 

Consumption 

Determined for each application based on 

estimated loading points and usage profiles 

(for EPSs), and battery characteristics and 

usage profiles (for battery chargers). 

Used same methodology with 

additional data sources. See chapter 

7 of the TSD for details. 

Electricity Prices Price: Based on EIA’s 2008 Form EIA-861 

data.3 

Variability: Regional energy prices 

determined for 13 regions. 

Price: No change. The 2008 Form 

EIA-861 is the most current source 

available. DOE also considered 

subgroup analyses using electricity 

prices for low-income consumers 

and top tier marginal price 

consumers. 

Variability: No change. 

Electricity Price 

Trends 

Forecasted with EIA’s Annual Energy 

Outlook Early Release 2010.4 

Updated with EIA’s Annual Energy 

Outlook 2010.5 

210 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Lifetime Determined for each application based on 

multiple data sources. 

Used same methodology with 

additional data sources. See chapter 

3 of the TSD for details. 

Discount Rate Residential: Approach based on the finance 

cost of raising funds to purchase and operate 

battery chargers or EPSs either through the 

financial cost of any debt incurred (based on 

the Federal Reserve’s Survey of Consumer 

Finances data6

 for 1989, 1992, 1995, 1998, 

2001, 2004, and 2007) or the opportunity cost 

of any equity used. Time-series data was 

based on arithmetic means from 1979-2009. 

Commercial: Derived discount rates using the 

cost of capital of publicly-traded firms based 

on data from Damodaran Online,7

 the Value 

Line Investment survey,8

 and the Office of 

Management and Budget (OMB) Circular No. 

A-94.9 

Residential: DOE updated the 

calculations to consider the 

geometric means for all time-series 

data from 1980-2009. 

Commercial: DOE updated the riskfree rate to use a 40-year average 

return on 10-year treasury notes, as 

reported by the U.S. Federal 

Reserve.10 DOE updated the equity 

risk premium to use the geometric 

average return on the S&P 500 over 

a 40-year time period. 

Sectors Analyzed All reference case results used the residential 

sector inputs. Commercial sector results were 

presented in Appendix 8B as a sensitivity 

analysis. 

All reference case results represent a 

weighted average of the residential 

and commercial sectors. 

Base Case Market All market efficiency distributions were Where possible, DOE derived 

Efficiency constant across representative units and market efficiency distributions for 

Distribution product classes. Distributions were derived 

from test results. 

specific applications within a 

representative unit or product class. 1 The four large States are New York, California, Texas, and Florida. 2 Sales Tax Clearinghouse, Aggregate State Tax Rates. Available at: https://thestc.com/STRates.stm. 3

 U.S. Department of Energy. Energy Information Administration. Form EIA-861 Final Data File for 2008. 

November, 2010. Washington, D.C. Available at: 

http://www.eia.doe.gov/cneaf/electricity/page/eia861.html. 4 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2010 Early 

Release. March, 2010. Washington, D.C. Available at: http://www.eia.doe.gov/oiaf/aeo/. 5 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2010. 

November, 2010. Washington, D.C. Available at: http://www.eia.doe.gov/oiaf/aeo/. 6 The Federal Reserve Board, Survey of Consumer Finances 1989, 1992, 1995, 1998, 2001, 2004, 2007. 

Available at: http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html. 7

 Damodaran Online Data Page, Historical Returns on Stocks, Bonds and Bills-United States, 2010. 

Damodaran. 

Available at: http://pages.stern.nyu.edu/~adamodar. 8 Value Line. Value Line Investment Survey. 2010. Available at: http://www.valueline.com. 9 U.S. Office of Management and Budget. Circular No. A-94. Appendix C. 2009. Available at: 

http://www.whitehouse.gov/omb/circulars_a094_a94_appx-c/. 10 The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, Historical Data, 

Instrument: Treasury Constant Maturities, Maturity: 10-year, Frequency: Annual, Description: Market yield 

on U.S. Treasury securities at 10-year constant maturity, quoted on investment basis. Available at: 

http://www.federalreserve.gov/releases/H15/data.htm. 

1. Manufacturer Selling Price 

As in the preliminary analysis, DOE used a combination of test and teardown 

results and manufacturer interview results to develop manufacturer selling prices. DOE 

211 
 

 

 

 

conducted tests and teardowns on a large number of additional units and applications for 

the NOPR, and incorporated these findings into the MSP. Further detail on the MSPs can 

be found in chapter 5 of the TSD. 

Examination of historical price data for a number of appliances that have been 

subject to energy conservation standards indicates that an assumption of constant real 

prices and costs may overestimate long-term trends in appliance prices. Economic 

literature and historical data suggest that the real costs of these products may in fact trend 

downward over time according to “learning” or “experience” curves. On February 22, 

2011, DOE published a Notice of Data Availability (NODA, 76 FR 9696) stating that 

DOE may consider improving regulatory analysis by addressing equipment price trends. 

In the NODA, DOE proposed that when sufficiently long-term data are available on the 

cost or price trends for a given product, it would analyze the available data to forecast 

future trends. 

To forecast a price trend for the NOPR, DOE considered the experience curve 

approach, in which an experience rate parameter is derived using two historical data 

series on price and cumulative production, but in the absence of historical shipments of 

battery chargers and EPSs and of sufficient historical Producer Price Index (PPI) data for 

small electrical appliance manufacturing from the Bureau of Labor Statistics’ (BLS)45, 

DOE could not use this approach. This situation is partially due to the nature of EPS and 

battery charger design. EPSs and battery chargers are made up of many electrical 

45 Series ID PCU33521-33521; http://www.bls.gov/ppi/ 

212 
 

components whose size, cost, and performance rapidly change, which leads to relatively 

short design lifetimes. DOE also considered performing an exponential fit on the deflated 

AEO’s Projected Price Indexes that most narrowly include battery chargers and EPSs. 

However, DOE believes that these indexes are sufficiently broad that they may not 

accurately capture the trend for battery chargers and EPSs. Furthermore, battery chargers 

and EPSs are not typical consumer products; they are more like a commodity that OEMs 

purchase. 

Given the uncertainty, DOE is not incorporating product price changes into 

today’s NOPR. For the NIA, DOE also analyzed the sensitivity of results to three 

alternative battery chargers and EPSs price forecasts. Appendix 10-B of the NOPR TSD 

describes the derivation of alternative price forecasts. 

DOE requests comments on the most appropriate trend to use for real battery 

charger and EPS prices, both in the short run (to 2013) and the long run (2013-2042). 

2. Markups 

DOE applies a series of markups to the MSP to account for the various 

distribution chain markups applied to the analyzed product. These markups are evaluated 

for each application individually, depending on its path to market. Additionally, DOE 

splits its markups into “baseline” and “incremental” markups. The baseline markup is 

applied to the entire MSP of the baseline product. The incremental markups are then 

Comment [A16]: Changes recommended by 

OIRA. 

213 
 

 

applied to the marginal increase in MSP over the baseline’s MSP. Further detail on the 

markups can be found in chapter 6 of the TSD. 

3. Sales Tax 

As in the preliminary analysis, DOE obtained State and local sales tax data from 

the Sales Tax Clearinghouse. The data represented weighted averages that include county 

and city rates. DOE used the data to compute population-weighted average tax values for 

each Census division and four large States (New York, California, Texas, and Florida). 

For the NOPR, DOE retained this methodology and used updated sales tax data from the 

Sales Tax Clearinghouse.46 The U.S. Census Bureau population estimates used in the 

preliminary analysis are the most current data available.47 

4. Installation Cost 

As detailed in the preliminary analysis, DOE considered installation costs to be 

zero for battery chargers and EPSs because installation would typically entail a consumer 

simply unpacking the battery charger or EPS from the box in which it was sold and 

connecting the device to mains power and its associated product or battery. Because the 

cost of this “installation” (which may be considered temporary, as intermittently used 

devices might be unplugged for storage) is not quantifiable in dollar terms, DOE 

considered the installation cost to be zero. 

46 Sales Tax Clearinghouse, Aggregate State Tax Rates. https://thestc.com/STRates.stm. 47 The U.S. Census Bureau. Annual Estimates of the Population for the United States, Regions, States, and 

Puerto Rico: April 1, 2000 to July 1, 2009. http://www.census.gov/popest/states/tables/NST-EST2009­

01.xls. 

214 
5. Maintenance Cost 

In the preliminary analysis, DOE did not consider repair or maintenance costs for 

battery chargers or EPSs. In making this decision, DOE recognized that the service life of 

a battery charger or EPS typically exceeds that of the consumer product with which it is 

designed to operate. Thus, a consumer would not incur repair or maintenance costs for a 

battery charger or EPS. Also, if a battery charger or EPS failed, DOE expects that 

consumers would typically discard the battery charger or EPS and purchase a 

replacement. DOE received no comments challenging this assumption and has continued 

relying on this assumption for purposes of calculating the NOPR’s potential costs and 

benefits. 

Although DOE did not assume any repair or maintenance costs would apply 

generally to battery chargers or EPSs, DOE has considered including a maintenance cost 

for the replacement of lithium ion batteries in certain battery charger applications. 

Through conversations with manufacturers, DOE learned that such batteries would need 

replacing within the service life of the battery charger for certain applications based on 

the battery lifetime and the usage profile assigned to the application. Lithium ion batteries 

are marginally more expensive than batteries with nickel chemistries (e.g. nickel metalhydride or “Ni-MH”), as explained in chapter 5 of the TSD. DOE accounted for this 

marginal cost increase in these applications at CSLs that use lithium batteries. This 

maintenance cost only applied to applications where DOE believed the lifetime of the 

application would surpass the lifetime of the battery. DOE estimated the battery lifetime 

based on the total number of charges the battery could handle divided by the number of 

215 
 

charges per year projected for the application. DOE relied on data provided by 

manufacturers to estimate the total number of charges the battery could undergo before 

expiring. Further detail on maintenance costs can be found in chapter 8 of the TSD. 

6. Product Price Forecast 

As noted in section IV.F., to derive its central estimates DOE assumed no change 

in battery charger and EPS prices over the 2013-2042 period. In addition, DOE 

conducted a sensitivity analysis using three alternative price trends based on AEO 

indexes. These price trends, and the NPV results from the associated sensitivity cases, are 

described in appendix 10-B of the NOPR TSD. 

6.7. Unit Energy Consumption 

The NOPR analysis uses the same approach for determining UECs as the one 

used in the preliminary analysis. The UEC was determined for each application based on 

estimated loading points and usage profiles (for EPSs), and battery characteristics and 

usage profiles (for battery chargers). DOE refined the usage profiles, battery 

characteristics, and usage profiles for the NOPR. Further detail on the UEC calculations 

can be found in chapter 7 of the TSD. 

7.8. Electricity Prices 

DOE determined energy prices by deriving regional average prices for 13 

geographic areas consisting of the nine U.S. Census divisions, with four large states (New 

Comment [A17]: Changes recommended by 

OIRA. 

216 
 

 

 

 

York, Florida, Texas, and California) treated separately. The derivation of prices was 

based on data in EIA’s Form EIA-861. 

In its written comments, NEEP stated that the high electricity prices in the 

Northeast region of the United States would likely make the LCC and PBP results more 

attractive for customers in this region. (NEEP, No. 49 at p. 2) Typically, higher energy 

costs increase a consumer’s operating cost savings. As in the preliminary analysis, DOE 

sampled a regional electricity price for each trial of the Monte Carlo simulation. 

Additionally, the electricity price for the Northeast region used by DOE’s analysis is 

greater than the national average. DOE estimates a residential electricity price of 

$0.166/kWh for the New England region and $0.181/kWh for the state of New York, 

which exceeds the national average of $0.112/kWh. Further detail on regional electricity 

price sampling is available in chapter 8 of the TSD. 

8.9. Electricity Price Trends 

To project electricity prices to the end of the product lifetime in the preliminary 

analysis, DOE used data from EIA’s Annual Energy Outlook (AEO) 2010 Early 

Release.

48 This data source only contained a reference case scenario, which required 

DOE to separately project the high- and low-economic-growth scenarios using the 

relationship between the scenarios in the AEO 2009 data.49 For the NOPR, DOE used the 

48 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2010 Early 

Release. March, 2010. Washington, D.C. Available at: http://www.eia.doe.gov/oiaf/aeo/. 49 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2009 with 

Projections to 2030. March, 2009. Washington, D.C. Available at: http://www.eia.doe.gov/oiaf/aeo/. 

217 
 

 

final release of the AEO 2010,50 which contained reference, high- and low-economicgrowth scenarios. 

9.10. Lifetime 

DOE considers the lifetime of a battery charger or EPS to be from the moment it 

is purchased for end-use up until the time when it is permanently retired from service. 

Because the typical battery charger or EPS is purchased for use with a single associated 

application, DOE assumed that it will remain in service for as long as the application 

does. Even though many of the technology options to improve battery charger and EPS 

efficiencies may result in an increased useful life for the battery charger or EPS, the 

lifetime of the battery charger or EPS is still directly tied to the lifetime of its associated 

application. Even if an EPS or battery charger has a lifetime that exceedsWith the 

lifetimeexception of its application,EPSs for mobile phones and smartphones (see below), 

the typical consumer will not continue to use thean EPS or battery charger once theits 

application has been discarded. For this reason, DOE used the same lifetime estimate for 

the baseline and standard level designs of each application for the LCC and PBP 

analyses. Further detail on product lifetimes and how they relate to applications can be 

found in chapter 3 of the TSD. 

The one exception to the rule that EPSs do not exceed the lifetime of their 

associated end-use products is the lifetime of EPSs for mobile phones and smartphones. 

While the typical length of a mobile phone contract is 2 years, and thus many phones are 

50 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2010. 

November, 2010. Washington, D.C. http://www.eia.doe.gov/oiaf/aeo/. 

Comment [A18]: Changes recommended by 

OIRA. 

218 
 

 

 

 

 

replaced and no longer used after 2 years, DOE assumed that the EPSs for these products 

will remain in use for an average of 4 years. This assumption is based on an expected 

standardization of the market around micro-USB plug technology, driven largely by the 

GSMA Universal Charging Solution.51 To verify that this evolution towards micro-USB 

plug technology is in fact taking place, DOE examined more than 30 top-selling basic 

mobile phone and smartphone models offered online by Amazon.com, Sprint, Verizon 

Wireless, T-Mobile, and AT&T. DOE found that all of the newest smartphone models 

other than the Apple iPhone use micro-USB plug technology. While some basic mobile 

phones continue to use mini-USB or other connector technologies, DOE found more than 

15 basic mobile phone models that have adopted the micro-USB technology. 

If new EPSs are compatible with a wide range of mobile phone and smartphone 

models, a consumer may continue to use the EPS from their old phone after upgrading to 

a new phone. Even though it is currently standard practice to receive a new EPS with a 

phone upgrade, DOE assumes that in the near future consumers will no longer expect 

manufacturers to include an EPS with each new phone. DOE requests comment from 

stakeholders on the reasonableness of this assumption. Tables IV-27 and IV-28 show that 

assuming a lifetime of 2 years (rather than 4 years) for mobile phone and smartphone 

EPSs results in lower life-cycle cost savings (or greater net costs) for consumers of those 

products. However, the net effect on Product Class B as a whole is negligible due to the 

51 The GSMA Universal Charging Solution is an agreement between 17 mobile operators and 

manufacturers to have the majority of all new mobile phones support a universal charging connector by 

January 1, 2012. The press release for the agreement can be accessed here: 

<http://www.gsma.com/articles/mobile-industry-unites-to-drive-universal-charging-solution-for-mobilephones/17752/> 

219 
 

 

 

 

fact that mobile phones and smartphones together comprise only 7 percent of shipments 

in Product Class B. LCC results for all other applications in Product Class B are shown in 

chapter 11 of the TSD. 

Table IV-27 EPS Life-Cycle Cost Savings with 4-Year Lifteime Assumptions 

Weighted Average LCC Savings for a 

Standard at the Given CSL [2010$] 

CSL 1 CSL 2 CSL 3 CSL 4 

Mobile Phones 0.06 (0.01) (0.12) (0.15) 

Smartphones 0.05 (0.02) (0.13) (0.16) 

Product Class B 

Shipment-Weighted Average 

0.18 0.21 0.16 (0.99) 

Table 28IV-28 EPS Life-Cycle Cost Savings with Alternative (2-year) Lifetime 

Assumptions 

Weighted Average LCC Savings for a 

Standard at the Given CSL [2010$] 

CSL 1 CSL 2 CSL 3 CSL 4 

Mobile Phones (0.02) (0.19) (0.34) (0.40) 

Smartphones (0.02) (0.18) (0.31) (0.38) 

Product Class B 

Shipment-Weighted Average 

0.18 0.20 0.15 (1.01) 

10.11. Discount Rate 

In the preliminary analysis, DOE derived residential discount rates by identifying 

all possible debt or asset classes that might be used to purchase and operate products, 

including household assets that might be affected indirectly. DOE estimated the average 

shares of the various debt and equity classes in the average U.S. household equity and 

debt portfolios using data from the Survey of Consumer Finances (SCF) from 1989 to 

2007. DOE used the mean share of each class across the seven sample years as a basis for 

estimating the effective financing rate for products. DOE estimated interest or return rates 

associated with each type of equity and debt using SCF data and other sources. The mean 

Comment [A19]: Changes recommended by 

OIRA. 

220 
 

 

 

 

 

real effective rate across the classes of household debt and equity, weighted by the shares 

of each class, is 5.6 percent. 

For the commercial sector, DOE derived the discount rate from the cost of capital 

of publicly-traded firms falling in the categories of products that involve the purchase of 

battery chargers or EPSs. To obtain an average discount rate value for the commercial 

sector, DOE used the share of each category in total paid employees provided by the U.S. 

Census Bureau52 and Federal,53 State, and local54 governments. By multiplying the 

discount rate for each category by its share of paid employees, DOE derived a 

commercial discount rate of 7.0 percent. 

For the NOPR analysis, DOE uses the same methodology employed in the 

preliminary analysis but has changed the calculations to account for the geometric means 

for all time-series data. Additionally, the analysis now includes updates to the risk-free 

rate to use a 40-year average return on 10-year U.S. Treasury notes, as reported by the 

U.S. Federal Reserve,55 and the equity risk premium -- which now uses the geometric 

average return on the S&P 500 over a 40-year timer period. The new discount rates are 

estimated to be 5.1 percent and 7.1 percent in the residential and commercial sectors, 

52 U.S. Census Bureau. The 2010 Statistical Abstract. Table 607 – Employment by Industry. 

http://www.census.gov/compendia/statab/2010/tables/10s0607.xls. 53 U.S. Census Bureau. The 2010 Statistical Abstract. Table 484 – Federal Civilian Employment and 

Annual Payroll by Branch. http://www.census.gov/compendia/statab/2010/tables/10s0484.xls. 54 U.S. Census Bureau. Government Employment and Payroll. 2008 State and Local Government. 

http://www2.census.gov/govs/apes/08stlall.xls. 55 The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, Historical Data, 

Instrument: Treasury Constant Maturities, Maturity: 10-year, Frequency: Annual, Description: Market yield 

on U.S. Treasury securities at 10-year constant maturity, quoted on investment basis. Available at: 

http://www.federalfederalreserve.gov/releases/H15/data.htm. 

221 
 

 

 

respectively. For further details on discount rates, see chapter 8 and appendix 8D of the 

TSD. 

11.12. Sectors Analyzed 

In the preliminary analysis, DOE analyzed battery chargers and EPSs in the 

residential sector for the reference case scenario and presented commercial sector results 

in appendix 8B. DOE developed several inputs specifically for the commercial sector, 

such as energy prices, energy price trends, and discount rates. Other application-specific 

inputs -- e.g. UEC, markups, and market distribution -- were not altered between the 

residential sector and commercial sector analyses. 

The NOPR analysis includes an examination of a weighted average of the 

residential and commercial sectors as the reference case scenario. Additionally, all 

application inputs are specified as either residential or commercial sector data. Using 

these inputs, DOE then sampled each application based on its shipment weighting and 

used the appropriate residential or commercial inputs based on the sector of the sampled 

application. This approach provides more specificity as to the appropriate input values for 

each sector, and permits an examination of the LCC results for a given representative unit 

or product class in total. For further details on sectors analyzed, see chapter 8 of the TSD. 

12.13. Base Case Market Efficiency Distribution 

For purposes of conducting the LCC analysis, DOE analyzed candidate standard 

levels relative to a base case (i.e., a case without new federal energy conservation 

222 
 

 

standards). This analysis required an estimate of the distribution of product efficiencies in 

the base case (i.e., what consumers would have purchased in 2013 in the absence of new 

federal standards). Rather than analyzing the impacts of a particular standard level 

assuming that all consumers will purchase products at the baseline efficiency level, DOE 

conducted the analysis by taking into account the breadth of product energy efficiencies 

that consumers are expected to purchase under the base case. 

The preliminary analysis contained base case market efficiency distributions for 

each representative unit or product class. The distributions were based on test results, 

shipment-weighting of applications, and trends in efficiency that DOE identified. Under 

this approach, the resulting efficiency distribution could be heavily influenced by one or 

two very common applications associated with a particular product class or representative 

unit. 

In preparing the NOPR analysis, DOE derived base case market efficiency 

distributions that are specific to each application where it had sufficient data to do so. 

This approach helped to ensure that the market distribution for applications with fewer 

shipments was not disproportionately skewed by the market distribution of the 

applications with the majority of shipments. For battery chargers, DOE also adjusted its 

efficiency distributions for pending efficiency regulations in California (for more 

information please see IV.G.4). As a result, the updated analysis more accurately 

accounts for LCC and PBP impacts. 

223 
 

 

13.14. Compliance Date 

The compliance date is the date when a new standard becomes operative, i.e., the 

date by which battery charger and EPS manufacturers must manufacture products that 

comply with the standard. DOE’s publication of a final rule in this standards rulemaking 

is scheduled for completion in 2011by 2013. EPCA requireshad prescribed that the 

compliance date for amended DOE complete a rulemaking to amend the Class A EPS 

standards beby July 2011 and had given manufacturers a two years after the publication 

date, which would be-year lead time to satisfy those standards – i.e. July 2013. (42 U.S.C. 

6295(u)(3)(D)(i)(II)(bb) Given the timing in issuing this rule, DOE may choose to retain 

this prescribed two-year lead time for EPS manufacturers in spite of the compliance date 

currently provided in EPCA. There are no similar requirements for the compliance date 

for battery charger and new (non-Class A) EPS standards, but DOE is also targeting a 

two-year time period between publication and compliance, which would be 2013.. DOE 

calculated the LCCs for all consumers as if each would purchase a new product in the 

year thethat manufacturers would be required to meet the new standard takes effect 

(2013). However, DOE bases the cost of the equipment on the most recent available data; 

all dollar values are expressed in 2010$. DOE invites comment on the compliance date it 

should provide manufacturers in light of the current set of circumstances. Comment [A20]: Change requested by OIRA. 

14.15. Payback Period Inputs 

The PBP is the amount of time a consumer needs to recover the assumed 

additional costs of a more-efficient product through lower operating costs. As in the 

preliminary analysis, DOE used a “simple” PBP for the NOPR, because the PBP does not 

224 
 

 

take into account other changes in operating expenses over time or the time value of 

money. As inputs to the PBP analysis, DOE used the total installed cost of the product to 

the consumer for each efficiency level, as well as the first-year annual operating costs for 

each efficiency level. The calculation requires the same inputs as the LCC, except for 

energy price trends and discount rates; only energy prices for the year the standard 

becomes required for compliance (2013 in this case) are needed. 

DOE received a single comment addressing its initial PBP analysis. In particular, 

Philips commented that DOE had underestimated the projected PBP for inductively 

charged toothbrushes (i.e., battery charger product class 1). (Philips, No. 43 at p. 2) DOE 

notes that payback periods comprise a metric demonstrating the underlying costeffectiveness of a standard level. An underestimated PBP could result from an 

underestimated incremental consumer purchase price or an overestimated amount of 

operating cost savings. Philips suggested an alternate usage profile for battery charger 

product class 1 that included time spent in unplugged mode. (Philips, No. 41 at p. 2) In its 

view, the use of such an adjusted profile would provide a more accurate picture of the 

projected savings. 

DOE agrees with Philips that battery chargers in product class 1 likely spend 

some time in unplugged mode and adjusted its usage profile accordingly. The usage 

profile for these products now includes time in unplugged mode, which resulted in a 

reduction in operating cost savings. In the NOPR, DOE refined many of its estimates for 

the inputs contributing to purchase price and operating costs. While DOE is confident in 

225 
 

 

 

the accuracy of these inputs and the accompanying PBP calculations presented in this 

NOPR, DOE continues to seek comment to help refine its approach as needed. 

G. National Impact Analysis 

The National Impact Analysis (NIA) assesses the national energy savings (NES) 

and the net present value (NPV) of total consumer costs and savings that would be 

expected to result from new or amended standards at specific efficiency levels. 

(“Consumer” in this context refers to consumers of the product being regulated.) DOE 

calculates the NES and NPV based on projections of annual unit shipments, along with 

the annual energy consumption and total installed cost data from the energy use and LCC 

analyses. For the NOPR analysis, DOE forecasted the energy savings, operating cost 

savings, product costs, and NPV of consumer benefits for products sold from 2013 

through 2042. 

DOE evaluates the impacts of new and amended standards by comparing basecase projections with standards-case projections. The base-case projections characterize 

energy use and consumer costs for each product class in the absence of new or amended 

energy conservation standards. DOE compares these projections with projections 

characterizing the market for each product class if DOE adopted new or amended 

standards at specific energy efficiency levels (i.e., the TSLs or standards cases) for that 

class. For the base case forecast, DOE considers historical trends in efficiency and 

various forces that are likely to affect the mix of efficiencies over time. For the standards 

cases, DOE also considers how a given standard would likely affect the market shares of 

efficiencies greater than the standard. 

226 
 

To make the analysis more accessible and transparent to all interested parties, 

DOE used an MS Excel spreadsheet model to calculate the energy savings and the 

national consumer costs and savings from each TSL. MS Excel is the most widely used 

spreadsheet calculation tool in the United States and there is general familiarity with its 

basic features. Thus, DOE’s use of MS Excel as the basis for the spreadsheet models 

provides interested parties with access to the models within a familiar context. The TSD 

and other documentation that DOE provides during the rulemaking help explain the 

models and how to use them, and interested parties can review DOE’s analyses by 

changing various input quantities within the spreadsheet. The NIA spreadsheet model 

uses average values as inputs (as opposed to probability distributions). 

For the current analysis, the NIA used projections of energy prices from the 

AEO2010 Reference case. In addition, DOE analyzed scenarios that used inputs from the 

AEO2010 High Economic Growth, Low Economic Growth, and Carbon Cap and Trade 

cases. These cases have higher or lower energy price trends compared to the Reference 

case. NIA results based on these cases are presented in appendix 10A to the TSD. 

Table IV-29Table IV-29 summarizes the inputs and key assumptions DOE used 

in its preliminary NIA and the changes to the analysis for the NOPR. Discussion of these 

inputs and changes follows the table. See chapter 10 of the TSD for further details. 

227 
 

 

Table IV-29 Summary of Inputs, Sources and Key Assumptions for the National 

Impact Analysis 

Inputs Source Key Assumptions 

Base Year 

Shipments 

Market Assessment [Refer to the Market Assessment] 

Shipment 

Growth Rate 

Shipment Analysis 0.75 percent annually, equal to population growth 

Lifetimes Market Assessment Battery charger and EPS lifetime is equal to the 

lifetime of the end-use product it powers. 

Base Year 

Efficiencies 

Market Assessment [Refer to the Market Assessment] 

Base-Case 

Forecasted 

Efficiencies 

Shipments Analysis Efficiency distributions remain unchanged 

throughout the forecast period 

Standards-Case 

Forecasted 

Efficiencies 

Shipments Analysis ”Roll-up” scenario 

Annual Energy 

Consumption 

per Unit 

Energy Use Analysis Annual shipment weighted-average marginal 

energy consumption values for each product class 

Improvement 

Cost per Unit 

Engineering Analysis Annual shipment weighted-average marginal cost 

values for each product class 

Markups Markups Analysis [Refer to the Markups Analysis] 

Repair and 

Maintenance 

Cost per Unit 

None Assumed to be zero 

Energy Prices AEO 2010 Trend extrapolation from 2035 to 2062 

Electricity Siteto-Source 

Conversion 

Factor 

AEO 2010 Conversion factor does not change after 2035 

Discount Rate Office of Management 

and Budget 

Three and seven percent real 

Compliance 

Date of Standard 

EISA 2007 for EPSs Compliance date for battery charger standards 

matches that specified in the statute for EPS 

standards (2013) 

1. Shipments 

Forecasts of product shipments are needed to forecast the impacts standards will 

have on the Nation. DOE develops shipment forecasts based on an analysis of key market 

drivers for each considered product. In DOE’s shipments model, shipments of products 

were calculated based on current shipments of product applications powered by battery 

228 
chargers or EPSs. The inventory model takes an accounting approach, tracking remaining 

shipments and the vintage of units in the existing stock for each year of the analysis 

period. 

Stakeholders submitted several comments questioning DOE's assumption in the 

preliminary analysis that shipment volumes would not be affected by new or amended 

standards. AHAM and PTI stated that certain products, such as hair clippers, cordless 

vacuum cleaners, electric shavers, and DIY power tools, are discretionary purchases for 

consumers. Because of the discretionary nature of these purchases, AHAM and PTI 

claimed, standards that cause significant increases in the end-use product's price may lead 

some families to forgo purchasing these products and find other means to meet their 

needs. These parties asked DOE to consider lower shipments in its standards case 

forecasts. (AHAM, No. 42 at pp. 14-15; PTI, No. 45 at p. 12) In addition, AHAM, CEA, 

and Cobra Electronics all stated that increases in product price could lead some 

manufacturers to substitute primary batteries for rechargeable batteries in certain 

products, e.g., portable navigation devices and portable radios, reducing the number of 

battery chargers and EPSs for these products. (AHAM, No. 42 at p. 14; CEA, No. 46 at p. 

3; Cobra, No. 51 at p. 2) Lastly, Stanley Black & Decker and Lester stated that increases 

in product price for battery-operated gardening products and golf cars could drive 

consumers toward their gasoline-powered equivalents. (SBD, No. 44 at p. 2; Lester, No. 

50 at p. 3) 

229 
 

 

In response to these comments, DOE conducted a sensitivity analysis to examine 

how increases in end-use product prices resulting from standards might affect shipment 

volumes. To DOE’s knowledge, elasticity estimates are not readily available in existing 

literature for battery chargers, EPSs, or the end-use consumer products that DOE is 

analyzing in this rulemaking. Because some applications using battery chargers and 

EPSs, such as smartphones and videogame consoles, could be considered more 

discretionary than home appliances, which have an estimated relative price elasticity of ­

0.34 (See – 

http://ees.ead.lbl.gov/bibliography/an_analysis_of_the_price_elasticity_of_demand_for_ 

household_appliances In its), DOE believed a higher elasticity of demand was possible. 

In its sensitivity analysis, DOE assumed a price elasticity of demand of -1, meaning a 

given percentage increase in the final product price would be accompanied by that same 

percentage decrease in shipments. 

Even under this relatively high assumption for price elasticity of demand, the 

standards being proposed today are unlikely to have a significant effect on the shipment 

Comment [A22]: Change recommended by 

OIRA. 

volumes of those battery charger applications mentioned by stakeholders, with forecasted 

effects ranging from a decrease of 0.0203 percent for electric shavers to a decrease of 

2.01.46 percent for DIY power tools with detachable batteries. Results for all battery 

charger applications are contained in appendix 9A to the TSD. The corresponding 

impacts on NES and NPV are included in appendix 10A. DOE did not conduct a similar 

analysis for EPS applications due to the small size of the price increases (relative to the 

Comment [A21]: Changes recommended by 

OIRA. 

230 
 

 

price of EPS applications) expected to result from the EPS standards being proposed 

today. 

2. Shipment Growth Rate 

In the preliminary analysis, DOE noted that the market for battery chargers and 

EPSs has grown tremendously in the past 10 years. Additionally, DOE found that many 

market reports have predicted enormous future growth for the applications that employ 

battery chargers and EPSs. However, in forecasting the size of these markets over the 

next 32 years, DOE considered the possibility that much of the market growth associated 

with these products has already occurred. In many reports predicting growth of 

applications that employ battery chargers or EPSs, DOE noted that growth was predicted 

for new applications, but older applications were generally not included. That is, the 

demand for battery chargers and EPSs had not grown, but rather the products that use 

such devices had transitioned to a new product mix. (See chapter 9 of the Preliminary 

TSD.) 

With this in mind, DOE took a conservative approach in its forecast and estimated 

that while the specific applications that use battery chargers or EPSs will change, the 

overall number of individual units that use battery chargers or EPSs will grow slowly, 

with new applications replacing some current applications, but with little change in percapita consumption of battery chargers or EPSs over time. 

231 
 

 

To estimate future market size while assuming no change in the per-capita battery 

charger and EPS purchase rate, DOE used population growth rate as the compound 

annual market growth rate. DOE presented this approach to stakeholders for comment 

and received no comments objecting to its use. Population growth rate values were 

obtained from the U.S. Census Bureau 2009 National Projections, which forecast 

population through 2050. DOE took the average annual population growth rate, 0.75 

percent, and applied this rate to all battery charger and EPS product classes. For the 

NOPR analysis, DOE continues to apply this scenario. 

3. Product Class Lifetime 

For the preliminary analysis, DOE calculated product class lifetime profiles using 

the percentage of shipments of applications within a given product class, and the lifetimes 

of those applications. These values were combined to estimate the percentage of units 

remaining in use for each year following the initial year in which those units were 

shipped. For the NOPR analysis, DOE continued to apply this scenario. 

For more information on the calculation of product class lifetime profiles, see 

chapter 10 of the TSD. 

4. Forecasted Efficiency in the Base Case and Standards Cases 

A key component of the NIA is the trend in energy efficiency forecasted for the 

base case (without new or amended standards) and each of the standards cases. Section 

IV.A.2 above explains how DOE developed efficiency distributions (which yield 

232 
 

 

 

shipment-weighted average efficiency) for battery charger and EPS product classes for 

the first year of the forecast period. To project the trend in efficiency over the entire 

forecast period, DOE considered recent trends and standards, voluntary programs such as 

ENERGY STAR. , and other trends. 

DOE received two comments regarding the effect of European Union (EU) 

energy efficiency standards on the efficiency of battery chargers and EPSs in the U.S. 

market. AHAM commented that the EU is planning to begin a series of battery charger 

efficiency standards in 2011 that could have an effect on some non-wall-adapter battery 

chargers. (AHAM, No. 42 at p. 15) Similarly, Cobra Electronics commented that the 

EU’s most recent energy efficiency standard for EPSs was established at international 

efficiency marking protocol level V. (Cobra, No. 51 at p. 3)In the preliminary analysis, 

DOE found no battery charger standards slated to take effect by 2013.

 In addition, after reviewing the ENERGY STAR voluntary program for battery 

charging systems, DOE found that as of January 22, 2010, less than 150 battery charging 

systems had been qualified. As of July 1, 2011, only 241 battery charging systems had 

been qualified.56 (Contrast this with the more than 3,300 EPSs that were ENERGY 

STAR-qualified as of May 2010. See below.) Therefore, DOE continues to find no 

compelling evidence that battery chargers will improve in efficiency in the short-term. 

56 EPA, "Qualified Product (QP) List for ENERGY STAR Qualified Battery Charging Systems." Retrieved 

on July 8, 2011 from http://www.energystar.gov/ia/products/prod_lists/BCS_prod_list.xls. 

233 
 

 

 

In the preliminary analysis, DOE found two programs that would influence EPS 

efficiency in the short term. The first is the ENERGY STAR program for EPSs (called 

“external power adapters”), which specified that EPSs be at or above CSL 1 in order to 

qualify. This voluntary program was very active, with more than 3,300 qualified products 

as of May 2010.57 The second program influencing EPS efficiency is the European Union 

Ecodesign requirements on Energy Using Products, which includes legislation on EPSs 

that requires that EPSs sold in the EU be at or above CSL 1, effective April 2011. Europe 

currently represents approximately one-third of the global EPS market. DOE did not 

identify any programs that required efficiency above CSL 1. These factors apply to Class 

A EPSs. 

With these twoDOE agrees that standards established by the EU will affect the 

U.S. market, due to the global nature of EPS design, production, and distribution. With 

these programs in mind, DOE estimated that approximately half of the Class A EPS 

market at CSL 0 in 2009 would transition to CSL 1 by 2013. In updating its analysis for 

the NOPR, DOE reviewed these two programs for any changes. DOE found that no new 

European standards had been announced during the time between the preliminary 

analysis and the NOPR. However, in regard to the ENERGY STAR program, the U.S. 

Environmental Protection Agency announced that its program for EPSs would be 

57EPA, "ENERGY STAR External Power Supplies AC-DC Product List," May 24, 2010 and EPA, 

"ENERGY STAR External Power Supplies AC-AC Product List," May 24, 2010. Both documents last 

retrieved on May 28, 2010 from 

http://www.energystar.gov/index.cfm?c=ext_power_supplies.power_supplies_consumers. 

234 
 

 

 

cancelled effective December 31, 2010.58 In preparing today's notice, DOE also noted 

that the European mobile phone industry agreed to adhere to the GSMA Universal 

Charging Solution, which incorporates a no-load (“standby”) power consumption 

requirement that is stricter than both the current Federal standard and ENERGY STAR 

version 2.0 criteria. 

In summary, DOE found no new evidence to support the long-term improvement 

of EPSs beyond the initial improvement of units as estimated during the preliminary 

analysis. Thus, DOE has maintained its earlier assumption that EPSs will not improve in 

efficiency after 2013 in the base case. 

For battery charger efficiency trends, DOE considered three key factors: 

European standards, the EPA's ENERGY STAR program, and the recently approved 

battery charger standards in California. 

The EU included battery chargers in a preparatory study on eco-design 

requirements that it published in January 2007. However, it has not yet announced plans 

to regulate battery chargers. Thus, DOE did not adjust the efficiency distributions that it 

calculated for battery chargers between the present-day and the compliance date in 2013 

to account for European standards. 

58 EPA, "ENERGY STAR EPS EUP Sunset Decision Memo," July 19, 2010. Last retrieved on July 8, 2011 

from 

http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/eps_eup_sunset_decision_ju 

ly2010.pdf. 

235 
 

 

 

 

DOE examined the ENERGY STAR voluntary program for battery charging 

systems and found that as of January 22, 2010, less than 150 battery charging systems 

had been qualified. As of July 1, 2011, only 241 battery charging systems had been 

qualified.59 (Contrast this with the more than 3,300 EPSs that were ENERGY STARqualified as of May 2010.) Given the small number of qualified products, DOE also did 

not adjust its battery charger efficiency distributions to account for any potential market 

effects of the ENERGY STAR program. 

In the preliminary analysis, DOE found no battery charger standards slated to take 

effect by 2013. Subsequently, the California Energy Commission (CEC) approved battery 

charger standards on January 12, 2012 that will take effect on February 1, 2013 for most, 

if not all, of the battery chargers within the scope of DOE's rulemaking. Hence, DOE 

adjusted its base case efficiency distributions for battery chargers to account for these 

standards by assuming that in the absence of Federal standards all battery chargers sold in 

California would meet the CEC standards. In the absence of market share data, DOE 

assumed that California's share of the U.S. battery charger market is equivalent to its 

share of U.S. GDP (13 percent). Table IV-30 contrasts the resultant base case efficiency 

distributions, used in preparing today's notice, with those used in the preliminary 

analysis. 

Table IV-30 Changes to Base Case Efficiency Distributions to Account for CEC 

Standards 

DOE CSL that Best Scenario Percent of Battery Charger Market at Given CSL Prior 

Product Approximates to Federal Standards Taking Effect 

59 EPA, "Qualified Product (QP) List for ENERGY STAR Qualified Battery Charging Systems." Retrieved 

on July 8, 2011 from http://www.energystar.gov/ia/products/prod_lists/BCS_prod_list.xls. 

236 
Class the CEC 

Standard CSL 0 CSL 1 CSL 2 CSL 3 

1 0 

Ref – Prelim. 77.8% 11.1% 11.1% 0.0% 

Ref. – NOPR 77.8% 11.1% 11.1% 0.0% 

Sensitivity Case 77.8% 11.1% 11.1% 0.0% 

2 2 

Ref – Prelim. 20.6% 25.7% 50.6% 3.1% 

Ref. – NOPR 17.9% 22.3% 56.6% 3.1% 

Sensitivity Case 0.0% 0.0% 96.9% 3.1% 

3 2 

Ref – Prelim. 19.5% 71.1% 9.4% 0.0% 

Ref. – NOPR 17.0% 61.8% 21.2% 0.0% 

Sensitivity Case 0.0% 0.0% 100.0% 0.0% 

4 2 

Ref – Prelim. 10.6% 45.1% 44.3% 0.0% 

Ref. – NOPR 9.2% 39.3% 51.5% 0.0% 

Sensitivity Case 0.0% 0.0% 100.0% 0.0% 

5 3 

Ref – Prelim. 32.4% 59.5% 8.1% 0.0% 

Ref. – NOPR 28.2% 51.8% 7.0% 13.0% 

Sensitivity Case 0.0% 0.0% 0.0% 100.0% 

6 3 

Ref – Prelim. 40.9% 33.4% 25.7% 0.0% 

Ref. – NOPR 35.5% 29.1% 22.4% 13.0% 

Sensitivity Case 0.0% 0.0% 0.0% 100.0% 

7 1 

Ref – Prelim. 50.0% 50.0% 0.0% 0.0% 

Ref. – NOPR 43.5% 56.5% 0.0% 0.0% 

Sensitivity Case 0.0% 100.0% 0.0% 0.0% 

8 0 

Ref – Prelim. 50.0% 40.0% 10.0% 0.0% 

Ref. – NOPR 50.0% 40.0% 10.0% 0.0% 

Sensitivity Case 50.0% 40.0% 10.0% 0.0% 

10a/b 3 

Ref – Prelim. 100.0% 0.0% 0.0% 0.0% 

Ref. – NOPR 87.0% 0.0% 0.0% 13.0% 

Sensitivity Case 0.0% 0.0% 0.0% 100.0% 

DOE recognizes that the CEC standards may also raise the efficiency of battery 

chargers sold outside of California. However, the magnitude of this effect cannot be 

determined. Nevertheless, to explore the full range of possibilities DOE also evaluated 

the potential impacts of Federal standards under the assumption that the CEC standards 

become the de facto standard for the nation, i.e., all battery chargers sold in the United 

237 
 

 

 

States just before the Federal standard takes effect in 2013 meet the CEC standards. The 

base case efficiency distributions assumed in this sensitivity case are shown in Table 

IV-30Table IV-28. This scenario represents an upper bound on the possible impacts of 

the CEC standards and a lower bound on the energy savings that could be achieved by 

Federal standards. In fact, under this scenario, DOE might be limited to setting standards 

only for product classes 1 and 8, as further improvements to the efficiency of products in 

the other product classes are not currently projected to be cost-effective. Results of this 

sensitivity analysis can be found in Appendix 8-B and Appendix 10-A. 

DOE believes it is unlikely that all battery chargers sold in the United States will 

meet the CEC standards by February 1, 2013. First, manufacturers have been given an 

extremely short transition period of only one year; second, DOE's proposed standards are 

not as stringent as the CEC standards for product classes 2 through 6, which would 

potentially reduce the cost of production for these products and make it unlikely that they 

would be manufactured on a nationwide basis to the higher CEC levels; and third, the 

CEC standards will be preempted by Federal standards in the future if DOE finalizes 

standards for these products, giving manufacturers the option of specifically producing 

products solely for the California market for an interim period. 

DOE seeks comment on its assumptions concerning the impacts of the CEC 

standards on its base case efficiency distributions. In addition, DOE seeks comment on its 

assumptions about EPS efficiency, specifically, that EPSs within product classes B (DC 

output, basic-voltage), C (DC output, low-voltage), D (AC output, basic-voltage) and E 

Comment [A23]: Change recommended by 

OIRA. 

238 
(AC output, low-voltage) will improve in efficiency slightly prior to 2013, but then no 

longer improve in the absence of standards, and that EPSs within product classes X 

(multiple-voltage) and H (high-power) will not improve in efficiency in the absence of 

standards. (See issues 10 and 11 under “Issues on Which DOE Seeks Comment” in 

section VII.E of this notice.) 

To estimate efficiency trends in the standards cases, DOE has used “roll-up” 

and/or “shift” scenarios in its standards rulemakings. Under the “roll-up” scenario, DOE 

assumes: (1) product efficiencies in the base case that do not meet the standard level 

under consideration would “roll-up” to meet the new standard level; and (2) product 

efficiencies above the standard level under consideration would not be affected. Under 

the “shift” scenario, DOE reorients the distribution above the new minimum energy 

conservation standard. 

In the preliminary analysis, DOE used a roll-up scenario to develop its forecasts 

of efficiency trends in the standards cases. The NOPR analysis also applies this scenario. 

For further details about the forecasted efficiency distributions, see chapter 9 of the TSD. 

5. Product Price Forecast 

As noted in section IV.F., DOE assumed no change in battery charger and EPS 

pricing over the 2013-2042 period. In addition, DOE conducted sensitivity analysis using 

three alternative price trends based on AEO indexes. These price trends, and the NPV 

239 
 

results from the associated sensitivity cases, are described in appendix 10-B of the NOPR 

TSD. 

5.6. Unit Energy Consumption and Savings 

DOE uses the efficiency distributions for the base case along with the annual unit 

energy consumption values to estimate shipment-weighted average unit energy 

consumption under the base and standards cases, which are then compared against one 

another to yield unit energy savings values for each CSL. 

To better evaluate actual energy savings when calculating unit energy 

consumption for a product class at a given CSL, DOE considered only those units that 

would actually be at that CSL and did not consider any units already at higher CSLs. That 

is, the shipment-weighted average unit energy consumption for a CSL ignored any 

shipments from higher CSLs. 

In addition, when calculating unit energy consumption for a product class, DOE 

used marginal energy consumption, which was taken to be the consumption of a unit 

above the minimum energy consumption possible for that unit. Marginal unit energy 

consumption values were calculated by subtracting the unit energy consumption values 

for the highest considered CSL from the unit energy consumption values at each CSL. 

For the NOPR, DOE assumes that energy efficiency would not improve after 

2013 in the base case. Therefore, the projected UEC values in the NOPR analysis, as well 

Comment [A24]: Changes recommended by 

OIRA. 

240 
 

 

as the unit energy savings values, do not vary over time. In addition, the analysis assumes 

that manufacturers would respond to a standard by improving the efficiency of 

underperforming products but not those that already meet or exceed the standard. 

For further details on the calculation of unit energy savings for the NIA, see 

chapter 10 of the NOPR TSD. 

6.7. Unit Costs 

DOE uses the efficiency distributions for the base case along with the unit cost 

values to estimate shipment-weighted average unit costs under the base and standards 

cases, which are then compared against one another to give incremental unit cost values 

for each CSL. In addition, when calculating unit costs for a product class, DOE uses that 

product class’s marginal costs -- the costs of a given unit above the minimum costs for 

that unit. 

For further details on the calculation of unit costs for the NIA, see chapter 10 of 

the NOPR TSD. 

7.8. Repair and Maintenance Cost per Unit 

In the preliminary analysis, DOE did not consider repair or maintenance costs for 

battery chargers or EPSs because the vast majority cannot be repaired and do not require 

any maintenance. DOE maintains this assumption in its NOPR analysis. 

241 
 

 

For the NOPR analysis, DOE considered the incremental maintenance cost for the 

replacement of lithium ion batteries in certain applications. After examining the possible 

impact of this cost in the life-cycle cost and payback period analyses, DOE determined 

that the actual impact at the product class level would most likely be negligible. Thus, 

DOE opted not to retool its NIA model to account for this cost in calculating NPV. For 

further discussion of this issue, see section IV.F.5 above. 

8.9. Energy Prices 

In the preliminary analysis, DOE assumed that all energy consumption and 

savings would take place in the residential sector, and therefore any energy cost savings 

would be calculated using residential sector rates. 

However, DOE is aware that many products that employ battery chargers and 

EPSs are located within commercial buildings. Given this fact, the energy cost savings 

from such products should be calculated using commercial sector rates, which are lower 

in value than residential sector rates, and would lower the overall financial benefits 

derived from energy savings in the NPV. In order to account for these products in the 

NOPR analysis, DOE considered the impacts of battery charger and EPS usage in a 

commercial setting. 

In order to determine the energy usage split between the residential and 

commercial sector, DOE first separated products into residential and commercial 

categories. Then, for each product class, using shipment values for 2013, average 

lifetimes, and base-case unit energy consumption values, DOE calculated the 

242 
 

approximate annual energy use split between the two sectors. DOE applied the resulting 

ratio to the electricity pricing to obtain a sector-weighted energy price. This ratio was 

held constant throughout the period of analysis. 

For further details on the calculation of sector-weighted energy prices for the 

NIA, see chapter 10 of the NOPR TSD. 

9.10. Site-to-Source Energy Conversion 

To estimate the national energy savings expected from appliance standards, DOE 

uses a multiplicative factor to convert site energy savings (at the home or commercial 

building) into primary or source energy savings (the energy required to convert and 

deliver the site energy). These conversion factors account for the energy used at power 

plants to generate electricity and losses in transmission and distribution, as well as for 

natural gas losses from pipeline leakage and energy used for pumping. For electricity, the 

conversion factors vary over time due to projected changes in generation sources (i.e., the 

power plant types projected to provide electricity to the country). The factors that DOE 

developed are marginal values, which represent the response of the system to an 

incremental decrease in consumption associated with appliance standards. 

In the preliminary analysis, DOE used annual site-to-source conversion factors 

based on reported values in AEO2010, which provides energy forecasts through 2035. 

For 2036–2062, DOE used conversion factors that remain constant at the 2035 values. 

For the NOPR, DOE continued to use this approach. 

243 
 

 

Section 1802 of the Energy Policy Act of 2005 (EPACT 2005) directed DOE to 

contract a study with the National Academy of Science (the Academy) to examine 

whether the goals of energy conservation standards are best served by measurement of 

energy consumed, and efficiency improvements, at the actual point-of-use or through the 

use of the full-fuel-cycle (FFC), beginning at the source of energy production. (Pub. L. 

No. 109-58). The FFC measure includes point-of-use energy plus the energy consumed in 

extracting, processing, and transporting primary fuels and the energy losses associated 

with generation, transmission, and distribution of electricity. The study, “Review of Site 

(Point-of-Use) and Full-Fuel-Cycle Measurement Approaches to DOE/EERE Building 

Appliance Energy-Efficiency Standards,” was completed in May 2009 and provided five 

recommendations. A free copy of the study can be downloaded at: 

http://www.nap.edu/catalog.php?record_id=12670. 

The Academy’s primary recommendation was that “DOE consider moving over 

time to use of a FFC measure of energy consumption for assessment of national and 

environmental impact, especially levels of greenhouse gas emissions, and to providing 

more comprehensive information to the public through labels and other means, such as an 

enhanced website.” The Academy further recommended that DOE work with the Federal 

Trade Commission (FTC) to consider options for making product-specific GHG 

emissions estimates available to enable consumers to make cross-class product 

comparisons. 

244 
 

 

 

More specifically, the Academy recommended that DOE use the FFC measure of 

energy consumption for the environmental assessment and national impact analyses used 

in energy conservation standards rulemakings. The FFC measure would provide more 

complete information about the total energy use and GHG emissions associated with 

operating an appliance than the primary energy measure currently used by DOE. 

Utilizing the FFC measure for environmental assessments and national impact analyses 

would not require alteration of the measures used to determine the energy efficiency of 

covered products and covered equipment as existing law still requires such measures to 

be based solely on the energy consumed at the point-of-use. (42 U.S.C. 6291(4), 

6311(4)). However, using the FFC measure in lieu of primary energy in environmental 

assessments and national impact analyses could affect DOE’s consideration of future 

alternative standard levels. 

In response to the NAS committee recommendations, on August 20, 2010, DOE 

issued a Notice of Proposed Policy proposing to incorporate a FFC analysis into the 

methods it uses to estimate the likely impacts of energy conservation standards on energy 

use and greenhouse gas (GHG) emissions, rather than the primary (extended site) energy 

measures it currently uses. Additionally, DOE proposed to work collaboratively with the 

FTC to make FFC energy and GHG emissions data available to the public to enable 

consumers to make cross-class comparisons. On October 7, 2010, DOE held an informal 

public meeting to discuss and receive comments on its planned approach. The Notice, a 

transcript of the public meeting and all public comments received by DOE are available 

at: http://www.regulations.gov/search/Regs/home.html#docketDetail?R=EERE-2010­

245 
 

 

 

BT-NOA-0028. DOE is developing a final policy statement on these subjects and intends 

to begin implementing the policy in future energy conservation standards rulemakings. 

For further details about the calculation of national energy savings, see chapter 10 

of the TSD. 

10.11. Discount Rates 

The inputs for determining the NPV of the total costs and benefits experienced by 

consumers of battery chargers and EPSs are: (1) total increased product cost, (2) total 

annual savings in operating costs, and (3) a discount factor. For each standards case, 

DOE calculates net savings each year as total savings in operating costs less total 

increases in product costs, relative to the base case. DOE calculates operating cost 

savings over the life of each product shipped from 2013 through 2042. 

DOE multiplies the net savings in future years by a discount factor to determine 

their present value. For the preliminary analysis and today’s NOPR, DOE estimated the 

NPV of consumer benefits using both a 3-percent and a 7-percent real discount rate. DOE 

uses these discount rates in accordance with guidance provided by the Office of 

Management and Budget (OMB) to Federal agencies on the development of regulatory 

analysis.60 The 7-percent real value is an estimate of the average before-tax rate of return 

to private capital in the U.S. economy. The 3-percent real value represents the “societal 

60 OMB Circular A-4 (Sept. 17, 2003), section E, “Identifying and Measuring Benefits and Costs. Available 

at: http://www.whitehouse.gov/omb/memoranda/m03-21.html. 

246 
 

 

 

rate of time preference,” which is the rate at which society discounts future consumption 

flows to their present value. 

For further details about the calculation of net present value, see chapter 10 of the 

TSD. 

11.12. Benefits from Effects of Standards on Energy Prices 

The reduction in electricity consumption associated with new and amended 

standards for battery chargers and EPSs could affect overall electricity generation, and 

thus affect the electricity prices charged to consumers in all sectors of the economy. As a 

simplifying assumption in the preliminary analysis, DOE assumed no change in 

electricity prices as a result of energy savings from new or amended standards for battery 

chargers and EPSs. 

Commenting on the preliminary analysis, NEEP stated that the economic benefits 

of the reduced need for new power plants should be estimated and requested that DOE 

quantify electricity demand reductions achieved by these updated standards in financial 

terms. (NEEP, No. 49 at p. 2) 

In preparing the NOPR analysis, DOE used NEMS-BT to assess the impacts of 

the reduced need for new electric power plants and infrastructure projected to result from 

standards. In NEMS-BT, changes in power generation infrastructure affect utility revenue 

requirements, which in turn affect electricity prices. From these data, DOE estimated the 

247 
 

 

impact on electricity prices associated with each considered TSL. Although the aggregate 

benefits for electricity users are potentially large, there may be negative effects on some 

of the entities involved in electricity supply, particularly power plant providers and fuel 

suppliers. Because there is uncertainty about the extent to which the benefits for 

electricity users from reduced electricity prices would be a transfer from entities involved 

in electricity supply to electricity consumers, DOE tentatively concludes that, at present, 

it should not give a heavy weight to this factor in its consideration of the economic 

justification of new or amended standards. DOE is continuing to investigate the extent to 

which electricity price changes projected to result from standards represent a net gain to 

society. 

For further details about the effect of standards on energy prices, see chapter 10 of 

the TSD. 

H. Consumer Subgroup Analysis 

In analyzing the potential impacts of new or amended standards, DOE evaluates 

the impacts on identifiable subgroups of consumers (e.g., low-income households or 

small businesses) that may be disproportionately affected by a national standard. In the 

preliminary analysis, DOE identified four consumer subgroups of interest -- low-income 

consumers, small businesses, top marginal electricity price tier consumers, and 

consumers of specific applications within a representative unit or product class. 

Interested parties supported DOE’s decision to analyze consumers of specific 

applications in the subgroup analysis. AHAM commented that DOE should consider 

248 
 

subgroups of applications to ensure that CSLs are justified for applications with different 

energy usage characteristics from the product class. (AHAM, No. 42 at p. 12) Stanley 

Black & Decker also commented that outdoor gardening appliances were only operated a 

portion of the year, and would have different energy usage characteristics from the 

product class, necessitating a subgroup analysis. (SBD, No. 44 at pp. 1-2) Wahl Clipper 

commented that infrequently charged products should not be compared in the same 

fashion as those that are plugged in most of the time. (Wahl, No. 53 at p. 2) 

Additionally, manufacturers commented that averaging LCC results of various 

applications within the representative unit or product class would not lend enough weight 

to applications with fewer shipments. PTI noted that power tools have little in common 

with other applications aside from their battery energy and voltage levels. In its view, the 

averaging of LCC results would diminish the impact of the power tools on the LCC 

results for the entire product class. (PTI, No. 45 at pp. 6, 13) Similarly, AHAM and PTI 

commented that certain applications sell at lower price points than other applications 

within the product class. They argued that averaging the LCC results across these 

applications would deemphasize the impacts on the individual applications. (AHAM, No. 

42 at pp. 13-14; PTI, No. 45 at pp. 6, 13) 

DOE’s subgroup analysis for consumers of specific applications considered the 

LCC impacts of each application within a representative unit or product class. This 

approach allowed DOE to consider the LCC impacts of individual applications when 

choosing the proposed standard level, regardless of the application’s weighting in the 

249 
 

 

calculation of average impacts. The impacts of the standard on the cost of the battery 

charger or EPS as a percentage of the application’s total purchase price are not relevant to 

DOE’s LCC analysis. The LCC considers the incremental cost between different standard 

levels. DOE used the cost of the EPS or battery charger component in the LCC, not the 

final price of the application. Therefore, a $2,000 and $20 product are assumed to have 

the same cost for a battery charger or EPS (e.g., $5) if they are within the same CSL of 

the same representative unit or product class. The LCC considers the incremental impacts 

on consumers who purchase the product, but does not account for price elasticity or the 

economic impacts of consumers switching to non-covered products. Instead, DOE 

explored these possibilities in a shipments sensitivity analysis, as explained in section 

IV.G.1 above. The application-specific subgroup analyses represent an estimate of the 

marginal impacts of standards on consumers of each application within a representative 

unit or product class. 

At the preliminary analysis public meeting, AHAM commented that some 

applications span multiple battery charger product classes, making it difficult for the LCC 

to focus on specific applications. (AHAM, Pub. Mtg. Tr., No. 57 at p. 153) 

DOE notes that several applications span more than one product class or 

representative unit. Because each product class has associated characteristics and costs, it 

is difficult to aggregate LCC results across product classes. Therefore, DOE calculated 

application-specific results for each product class and representative unit. For 

250 
 

applications that span multiple product classes, DOE calculated the LCC and PBP 

impacts for that application in each product class. 

For each subgroup, DOE considered variations on the standard inputs. DOE 

defined low-income consumers as residential consumers with incomes at or below the 

poverty line, as defined by the U.S. Census Bureau. DOE found that these consumers 

face electricity prices that are 0.2 cents per kWh lower, on average, than the prices faced 

by consumers above the poverty line. For small businesses, DOE analyzed the potential 

impacts of standards by conducting the analysis with different discount rates, as small 

businesses do not have the same access to capital as larger businesses. DOE estimated 

that for businesses purchasing battery chargers or EPSs, small companies have an 

average discount rate that is 4.5 percent higher than the industry average. For top tier 

marginal electricity price consumers, DOE researched inclined marginal block rates for 

the residential and commercial sectors. DOE found that top tier marginal rates for general 

usage in the residential and commercial sectors were $0.306 and $0.221, respectively. 

Lastly, for the application-specific subgroup, DOE used the inputs from each application 

for lifetime, markups, market efficiency distribution, and UEC to calculate LCC and PBP 

results. 

Chapter 11 of the TSD contains further information on the LCC analyses for all 

subgroups. 

251 
I. Manufacturer Impact Analysis 

1. Overview 

DOE conducted separate manufacturer impact analyses (MIA) for EPSs and 

battery chargers to estimate the financial impact of new or amended energy conservation 

standards on these industries. The MIA is both a quantitative and qualitative analysis. 

The quantitative part of the MIA relies on the Government Regulatory Impact Model 

(GRIM), an industry cash-flow model customized for EPSs and applications that include 

battery chargers covered in this rulemaking. The key MIA output is industry net present 

value, or INPV. DOE used the GRIM to calculate cash flows using standard accounting 

principles and to compare changes in INPV between a base case and various TSLs (the 

standards case). The difference in INPV between the base and standards cases represents 

the financial impact of the new and amended standards on manufacturers. Different sets 

of assumptions (scenarios) produce different results. 

DOE calculated the MIA impacts of new and amended energy conservation 

standards by creating separate GRIMs for EPS original device manufacturers (ODMs) 

and battery charger manufacturers. In each GRIM, DOE presents the industry impacts by 

grouping similarly impacted products. For EPSs DOE presented the industry impacts by 

grouping the four representative product class B units (with output powers at 2.5, 18, 60, 

and 120 Watts) to characterize the results for product classes B, C, D, and E. DOE also 

presented the results for product classes X and H separately. For battery chargers, DOE 

presented the industry impacts by the major product class groupings for which TSLs are 

selected (product class 1; product classes 2, 3, and 4; product classes 5 and 6; product 

252 
class 7; product class 8; product class 10). When appropriate, DOE also presented the 

results for differentially impacted industries within and across those groupings. This is 

necessary because a given industry, depending upon how narrowly it is defined, may fall 

into several product classes. By segmenting the results into these similar industries, DOE 

is also able to discuss how subgroups of battery charger manufacturers will be impacted 

by new energy conservation standards. 

The complete MIA is presented in chapter 12 of the NOPR TSD. 

2. EPS MIA 

The MIA for EPSs focused on the original device manufacturers—or ODMs. 

These companies manufacture the EPS itself, as opposed to the application it is designed 

for or sold with. DOE analyzed the impact of standards on EPS manufacturers at the 

ODM level for three basic reasons: (1) the ODM typically certifies compliance with the 

DOE energy conservation standards and completes most design work for the EPS (even if 

EPS specifications are given by an OEM); (2) unlike battery chargers, the EPS is not 

fully integrated into end-use applications; and (3) most of the EPS final assembly and 

manufacturing is done by ODMs, which then ship the EPS as a component to OEMs. In 

essence, unlike a battery charger, the EPS typically becomes a final product when under 

the control of the ODMs, regardless of any additional steps in the distribution chain to the 

consumer. 

253 
 

 

a. EPS GRIM Key Inputs 

Many of the inputs to the GRIM come from the engineering analysis, the NIA, 

manufacturer interviews, and other research conducted during the MIA. The major GRIM 

inputs are described in detail in the sections below. 

i. EPS Manufacturer Production Costs 

The MIA is concerned with how changes in efficiency impact the manufacturer 

production costs (MPCs). The MPCs and the corresponding prices for which fully 

assembled EPSs are sold to OEMs, frequently referred to as “factory costs” in the 

industry, are major factors in industry value calculations. DOE’s MPCs include the cost 

of components (including integrated circuits), other direct materials of the finalized EPS, 

the labor to assemble all parts, factory overhead, and all other costs borne by the ODM to 

fully assemble the EPS. 

In the engineering analysis, cost-efficiency curves are developed for the four 

representative product class B units and product classes X and H, which were all 

analyzed directly. The MPCs are calculated in one of two ways. For the product class B 

representative units, DOE based its MPCs on information gathered during manufacturer 

interviews. In these interviews, manufacturers described the costs they would incur to 

achieve increases in energy efficiency. For product classes H and X, the engineering 

analysis created a complete bill of materials (BOM) derived from the disassembly of the 

units selected for teardown. 

254 
 

To calculate the percentage of the MPC attributable to labor, material, and 

overhead, DOE used the average percentages from all teardowns completed as part of the 

engineering analysis. 

For further detail, see the Engineering Analysis discussion in section IV.C.1 of 

this NOPR. 

ii. EPS Shipment Forecast 

Industry value, the key GRIM output, depends on industry revenue, which, in 

turn, depends on the quantity and prices of EPSs shipped in each year of the analysis 

period. Industry revenue calculations require forecasts of: (1) total annual shipment 

volume; (2) the distribution of shipments across analyzed representative units (because 

prices vary by representative unit); and, (3) the distribution of shipments across 

efficiencies (because prices vary with efficiency). 

In the NIA, DOE estimated total EPS shipments by application in 2009 and 

assumed a constant compound annual growth rate for total EPS shipments throughout the 

analysis period. DOE did not assume a decrease in shipments due to energy conservation 

standards. 

The GRIM requires that shipments be disaggregated by analyzed representative 

unit. In the LCC, DOE allocated total EPS shipments among all analyzed EPS 

applications. In the MIA, DOE assigned each application’s associated EPS shipments to 

255 
 

one of the six representative units in the following manner. First, DOE assigned any EPS 

application that uses multiple voltages to product class X. Second, any EPS application 

with an output power greater than 250 Watts was assigned to product class H. Lastly, 

DOE assigned each unit shipped in product classes B, C, D, and E to one of four groups, 

corresponding to one of the four representative units (output powers of 2.5, 18, 60, and 

120 Watts), whichever has the closest output power. For example, if an application has an 

output power of 4 Watts, DOE assigned that application to the 2.5W representative unit 

grouping. 

As discussed above, revenue calculations also require knowledge of the efficiency 

distribution in each year of the analysis period. DOE first developed efficiency 

distributions for 2009 based on products that DOE tested. Next, DOE estimated a 2013 

efficiency distribution based on an assessment of recent trends in product efficiency. 

DOE then linearly extrapolated the efficiency distributions for the intermediate years 

between 2009 and 2013. DOE assumed a constant efficiency distribution in the base case 

throughout the analysis period. See section IV.G of this NOPR for more information 

about DOE’s base-case EPS shipments forecast. 

iii. EPS Product and Capital Conversion Costs 

DOE expects new and amended energy conservation standards to cause some 

manufacturers to incur one-time conversion costs to bring their production facilities and 

product designs into compliance with the new and amended standards. For the MIA, 

DOE classified these one-time conversion costs into two major groups: (1) product 

256 
conversion costs and (2) capital conversion costs. Product conversion costs are one-time 

investments in research, development, testing, marketing, and other non-capitalized costs 

focused on making product designs comply with the new and amended energy 

conservation standards. Capital conversion costs are one-time investments in property, 

plant, and equipment to adapt or change existing production facilities so that new product 

designs can be fabricated and assembled. 

DOE received several comments on the preliminary analysis about the impact of 

product and capital conversion costs on EPS manufacturers and OEMs. Many 

commenters expressed concerns about potential conversion costs. AHAM suggested that 

DOE seek input from manufacturers related to the impact of additional engineering, 

testing, and capital improvements that are associated with any significant design changes. 

Specifically, AHAM noted that changes to the outside housing of some battery chargers 

and EPSs will result in changes to plastic injection molds that cost tens of thousands of 

dollars each year, as well as changes in the size of external packaging of the product. 

(AHAM, No. 42 at p. 11) Similarly, Cobra suggested that incremental engineering design 

costs be assessed because they may become a significant part of the initial cost of the 

product. (Cobra, No. 51 at p. 2) 

DOE agrees that testing, certification, and engineering costs could represent a 

substantial cost for the EPS industry. DOE relied on a number of assumptions from other 

analyses and data gathered from publicly available sources to estimate product 

conversion costs. The key values used to estimate product conversion costs were 

257 
 

application lifetimes, shipments of each application from 2011 and 2013, and typical 

industry research and development expenses. Because the product lifecycle tends to be 

shorter for electronics, DOE assumed that in the base case, a portion of the applications 

will be redesigned between the announcement of an energy conservation standard and the 

implementation of that energy conservation standard. Those applications that are 

scheduled for redesign are excluded from the projected product conversion costs. 

For example, for an application with a five-year average lifetime, DOE assumed 

that one-fifth of these applications would be redesigned each year. .DOE assumed that an 

application’s product lifetime -- the average number of years a product is used by 

consumers -- is equal to its production cycle, the average number of years between when 

manufacturers redesign that application. DOE based this simplifying assumption on 

feedback received from several manufacturers during manufacturer interviews. However, 

DOE is aware that not all product lifetimes directly correspond to their production cycle, 

as some products may have shorter or longer production cycles compared to their product 

lifetimes. DOE believes on average the product lifetime is an appropriate estimate of the 

production cycle for an application. So for example, for an application with a five-year 

product lifetime, DOE assumed that application to also have a five-year production cycle. 

Therefore on average one-fifth of these applications would be redesigned each year by 

manufacturers. Because there is a two-year time period between the announcement of the 

standard and its compliance date, two-fifths of the applications with a five-year 

lifetimeproduction cycle will be redesigned in that timeframe, irrespective of whether a 

standard is implemented. As a result, three-fifths of the five-year applications would need 

Comment [A25]: Changes recommended by 

OIRA. 

258 
to be redesigned as a result of a new or amended energy conservation standard. In 

addition, only those products that do not meet the established energy conservation 

standard would be required to be redesigned, as the efficiency of products meeting or 

exceeding the standard would remain unchanged. 

AHAM stated that products that undergo changes must be sent to third-party 

testing laboratories for energy efficiency testing and these testing costs must be factored 

into the overall cost of changing a product’s design. AHAM suggested that DOE ask 

manufacturers for information on these costs. AHAM also argued the cost of safety 

certification should be included in the overall cost. (AHAM, No. 42 at pp. 11) Cobra 

commented that third-party testing would be an undue burden on manufacturers, stating 

that DOE should not require it unless a significant compliance problem with the current 

system is proven. (Cobra, No. 51 at p. 4) 

DOE notes that it does not currently require manufacturers to use third-party 

testing to demonstrate compliance with EPS or battery charger energy conservation 

standards as the above comments suggest. However, DOE recognizes other organizations 

that provide certifications for safety or other product attributes may constitute part of the 

total product conversion costs (such as UL certification). DOE also understands that 

many ODMs and/or OEMs will likely pay for third-party testing to ensure compliance 

with the energy conservation standard because many do not have certified labs. DOE 

included testing costs as part of the research and development costs used to calculate the 

259 
 

product conversion cost for the industry because these costs represent a significant 

portion of existing expenses that are factored into the methodology. 

DOE used a similar approach to calculate capital conversion costs, using 

application lifetimes and the shipments of each application between 2011 and 2013 as the 

key assumptions. Whereas DOE estimated product conversion costs using a multiple of 

typical industry R&D expenditures, DOE estimated capital conversion costs using a 

multiple of typical industry capital expenditures. In response to AHAM’s comment 

regarding the potential changes to the plastic injection molds used to cast the external 

casings of EPSs, DOE assumed in its analysis that the changes for the actual EPS designs 

would require a lower capital investment than for battery chargers because these changes 

would affect only the external housing of an EPS. By comparison, battery chargers may 

require changes to the entire housing, which would require a greater capital investment. 

Cobra also expressed concerns about conversion costs for manufacturers of linear 

EPSs because, depending on the efficiency level DOE sets, a manufacturer would have to 

transition from a mechanical assembly process to an automated printed circuit board 

(PCB) assembly process. (Cobra, No. 51 at p. 3) 

The capital cost of transitioning from a mechanical assembly process to an 

automated PCB assembly process would be borne by the EPS ODM in most cases. For 

most CSLs, there are a variety of technologies available for EPSs and many ODMs do 

not exclusively offer linear EPSs. OEMs that do not own their own manufacturing 

260 
facilities will also be impacted by this transition, but the impact will manifest itself 

primarily through higher factory costs after standards apply. DOE fully analyzed these 

costs in the engineering costs and the GRIM’s INPV calculations. In particular, the 

capital conversion cost assumptions that DOE used increase at CSLs that require a 

technology change because, as Cobra states, these transitions greatly increase the 

required capital and product conversion costs, especially for manufacturers that must 

transition to a new assembly process. This factor is taken into account for the 2.5W 

representative unit. DOE assumed the product and capital conversion costs associated 

with upgrading CSL 1 and baseline 2.5W representative units would be greater than the 

product and capital conversion costs of other representative units because the technology 

employed in upgrading those 2.5W representative units change from linear to switch 

mode technology. This technology change would be more costly than an ordinary product 

redesign because companies focusing on incremental changes for applications using 

linear technology may not have the experience and expertise to implement switch mode 

technology in their applications without additional product development efforts. 

See chapter 12 of the TSD for a complete description of DOE’s assumptions for 

the capital and product conversion costs. 

iv. Financial Inputs 

DOE was unable to locate sufficient data on publicly-traded EPS manufacturers 

because few, if any, major EPS ODMs are publicly traded in the United States. 

Consequently, few, if any, of these companies file annual 10-K reports with the Securities 

261 
 

and Exchange Commission. Because these documents were not available, the preliminary 

MIA DOE developed began with the basic financial parameters used in the ballast 

rulemaking (such as R&D percentage of revenue, capital expenditure percentage of 

revenue, SG&A percentage of revenue, tax rate as a percentage of revenue, etc.) because 

many of the companies included in that analysis were structured similarly to EPS 

manufacturers, manufacture products in similar locations, and use similar production 

processes [76 FR 20090, 20134-20135 April 11, 2011 (notice of proposed rulemaking to 

set amended efficiency standards for fluorescent lamp ballasts, describing various aspects 

of the manufacturing industry) and section 4.3 of chapter 13 of the NOPR TSD 

accompanying that notice]. During manufacturer interviews, DOE asked EPS 

manufacturers to comment on these initial financial parameters. Several EPS 

manufacturers interviewed confirmed that these initial financial parameters were an 

appropriate representation of the EPS industry. Consequently, DOE applied these 

parameters in analyzing the EPS industry in the MIA. 

v. EPS Standards-Case Shipments 

The base-case efficiency distribution and growth rate drive total industry revenue 

in the base case. In the standards case, DOE assumed that manufacturers will respond to 

new and amended standards by improving only those products that do not meet the 

standards in 2013, but not exceed, the new and amended standard level. Products that 

already meet or exceed the proposed level remain unaffected. This is referred to as a 

“roll-up” scenario. See chapter 9 of the TSD for a complete explanation of the efficiency 

distribution of EPSs and battery chargers by product class. 

Comment [A26]: Changes recommended by 

OIRA. 

262 
 

 

 

vi. EPS Markup Scenarios 

As discussed above, the MPCs of the six representative units are the factory costs 

of the ODM and include direct labor, material, overhead, and depreciation. The MSP is 

the price the ODM sells an EPS to an OEM. The MSP is equal to the MPC multiplied by 

the manufacturer markup. The manufacturer markup covers all the ODM’s nonproduction costs (i.e., SG&A, R&D, and interest, etc.) and profit. Total EPS revenue is 

equal to the MSPs at each CSL multiplied by the shipments at that CSL. 

Modifying these manufacturer markups in the standards case yields different sets 

of impacts on manufacturers. For the MIA, DOE modeled two standards-case markup 

scenarios to represent the uncertainty regarding the potential impacts on prices and 

profitability for manufacturers following the implementation of new and amended energy 

conservation standards: (1) a flat markup scenario and (2) a preservation of operating 

profit scenario. These scenarios lead to different markups values, which, when applied to 

the inputted MPCs, result in varying revenue and cash flow impacts. 

The flat markup scenario assumed that the cost of goods sold for each product is 

marked up by a flat percentage to cover SG&A expenses, R&D expenses, and profit. This 

scenario represents the upper bound of industry profitability in the standards case because 

manufacturers are able to fully pass through additional costs due to standards to their 

customers. 

263 
 

DOE also modeled a lower-bound profitability scenario. During interviews, 

ODMs and OEMs indicated that the electronics industry is extremely price sensitive 

throughout the distribution chain. Because of the highly competitive market, this scenario 

models the case in which ODMs’ higher production costs for more efficient EPSs cannot 

be fully passed through to OEMs. In this scenario, the manufacturer markups are lowered 

such that manufacturers are only able to maintain the base-case total operating profit in 

absolute dollars in the standards case, despite higher product costs and required 

investment. DOE implemented this scenario in the GRIM by lowering the manufacturer 

markups at each TSL to yield approximately the same earnings before interest and taxes 

in both the base case and standards cases in the year after the compliance date for the new 

and amended standards. This scenario represents the lower bound of industry profitability 

following new and amended energy conservation standards because higher production 

costs and the investments required to comply with the new and amended energy 

conservation standard do not yield additional operating profit. 

b. Comments from Interested Parties Related to EPSs 

DOE also received comments on the potential manufacturer impacts that would 

result from DOE’s treatment of EPSs as both a stand-alone product and a component of 

another regulated product (the battery charger). AHAM stated that this treatment could 

lead to duplicative testing if this rulemaking were to establish different compliance dates 

for EPSs and battery chargers, or if future standards were to be updated at different points 

for battery charger and EPSs. (AHAM No. 44 at p. 11) 

264 
 

 

 

In response, DOE notes that EPS and battery charger standards for this 

rulemaking will go into effect on the same date. Therefore, DOE does not foresee a 

situation in which updated regulations would occur at different intervals. 

To account for the compliance costs for certifying an EPS alone and as a 

component of a battery charging system, DOE has included compliance costs for both the 

EPS and the battery charging system in its conversion cost estimates in the EPS GRIM 

and the battery charger GRIM, respectively. DOE also notes for product class N EPSs, 

which only function as a battery charger component (as opposed to EPSs that can directly 

power the application), the Class A EPS standards prescribed in 42 U.S.C. 6295(u)(3) 

will continue to apply to the Class A EPSs in product class N. Any additional energyrelated savings generated by the use of more efficient product class N EPSs will be 

captured through the battery charger standards that DOE is proposing to set. 

Consequently, conversion costs for product class N EPSs are not included in the EPS 

analysis, but the conversion costs for the battery charging portion of the application are 

included in the battery charger GRIM for these applications. DOE believes that this 

approach will help to ensure that additional energy savings can be obtained by applying 

more stringent levels in a manner that reduces the complexity of the overall standards that 

are set. Depending on the additional information that DOE receives in response to this 

proposed approach, the agency may alter the approach to account for that additional 

information. 

265 
In response to the preliminary analysis, Cobra suggested that DOE account for 

incremental engineering design costs in the rulemaking analysis, as those costs may 

comprise a significant portion of the product’s initial cost. DOE notes that the 

incremental engineering costs are directly accounted for in the MPCs which are a central 

input to the GRIM. 

Cobra also questioned what it viewed as a DOE assumption that achieving a new 

or amended standard can be done with present staffing and within the two years between 

the notice and the compliance date. Cobra stated that while this may be possible if the 

standard is set close to today’s standards, it will not continue to be the case if the standard 

is set closer to the max tech level. Cobra stated that achieving a new or amended standard 

will take even longer if DOE regulates products under an EPS and battery charger 

regulation at the same time due to additional design burdens. (Cobra, No. 51 at p. 2) 

Partly in recognition of this situation, DOE is not proposing new or amended 

standards for product class N EPSs in today's notice. This approach allows manufacturers 

to focus on improving the efficiency of these products as a system. As shown by DOE’s 

capital and product conversion costs that increase at each higher efficiency level, DOE 

also agrees that standards that are closer to max-tech would require a more substantial 

research and development effort by manufacturers and are accounted for in DOE’s 

analysis. However, DOE does not assume that standards set closer to the max tech level 

could be met by all manufacturers with their present staffing. In addition to standard 

research and development expenses that account for ongoing product development, 

266 
 

DOE’s methodology accounts for the additional product conversion costs that would be 

required for products that fall below the required efficiency level or would not have been 

redesigned in the period between the final rule’s issuance and the compliance date of the 

standard. The EPS conversion cost estimates also account for any additional engineering 

or product development resources necessary to meet new or amended energy 

conservation standards. 

c. High-Power EPS Manufacturer Interviews 

To better understand the possible impacts on product class H, DOE attempted to 

gather more information about the possible impacts on high-power EPS ODMs. DOE 

identified a total of 13 manufacturers of high-power EPSs. DOE attempted to contact all 

manufacturers of high-power EPSs. DOE managed to locate contact information for 

eleven of these manufacturers and contacted each to schedule interviews. Six of these 

eleven were domestic manufacturers and five were foreign manufacturers. Of these 

eleven manufacturers for whom DOE found contact information, five were nonresponsive. The remaining six declined to discuss the impacts of new standards on highpower EPSs. Four of the six manufacturers that declined to be interviewed were domestic 

manufacturers and two were foreign manufacturers. 

3. Battery Charger MIA 

In the battery charger MIA, DOE analyzed the impacts of standards on 

manufacturers of the applications that incorporate the covered battery chargers (the 

267 
 

application OEMs). DOE believes this MIA focus, which differs from the approach DOE 

is using for the EPS MIA, is appropriate for several reasons. 

First, the application OEM will be the party most directly financially impacted by 

any energy conservation standards, as evidenced by their participation in the rulemaking 

process. Battery chargers are almost always integrated into and/or sold with the final 

application – meaning the severity of necessary conversion costs and the financial impact 

of higher battery charger costs can only be assessed meaningfully at the application level. 

Because most battery chargers are sold with, or fully integrated into, the end-use 

application, OEMs will pay for any costs required to alter the application if the new 

battery charger design requires it. These costs will vary from application to application, 

even within a product class. 

Second, the battery charger value chain varies greatly and is principally dictated 

by the application for which it is designed and with which it is sold. While EPSs are 

almost exclusively sold as finalized components, battery charger manufacturing is split 

between companies that produce battery chargers for OEMs and OEMs that produce 

battery chargers “in house.” 

Third, the OEM typically designs the battery charger and would certify 

compliance with any DOE regulations because it is often impossible to separate the 

battery charger from the application. 

268 
 

 

 

 

 

Fourth, even if the OEM does not design the battery charger, it typically will still 

integrate it into the final product. As a result, even if an OEM did not design the battery 

charger, it must still integrate it into the final application. Therefore, the OEM will be 

responsible for any changes to the application (such as the plastic housing) which are 

necessary due to the changes in the battery charger. 

Lastly, within a given product class, individual applications may be much more 

severely impacted than others within the same product class -- even at the same CSL. 

These differential impacts would be obscured if DOE did not consider the different 

characteristics of the application industries. 

In some industries, particularly those that utilize high-energy battery chargers, the 

directly impacted party will likely be the battery charger ODM (as opposed to the OEM). 

Manufacturers of battery chargers for golf cars, for example, produce and sell stand alone 

battery chargers and would be responsible for compliance with energy conservation 

standards and all associated conversion costs. DOE conducted a subgroup analysis for 

product class 7, which it presents in the regulatory flexibility analysis, section VI.B. That 

analysis addresses the potential impacts of the proposed standards on small businesses. 

DOE is following this approach because the only manufacturers of these products that 

DOE identified are small businesses. 

To calculate impacts on the application OEM, DOE analyzed the industries of the 

applications that use covered battery chargers. DOE presents results in two different 

269 
 

 

ways. First, DOE presents the industry impacts by the major product class groupings for 

which TSLs are derived (product class 1; product classes 2, 3, and 4; product classes 5 

and 6; product class 7; product class 8; product class 10). 

Second, DOE used an alternative construction for evaluating the MIA results for 

battery chargers. DOE has developed this approach because if it grouped results in the 

same manner as the TSL product class groupings noted above, they would not adequately 

account for the fact that many applications within the same product class groupings are 

very dissimilar. The aggregate projected impacts would not necessarily be representative 

of each particular industry within each product class grouping. To address this potential 

problem, the analysis (particularly for product classes 2, 3, and 4) groups applications 

into four industry subcategories. These industry subgroups share similar characteristics 

and the proposed standards are projected to affect these industry subgroups similarly. To 

group the applications, DOE assigned each application to one of four distinct industry 

subgroups: small appliances, consumer electronics, power tools, and high-energy 

products (“high-energy” products are those applications that fit into product classes 5, 6, 

and 7). This additional approach enhances the interpretability and transparency of the 

MIA results by providing a meaningful way to compare impacts across applications. 

DOE has set up a flexible methodology that allows the analysis of individual 

applications or a set of applications. DOE reports these quantitative MIA results for each 

individual application, product class, and industry subgroup in chapter 12 of the TSD. 

270 
 

 

 

a. Battery Charger GRIM Key Inputs 

Many of the inputs to the GRIM come from the engineering analysis, the NIA, 

manufacturer interviews, and other research conducted in preparing the MIA. The major 

GRIM inputs are described in detail in the sections below. 

i. Battery Charger Manufacturer Production Costs and Application Prices 

Calculating manufacturer impacts at the OEM level for battery chargers requires 

two critical inputs: First, the price that the application OEM charges for its finished 

product (to calculate revenue); and, second, the portion of that price represented by its 

battery charger (to calculate costs) at each CSL. 

For the first component, DOE determined representative retail prices for each 

application by surveying popular online retailer websites to sample a number of price 

points of the most commonly sold products for each application. The price of each 

application can vary greatly depending on many factors (such as the features of each 

individual product). For each application, DOE used the average application price found 

in the product survey. DOE then discounted this representative retail price back to the 

application MSP using the retail markups derived from annual SEC 10-K reports in the 

Markups Analysis, as discussed in section IV.F. 

DOE calculated the second figure—the price of the battery charger itself at each 

CSL—in the engineering analysis. The engineering analysis calculated a separate cost 

efficiency curve for each of the 10 battery charger product classes. Based on product 

271 
 

testing data, tear-down data and manufacturer feedback, DOE created a BOM at the 

ODM level to which markups were applied to calculate the MSP of the battery charger at 

each CSL. DOE then allocated the battery charger MSPs of each product class to all the 

applications within each product class. In this way, DOE arrived at the cost to the 

application OEM of the battery charger for each application. 

ii. Battery Charger Financial Parameters 

Because any two application OEMs may compete in very different markets, a 

single set of financial parameters cannot adequately characterize each manufacturer’s 

cost structure. To address this limitation, DOE gathered and disaggregated publicly 

available financial data for representative manufacturers in each of the four industry 

categories it analyzes: small appliance manufacturers, consumer electronics 

manufacturers, power tool manufacturers, and high-energy product manufacturers. DOE 

then assigned each application to one of the four industry subgroups. In the GRIM, each 

individual application uses the cost structure of the industry subgroup to which it belongs. 

iii. Battery Charger Shipment Forecast 

As with EPS shipments, DOE estimated total domestic shipments of each 

analyzed application for 2013 that is sold with a battery charger. DOE then distributed 

the associated shipments among the 10 product classes and among the four industry 

subgroups. See chapter 12 of the TSD for a complete list of the applications DOE 

included in each of the four industry subgroups. DOE also adjusted its efficiency 

distributions and shipments in the base case, to account for pending efficiency regulations 

272 
 

in California (for more information please see IV.A.2.d). In the GRIM, DOE used the 

battery charger shipment projections from 2009 to 20432042 that were generated in the 

NIA. 

iv. Battery Charger Product and Capital Conversion Costs 

Capital and product conversion costs triggered by a new energy conservation 

standard are critical inputs to the GRIM. DOE received various comments about the 

impact of product and capital conversion costs on manufacturers of applications that 

incorporate covered battery chargers. 

AHAM suggested that DOE seek manufacturer input regarding the impact of 

additional engineering, testing, and capital improvements that are associated with any 

significant design changes that would be needed to satisfy new standards for battery 

chargers. Specifically, AHAM noted that changes to the outside housing of some battery 

chargers will result in changes to plastic injection molds that cost tens of thousands of 

dollars each year, as well as changes in the size of the external packaging of the product. 

(AHAM, No. 42 at p. 11) PTI stated that manufacturers will encounter redesigning, 

retooling and re-qualifying costs for battery chargers used in power tools. The magnitude 

of these costs will depend on the final CSL selected. For example, the difference between 

CSL 1 and CSL 2 for product class 4 could be hundreds of thousands of dollars. (PTI, 

No. 45 at p. 13) Similarly, Cobra argued that incremental engineering design costs should 

be included in the analysis because they may become a significant part of the initial cost 

of the product. (Cobra, No. 51 at p. 2) 

273 
 

DOE agrees that testing and engineering costs could represent a substantial cost 

burden to manufacturers, depending on the efficiency levels eventually selected. DOE 

has included the testing costs for battery charger applications to comply with the energy 

conservation standards in its calculation of conversion costs. At the higher CSLs, 

manufacturers could be compelled to redesign products that would have been redesigned 

years later in the base case. DOE accounts for the additional testing and engineering time 

by assuming that energy conservation standards would require manufacturers to alter 

products before the end of their natural lifecycle, resulting in substantial product 

conversion costs. The extent of the product conversion costs depends largely on whether 

a given standard level requires a technology change—moving from NiMH to lithium ion 

chemistry, for example—or only minor design tweaks. Within a given product class, 

some applications will face technology changes and the associated major redesigns at 

much lower CSLs than other applications. Therefore, DOE estimated product conversion 

costs for each individual application, rather than in aggregate by product class. 

Because of the large number of applications analyzed, DOE approximates the 

impacts of standards-driven conversion costs by assuming manufacturers will incur a 

given multiple of normal R&D and normal capital expenditures. The exact multiple used 

depends on each CSL and each product class and is calibrated to manufacturer feedback 

received during interviews. Intuitively, this approach to product and capital expenditures 

accelerates the product cycle and compresses resources that would normally have been 

spread over a number of years into a shorter timeframe. In the standards case, these 

274 
 

expenditures are in addition to, and not in lieu of, normal engineering, testing and 

equipment costs. DOE only assumes conversion costs for the proportion of shipments 

that fall below the analyzed TSL within any given application. Also, DOE separately 

calculated the conversion costs associated with the products sold in California that would 

have to comply with the CEC battery charger standard. These conversion costs are 

included in the base case and separate from the conversion costs associated with the DOE 

standard. For example, in product class 4, computer notebooks would not be impacted at 

CSL 1 because all computer notebooks meet CSL 1 in the base case. In contrast, DIY 

power tools would face more substantial conversion costs at CSL 1 because nearly half40 

percent of all models would not meet this level and would need to be upgraded. 

Therefore, DOE assumes these applications, despite incorporating battery chargers that 

are in the same product class, would incur different levels of R&D and capital 

expenditures. 

Based on manufacturer interviews and the engineering analysis, DOE anticipates 

that new standards may result in the alteration of the external housing in the application, 

which would trigger additional design costs and expenses for new injection molds used to 

construct these housings. DOE tentatively believes these changes would most likely 

occur in those applications incorporating battery chargers that require a substantial 

technology shift to meet the new standards. DOE includes the associated housing costs in 

its estimates of the capital conversion costs and believes its methodology accounts for 

these changes. 

275 
 

As discussed in section IV.I.2.a.iii of the EPS MIA methodology, AHAM and 

Cobra communicated concerns regarding testing and certification costs that are associated 

with changes in products due to new standards. (AHAM, No. 42 at p. 11; Cobra, No. 51 

at p. 4) DOE summarizes and responds to these comments, which relate to battery 

chargers as well as EPSs, in section IV.I.2.a.iii. 

PTI also noted that manufacturers will encounter “stranded costs” when forced to 

retire tooling before the end of its service life, resulting in unused inventory. Stranded 

costs are capital assets that are not yet fully depreciated, but are made obsolete by a new 

or amended energy conservation standard. (PTI, No. 47 at p. 13) 

DOE agrees with PTI that energy conservation standards could strand tooling 

before the end of its useful life. DOE has estimated these costs as part of stranded assets, 

which are treated as a non-cash expense in the compliance year of the standard. 

PTI asserted that the resources that manufacturers would ordinarily devote to new 

product development, which drives much of the power tool industry, would be reduced in 

order to meet any new regulations. (PTI, No. 47 at p. 13) 

DOE understands there are opportunity costs related to any investment and that 

manufacturers may face difficult decisions in selecting non-energy related product 

development projects when faced with the prospect of standards-induced resource 

allocation. DOE notes that the GRIM analysis accounts for both ordinary, ongoing 

276 
research and development efforts, as well as those prompted by new energy standards. 

DOE weighs these impacts when deciding the most appropriate TSL for the proposed 

standard. 

PTI stated that the power tool industry is somewhat unique because a significant 

proportion of its members’ product offerings revolve around detachable pack battery 

systems. Achieving higher CSLs depends on fulfilling certain technical changes that 

would require redesigning the entire battery charger, including the battery pack. 

According to PTI, this situation would disrupt the market because manufacturers would 

be required to abandon these legacy systems and strand a large installed base of 

consumers with unsupported systems. For example, in product class 4, PTI argued that 

CSL 2 would require nickel-based systems to switch to Li-ion, which would most likely 

require a complete redesign of the system that is unlikely to be backward compatible with 

existing tools. (PTI, No. 47 at p. 12) 

DOE agrees it would take a substantial research and development effort to 

redesign nickel-based systems to Li-ion. For power tools, the backward compatibility 

issues described by PTI arise from designing the entire battery chargers (including the 

battery pack) for power tool applications. Based on its engineering analysis, DOE 

tentatively believes that the technical challenges to achieving backward compatibility 

could be met at CSL 2 in the context of a complete redesign. DOE has accounted for the 

additional engineering costs in the MIA. 

277 
 

 

v. Battery Charger Standards-Case Shipments 

The base-case efficiency distribution and growth rate drive total industry revenue 

in the base case. As with EPS shipments, the standards case assumes that manufacturers 

will respond to standards by improving those products that do not meet the new standards 

to meet, but not exceed, the standard level. Products that are already as efficient as, or 

more efficient than, the standard level would remain unaffected under this approach. This 

is referred to as a “roll-up” scenario. DOE did not consider elasticity or substitution away 

from battery chargers in the standards case in the main NIA scenario. However, this was 

considered as a sensitivity analysis which is included as an appendix in chapter 12 of the 

NOPR TSD. 

vi. Battery Charger Markup Scenarios 

The revenue DOE calculates for the battery charger GRIM is the revenue 

generated from the sale of the application that incorporates the covered battery charger. It 

is the revenue earned on the sale of the product to the OEM’s first customer (e.g., the 

retailer). After calculating the average retail price from the product price survey as 

discussed above, DOE discounted the price by the appropriate retailer markup (calculated 

in the market and technology assessment) to calculate the per-unit revenue the OEM 

generates for each application. To calculate the potential impacts on manufacturer 

profitability in the standards case, DOE analyzed how the incremental costs of more 

efficient battery chargers would impact this revenue stream on an application-byapplication basis. 

Comment [A27]: Change recommended by 

OIRA. 

278 
 

 

In comments, manufacturers raised concerns about higher battery charger input 

costs resulting in reduced profit margins. PTI stated that many manufacturers only sell 

through retailers and have “price points” that they must hit, particularly in the “do-ityourself” (DIY) market. Although the cost to produce the product may change with more 

efficient battery chargers, in its view, there would be no change in price for the consumer. 

Faced with higher product costs, PTI asserted that manufacturers will have to reduce 

gross margin or ultimately reduce the utility of the product. (PTI, No. 47 at p. 12) Lester 

also expressed concerns about increased costs to produce golf cars, which will either be 

passed along to purchasers or result in reduced profit margins for the manufacturers. 

(Lester, No. 52 at p. 1) 

DOE acknowledges that new or amended standards have the potential to increase 

product prices and disrupt manufacturer profitability, particularly as the market 

transitions to meet a new energy conservation standard. Based on the comments from 

interested parties and DOE’s manufacturer interviews, there is a great deal of uncertainty 

regarding how the markets for such a wide variety of applications will adjust, both in the 

near term and long term. To account for this uncertainty, DOE analyzes three 

profitability, or markup, scenarios in the GRIM: the “constant price,” “pass through,” and 

“flat markup” scenarios. 

The constant price scenario analyzes the situation in which manufacturers of 

applications are unable to pass on any incremental costs of more efficient battery 

chargers to their customers. This scenario is reflective of some manufacturers’ 

279 
description of the negotiating power of large retailers, who account for the vast majority 

of shipments of some applications. Manufacturers believe these large retailers would be 

unwilling to accept any price increases. This scenario results in the most significant 

negative impacts because no incremental costs added to the application—either because 

of higher battery charger component costs or because of investments in tooling and 

design—can be recouped. As a result, manufacturer gross margins decline as cost-ofgoods-sold increase, on a dollar-for-dollar basis. The higher the incremental cost of the 

battery charger with respect to the total application price, the greater the impacts on the 

manufacturer. For example, the impact of an incremental $2.00 increase in the cost of the 

battery charger is much greater on a product that sells for $50 than on a product that 

retails for $500. 

For some applications in certain product classes, the max-tech battery charger 

price is nearly as expensive as the total base case application price itself. Under the 

constant price scenario, such circumstances can yield highly negative results, which are 

not meaningful because, in reality, producers would not continue to produce at prices that 

did not cover variable costs. If prices fell below the level necessary to cover variable 

costs, a firm would be better off not producing anything at all. Therefore, DOE applies a 

boundary condition in the constant price scenario, which assumes that as battery charger 

costs increase, application prices remain constant (and gross margin would continue to 

decline) only until manufacturers cease to cover their variable costs (where gross margin 

is zero). At that point, DOE assumes manufacturers can pass on any further incremental 

costs of the battery charger on a dollar-for-dollar basis to their customers. 

280 
 

 

In the pass through scenario, DOE assumes that manufacturers are able to pass 

through the incremental costs of more efficient battery chargers to their customers, but 

without earning any additional operating profit on those higher costs. Therefore, though 

less severe than the constant price scenario in which manufacturers absorb all incremental 

costs, this scenario also results in margin compression and adverse financial impacts as 

battery charger costs increase. 

Lastly, DOE considers a flat markup scenario to analyze the upper bound (most 

positive) of profitability impacts following the compliance date of new standards. In this 

scenario, manufacturers are able to maintain their base case gross margin as a percentage 

of revenue at higher CSLs despite higher product costs of more efficient battery chargers. 

In other words, manufacturers are able to pass on, and fully mark up, the higher 

incremental product costs due to more efficient battery chargers. This scenario is a more 

likely outcome for high-value, differentiated products, for which energy efficiency 

indirectly drives customer-valued benefits such as lighter weight and greater 

transportability. For other applications, particularly low-cost products for which energy 

efficiency is not an important selling attribute, the scenario is less likely. 

In summary, DOE believes these three scenarios present the potential range of 

profitability impacts on OEM application manufacturers. 

281 
 

b. Battery Charger Comments from Interested Parties 

The following section discusses interested parties’ comments on the preliminary 

analyses that impact the battery charger MIA methodology. In general, DOE provides 

background on an issue that was raised by interested parties, summarizes the interested 

parties’ comments, and responds to those comments. 

i. Compliance Date and Implementation Period 

Many manufacturers commented on the implementation timeline of a new 

standard. For example, with respect to medical devices, Philips noted that the 

development life cycle is at least two to four years. Philips also mentioned that the 

regulatory approval cycle for medical products is longer than for consumer grade 

products, suggesting that medical devices should either be exempt or be given a longer 

transition time. (Philips, No. 43 at p. 3) 

Lester expressed similar concerns, noting that the proposed timelines are not 

reasonable for large, integrated vehicle manufacturers. It added that properly designing, 

testing, and ramping up production of a battery charging system commonly exceeds three 

years. Furthermore, Lester stated that an insufficient timeline could lead manufacturers to 

utilize components that have not been designed or tested properly. Additionally, a 

premature compliance date could cause product shortages, defects, increased costs, and 

unplanned capital expenditures that will either be passed on to purchasers or result in 

reduced profits. Lester suggested a timeline extension to five years. (Lester, No. 52 at p. 

282 
 

1, 2) Similarly, Cobra stated that two years will not be enough time to comply if DOE 

sets the standard level near max tech. (Cobra, No. 51 at p. 2) 

AHAM commented that the effective date should be two years after the final rule 

for small appliance battery charger products, but noted a longer time period might be 

necessary for some other product groups. AHAM argued that an earlier effective date 

would facilitate consistency across all 50 states. However, AHAM also mentioned that 

DOE must factor in additional time due to new requirements for third-party testing. 

(AHAM, No. 44 at p. 3, 11) Lastly, AHAM pointed out that the time needed depends 

significantly upon which standard level DOE chooses, as well as whether products are 

treated as both EPSs and battery chargers. (AHAM, Pub. Mtg. Tr., No. 37 at p. 373, 374) 

EISA 2007 prescribed a two-year period between the issuance of the final rule for 

Class A EPSs and the compliance date of the amended energy conservation standard. See 

42 U.S.C. 6295(u)(3)(D). Congress did not grant DOE with the specific authority to 

change this date for individual product classes falling within Class A as requested by 

Philips, Lester, and AHAM. However, DOE notes that Congress did not impose a 

specific compliance date timeline for battery chargers and newly covered non-Class A 

EPSs. For these products, DOE has tentatively concluded that the two-year window 

between the announcement of the final rule and compliance with rule is sufficient for 

manufacturers to meet the TSLs analyzed in today’s rule. As the comments suggest, 

depending on the resources available to a given manufacturer, their technological starting 

point, and the proposed CSL, the typical product design cycle will vary significantly. As 

283 
 

 

such, some manufacturers will likely have to dedicate more resources than others to 

upgrade some or all of their product lines. DOE notes, however, that designs achieving 

the levels proposed in today’s NOPR are currently on market. Hencethe market for all 

product classes except battery charger product class 10. For all of these product classes, 

the TSLs proposed are below the max-tech level and either represent the best-in-market 

efficiency or a lower level. For battery charger product class 10, however, DOE is 

proposing the max-tech level based on information derived from manufacturer input. 

Therefore, DOE has tentatively concluded that the technologies required to reach the 

efficiencies proposed in today’s rule are achievable within two years. 

DOE requests comment on what an appropriate compliance date for battery 

chargers and non-Class A EPSs would be, including whether a two-year lead time would 

be reasonable. DOE may decide to adjust the compliance date for these products 

depending on the nature of the information it receives on this issue. 

With respect to unplanned capital expenditures, DOE agrees that standards may 

require changes to tooling and equipment, as well as incremental engineering efforts. 

Ultimately, whether any manufacturer chooses to allocate the resources necessary to 

upgrade some or all of their product lines, or to source some or all of them, is a business 

decision. Regardless of these decisions, DOE accounts for the conversion costs for 

manufacturers to upgrade all their non-compliant products to comply with each TSL. 

DOE considers the results of this analysis in weighing the projected benefits and burdens 

associated with the rule. See section 0I.C for that determination. 

Comment [A28]: Change recommended by 

OIRA. 

284 
 

ii. Cumulative Regulatory Burden 

Several manufacturers expressed concerns about other regulations that affect 

battery chargers. TwoThree potential regulations are the U.S. Department of 

Transportation’s regulation of the packaging and transportation of Li-ion cells in both 

end-products and in cell configurations, see 75 FR 1302 (Jan. 11, 2010), and the future 

series of regulations on battery chargers from the European Union, (Commission 

Regulation (EC) No 278/2009 of 6 April 2009).), and the California battery charger 

standard set by CEC (Docket # 11-AAER-2). (AHAM, No. 44 at p. 11, 15) 

For the cumulative regulatory burden, DOE attempts to quantify and/or describe 

the impacts of other Federal regulations that have a compliance date within three years of 

the compliance date of this rulemaking. This analysis does not include the Department of 

Transportation’s proposal to regulate the packaging and transportation of lithium ion cells 

given that no requirements are yet in place and any analysis attempting to account for 

what these requirements might be would be speculative. DOE does acknowledge that EU 

regulations on battery chargers would be an overlapping regulatory burden on 

manufacturers, if the EU decides to regulate battery chargers in the future, because 

identical products are sold throughout the world. At this time the EU has specifically 

excluded battery chargers from their regulations but will consider in the future to expand 

the scope of the regulation to include battery chargers (see the adopted draft regulation of 

EC No 278/2009, 17 October 2008, p. 10). DOE does not include the costs to comply 

with future regulations in the EU because they are outside the scope of the cumulative 

285 
 

regulatory burden, which focuses on Federal regulations. However, DOE did 

quantitatively assess the impacts of the CEC battery charger standard on battery charger 

manufacturers in section V.B.2.e of this NOPR. 

iii. Employment 

Lester expressed concerns about losing domestic manufacturing jobs to low-cost 

countries as a result of implementing the new standard. The company stated that because 

switch-mode battery charger assembly is more labor intensive than other designs, it 

expects standards requiring switch-mode designs to accelerate the trend towards offshore 

manufacturing. Lester added that DOE should prioritize the impact to manufacturing in 

the U.S. among other criteria in determining which standards to adopt. According to 

Lester, battery chargers for applications that use transformer-based battery chargers, 

which are typically used in high-energy applications, tend to correlate with requirements 

for longer life, greater durability, and higher reliability. (Lester, No. 52 at p. 3) 

While the vast majority of applications using EPSs and battery chargers are 

manufactured overseas, DOE agrees that new or amended standards could adversely 

impact domestic employment for companies currently producing covered products in the 

United States. This is especially a concern for the golf car industry because battery 

chargers for this application still have a significant U.S. manufacturing presence. Any 

manufacturers that would be forced to develop a new technology to meet new standards, 

especially one that is more labor intensive, would face significant economic pressures to 

move operations overseas or source products directly from overseas third-party suppliers. 

286 
DOE’s direct employment analysis (see section V.B.2.b) discusses the preliminary 

estimates for the impacts on changes in employment at the analyzed TSLs. 

In selecting the TSLs proposed in today’s notice, the Secretary considers a variety 

of factors to weigh the overall benefits and burdens of the rule, including, as Lester notes, 

the impact on United States manufacturing. DOE also notes that the impacts on small 

businesses are treated directly in the Regulatory Flexibility Analysis in section VI.B. 

iv. Supply Chain 

Lester expressed concerns over the potential for supply chain disruptions, noting 

that as production of chargers is moved to lower-cost countries, manufacturers of electric 

vehicles will face logistical risks that are less likely to occur domestically. (Lester, No. 52 

at p. 2) 

DOE agrees that overseas manufacturing can complicate the supply chain of firms 

that elect to move production offshore. However, such a strategy is a business decision 

and not one that is required to meet the TSLs analyzed in today’s rulemaking. DOE also 

notes that the vast majority of all battery chargers on the market already make use of 

global supply chains. 

4. Comments from Interested Parties Related to EPSs and Battery Chargers 

The following section discusses interested parties’ comments on the preliminary 

analyses that impact the both the EPS and battery charger MIA methodology. This 

287 
 

 

section provides background on specific issues raised by interested parties, summarizes 

the relevant comments, and discusses DOE’s response. 

a. Cumulative Burden 

AHAM expressed concern about the possibility of DOE applying CEC’s Tier 2 

EPS standards which, it asserts, are wrongly applied to the wall adapters of battery 

chargers. (AHAM, No. 44 at p. 15) PTI added that DOE should consider the cumulative 

regulatory burden that would be imposed if the CEC were to regulate the power factor of 

battery chargers. This would increase the costs of achieving higher efficiencies. (PTI, No. 

47 at p. 11) 

With respect to the CEC standards, DOE notes that the proposed EPS standards in 

today’s NOPR would preempt state regulations on EPS efficiencies. As for potential 

power factor regulation, DOE does not include has included a quantitative analysis of the 

CEC standard on battery charger manufacturers in section V.B.2.eburden of possible 

regulations that have not yet been passed into law.. 

Similarly, Philips expressed concerns about FDA regulations on medical 

products, which can delay the time-to-market from a few weeks to many months. Philips 

also noted that the EU Directive on the Restriction of Hazardous Substances (RoHS) 

proposed a minimum of six years for medical device manufacturers to reach compliance, 

which reflects a longer product design cycle and regulatory approval process. (Philips, 

No. 43 at p. 3) 

288 
 

DOE acknowledges that the EU RoHS proposed a minimum of six years for 

medical device manufacturers to comply with the directive. However, EU’s RoHS 

regulations have the potential to affect the entire medical application, while the DOE 

energy conservation standards at issue here cover only the battery charger or EPS portion 

of the device. DOE does not include the costs to comply with future regulations in the EU 

as part of the cumulative regulatory burden because they are outside its scope, which 

focuses on U.S. regulations. DOE notes that it has the authority to set a compliance 

period for non-Class A EPSs and battery chargers that varies from the two-year lag 

between the issuance of the final rule and the compliance date of the standard prescribed 

in EISA for Class A EPSs. However, DOE has consulted with the FDA and does not 

believe that this extension for non-Class A EPSs is necessary. This situation is described 

in detail in chapter 3 of the TSD. DOE also does not believe there are technical 

differences between medical EPSs and non-medical EPSs that would affect the ability of 

manufacturers to improve the efficiency of medical EPSs. However, DOE requests 

further comment on the appropriateness of the proposed compliance date for non-Class A 

EPS and battery charger product classes and if there are any specific medical applications 

that would be adversely affected by a 2013 date that mirrors the statutorily-prescribed 

compliance date for Class A EPSs. 

Cobra commented on the significant burden facing small manufacturers from 

recent regulatory actions including EISA 2007, the Consumer Product Safety 

Improvement Act of 2008 (CPSIA 2008), California’s Safe Drinking Water and Toxic 

289 
 

 

Enforcement Act of 1986 (Proposition 65), Mercury-Containing and Rechargeable 

Battery Management Act, recycling regulations, and EU’s RoHS. Cobra contended that 

these regulations challenge its ability to compete against larger companies while 

spending resources to prove compliance with all established regulations. Cobra also 

mentioned that while it does not manufacture products that are covered under CPSIA 

2008, it asserted that it needs to demonstrate to customers that its products can still satisfy 

those requirements for marketing purposes. (Cobra, No. 53 at pp. 1, 2) 

DOE agrees that maintaining compliance with the various standards may be a 

challenge for manufacturers, especially smaller manufacturers. Furthermore, DOE 

understands that because products with EPSs and battery chargers are sold globally, the 

design of these products are more harmonized than for other appliances. DOE has 

analyzed the cost to comply with the EISA requirements in this rulemaking. DOE also 

further describes the recycling requirements and RoHS in chapter 12 of the TSD. DOE 

has also attempted to quantify these costs where applicable. 

b. Competition 

AHAM asked DOE to evaluate the potential for a reduction in competition, in the 

event standards cause manufacturers of low-cost products to leave the market. (AHAM, 

Pub. Mtg. Tr., No. , No. 37 at p. 144) 

EPCA directs DOE to consider any lessening of competition likely to result from 

standards. It directs the Attorney General to determine the impact, if any, of any 

290 
lessening of competition likely to result from a proposed standard and to transmit such 

determination to the Secretary, not later than 60 days after the publication of a proposed 

rule, together with an analysis of the nature and extent of such impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii)) DOE will transmit a copy of today’s proposed rule to the 

Attorney General and request that the U.S. Department of Justice (DOJ) provide its 

determination on this issue. DOE will publish and address the Attorney General’s 

determination in the final rule, if any, and will pay particular attention to any potential 

competitive impacts in that determination. 

At this time, DOE does not believe there is significant potential for a reduction in 

competition due to the standards proposed in this rule. Particularly for some of the lowcost products, there are relatively few barriers to entry and the TSLs proposed in today’s 

rule do not require use of patented technology. Technology that can be used exclusively 

by one manufacturer does not pass the screening analysis. 

However, given the wide array of applications that incorporate covered EPSs and 

battery chargers, DOE seeks comment on which specific markets, if any, exhibit the 

potential for a reduction in competition. 

5. Manufacturer Interviews 

DOE conducted additional interviews with manufacturers following the 

preliminary analysis in preparation for the NOPR analysis. In these interviews, DOE 

asked manufacturers to describe their major concerns with this rulemaking. The 

291 
following section describes the key issues identified by manufacturers during these 

interviews. 

a. Product Groupings 

Several manufacturers expressed concern over the approach DOE outlined in 

which a variety of different applications would be grouped together within the same 

product class and would have to meet equivalent standards. EPS and battery charger 

product classes are defined by characteristics such as type of current conversion, voltage, 

and output power. However, the proposed EPS and battery charger product classes do not 

necessarily group applications performing similar end-use functions. Manufacturers 

stated that grouping applications that consume a larger amount of electricity over their 

lifetime with applications that consume only a fraction of electricity over their lifetime 

can put the applications that are used less frequently at an unfair disadvantage. 

Manufacturers were particularly concerned about the potential for groupings to 

impact specific battery charger applications after finalizing the standard. For battery 

chargers, DOE is proposing standards using one UEC equation for each product class. 

Specific applications can be grouped into a product class whose individual usage profile 

differs from the usual profile of the product class. This is especially true if the shipments 

of one application are significantly greater than the shipments of another application with 

a very different usage profile (i.e., the millions of laptop shipments versus DIY power 

tools). Both laptops and DIY power tools would be regulated using the same usage 

profile parameters to satisfy a given energy conservation standard. Therefore, there is less 

292 
 

 

potential for consumers to save energy cost effectively with respect to those applications 

that are not used frequently compared to applications that are used continuously even 

though both applications would be required to meet the same standard. 

DOE recognizes manufacturer concerns over how specific applications are 

grouped together as a result of the proposed division of product classes. DOE’s LCC 

analysis and manufacturing impact analysis evaluate the impacts on users and 

manufacturers, respectively, on a applications-specific basis. Although the UEC is 

established at the product class level, the granularity of these analyses enables DOE to 

consider the benefits and burdens on users and manufacturers of specific applications, 

and take those results into consideration in determining which TSLs to select. 

b. Competition from Substitutes 

Manufacturers have stated that several of their applications compete directly with 

applications using other forms of energy, such as products powered by gasoline, 

disposable alkaline batteries, or corded products. Products that use battery chargers must 

remain cost competitive with these alternatively powered products because these products 

are close substitutes. Manufacturers of lawn care products, such as mowers and trimmers, 

and mobility units, such as motorized bikes and golf cars, are competing in the same 

markets as gas-powered versions of these applications. Similarly, manufacturers of 

smaller electronic devices, such as digital cameras, are competing in the same market as 

disposable alkaline battery-powered digital cameras. Several applications also have direct 

competition with similar non-electric applications, such as electric toothbrushes and DIY 

293 
 

 

power tools. Having products powered by a rechargeable battery is a feature that adds 

value for consumers. A significant increase in the cost of manufacturing the battery 

charger could lead manufacturers to remove the rechargeable feature of an application or 

choose an alternative method to power the device, ultimately reducing the consumer 

utility for these applications. If energy conservation standards lead to a significant price 

increase, consumers could switch to these alternatives. 

Based on these concerns, DOE considered the impact of price elasticity on 

application shipment volumes. These price elasticity sensitivity results are presented in 

Appendix 12-B of the TSD. 

c. Test Procedure Concerns 

While most manufacturers agree that using the UEC is an appropriate test 

procedure metric for battery chargers, some battery charger manufacturers stated there is 

a problem of separating the battery charging function of an application from the other 

functions being performed by the application. In their view, it is not easy to isolate the 

battery charging portion of the application for testing and/or creating cost-efficiency 

curves. Manufacturers stated that the test procedure must clearly separate out the 

charging portion of the energy consumption in order to regulate its efficiency accurately. 

DOE specifically took this factor into consideration for UPS manufacturers and explains 

its approach in detail in section IV.C.2.i of this NOPR. 

294 
 

 

d. Multiple Regulation of EPSs and Battery Chargers 

Manufacturers raised concerns that specific applications that are shipped with 

both an EPS and a battery charger would be subject to regulations for both components - 

one energy conservation standard for the EPS and a separate energy conservation 

standard for the battery charger of the same application. Having to meet two separate 

standards may not allow the manufacturers to maximize the efficiency of both the EPS 

and the battery charger together and could add to the overall cost of the application. DOE 

took these comments into consideration but has tentatively determined that establishing 

standards for each product was the most appropriate action given the statutory 

requirements to set standards for these products. For further detail and DOE’s rationale 

for this decision, see section IV.A.1 of this NOPR. 

e. Profitability Impacts 

Several manufacturers stated that they expect energy conservation standards to 

negatively impact the profitability of battery chargers. At higher CSLs, standards could 

increase MPCs and manufacturers believed these higher costs would not necessarily be 

passed on to consumers. Several applications use specific price points that consumers 

expect those applications to have. Consequently, manufacturers believe that cost 

increases would be at least partly absorbed by manufacturers to keep retail prices from 

rising sharply. 

The battery charger often represents a significant portion of the overall cost of the 

application. Any increase in the cost of the battery charger would have a significant 

295 
 

impact on the cost of these applications as a whole. If energy conservation standards led 

to a significant reduction in profitability, some manufacturers could potentially exit the 

market and reduce the number of competitors. Additionally, many electronic applications 

are considered luxury items so consumers could also chose to forgo their purchases 

altogether if the application prices increased substantially. 

As discussed in section IV.I.2.a and IV.I.3.a of this NOPR, DOE evaluates a 

range of profitability scenarios in the MIA that take these specific concerns into account. 

These sections and Chapter 12 of the TSD discuss the results and details of those 

analyses. 

f. Potential Changes to Product Utility 

Manufacturers believe adverse impacts from new and amended standards could 

also indirectly affect product utility. Several manufacturers indicated that other features 

that do not affect efficiency could be removed or component quality could be sacrificed 

to meet new and amended standard levels and maintain current application prices. 

Manufacturers also stated that the financial burden of developing products to meet new 

and amended energy conservation standards has an opportunity cost due to limited capital 

and R&D dollars. Investments incurred to meet new and amended energy conservation 

standards reflect foregone investments in innovation and the development of new features 

that consumers value and on which manufacturers earn higher absolute profit. 

296 
 

DOE’s engineering analysis only analyzes utility-neutral design changes to meet 

higher efficiency standards and accounts for the costs incurred to achieve those levels. 

While there may be cheaper ways to meet a given efficiency level by reducing other 

features that provide utility, those design paths are not assumed in DOE’s analyses. DOE 

recognizes the opportunity cost of standards-induced investment and accounts for the 

conversion expenditures manufacturers may incur at each TSL, as discussed in section 

IV.I.3.a.iv. Whether a given manufacturer chooses to mitigate these costs (and the 

associated product costs illustrated in the engineering analysis’ cost-efficiency curves) by 

reducing product utility is a business decision and not one mandated by the proposed 

energy conservation standards. 

J. Employment Impact Analysis 

DOE considers employment impacts in the domestic economy as one factor in 

selecting a proposed standard. Employment impacts consist of bothinclude direct and 

indirect impacts. Direct employment impacts are any changes in the number of 

employees of manufacturers of the appliance products which are the subject of this 

rulemakingto standards, their suppliers, and related service firms. Indirect employment 

impacts are changes in national employment that occur due to the shift in expenditures 

and capital investment caused by the purchase and operation of more-efficient appliances. 

The MIA addresses the direct employment impacts that concern manufacturers of battery 

chargers and EPSs. The employment impact analysis addresses the Indirect employment 

impacts. 

297 
 

 

 

 

Indirect employment impacts from standards consist of the net jobs created or 

eliminated in the national economy, other than in the manufacturing sector being 

regulated, due to: (1) reduced spending by end users on energy; (2) reduced spending on 

new energy supplies by the utility industry; (3) increased spending on new products to 

which the new standards apply; and (4) the effects of those three factors throughout the 

economy. DOE expects the net monetary savings from amended and new energy 

conservation standards to be redirected to other forms of economic activity. DOE also 

expects these shifts in spending and economic activity to affect the demand for labor in 

the short term, as explained below. 

One method for assessing the possible effects on the demand for labor of such shifts in 

economic activity is to compare sectoral employment statistics developed by the Labor 

Department’s Bureau of Labor Statistics (BLS).61 The BLS regularly publishes its 

estimates of the number of jobs per million dollars of economic activity in different 

sectors of the economy, as well as the jobs created elsewhere in the economy by this 

same economic activity. Data from BLS indicate that expenditures in the utility sector 

generally create fewer jobs (both directly and indirectly) than do expenditures in other 

sectors of the economy.62 There are many reasons for these differences, including wage 

61 Data on industry employment, hours, labor compensation, value of production, and the implicit price 

deflator for output for these industries are available upon request by calling the Division of Industry 

Productivity Studies (202-691-5618) or by sending a request by e-mail to dipsweb@bls.gov. (Available at: 

http://www.bls.gov/news.release/prin1.nr0.htm.) 62 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional InputOutput Modeling System (RIMS II), U.S. Department of Commerce (1992). 

Comment [A29]: Changes recommended by 

OIRA. 

298 
 

 

 

differences and the fact that the utility sector is more capital-intensive and less laborintensive than other sectors. 63 

Energy conservation standards have the effect of reducing consumer utility bills. 

Because reduced consumer expenditures for energy likely lead to increased expenditures 

in other sectors of the economy, the general effect of energy conservation standards is to 

shift economic activity from a less labor-intensive sector (i.e., the utility sector) to more 

labor-intensive sectors (e.g., the retail and service sectors). Thus, based on the BLS data 

alone, the Department believes net national indirect employment willmay increase due to 

shifts in economic activity resulting from amended standards for Class A EPSs and new 

standards for non-Class A EPSs and battery chargers. 

For the proposed standards considered inIn developing today’s NOPR, DOE 

estimated indirect national employment impacts using an input/output (I–O) model of the 

U.S. economy called Impact of Sector Energy Technologies version 3.1.1 (ImSET). 

ImSET is a spreadsheet model of the U.S. economy that focuses on 187 sectors most 

relevant to industrial, commercial, and residential building energy use.64 ImSET is a 

special purpose version of the “U.S. Benchmark National Input-Output” (I–O) model,65 

which has been designed to estimate the national employment and income effects of 

63 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional InputOutput Modeling System (RIMS II), U.S. Department of Commerce (1992). 64 M.J. Scott, O.V. Livingston, J.M. Roop, R.W. Schultz, and P.J. Balducci, ImSET 3.1: Impact of Sector 

Energy Technologies; Model Description and User’s Guide (2009) (Available at: 

http://www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf). 65 R.L. Stewart, J.B. Stone, and M.L. Streitwieser. U.S. Benchmark Input-Output Accounts, 2002. Survey 

of Current Business, October 2007. (Available at 

http://www.bea.gov/scb/pdf/2007/10%20October/1007_benchmark_io.pdf) 

299 
 

 

 

energy-saving technologies. The ImSET software includes a computer-based I–O model 

with structural coefficients to characterize economic flows among the 187 sectors. 

ImSET’s national economic I–O structure is based on a 2002 U.S. benchmark table, 

specially aggregated to the 187 sectors. DOE estimated changes in expenditures using the 

NIA spreadsheet. Using ImSET, DOE then estimated the net national, indirect 

employment impacts by sector of potential amended standards for Class A EPSs and new 

standards for non-Class A EPSs and battery chargers.187 sectors most relevant to 

industrial, commercial, and residential building energy use. DOE notes that ImSET is not 

a general equilibrium forecasting model. Given the relatively small change to 

expenditures due to efficiency standards and the resulting small changes to employment, 

however, DOE believes that the size of any forecast error caused by using ImSET will be 

small. 

No comments were received on the preliminary TSD for battery chargers and 

EPSs concerning the employment impacts analysis. For more details on the employment 

impact analysis, see chapter 13 of the NOPR TSD. 

K. Utility Impact Analysis 

The utility impact analysis estimates several important effects on the utility 

industry that would result from the adoption of new or amended energy conservation 

standards. For the NOPR analysis, DOE used the NEMS-BT model to generate forecasts 

of electricity and natural gas consumption, electricity generation by plant type, and 

electric generating capacity by plant type, that would result from each considered TSL. 

Comment [A30]: Changees recommended by 

OIRA. 

300 
 

 

DOE obtained the energy savings inputs associated with efficiency improvements to the 

subject products from the NIA. DOE conducts the utility impact analysis as a scenario 

that departs from the latest AEO Reference case. For this NOPR, the estimated impacts of 

amended energy conservation standards are the differences between values forecasted by 

NEMS–BT and the values in the AEO2010 Reference case (which does not contemplate 

amended standards). 

As part of the utility impact analysis, DOE used NEMS-BT to assess the impacts 

on natural gas prices of the reduced demand for natural gas projected to result from the 

considered standards. DOE also used NEMS-BT to assess the impacts on electricity 

prices of the reduced need for new electric power plants and infrastructure projected to 

result from the considered standards. In NEMS-BT, changes in power generation 

infrastructure affect utility revenue, which in turn affects electricity prices. DOE 

estimated the change in electricity prices projected to result over time from each 

considered TSL. The benefits associated with the impacts of proposed standards on 

energy prices are discussed in section IV.G.5. 

For more details on the utility impact analysis, see chapter 14 of the NOPR TSD 

L. Environmental Assessment 

Pursuant to the National Environmental Policy Act of 1969 and the requirements 

of 42 U.S.C. 6295(o)(2)(B)(i)(VI), DOE has prepared a draft environmental assessment 

(EA) of the impacts of amended energy conservation standards for Class A EPSs and new 

301 
energy conservation standards for non-Class A EPSs and battery chargers in today’s 

proposed rule, which it has included as chapter 15 of the NOPR TSD. 

L. Emissions Analysis 

In the EAemissions analysis, DOE estimated the reduction in power sector 

emissions of carbon dioxide (CO2), nitrogen oxides (NOx), and mercury (Hg) usingfrom 

amended energy conservation standards for Class A EPSs and new energy conservation 

standards for non-Class A EPSs and battery chargers. DOE used the NEMS-BT computer 

model. In the EA, NEMS-BT, which is run similarly to the AEO NEMS, except that 

battery charger and EPS energy use is reduced by the amount of energy saved (by fuel 

type) due to each TSL. The inputs of national energy savings come from the NIA 

spreadsheet model, while the output is the forecasted physical emissions. The net benefit 

of each TSL in today’s proposed rule is the difference between the forecasted emissions 

estimated by NEMS-BT at each TSL and the AEO 2010 Reference Case. NEMS-BT 

tracks CO2 emissions using a detailed module that provides results with broad coverage 

of all sectors and inclusion of interactive effects. For today’s NOPR, DOE used the 

version of NEMS-BT based on AEO2010, which incorporated projected effects of all 

emissions regulations promulgated as of January 31, 2010. For the final rule, DOE 

intends to revise the emissions analysis using the most current version of NEMS-BT. 

SO2 emissions from affected electric generating units (EGUs) are subject to 

nationwide and regional emissions cap-and-trade programs, and DOE has preliminarily 

Comment [A31]: Change recommended by 

OIRA. 

302 
 

 

 

determined that these programs create uncertainty about the impact of energy 

conservation standards on SO2 emissions. Title IV of the Clean Air Act sets an annual 

emissions cap on SO2 for affected EGUs in the 48 contiguous States and the District of 

Columbia (D.C.). SO2 emissions from 28 eastern states and D.C. are also limited under 

the Clean Air Interstate Rule (CAIR; 70 FR 25162 (May 12, 2005)), which created an 

allowance-based trading program. Although CAIR was remanded to EPA by the U.S. 

Court of Appeals for the District of Columbia Circuit (D.C. Circuit), see North Carolina 

v. EPA, 550 F.3d 1176 (D.C. Cir. 2008), it remains in effect temporarily, consistent with 

the D.C. Circuit’s earlier opinion in North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 

2008). On July 6, 2011 EPA issued a replacement for CAIR, the Cross-State Air 

Pollution Rule. 76 FR 48208 (August 8, 2011). (See 

http://www.epa.gov/crossstaterule/On August 2, 2010, EPA issued the Transport Rule 

proposal, a replacement for CAIR, which would limit emissions from EGUs in 32 states 

and may allow some amount of interstate trading. 75 FR 45210 (Aug. 2, 2010).

 However, EPA has yet to issue a final Transport Rule and, as a result, the Transport 

Rule’s impact on EGU emissions is currently uncertain. EPA issued the final transport 

rule, entitled the Cross-State Air Pollution Rule, on July 6, 2011.66 

(http://www.epa.gov/crossstaterule/)). On December 30, 2011, however, the D.C. Circuit 

stayed the new rules while a panel of judges reviews them, and told EPA to continue 

enforcing CAIR (see EME Homer City Generation v. EPA, No. 11-1302, Order at *2 

(D.C. Cir. Dec. 30, 2011)). The AEO 2010 NEMS used for today’s NOPR assumes the 

implementation of CAIR. 

66 DOE notes that future iterations of the NEMS-BT model will incorporate any changes necessitated by 

issuance of the Cross-State Air Pollution Rule. 

303 
 

 

 

The attainment of emissions caps is typically flexible among EGUs and is 

enforced through the use of emissions allowances and tradable permits. Under existing 

EPA regulations any excess SO2 emissions allowances resulting from the lower 

electricity demand caused by the imposition of an efficiency standard could be used to 

permit offsetting increases in SO2 emissions by any regulated EGU. However, if the 

amended and new standards resulted in a permanent increase in the quantity of unused 

emissions allowances, there would be an overall reduction in SO2 emissions from the 

standards. While there remains some uncertainty about the ultimate effects of efficiency 

standards on SO2 emissions covered by the existing cap-and-trade system, the NEMS-BT 

modeling system that DOE uses to forecast emissions reductions currently indicates that 

no physical reductions in power sector emissions would occur for SO2. 

A cap on NOx emissions, affecting electric generating units in As discussed 

above, the CAIR region, means that AEO 2010 NEMS used for today’s NOPR assumes 

the implementation of CAIR, which established a cap on NOx emissions in 28 eastern 

States and the District of Columbia. With CAIR in effect, the energy conservation 

standards for battery chargerchargers and EPSs mayare expected to have little or no 

physical effect on NOx emissions in the 28 easternthose States and the DC covered by 

CAIR. The , for the same reasons that they may have little effect on SO2 emissions. 

However, the proposed standards would, however, be expected to reduce NOx emissions 

in thosethe 22 States not affected by the CAIR. As a resultFor these 22 States, DOE 

304 
 

usedis using the NEMS-BT to forecast emissionestimate NOx emissions reductions from 

the standards considered forin today’s NOPR. 

On December 21, 2011, EPA announced national emissions standards for 

hazardous air pollutants (NESHAPs) for mercury and certain other pollutants emitted 

from coal and oil-fired EGUs. (See 

http://epa.gov/mats/pdfs/20111216MATSfinal.pdfSimilar to emissions of SO2 and NOx, 

future emissions of Hg would have been subject to emissions caps. In May 2005, EPA 

issued the Clean Air Mercury Rule (CAMR). 70 FR 28606 (May 18, 2005). CAMR 

would have permanently capped emissions of mercury for new and existing coal-fired 

power plants in all states by 2010. However, on February 8, 2008, the D.C. Circuit issued 

a decision in New Jersey v. Environmental Protection Agency, 517 F.3d 574 (D.C. Cir. 

2008), in which it vacated CAMR. EPA has decided to develop emissions standards for 

power plants under Section 112 of the Clean Air Act, consistent with the DC Circuit’s 

opinion on CAMR. See . Pending EPA’s forthcoming revisions to the rule, DOE is 

excluding CAMR from its environmental assessment. In the absence of CAMR, a DOE 

standard would likely reduce Hg emissions and DOE used NEMS-BT to estimate these 

reductions. However, DOE continues to review the impact of rules that reduce energy 

consumption on Hg emissions, and may revise its assessment of Hg emission reductions 

in future rulemakings. 

). The NESHAPs do not include a trading program and, as such, DOE’s energy 

conservation standards would likely reduce Hg emissions. For the emissions analysis for 

this rulemaking, DOE estimated mercury emissions reductions using NEMS-BT based on 

305 
 

 

AEO2010, which does not incorporate the NESHAPs. DOE expects that future versions 

of the NEMS-BT model will reflect the implementation of the NESHAPs. 

For more details on the emissions analysis, see chapter 15 of the NOPR TSD. 

M. Monetizing Carbon Dioxide and Other Emissions Impacts 

As part of the development of this proposed rule, DOE considered the estimated 

monetary benefits likely to result from the reduced emissions of CO2 and NOX that are 

expected to result from each of the TSLs considered. In order to make this calculation 

similar to the calculation of the NPV of consumer benefit, DOE considered the reduced 

emissions expected to result over the lifetime of products shipped in the forecast period 

for each TSL. This section summarizes the basis for the monetary values used for each of 

these emissions and presents values considered in this rulemaking. 

For today’s NOPR, DOE is relying on a set of values for the social cost of carbon 

(SCC) that was developed by an interagency process. A summary of the basis for these 

values is provided below, and a more detailed description of the methodologies used is 

provided as an appendix to chapter 16 of the TSD. 

1. Social Cost of Carbon 

Under section 1(b) of Executive Order 12866, agencies must, to the extent 

permitted by law, “assess both the costs and the benefits of the intended regulation and, 

recognizing that some costs and benefits are difficult to quantify, propose or adopt a 

306 
 

 

 

 

regulation only upon a reasoned determination that the benefits of the intended regulation 

justify its costs.” The purpose of the SCC estimates presented here is to allow agencies to 

incorporate the monetized social benefits of reducing CO2 emissions into cost-benefit 

analyses of regulatory actions that have small, or “marginal,” impacts on cumulative 

global emissions. The estimates are presented with an acknowledgement of the many 

uncertainties involved and with a clear understanding that they should be updated over 

time to reflect increasing knowledge of the science and economics of climate impacts. 

As part of the interagency process that developed these SCC estimates, technical 

experts from numerous agencies met on a regular basis to consider public comments, 

explore the technical literature in relevant fields, and discuss key model inputs and 

assumptions. The main objective of this process was to develop a range of SCC values 

using a defensible set of input assumptions grounded in the existing scientific and 

economic literatures. In this way, key uncertainties and model differences transparently 

and consistently inform the range of SCC estimates used in the rulemaking process. 

a. Monetizing Carbon Dioxide Emissions 

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited 

to) changes in net agricultural productivity, human health, property damages from 

increased flood risk, and the value of ecosystem services. Estimates of the SCC are 

provided in dollars per metric ton of carbon dioxide. 

307 
 

When attempting to assess the incremental economic impacts of carbon dioxide 

emissions, the analyst faces a number of serious challenges. A recent report from the 

National Research Council67 points out that any assessment will suffer from uncertainty, 

speculation, and lack of information about (1) future emissions of greenhouse gases, (2) 

the effects of past and future emissions on the climate system, (3) the impact of changes 

in climate on the physical and biological environment, and (4) the translation of these 

environmental impacts into economic damages. As a result, any effort to quantify and 

monetize the harms associated with climate change will raise serious questions of 

science, economics, and ethics and should be viewed as provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates 

can be useful in estimating the social benefits of reducing carbon dioxide emissions. 

Consistent with the directive in Executive Order 12866 quoted above, the purpose of the 

SCC estimates presented here is to make it possible for Federal agencies to incorporate 

the social benefits from reducing carbon dioxide emissions into cost-benefit analyses of 

regulatory actions that have small, or “marginal,” impacts on cumulative global 

emissions. Most Federal regulatory actions can be expected to have marginal impacts on 

global emissions. 

For such policies, the agency can estimate the benefits from reduced (or costs 

from increased) emissions in any future year by multiplying the change in emissions in 

that year by the SCC value appropriate for that year. The net present value of the benefits 

67 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and 

Use. National Academies Press: Washington, DC (2009). 

308 
 

 

 

 

 

 

can then be calculated by multiplying each of these future benefits by an appropriate 

discount factor and summing across all affected years. This approach assumes that the 

marginal damages from increased emissions are constant for small departures from the 

baseline emissions path, an approximation that is reasonable for policies that have effects 

on emissions that are small relative to cumulative global carbon dioxide emissions. For 

policies that have a large (non-marginal) impact on global cumulative emissions, there is 

a separate question of whether the SCC is an appropriate tool for calculating the benefits 

of reduced emissions. This concern is not applicable to this notice, and DOE does not 

attempt to answer that question here. 

At the time of the preparation of this notice, the most recent interagency estimates 

of the potential global benefits resulting from reduced CO2 emissions in 2010, expressed 

in 2010$, were $4.9, $22.3, $36.5, and $67.6 per metric ton avoided. For emissions 

reductions that occur in later years, these values grow in real terms over time. 

Additionally, the interagency group determined that a range of values from 7 percent to 

23 percent should be used to adjust the global SCC to calculate domestic effects,68 

although preference is given to consideration of the global benefits of reducing CO2 

emissions. 

It is important to emphasize that the interagency process is committed to updating 

these estimates as the science and economic understanding of climate change and its 

68 It is recognized that this calculation for domestic values is approximate, provisional, and highly 

speculative. There is no a priori reason why domestic benefits should be a constant fraction of net global 

damages over time. 

309 
 

 

impacts on society improves over time. Specifically, the interagency group has set a 

preliminary goal of revisiting the SCC values within 2 years or at such time as 

substantially updated models become available, and to continue to support research in 

this area. In the meantime, the interagency group will continue to explore the issues 

raised by this analysis and consider public comments as part of the ongoing interagency 

process. 

b. Social Cost of Carbon Values Used in Past Regulatory Analyses 

To date, economic analyses for Federal regulations have used a wide range of 

values to estimate the benefits associated with reducing carbon dioxide emissions. In the 

final model year 2011 CAFE rule, the U.S. Department of Transportation (DOT) used 

both a “domestic” SCC value of $2 per ton of CO2 and a “global” SCC value of $33 per 

ton of CO2 for 2007 emission reductions (in 2007$), increasing both values at 2.4 percent 

per year.69 DOT also included a sensitivity analysis at $80 per ton of CO2. See Average 

Fuel Economy Standards Passenger Cars and Light Trucks Model Year 2011, 74 FR 

14196 (March 30, 2009) (Final Rule); Final Environmental Impact Statement Corporate 

Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2011­

2015 at 3-90 (Oct. 2008) (Available at: http://www.nhtsa.gov/fuel-economy). A domestic 

SCC value is meant to reflect the value of damages in the United States resulting from a 

unit change in carbon dioxide emissions, while a global SCC value is meant to reflect the 

value of damages worldwide. 

69 Throughout this section, references to tons of CO2 refer to metric tons. 

310 
 

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per ton 

of CO2 (in 2006$) for 2011 emission reductions (with a range of $0$14 for sensitivity 

analysis), also increasing at 2.4 percent per year. See Average Fuel Economy Standards, 

Passenger Cars and Light Trucks, Model Years 2011-2015, 73 FR 24352 (May 2, 2008) 

(Proposed Rule); Draft Environmental Impact Statement Corporate Average Fuel 

Economy Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at 3-58 

(June 2008) (Available at: http://www.nhtsa.gov/fuel-economy). A regulation for 

packaged terminal air conditioners and packaged terminal heat pumps finalized by DOE 

in October of 2008 used a domestic SCC range of $0 to $20 per ton CO2 for 2007 

emission reductions (in 2007$).73 FR 58772, 58814 (Oct. 7, 2008) In addition, EPA’s 

2008 Advance Notice of Proposed Rulemaking on Regulating Greenhouse Gas Emissions 

Under the Clean Air Act identified what it described as “very preliminary” SCC 

estimates subject to revision. 73 FR 44354 (July 30, 2008). EPA’s global mean values 

were $68 and $40 per ton CO2 for discount rates of approximately 2 percent and 3 

percent, respectively (in 2006$ for 2007 emissions). 

In 2009, an interagency process was initiated to offer a preliminary assessment of 

how best to quantify the benefits from reducing carbon dioxide emissions. To ensure 

consistency in how benefits are evaluated across agencies, the Administration sought to 

develop a transparent and defensible method, specifically designed for the rulemaking 

process, to quantify avoided climate change damages from reduced CO2 emissions. The 

interagency group did not undertake any original analysis. Instead, it combined SCC 

estimates from the existing literature to use as interim values until a more comprehensive 

311 
 

 

 

analysis could be conducted. The outcome of the preliminary assessment by the 

interagency group was a set of five interim values: global SCC estimates for 2007 (in 

2006$) of $55, $33, $19, $10, and $5 per ton of CO2. 

These interim values represent the first sustained interagency effort within the 

U.S. government to develop an SCC for use in regulatory analysis. The results of this 

preliminary effort were presented in several proposed and final rules and were offered for 

public comment in connection with proposed rules, including the joint EPA-DOT fuel 

economy and CO2 tailpipe emission proposed rules. 

c. Current Approach and Key Assumptions 

Since the release of the interim values, the interagency group reconvened on a 

regular basis to generate improved SCC estimates, which were considered for this 

proposed rule. Specifically, the group considered public comments and further explored 

the technical literature in relevant fields. The interagency group relied on three integrated 

assessment models (IAMs) commonly used to estimate the SCC: the FUND, DICE, and 

PAGE models.70 These models are frequently cited in the peer-reviewed literature and 

were used in the last assessment of the Intergovernmental Panel on Climate Change. Each 

model was given equal weight in the SCC values that were developed. 

70 The models are described in appendix 16-A of the TSD. 

312 
Each model takes a slightly different approach to model how changes in 

emissions result in changes in economic damages. A key objective of the interagency 

process was to enable a consistent exploration of the three models while respecting the 

different approaches to quantifying damages taken by the key modelers in the field. An 

extensive review of the literature was conducted to select three sets of input parameters 

for these models: climate sensitivity, socio-economic and emissions trajectories, and 

discount rates. A probability distribution for climate sensitivity was specified as an input 

into all three models. In addition, the interagency group used a range of scenarios for the 

socio-economic parameters and a range of values for the discount rate. All other model 

features were left unchanged, relying on the model developers’ best estimates and 

judgments. 

The interagency group selected four SCC values for use in regulatory analyses. 

Three values are based on the average SCC from three integrated assessment models, at 

discount rates of 2.5, 3, and 5 percent. The fourth value, which represents the 95th 

percentile SCC estimate across all three models at a 3-percent discount rate, is included 

to represent higher-than-expected impacts from temperature change further out in the 

tails of the SCC distribution. For emissions (or emission reductions) that occur in later 

years, these values grow in real terms over time, as depicted in Table IV-31Table IV-31. 

313 
 

Table IV-31 Social Cost of CO2, 2010–2050 (in 2007 dollars per metric ton) 

Discount Rate 

5% 

Avg 

3% 2.5% 

Avg Avg 

3% 

95th 

2010 

2015 

2020 

2025 

2030 

2035 

2040 

2045 

2050 

4.7 

5.7 

6.8 

8.2 

9.7 

11.2 

12.7 

14.2 

15.7 

21.4 

23.8 

26.3 

29.6 

32.8 

36.0 

39.2 

42.1 

44.9 

35.1 

38.4 

41.7 

45.9 

50.0 

54.2 

58.4 

61.7 

65.0 

64.9 

72.8 

80.7 

90.4 

100.0 

109.7 

119.3 

127.8 

136.2 

It is important to recognize that a number of key uncertainties remain, and that 

current SCC estimates should be treated as provisional and revisable since they will 

evolve with improved scientific and economic understanding. The interagency group also 

recognizes that the existing models are imperfect and incomplete. The National Research 

Council report mentioned above points out that there is tension between the goal of 

producing quantified estimates of the economic damages from an incremental ton of 

carbon and the limits of existing efforts to model these effects. There are a number of 

concerns and problems that should be addressed by the research community, including 

research programs housed in many of the Federal agencies participating in the 

interagency process to estimate the SCC. 

DOE recognizes the uncertainties embedded in the estimates of the SCC used for 

cost-benefit analyses. As such, DOE and others in the U.S. Government intend to 

periodically review and reconsider those estimates to reflect increasing knowledge of the 

314 
 

 

 

science and economics of climate impacts, as well as improvements in modeling. In this 

context, statements recognizing the limitations of the analysis and calling for further 

research take on exceptional significance. 

In summary, in considering the potential global benefits resulting from reduced 

CO2 emissions, DOE used the most recent values identified by the interagency process, 

adjusted to 2010$ using the GDP price deflator. For each of the four cases specified, the 

values used for emissions in 2010 were $4.9, $22.3, $36.5, and $67.6 per metric ton 

avoided (values expressed in 2010$).71 To monetize the CO2 emissions reductions 

expected to result from amended standards for Class A EPSs and new standards for nonClass A EPSs and battery chargers in 2013–2042, DOE used the values identified in 

Table A1 of the “Social Cost of Carbon for Regulatory Impact Analysis Under Executive 

Order 12866,” which is reprinted in appendix 16-A of the NOPR TSD, appropriately 

adjusted to 2010$. To calculate a present value of the stream of monetary values, DOE 

discounted the values in each of the four cases using the specific discount rate that had 

been used to obtain the SCC values in each case. 

d. Valuation of Other Emissions Reductions 

DOE investigated the potential monetary benefit of reduced NOx emissions from 

the TSLs it considered. As noted above, new or amended energy conservation standards 

would reduce NOx emissions in those 22 states that are not affected by the CAIR. DOE 

estimated the monetized value of NOx emissions reductions resulting from each of the 

71 Table A1 presents SCC values through 2050. For DOE’s calculation, it derived values after 2050 using 

the 3-percent per year escalation rate used by the interagency group. 

315 
 

 

 

 

TSLs considered for today’s NOPR based on environmental damage estimates found in 

the relevant scientific literature. Available estimates suggest a very wide range of 

monetary values, ranging from $370 per ton to $3,800 per ton of NOx from stationary 

sources, measured in 2001$ (equivalent to a range of $450 to $4,623 per ton in 2010$).72 

In accordance with OMB guidance, DOE conducted two calculations of the monetary 

benefits derived using each of the economic values used for NOx, one using a real 

discount rate of 3 percent and another using a real discount rate of 7 percent.73 

DOE is aware of multiple agency efforts to determine the appropriate range of values 

used in evaluating the potential economic benefits of reduced Hg emissions. DOE has 

decided to await further guidance regarding consistent valuation and reporting of Hg 

emissions before it once again monetizes Hg emissions in its rulemakings. 

N. Discussion of Other Comments 

NEEP viewed the adoption of strong Federal energy conservation standards for 

battery chargers and EPSs as smart, minimal-cost mechanisms to help Northeast states 

achieve their aggressive energy savings goals. (NEEP, No. 49 at p. 3) 

Lester suggested that DOE consider establishing incentive programs for U.S. 

manufacturers as an alternative to setting efficiency standards. The company claimed that 

these incentives would encourage the development of efficient, domestically produced 

72 For additional information, refer to U.S. Office of Management and Budget, Office of Information and 

Regulatory Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal Entities, Washington, DC. 73 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 

316 
 

products. (Lester, No. 50 at p. 3) DOE notes that this rulemaking constitutes an 

“economically significant regulatory action” under Executive Order (E.O.) 12866, 

Regulatory Planning and Review. 58 FR 51735 (October 4, 1993) Under 10 CFR part 

430, subpart C, appendix A, section III.12, DOE must evaluate non-regulatory 

alternatives to proposed standards by performing a regulatory impact analysis (RIA). 61 

FR 36981 at p. 36978 (July 15, 1996) In this RIA, DOE compared the effectiveness of 

multiple possible alternatives to standards, including manufacturer tax credits for 

efficient battery chargers and EPSs. The results of this analysis are available in chapter 

17 of the TSD. 

During manufacturer interviews, DOE also received questions regarding multivoltage and multi-capacity battery chargers. Particularly with multi-voltage battery 

chargers, it is possible for the device to fall into more than one product class and 

manufacturers sought clarification on how to certify these devices. DOE notes that its 

recently promulgated test procedure describes the manner in which a multi-voltage or 

multi-capacity device must be tested. 76 FR 31750. For these devices, manufacturers may 

be required to test their product more than once and the batteries with which the devices 

are used for each test may put the battery charger into two product classes. If that is the 

case, the device would need to be certified for each product class for which it has been 

tested. This approach is consistent with DOE’s approach for switch-selectable EPSs and 

DOE tentatively believes that this approach will result in the maximum energy savings 

for its proposed standards. DOE will consider alternative approaches and requests 

317 
 

 

 

feedback from manufacturers and other interested parties on this proposal and any others, 

such as certifying at just the highest or lowest capacity or voltage. 

O. Marking Requirements 

Under 42 U.S.C. 6294(a)(5), Congress granted DOE with the specific authority to 

establish labeling or marking requirements for a number of consumer products. Among 

these products are battery chargers and EPSs. DOE notes that the creation of such 

marking requirements, particularly for a portion of the products covered by today’s 

proposal, was specifically contemplated by Congress. In particular, EISA 2007 set 

standards for Class A EPSs and created marking requirements for these products. Section 

301 of that public law specified that all Class A EPSs shall be clearly and permanently 

marked in accordance with the "International Efficiency Marking Protocol for External 

Power Supplies" (the "Marking Protocol").74 (42 U.S.C. 6295(u)(3)(C)) 

The Marking Protocol, developed by the EPA in consultation with stakeholders 

both within and outside the United States, was originally designed in 2005 and updated in 

2008 to meet the needs of those voluntary and regulatory programs in place at those 

times. In particular, the Marking Protocol defines efficiency mark "IV", which 

corresponds to the current Federal standard for Class A EPSs, and efficiency mark "V", 

which corresponds to ENERGY STAR version 2.0. (The ENERGY STAR program for 

EPSs ended on December 31, 2010.) In addition, these marks currently apply only to 

74 U.S. EPA, "International Efficiency Marking Protocol for External Power Supplies," October 2008, 

available at Docket No. 62. 

318 
 

 

single-voltage EPSs with nameplate output power less than 250 watts, but not to 

multiple-voltage or high-power EPSs. 

In today's notice, DOE proposes to amend the product marking (or "labeling") 

requirements for EPSs and is considering adopting a similar requirement for battery 

chargers. Specifically, DOE proposes to (1) extend to all EPSs the marking requirement 

created by EISA 2007, which currently applies only to Class A EPSs; (2) reserve an 

efficiency mark (or marks) in the Marking Protocol for standard levels in the final rule 

that do not already have a corresponding mark; and (3) require that EPSs in proposed 

product class N bear a specific marking to distinguish them from other EPSs and 

facilitate compliance verification. In addition, DOE is considering establishing a 

distinguishing mark for EPSs for certain security or life safety alarm or surveillance 

systems and is considering requiring that battery chargers be marked in accordance with a 

battery charger marking protocol similar to that for EPSs. DOE welcomes comment on 

all of these issues. 

DOE notes that it is proposing standards for EPSs in product classes B, C, D, and 

E that exceed efficiency level "V", the highest level currently defined in the Marking 

Protocol. In addition, it is proposing standards for multiple-voltage and high-power EPSs. 

DOE is working with EPA to revise the Marking Protocol to accommodate all of the new 

and amended standards for EPSs being proposed today. 

319 
 

DOE is also proposing to create a separate product class (product class N) for 

EPSs that cannot power an end-use consumer product directly. They would be subject to 

less stringent standards than those being proposed today for their "direct operation" 

counterparts. To aid in determining whether EPSs are in compliance with standards, DOE 

proposes that (1) a Class A EPS in product class N be permanently marked with an "N" 

as a superscript to the circle that contains the appropriate Roman numeral; (2) a nonClass A EPS in product class N be permanently marked with the abbreviation "EPS-N"; 

(3) an EPS in product class N that is sold separately from the battery charger or end-use 

consumer product with which it is intended to be used shall also be permanently marked 

with the manufacturer and model number of that battery charger or end-use consumer 

product; and (4) an EPS that is in product class N but, nonetheless, meets the relevant 

standard set for direct operation EPSs (and bears the appropriate Roman numeral) need 

not be marked with an "N", with "EPS-N", nor with the manufacturer and model number 

of the associated device. 

DOE seeks input on what distinguishing mark should appear on EPSs for certain 

security and life safety equipment. A recently enacted law amended EPCA to exclude 

these devices from the no-load mode efficiency standards. Pub. L. 111-360 (Jan. 4, 2011) 

(to be codified at 42 U.S.C. 6295(u)(3)). The exclusion applies to AC-AC EPSs 

manufactured before July 1, 2017, that have nameplate output of 20 watts or more, are 

certified as being designed to be connected to a security or life safety alarm or 

surveillance system component (as defined in the law), and are permanently marked with 

a distinguishing mark for such products as established within the Marking Protocol. No 

320 
 

such distinguishing mark exists within the Marking Protocol, but DOE intends to work 

with EPA and other stakeholders to establish such a mark. The mark, which could be the 

word "ACTIVE" or an "A" in a circle, for example, would likely be required to appear 

adjacent to the appropriate Roman numeral. DOE welcomes input on what mark would 

be appropriate, where it should be located, and any other details related to how that mark 

should be presented on a given device. 

Lastly, EPS efficiency markings can be useful in certain circumstances to help 

verify whether a given product complies with the relevant standards. To assist in ensuring 

that compliant products can be readily identified, DOE is also considering marking 

requirements for battery chargers. NRDC submitted a comment in November 2010, after 

the close of the preliminary analysis comment period, requesting that DOE consider such 

a marking protocol for battery chargers. (NRDC, No. 56) NRDC claimed that 

establishing an efficiency marking protocol for battery chargers would have several 

benefits, including creating a simple vocabulary for all stakeholders, facilitating 

enforcement, lowering the cost of compliance for industry by facilitating international 

adoption, and encouraging voluntary adoption of higher levels. NRDC proposed using 

Roman numerals, as is done for EPSs. To avoid confusion, the Roman numerals on 

battery chargers would appear next to the word "BC", as shown in Table IV-32Table IV32, in contrast to the Roman numerals on EPSs, which stand alone. NRDC's comment 

also includes recommendations on where the mark should be located. 

321 
Consistent with this suggestion, DOE is considering adopting a marking protocol 

for battery chargers that would have "BC III" denote the battery charger standard levels 

adopted in the final rule. This marking would give other standards-setting bodies the 

option of defining a lower efficiency level ("BC II") for use on BCs sold to consumers 

outside the United States and would reserve "BC I" for products that do not meet the 

criteria for the other (higher) marks. A similar approach was used when the efficiency 

marking protocol for EPSs was established. The formulas given for each of the battery 

charger product classes for BC Level III match the standards being proposed today and 

could change. 

Table IV-32 Proposed Efficiency Marking Protocol for Battery Chargers 

Level Description Maximum Annual Energy Consumption† 

BC I Used if no other criteria are met 

BC II Less than Level III TBD 

BC III 

DOE standards 

(compliance date in 

2013) 

PC 1 3.04 

PC 2 = 0.2095(Ebatt*) + 5.87 

PC 3 

For Ebatt < 9.74 Wh, 

= 4.68 

For Ebatt ≥ 9.74 Wh, 

= 0.0933(Ebatt) + 3.77 

PC 4 

For Ebatt < 9.71 Wh, 

= 9.03 

For Ebatt ≥ 9.71 Wh, 

= 0.2411(Ebatt) + 6.69 

PC 5 

For Ebatt < 355.18 Wh, 

= 20.06 

For Ebatt ≥ 355.18 Wh, 

= 0.0219(Ebatt) + 12.28 

PC 6 For Ebatt < 239.48 Wh 

= 30.37 

322 
 

 

For Ebatt ≥ 239.48 Wh 

= 0.0495(Ebatt) + 18.51 

PC 7 = 0.502(Ebatt) + 4.53 

PC 8 0.66 

PC 9 See Product Class 2, 3, or 4 depending 

upon battery voltage. 

PC 10 1.50 

and higher 

BC IV Reserved for future use TBD 

†

 Annual energy consumption is determined using the DOE test procedure and 

compliance formulas. Ebatt stands for battery energy. 

DOE is considering multiple approaches for determining where on the external 

housing of the battery charger the mark shall be placed. NRDC's proposal specifies where 

the mark shall be placed in cases where the battery charger has more than one housing, as 

described in Table IV-33Table IV-33. (NRDC, No. 56) DOE's concern with NRDC's 

proposal is the difficulty in accurately identifying and locating charge control in a battery 

charger. Alternatively, DOE could give manufacturers the flexibility to choose where to 

place the mark. DOE expects that manufacturers will most often choose to place the mark 

on a cradle or charging base, if one is present, or on the end-use consumer product. 

Table IV-33 Proposed Location for Battery Charger Marking 

Form Factor Location of Battery Charger Marking 

Three separate housings Charge control component 

Power supply and charge control together, 

battery separate 

Power supply & charge control component 

Charge control and battery together, power 

supply separate 

Charge control & battery component 

323 
 

DOE is also considering other requirements for the battery charger mark. For 

example, DOE could require that the mark be placed on a nameplate or in an equally 

visible location or that the font size used for the mark be similar to that used for other 

markings on the product such as the UL and CE symbols. DOE is aware that the CEC 

also is considering establishing marking requirements for battery chargers and is 

following that process as it develops. If the CEC adopts marking requirements for battery 

chargers within the scope of today's notice, those requirements would be preempted by 

any future battery charger marking requirements adopted by DOE. Manufacturers would 

then have to transition from meeting the CEC's requirements to meeting DOE's 

requirements. Therefore, DOE would consider adopting the CEC's requirements to 

minimize the burden associated with that transition. 

DOE recognizes that there are several challenges inherent in creating a marking 

protocol for battery chargers. First, it may prove difficult to specify unambiguously 

where the mark should be placed given the variety of form factors found in the 

marketplace. Second, in contrast to EPSs, some battery chargers may not have a 

nameplate to add a mark to. Third, in those cases where the mark is placed on an end-use 

consumer product containing a battery charger, it may be misinterpreted by consumers as 

an endorsement of that product. DOE welcomes comment on these issues, NRDC's 

proposal, and any other issues related to efficiency markings for battery chargers. 

324 
 

 

P. Reporting Requirements 

For battery chargers and non-Class A external power supplies, DOE will establish 

certification, compliance, and enforcement provisions in a future rulemaking. This future 

rulemaking will outline the necessary information that manufacturers must provide in 

order to certify compliance with any energy conservation standards established by this 

rulemaking. 

Q. Manufacturer Learning Rates 

For some of DOE’s recent rulemakings, it has begun using historical pricing data 

to demonstrate that manufacturers tend to become more efficient producers of their 

products. As manufacturers become better at producing their products, manufacturing 

costs can decrease, performance (including efficiency) can increase, and these benefits 

can be passed along to the manufacturers’ customers. However, for EPS and battery 

charger manufacturers, DOE does not have historical pricing data or indices to reference 

to demonstrate such manufacturer efficiencies over time. This situation is partially due to 

the nature of EPS and battery charger design. EPSs and battery chargers are made up of 

many electrical components whose size, cost, and performance rapidly change, which 

leads to relatively short design lifetimes. DOE also lacks the necessary data because the 

test procedures for EPSs and battery chargers are new, which means the metrics are new, 

and, consequently, virtually no data on performance relative to price is currently 

available. Therefore, DOE is not incorporating manufacturer learning rates into today’s 

NOPR. 

325 

Comment [A32]: Changes recommended by 

OIRA. 
 

 

V. Analytical Results 

The following section addresses the results from DOE’s analyses with respect to 

potential energy efficiency standards for the various product classes examined as part of 

this rulemaking. Issues discussed include the TSLs examined by DOE, the projected 

impacts of each of these levels if adopted as energy efficiency standards for battery 

chargers and EPSs, and the standards levels that DOE is tentatively proposing in today’s 

NOPR. Additional details regarding the analyses conducted by the agency are contained 

in the publicly available TSD supporting this proposal. 

A. Trial Standard Levels 

DOE analyzed the benefits and burdens of multiple TSLs for the products that are 

the subject of today’s proposed rule. A description of each TSL DOE analyzed is 

provided below. DOE attempted to limit the number of TSLs considered for the NOPR 

by excluding efficiency levels that do not exhibit significantly different economic and/or 

engineering characteristics from the efficiency levels already selected as a TSL. While 

the NOPR presents only the results for those efficiency levels in TSL combinations, the 

TSD contains a more fulsome discussion and includes results for all efficiency levels that 

DOE examined. 

1. External Power Supply TSLs 

Table V-1Table V.1 presents the TSLs for EPSs and the corresponding efficiency 

levels. DOE chose to analyze product class B directly and scale the results from the 

engineering analysis to product classes C, D, and E. As a result, the TSLs for these three 

326 
product classes correspond to the TSLs for product class B. DOE created separate TSLs 

for the multiple-voltage (product class X) and high-power (product class H) EPSs to 

determine their standards. DOE did not analyze TSLs above the baseline CSL for product 

class N and instead proposes applying the baseline EISA 2007 standard to all EPSs in this 

product class, as discussed in section B below. 

Table V-1 Trial Standard Levels for External Power Supplies 

Product Class 

Trial Standard Level 

TSL 1 TSL 2 TSL 3 

DC Output, Basic-Voltage (B) CSL 2 CSL 3 CSL 4 

DC Output, Low-Voltage (C) Scaled Product Classes 

(Same CSLs as Product Class B) AC Output, Basic-Voltage (D) 

AC Output, Low-Voltage (E) 

Multiple Voltage (X) CSL 1 CSL 2 CSL 3 

High-Power (H) CSL 2 CSL 3 CSL 4 

For EPS product class B, DOE examined three TSLs corresponding to each 

candidate standard level of efficiency developed in the engineering analysis. TSL 1 is an 

intermediate level of performance above ENERGY STAR, which offers the greatest 

consumer NPV. TSL 2 is equivalent to the best-in-market CSL and represents an 

incremental rise in energy savings over TSL 1. TSL 3 is the max-tech level and 

corresponds to the greatest NES. 

For product class X, DOE examined three TSLs above the baseline. TSL 1 is an 

intermediate level of performance above the baseline. TSL 2 is equivalent to the best-inmarket CSL and corresponds to the maximum consumer NPV. TSL 3 is the max-tech 

level and corresponds to the greatest NES. 

327 
 

For product class H, DOE examined three TSLs above the baseline. TSL 1 

corresponds to an intermediate level of efficiency. TSL 2 is the scaled best-in-market 

CSL and corresponds to the maximum consumer NPV. TSL 3 is the scaled max-tech 

level, which provides the highest NES. 

2. Battery Charger TSLs 

Table V-2Table V.2 presents the TSLs and corresponding candidate standard 

levels for battery chargers. While DOE examined most product classes individually, there 

were two groups of product classes that use generally similar technology options and 

cover the exact same range of battery energies. Because of this situation, DOE grouped 

all three low-energy, non-inductive, product classes (i.e. 2, 3, and 4) together and 

examined the results. Similarly, DOE grouped the two medium energy product classes, 

product classes 5 and 6, together when it examined those results. 

328 
 

Table V-2 Trial Standard Levels for Battery Chargers 

Product Class 

Trial Standard Level 

TSL 1 TSL 2 TSL 3 TSL 4 

Low-Energy, Inductive (1) CSL 1 CSL 2 CSL 3 -

Low-Energy, Low-Voltage (2) 

Low-Energy, Med.-Voltage (3) 

Low-Energy, High-Voltage (4) 

CSL 1 

CSL 1 

CSL 1 

CSL 2 

CSL 1 

CSL 1 

CSL 3 

CSL 2 

CSL 2 

CSL 4 

CSL 3 

CSL 3 

Med.-Energy, Low-Voltage (5) 

Med.-Energy, High-Voltage (6) 

CSL 1 

CSL 1 

CSL 2 

CSL 2 

CSL 3 

CSL 3 

-

-

High-Energy (7) CSL 1 CSL 2 - -

Low-Voltage DC Input (8) CSL 1 CSL 2 CSL 3 -

High-Voltage DC Input (9) - - - -

AC Input, AC Output (10) CSL 1 CSL 2 CSL 3 -

For battery charger product class 1 (low-energy, inductive), DOE examined three 

trial standard levels corresponding to each candidate standard level developed in the 

engineering analysis. TSL 1 is an intermediate level of performance above the baseline. 

TSL 2 is equivalent to the best-in-market and corresponds to the maximum consumer 

NPV. TSL 3 is the max-tech level and corresponds to the greatest NES. 

For its second set of TSLs, which covers product classes 2 (low-energy, lowvoltage), 3 (low-energy, medium-voltage), and 4 (low-energy, high-voltage), DOE 

examined four TSLs of different combinations of the various efficiency levels found for 

each product class in the engineering analysis. In this grouping, TSL 1 is an intermediate 

efficiency level above the baseline for each product class and corresponds to the 

maximum consumer NPV. For 2 of the 3 product classes, TSL 2 corresponds to the same 

efficiency level, but for the third class, product class 2, TSL 2 represents an incremental 

efficiency level below best-in-market. TSL 3 corresponds to the best-in-market efficiency 

329 
level for all product classes. Finally, TSL 4 corresponds to the max-tech efficiency level 

for all product classes and therefore, the maximum NES. 

DOE’s third set of TSLs corresponds to the grouping of product classes 5 

(medium-energy, low-voltage) and 6 (medium-energy, high-voltage). For this grouping, 

three TSLs corresponding to different combinations of efficiency levels were examined. 

For both product classes, TSL 1 is an intermediate efficiency level above the baseline. 

TSL 2 corresponds to the best-in-market efficiency level for both product classes and is 

the level with the highest consumer NPV. Finally, TSL 3 corresponds to the max-tech 

efficiency level for both product classes and the maximum NES. 

For product class 7 (high-energy), DOE examined only two TSLs because of the 

paucity of products available on the market. TSL 1 corresponds to an efficiency level 

equivalent to the best-in-market and maximizes consumer NPV is maximized. TSL 2 is 

the max-tech level and corresponds to the level with the maximum NES. 

For product class 8 (low-voltage DC input), DOE examined three TSLs at 

incremental levels above the baseline. TSL 1 is the first incremental level between the 

baseline and best-in-market. Consumer NPV is maximized at this level. TSL 2 is the bestin-market efficiency level and is projected to yield higher NES levels over TSL 1. 

Finally, at TSL 3, or the max-tech efficiency level, NES is maximized. 

330 
 

 

For product class 9 (high-voltage DC input), DOE did not examine any TSLs in 

depth. Rather, when DOE completed its engineering analysis, it conducted its LCC 

analysis on the efficiency levels that had been developed and found that all efficiency 

levels above the baseline showed negative LCC savings. This fact, combined with the 

minimal energy consumed per year for these devices, led DOE to propose an alternative 

standard level for these products. DOE’s proposal for this product class is discussed in 

section V.B.2.f below. 

For product class 10 (AC input, AC output), DOE examined three TSLs, each 

corresponding to an efficiency level developed in the engineering analysis. TSL 1 

corresponds to an incremental level of performance above the baseline. TSL 2 is 

equivalent to what manufacturers stated would be equivalent to the best-in-market level. 

TSL 3, which DOE projects to yield maximized NPV and NES values, is equivalent to 

the max-tech efficiency level for product class 10. 

B. Economic Justification and Energy Savings 

As discussed in section II.A, EPCA provides seven factors to be evaluated in 

determining whether a potential energy conservation standard is economically justified. 

(42 U.S.C. 6295(o)(2)(B)(i)) The following sections generally discuss how DOE is 

addressing each of those seven factors in this rulemaking. For further details and the 

results of DOE’s analyses pertaining to economic justification, see sections IV and V of 

today’s notice. 

331 
1. Economic Impacts on Individual Consumers 

For individual consumers, measures of economic impact include the changes in 

LCC and the PBP associated with new or amended standards. The LCC, which is also 

separately specified as one of the seven factors to be considered in determining the 

economic justification for a new or amended standard (42 U.S.C. 6295(o)(2)(B)(i)(II)), is 

discussed in the following section. For consumers in the aggregate, DOE also calculates 

the net present value from a national perspective of the economic impacts on consumers 

over the forecast period used in a particular rulemaking. 

a. Life-Cycle Cost and Payback Period 

As in the preliminary analysis phase, DOE calculated the average LCC savings 

relative to the base case market efficiency distribution for each representative unit and 

product class. DOE’s projections indicate that a new standard would affect different 

battery charger and EPS consumers differently, depending on the market segment to 

which they belong and their usage characteristics. Section IV.F discusses the inputs used 

for calculating the LCC and PBP. Inputs used for calculating the LCC include total 

installed costs, annual energy savings, electricity rates, electricity price trends, product 

lifetime, and discount rates. 

The key outputs of the LCC analysis are average LCC savings for each product 

class for each considered efficiency level, relative to the base case, as well as a 

probability distribution of LCC reduction or increase. The LCC analysis also estimates, 

for each product class or representative unit, the fraction of customers for which the LCC 

332 
 

 

 

 

will either decrease (net benefit), or increase (net cost), or exhibit no change (no impact) 

relative to the base case forecast. No impacts occur when the product efficiencies of the 

base case forecast already equal or exceed the considered efficiency level. Battery 

chargers and EPSs are used in applications that can have a wide range of operating hours. 

Battery chargers and EPSs that are used more frequently will tend to have a larger net 

LCC benefit than those that are used less frequently because of the large operating cost 

savings. 

Another key output of the LCC analysis is the median payback period at each 

CSL. DOE relies onpresents the median payback period overrather than the mean 

payback period because it is more robust in the presence of outliers in the data.75 These 

outliers skew the mean payback period calculation but have little effect on the median 

payback period calculation. A small change in operating costs, which derive the 

denominator of the payback period calculation, can sometimes result in a very large 

payback period, which skews the mean payback period calculation. For example, 

consider a sample of PBPs of 2, 2, 2, and 20 years, where 20 years is an outlier. The 

mean PBP would return a value of 6.5 years, whereas the median PBP would return a 

value of 2 years. Therefore, DOE considers the median payback period, which is not 

skewed by occasional outliers. Table V-3Table V.3 through Table V-5Table V.5 show 

the results for the representative units and product classes analyzed for EPSs and battery 

chargers. Additional detail for these results, including frequency plots of the distributions 

of life-cycle costs and payback periods, are available in chapter 8 of the TSD. 

75 DOE notes that it uses the median payback period to reduce the effect of outliers on the data. This 

method, however, does not eliminate the outliers from the data. 

Comment [A33]: Changes and footnote 

recommended by OIRA. 

333 
 

 

 

 

 

 

 

 

Table V-3 LCC Savings and Payback Period for DC Output, Basic-Voltage External 

Power Supplies 

Weighted Average LCC 

Savings2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

2.5W AC-DC, Basic V 0.10 0.04 0.02 3.5 4.3 4.3 

18W AC-DC, Basic V 0.68 0.69 (1.19) 1.2 3.1 8.1 

60W AC-DC, Basic V (0.33) (0.45) (1.38) 6.3 5.4 6.4 

120W AC-DC, Basic V 0.60 0.61 (5.49) 1.4 1.9 9.1 

For EPS product class B (basic-voltage, AC-DC, class A EPSs), each 

representative unit has a unique value for LCC savings and median PBP. The 2.5W 

representative unit has positive LCC savings at all TSLs considered, while the 60W 

representative unit has negative LCC savings at all TSLs. Both the 18W and 120W 

representative units have positive LCC savings through TSL 2, but turn negative at TSL 

3. 

Table V-4 LCC Savings and Payback Period for Non-Class A External Power 

Supplies 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

203W Multiple Voltage 2.05 2.07 (3.09) 0.4 4.7 13.2 

345W High-Power 124.82 129.08 92.96 0.0 0.2 2.5 

The Non-Class A EPSs have varying LCC results at each TSL. See Table 

V-4Table V.4. The 203W Multiple Voltage unit (product class X) has positive LCC 

savings through TSL 2. DOE notes that for this product class, the LCC savings remain 

largely the same for TSL 1 and 2 because the difference in LCC is approximately $0.01 

and 95 percent of this market consists of purchased products that are already at TSL 1. 

Therefore, the effects are largely from the movement of the 5 percent of the market up 

from the baseline. The 345W High-Power unit (product class H) has positive LCC Comment [A34]: Change recommended by 

OIRA. 

334 
 

 

 

 

 

 

 

 

savings for each TSL. This projection is largely attributable to the installed price of the 

baseline unit, a linear switching device, which is more costly than higher efficiency 

switch-mode power devices, so as consumers move to higher efficiencies, the purchase 

price actually decreases, resulting in savings. 

Table V-5 LCC Savings and Payback Period for Battery Chargers 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 4 TSL 1 TSL 2 TSL 3 TSL 4 

PC1 - Low E, 

Inductive 0.76 1.52 (2.87) N/A 1.2 1.7 8.5 N/A 

PC2 - Low E, 

Low-Voltage 0.18 16 (0.1612) (1.8581) (4.5854) 0.5 5.2 8.4 5 

15.6 

16.9 

PC3 - Low E, 

Medium-Voltage 0.40 35 0.40 35 (2.4512) (2.4815) 3.6 9 3.6 9 21.9 21.7 5 

PC4 - Low E, 

High-Voltage 0.41 43 0.41 43 

(3.322.7 

3) 

(10.761 

4) 2.9 3.0 2.9 3.0 

14.1 

13.8 

34.7 

37.6 

PC5 - Medium E, 

Low-Voltage 

11.38 

9.69 

39.15 

33.79 

(119.78 

104.58) N/A 1.7 0.0 53.4 N/A 

PC6 - Medium E, 

High-Voltage 

11.49 

9.96 

46.99 

40.78 

(103.49 

86.76) N/A 1.2 0.0 

21.5 

20.8 N/A 

PC7 - High E 43.92 

38.26 

(120.64 

127.30) N/A N/A 0.0 

20.8 

27.2 N/A N/A 

PC8 - DC-DC, 

<9V Input 3.05 04 (1.9396) (2.2831) N/A 0.0 0.0 

26.1 

24.9 N/A 

PC9 - DC-DC, ≥9 

V Input (0.0809) (0.2425) 0.00 N/A 7.2 8.8 0.0 N/A 

PC10 - Low E, 

AC Out 6.61 41 7.47 26 8.52 30 N/A 1.3 1.4 1.5 N/A 

The LCC results for battery chargers depend on the product class being 

considered. See Table V-5Table V.5. For product class 1, LCC results are positive 

through TSL 2. For the low-energy product classes (PC2, 3, and 4), LCC results are 

generally positive through TSL 2, with the exception of product class 2, and become 

negative at TSL 3. The medium-energy product classes (PC5 and 6) are positive through 

TSL 2 and negative at TSL 3. The high-energy product class (PC7) has positive LCC 

savings of $43.9238.26 at TSL 1, and then becomes negative at TSL 2. Product class 8 

335 
 

 

has positive LCC savings only at TSL 1, while product class 10 has positive LCC savings 

at each TSL (see entries for PC8 and PC10 in Table V-5Table V.5). 

b. Consumer Subgroup Analysis 

Certain consumer subgroups may be disproportionately affected by standards. 

DOE performed LCC subgroup analyses in this NOPR for low-income consumers, small 

businesses, top tier marginal electricity price consumers, and consumers of specific 

applications. See section IV.F of this NOPR for a review of the inputs to the LCC 

analysis. The following discussion presents the most significant results from the LCC 

subgroup analysis. 

Low-Income Consumers 

For low-income consumers, the LCC impacts and payback periods are different 

than for the general population. This subgroup considers only the residential sector, and 

uses an adjusted electricity price from the reference case scenario. DOE found that lowincome consumers below the poverty line typically paid electricity prices that were 0.2 

cents per kWh lower than the general population. To account for this difference, DOE 

adjusted electricity prices by a factor of 0.9814 to derive electricity prices for this 

subgroup. Table V-6Table V.6 through Table V-8Table V.8 show the LCC impacts and 

payback periods for low-income consumers purchasing EPSs and battery chargers. 

The LCC savings and PBPs of low-income consumers is similar to that of the 

total population of consumers. In general, low-income consumers experience slightly 

336 
 

 

 

 

 

 

 

reduced LCC savings, particularly in product classes dominated by residential 

applications. However, product classes with a large proportion of commercial 

applications experience less of an effect under the low-income consumer scenario, which 

is specific to the residential sector, and sometimes have greater LCC savings than the 

reference case results. None of the changes in LCC savings move a TSL from positive to 

negative LCC savings, or vice versa. 

Table V-6 DC Output, Basic-Voltage External Power Supplies: Low-Income 

Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

2.5W AC-DC, Basic V 0.10 0.04 0.01 3.5 4.4 4.4 

18W AC-DC, Basic V 0.69 0.70 (1.19) 1.2 3.4 9.8 

60W AC-DC, Basic V (0.29) (0.35) (1.19) 6.4 5.3 6.3 

120W AC-DC, Basic V 0.65 0.68 (5.32) 1.3 1.8 8.8 

Table V-7 Non-Class A External Power Supplies: Low-Income Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

203W Multiple-Voltage 2.00 2.01 (3.20) 0.4 4.8 13.5 

345W High-Power 122.51 126.61 90.23 0.0 0.4 4.3 

337 
 

 

 

 

 

 

 

 

 

 

 

Table V-8 Battery Chargers: Low-Income Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 4 TSL 1 TSL 2 TSL 3 TSL 4 

PC1 - Low E, 

Inductive 0.74 1.47 (2.9394) N/A 1.3 1.7 8.6 N/A 

PC2 - Low E, LowVoltage 0.1615 (0.1916) (1.8987) (4.6260) 0.5 5.45 8.67 16.617 

.2 

PC3 - Low E, 

Medium-Voltage 0.3731 0.3731 (2.5521) (2.5925) 3.64.4 3.64.4 22.4 22.4 

PC4 - Low E, 

High-Voltage 0.6061 0.6061 

(3.432.7 

9) 

(10.942 

8) 3.2 3.2 12.53 

36.343 

.1 

PC5 - Medium E, 

Low-Voltage 

11.129. 

47 

38.5433 

.26 

(120.57 

105.27) N/A 1.8 0.0 54.5 N/A 

PC6 - Medium E, 

High-Voltage 

11.239. 

72 

46.1840 

.06 

(104.63 

87.83) N/A 1.3 0.0 21.92 N/A 

PC7 - High E 44.9939 

.20 

(128.74 

135.53) N/A N/A 0.0 

59126. 

6 N/A N/A 

PC8 - DC-DC, <9V 

Input 3.05 (1.9493) (2.29) N/A 0.0 0.0 26.6 N/A 

PC9 - DC-DC, ≥9 

V Input (0.0809) (0.2425) 0.00 N/A 7.2 8.8 0.0 N/A 

PC10 - Low E, AC 

Out 

7.196.2 

4 

8.157.0 

8 

9.308.0 

8 N/A 1.3 1.4 1.5 N/A 

Small Businesses 

For small business customers, the LCC impacts and payback periods are different 

than for the general population. This subgroup considers only the commercial sector, and 

uses an adjusted discount rate from the reference case scenario. DOE found that small 

businesses typically have a cost of capital that is 4.48 percent higher than the industry 

average, which was applied to the discount rate for the small business consumer 

subgroup. 

and show the LCC impacts and payback periods for small businesses purchasing 

EPSs and battery chargers. DOE did not identify any commercial applications for NonClass A EPSs, and, consequently, did not evaluate these products as part of the small 

business consumer subgroup analysis. 

338 
 

 

 

 

 

The small business consumer subgroup LCC results are not directly comparable 

to the reference case LCC results because this subgroup only considers commercial 

applications. In the reference case scenario, the LCC results are strongly influenced by 

the presence of residential applications, which typically comprise the majority of 

application shipments. For EPS product class B, the LCC savings for the 2.5W 

representative unit become negative at TSL 2 and 3 under the small business scenario, 

but none of the savings for other representative units change from positive to negative, or 

vice versa. Similarly, none of the battery charger product classes that were positive in the 

reference case become negative in the small business subgroup analysis, and vice versa. 

This observation indicates that small business consumers would experience similar LCC 

impacts as the general population. 

Table V-9Table V.9 and Table V-10Table V.10 show the LCC impacts and 

payback periods for small businesses purchasing EPSs and battery chargers. DOE did not 

identify any commercial applications for Non-Class A EPSs, and, consequently, did not 

evaluate these products as part of the small business consumer subgroup analysis. 

Table V-9 DC Output, Basic-Voltage External Power Supplies: Small Business 

Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

2.5W AC-DC, Basic V 0.03 (0.04) (0.08) 4.4 5.0 5.0 

18W AC-DC, Basic V 0.44 0.32 (1.81) 1.1 2.8 6.9 

60W AC-DC, Basic V (0.46) (0.73) (1.93) 7.1 6.0 7.2 

120W AC-DC, Basic V 0.46 0.45 (5.98) 1.4 2.0 9.2 

339 
 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-10 Battery Chargers: Small Business Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 4 TSL 1 TSL 2 TSL 3 TSL 4 

PC1 - Low E, 

Inductive* N/A N/A N/A N/A N/A N/A N/A N/A 

PC2 - Low E, 

Low-Voltage 0.2118 (0.2018) (1.9088) (4.6866) 0.5 4.34 8.24 

14.615. 

4 

PC3 - Low E, 

Medium-Voltage 1.2408 1.2408 (0.9885) (0.8875) 1.2 1.2 4.7 4.6 

PC4 - Low E, 

High-Voltage 0.0006 0.0006 

(3.362.8 

2) 

(10.771 

8) 2.3 2.3 17.0 

30.934. 

8 

PC5 - Medium E, 

Low-Voltage* N/A N/A N/A N/A N/A N/A N/A N/A 

PC6 - Medium E, 

High-Voltage* N/A N/A N/A N/A N/A N/A N/A N/A 

PC7 - High E 42.9737. 

40 

(122.01 

128.58) N/A N/A 0.0 

16.327. 

2 N/A N/A 

PC8 - DC-DC, 

<9V Input 3.0100 

(1.962.0 

0) (2.3236) N/A 0.0 0.0 10.9 N/A 

PC9 - DC-DC, ≥9 

V Input* N/A N/A N/A N/A N/A N/A N/A N/A 

PC10 - Low E, 

AC Out 4.273.71 4.7614 5.354.65 N/A 1.5 1.7 1.8 N/A 

* These product classes do not contain any commercial applications, so the small business consumer 

subgroup is not applicable. 

Top Tier Marginal Electricity Price Consumers 

For top tier marginal electricity price consumers, the LCC impacts and payback 

periods are different than for the general population. The analyses for this subgroup 

consider a weighted-average of the residential and commercial sectors, and uses an 

adjusted electricity price from the reference case scenario. DOE used an upper tier 

inclined marginal block rate for the electricity price in the residential and commercial 

sectors, resulting in a price of $0.310 and $0.225 per kWh, respectively. Table V-11Table 

V.11 through Table V-13Table V.13 show the LCC impacts and payback periods for top 

tier marginal electricity price consumers purchasing EPSs and battery chargers. 

340 
 

 

 

 

 

 

 

Consumers in the top tier marginal electricity price bracket experience greater 

LCC savings than those in the reference case scenario. This result occurs because these 

consumers pay more for their electricity than other consumers, and, therefore, experience 

greater savings when using products that are more energy efficient. This subgroup 

analysis changed many of the negative LCC savings results to positive LCC savings. 

Some product classes and representative units still have negative LCC savings, which 

indicates that these product classes have increasing installed costs (purchase price plus 

installation costs, the latter of which are assumed to be zero) at higher TSLs that cannot 

be overcome through operating cost savings using top tier marginal electricity prices. 

Table V-11 DC Output, Basic-Voltage External Power Supplies: Top Tier Marginal 

Electricity Price Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

2.5W AC-DC, Basic V 0.86 0.97 1.08 1.4 1.7 1.7 

18W AC-DC, Basic V 2.14 3.19 3.54 0.4 1.2 3.2 

60W AC-DC, Basic V 0.73 1.51 2.45 2.1 1.9 2.2 

120W AC-DC, Basic V 2.05 2.38 (0.28) 0.5 0.6 3.8 

Table V-12 Non-Class A External Power Supplies: Top Tier Marginal Electricity 

Price Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

203W Multiple Voltage 6.02 6.62 6.25 0.1 1.5 4.2 

345W High-Power 313.34 331.76 318.23 0.0 0.0 0.2 

341 
 

 

 

 

 

 

 

 

 

 

 

 

Table V-13 Battery Chargers: Top Tier Marginal Electricity Price Consumer 

Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 4 TSL 1 TSL 2 TSL 3 TSL 4 

PC1 - Low E, 

Inductive 2.5655 5.71 2.8786 N/A 0.4 0.5 2.7 N/A 

PC2 - Low E, 

Low-Voltage 0.5346 1.2913 0.9983 (1.5975) 0.2 1.8 3.0 5.86.0 

PC3 - Low E, 

Medium-Voltage 1.7147 1.7147 1.7960 1.7960 1.4 1.4 7.1 7.12 

PC4 - Low E, 

High-Voltage 1.8983 1.8983 (0.19)22 (6.8334) 1.0 1.0 6.4 14.27 

PC5 - Medium E, 

Low-Voltage 

34.3029. 

35 

92.0679. 

29 

(50.234 

4.77) N/A 0.9 0.0 21.3 N/A 

PC6 - Medium E, 

High-Voltage 

35.2830. 

62 

118.451 

02.95 

(3.36)6. 

30 N/A 0.4 0.0 6.7.2 N/A 

PC7 - High E 57.1349. 

74 

(86.079 

4.46) N/A N/A 0.0 1013.6 N/A N/A 

PC8 - DC-DC, 

<9V Input 3.13 (1.57) (1.8889) N/A 0.0 0.0 8.1 N/A 

PC9 - DC-DC, ≥9 

V Input (0.0809) (0.2425) 0.00 N/A 7.2 8.8 0.0 N/A 

PC10 - Low E, 

AC Out 20.1843 23.2253 

26.8927. 

27 N/A 0.4 0.54 0.5 N/A 

Consumers of Specific Applications 

DOE performed an LCC and PBP analysis on every application within each 

representative unit and product class. This subgroup analysis used the application’s 

specific inputs for lifetime, markups, base case market efficiency distribution, and UEC. 

Many applications in each representative unit or product class experienced LCC impacts 

and payback periods that were different from the average results across the representative 

unit or product class. Because of the large number of applications considered in the 

analysis, some of which span multiple representative units or product classes, DOE did 

not present application-specific LCC results here. Detailed results on each application are 

available in chapter 11 of the TSD. 

342 
 

 

 

 

For EPS product class B, the application-specific LCC results indicate that most 

applications will experience similar levels of LCC savings as the representative unit’s 

average LCC savings. The 2.5W representative unit has positive LCC savings for each 

TSL, but infrequently charged applications, such as beard and moustache trimmers 

(among others), experience negative LCC savings. Similarly, the 18W representative unit 

has projected positive LCC savings through TSL 2, but other applications using EPSs, 

such as portable DVD players and camcorders, have negative savings. For the 60W 

representative unit, all applications follow the shipment-weighted average trends, except 

EPSs used in sleep apnea machines, which have positive LCC savings at each TSL. The 

same is true for the 120W representative unit, except for EPSs used in portable O2 

concentrator applications, which are projected to yield negative LCC results for all TSLs. 

For battery charger product classes, DOE noted similar trends where less 

frequently used applications experienced lower LCC savings. For product class 2, LCC 

savings are negative beyond TSL 1, but frequently used applications within that class -- 

e.g. answering machines, cordless phones, and home security systems -- experience 

positive LCC savings. The top three product class 3 applications (which account for over 

50 percent of total shipments) have negative LCC savings and contribute to the negative 

LCC savings of the product class average. However, some applications have significantly 

positive LCC savings, such as handheld vacuums, LAN equipment, stick vacuums, and 

universal battery chargers, which together comprise 15 percent of the total shipments in 

PC3. Product class 4 (e.g. notebooks and netbooks) have no impacts at TSL 1 or TSL 2 

because these products already use battery charger technology above the baseline 

343 
 

efficiency level. In the other battery charger product classes, the disparate applications 

tend to experience similar LCC savings. See chapter 11 of the TSD for further detail. 

c. Rebuttable Presumption Payback 

As discussed in section III.D.2, EPCA provides a rebuttable presumption where, 

in essence, an energy conservation standard is economically justified if the increased 

purchase cost for a product that meets the standard is less than three times the value of 

the first-year energy savings resulting from the standard. However, DOE routinely 

conducts a full economic analysis that considers the full range of impacts, including those 

to the customer, manufacturer, Nation, and environment, as required under 42 U.S.C. 

6295(o)(2)(B)(i) and 42 U.S.C. 6316(e)(1). The results of this analysis serve as the basis 

for DOE to evaluate definitively the economic justification for a potential standard level 

(thereby supporting or rebutting the results of any preliminary determination of economic 

justification). 

For EPSs and battery chargers, energy savings calculations in the LCC and PBP 

analyses used both the relevant test procedures as well as the relevant usage profiles. 

DOE’s recent changes to the test procedures did not affect any characteristics that impact 

the payback period calculation. Because DOE calculated payback periods using a 

methodology consistent with the rebuttable presumption test for EPSs and battery 

chargers in the LCC and payback period analyses, DOE did not perform a stand-alone 

rebuttable presumption analysis, as it was already embodied in the LCC and PBP 

analyses. 

344 
2. Economic Impacts on Manufacturers 

DOE performed an MIA to estimate the impact of new and amended energy 

conservation standards on manufacturers of EPSs and battery chargers. The section below 

describes the expected impacts on manufacturers at each potential TSL. 

a. Cash-Flow Analysis Results 

The INPV results refer to the difference in industry value between the base case 

and the standards case, which DOE calculated by summing the discounted industry cash 

flows from the base year (2011) through the end of the analysis period. The discussion 

also notes the difference in cash flow between the base case and the standards case in the 

year before the compliance date of potential new and amended energy conservation 

standards. This figure provides a proxy for the magnitude of the required conversion 

costs, relative to the cash flow generated by the industry in the base case. 

i. EPS Cash Flow Impacts 

For EPSs, the MIA describes the impacts on EPS ODMs. Each set of results 

below shows two tables of INPV impacts on the ODM. The first table reflects the lower 

(less severe) bound of impacts and the second represents the upper (more severe) bound. 

To evaluate this range of cash-flow impacts on EPS manufacturers, DOE modeled two 

different scenarios using different markup assumptions. These assumptions correspond to 

the bounds of a range of market responses that DOE anticipates could occur in the 

345 
 

standards case. Each scenario results in a unique set of cash flows and corresponding 

industry value at each TSL. 

To assess the lower (less severe) end of the range of potential impacts, DOE 

modeled the flat markup scenario. The flat markup scenario assumes that in the standards 

case manufacturers would be able to pass the higher production costs required to 

manufacture more efficient products on to their customers. To assess the higher (more 

severe) end of the range of potential impacts, DOE modeled the preservation of operating 

profit markup scenario in which higher energy conservation standards result in lower 

manufacturer markups. DOE used the main NIA shipment scenario for both the lowerand higher-bound MIA scenarios that were used to characterize the potential INPV 

impacts. 

Product Classes B, C, D, and E 

Table V-14 and Table V-15 present the projected results for product classes B, C, 

D, and E under the flat and preservation of operating profit markup scenarios. DOE 

examined four representative units in product class B and scaled the results to product 

classes C, D, and E using the most appropriate representative unit for each product class. 

346 
 

 

 

 

Table V-14 Manufacturer Impact Analysis for Product Classes B, C, D, and E – Flat 

Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV (2010$ millions) 231.9 197.6193.0 201.6196 

.7 

254.9249. 

8 

Change in INPV 

(2010$ millions) - (34.338.9) (30.335.2 

) 23.017.9 

(%) - -1416.8% 

-

13.115.2 

% 

9.97.7% 

Product Conversion Costs (2010$ millions) - 26.629.1 31.834.5 33.536.3 

Capital Conversion Costs (2010$ millions) - 29.432.2 3538.1 37.040.1 

Total Conversion Costs (2010$ millions) - 56.061.4 66.972.6 70.576.4 

Table V-15 Manufacturer Impact Analysis for Product Classes B, C, D, and E – 

Preservation of Operating Profit Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV (2010$ millions) 231.9 174.1169.4 155.4150 

.5 

113.5108. 

4 

Change in INPV 

(2010$ millions) - (57.962.5) (76.581.4 

) 

(118.4123. 

5) 

(%) - -2426.9% 

-

33.035.1 

% 

-

51.153.2% 

Product Conversion Costs (2010$ millions) - 26.629.1 31.834.5 33.536.3 

Capital Conversion Costs (2010$ millions) - 29.432.2 3538.1 37.040.1 

Total Conversion Costs (2010$ millions) - 56.061.4 66.972.6 70.576.4 

At TSL 1, DOE estimates impacts on INPV to range from -$34.3 million to ­

$5738.9 million to -$62.5 million, or a change in INPV of -1416.8 percent to -2426.9 

percent. At this level, industry free cash flow is estimated to decrease by approximately 

163.6179.2 percent to -$10.8.6 million, compared to the base-case value of $13.6 million 

in the year leading up to when the new and amended energy conservation standards 

would need to be met. 

347 
At TSL 1, manufacturers of product class B, C, D, and E EPSs face a moderate 

loss in INPV. For these product classes, the required efficiencies at TSL 1 correspond to 

an intermediate level above the ENERGY STAR 2.0 levels but below the best in market 

efficiencies. The conversion costs are a major contribution of the decrease in INPV 

because the vast majority of the product class B, C, D, and E EPS shipments fall below 

CSL 2. Manufacturers will incur product and capital conversion costs of approximately 

$5661.4 million at TSL 1. In 2013, approximately 8084 percent of product class B, C, D, 

and E shipments are projected to fall below the proposed amended energy conservation 

standards. In addition, 9092 percent of the products in 2013 for the 2.5W representative 

unit would are projected to fall below the proposed efficiency standard, and would likely 

require more substantial conversion costs because meeting the efficiency standard would 

require 2.5W representative units to switch from linear to switch mode technology. This 

change would increase the conversion costs for these 2.5W representative units, which 

account for approximately halfa quarter of all the product class B, C, D, and E shipments. 

At TSL 1, the MPC increases 45 percent for the 2.5W representative units (a 

representative unit for product class B and all shipments of product classes C and E), 5 

percent for the 18 Watt representative units (a representative unit for product class B and 

all shipments of product class D), 14 percent for the 60W representative units, and 3 

percent for the 120W representative units over the baseline. The conversion costs are 

significant enough to cause a moderately negative industry impact even if the incremental 

change in MPCs is fully passed on to OEMs. Impacts are more significant under the 

348 
 

 

 

preservation of operating profit scenario because under this scenario manufacturers 

would be unable to pass on the full increase product cost. 

At TSL 2, DOE estimates impacts on INPV to range from -$30.335.2 million to ­

$76.581.4 million, or a change in INPV of -1315.2 percent to -35.1 percent to -33.0 

percent. At this level, industry free cash flow is estimated to decrease by approximately 

195.4212.1 percent to -$13.015.2 million, compared to the base-case value of $13.6 

million in the year before the compliance date. 

TSL 2 represents the best-in-market efficiencies for product class B, C, D, and E 

EPSs. The difference in conversion costs and incremental production costs at TSL 2 

make the INPV impacts slightly better than TSL 1 in the flat markup scenario and worse 

under the preservation of operating profit scenario. The product conversion costs increase 

by $5.24 million and the capital conversion costs increase by $5.79 million from TSL 1 

because the vast majority of current products fall below the efficiency requirements at 

TSL 2. Also, at TSL 2, the MPC increases 60 percent for the 2.5W representative units (a 

representative unit for product class B and all shipments of product classes C and E), 18 

percent for the 18 Watt representative units (this is a representative unit for product class 

B and all shipments of product class D), 22 percent for the 60W representative units, and 

4 percent for the 120W representative units over the baseline. However, the similar 

conversion costs and relatively minor additional incremental costs make the industry 

impacts at TSL 2 similar to those at TSL 1. 

349 
 

 

At TSL 3, DOE estimates impacts on INPV to range from $23.017.9 million to ­

$118.4123.5 million, or a change in INPV of 9.97.7 percent to -51.153.2 percent. At this 

level, industry free cash flow is estimated to decrease by approximately 206223.0 percent 

to -$14.416.7 million, compared to the base-case value of $13.6 million in the year before 

the compliance date. 

TSL 3 represents the max-tech CSL for product class B, C, D, and E EPSs. At 

TSL 3, DOE modeled a wide range of industry impacts because the very large increases 

in per-unit costs lead to a wide range of potential impacts depending on who captures the 

additional value in the distribution chain. None of the existing products on the market 

meet the efficiency requirements at TSL 3. However, since most of the products at TSL 2 

also fall below the standard level, there is only a slight difference between the conversion 

costs at TSL 2 and TSL 3. The different INPV impacts occur due to the large changes in 

incremental MPCs at the max-tech level. At TSL 3, the MPC increases 69 percent for the 

2.5W representative unit (this is a representative unit for product class B and all 

shipments for product classes C and E), 80 percent for the 18 Watt representative units 

(this is a representative unit for product class B and all shipments for product class D), 46 

percent for the 60W representative units, and 53 percent for the 120W representative 

units over the baseline. If manufacturers are able to fully pass on these costs to OEMs 

(the flat markup scenario), the increase in cash flow from operations is enough to 

overcome the conversion costs to meet the max-tech level and INPV increases slightly. 

However, if the manufacturers are unable to pass on these costs and only maintain the 

current operating profit (the preservation of operating profit markup scenario), there is a 

350 
 

large, negative impact on INPV, because substantial increases in working capital drain 

operating cash flow. The conversion costs associated with switching the entire market, 

the large increase in incremental MPCs, and the extreme pressure from OEMs to keep 

product prices down make it more likely that ODMs will not be able to fully pass on 

these costs to OEMs and the ODMS would face a substantial loss instead of a slight gain 

in INPV at TSL 3. 

Product Class X 

Table V-16Table V.16 and Table V-17Table V.17 below present the projected 

results for product class X under the flat and preservation of operating profit markup 

scenarios. 

Table V-16 Manufacturer Impact Analysis for Product Class X EPS – Flat Markup 

Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 

INPV (2010$ millions) 44.1 43.7 32.2 39.6 

Change in INPV (2010$ millions) - (0.4) (12.0) (4.6) 

(%) - -1.0% -27.1% -10.3% 

Product Conversion Costs (2010$ millions) - 0.3 6.9 6.9 

Capital Conversion Costs (2010$ millions) - 0.4 7.6 7.6 

Total Conversion Costs (2010$ millions) - 0.7 14.4 14.4 

Table V-17 Manufacturer Impact Analysis for Product Class X EPS – Preservation 

of Operating Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 

INPV (2010$ millions) 44.1 43.4 31.4 26.3 

Change in INPV (2010$ millions) - (0.7) (12.8) (17.9) 

(%) - -1.7% -28.9% -40.5% 

Product Conversion Costs (2010$ millions) - 0.3 6.9 6.9 

Capital Conversion Costs (2010$ millions) - 0.4 7.6 7.6 

Total Conversion Costs (2010$ millions) - 0.7 14.4 14.4 

351 
 

 

 

At TSL 1, DOE estimates impacts on INPV to range from -$0.4 million to -$0.7 

million, or a change in INPV of -1.0 percent to -1.7 percent. At this level, industry free 

cash flow is estimated to decrease by approximately 10.9 percent to $2.3 million, 

compared to the base-case value of $2.6 million in the year before the compliance date. 

At TSL 1, manufacturers of product class X face a very slight decline in INPV 

because most of the market already meets TSL 1. The total conversion costs are 

approximately $0.7 million. Conversion costs are low because 95 percent of the products 

already meet the TSL 1 efficiency requirements. 

At TSL 2, DOE estimates impacts on INPV to range from -$12.0 million to ­

$12.8 million, or a change in INPV of -27.1 percent to -28.9 percent. At this level, 

industry free cash flow is estimated to decrease by approximately 218.6 percent to -$3.1 

million, compared to the base-case value of $2.6 million in the year leading up to when 

the new energy conservation standards would need to be met. 

At TSL 2, manufacturers face a more noticeable loss in industry value. DOE 

estimates that manufacturers will incur total product and capital conversion costs of $14.4 

million at TSL 2. The conversion costs increase at TSL 2 because the entire market falls 

below the efficiency requirements at TSL 2. However, the total impacts are also driven 

by the incremental MPCs at TSL 2. At TSL 2, the MPC increases 16 percent over the 

baseline. Therefore, the projected changes in INPV under both the flat and preservation 

of operating profit markup scenarios are similar. 

352 
 

 

 

At TSL 3, DOE estimates impacts on INPV to range from -$4.6 million to -$17.9 

million, or a change in INPV of -10.3 percent to -40.5 percent. At this level, industry free 

cash flow is estimated to decrease by approximately 218.6 percent to $3.1 million, 

compared to the base-case value of $2.6 million in the year before the compliance date. 

TSL 3 could result in substantial impacts on INPV. As with TSL 2, the entire 

market falls below the required efficiency at TSL 3 and total industry conversion costs 

are also $14.4 million. However, the main difference at TSL 3 is the increase in the MPC. 

At TSL 3, the MPC increases 46 percent over the baseline. If the ODM can pass on the 

higher price of these products to the OEM at TSL 3, the decline in INPV is not severe. 

However, if ODMs cannot pass on these higher MPCs to OEMs, the loss in INPV is 

much more substantial. 

Product Class H 

Table V-18Table V.18 and Table V-19Table V.19 present the projected results for 

product class H under the flat and preservation of operating profit markup scenarios. 

Table V-18 Manufacturer Impact Analysis for Product Class H EPS – Flat Markup 

Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV (2010$ millions) 0.11 0.06 0.06 0.08 

Change in INPV (2010$ millions) - (0.05) (0.05) (0.03) 

(%) - -45.5% -44.0% -24.4% 

Product Conversion Costs (2010$ millions) - 0.02 0.02 0.02 

Capital Conversion Costs (2010$ millions) - 0.02 0.02 0.02 

Total Conversion Costs (2010$ millions) - 0.05 0.05 0.05 

353 
 

 

Table V-19 Manufacturer Impact Analysis for Product Class H EPS – Preservation 

of Operating Profit Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV (2010$ millions) 0.11 0.07 0.07 0.06 

Change in INPV (2010$ millions) - (0.04) (0.04) (0.05) 

(%) - -32.7% -33.8% -47.3% 

Product Conversion Costs (2010$ millions) - 0.02 0.02 0.02 

Capital Conversion Costs (2010$ millions) - 0.02 0.02 0.02 

Total Conversion Costs (2010$ millions) - 0.05 0.05 0.05 

A t TSL 1, DOE estimates impacts on INPV to range -$0.04 million to -$0.05 

million, or a change in INPV of -32.7 percent to -45.5 percent. At this level, industry free 

cash flow is estimated to decrease by approximately 284.4 percent to -$0.01 million, 

compared to the base-case value of $0.01 million in the year before the compliance date. 

At TSL 1, product class H manufacturers face a significant relative loss in 

industry value. The base case industry value of $100,000 is low and since DOE estimates 

that total conversion costs at TSL 1 would be approximately $50,000, the conversion 

costs represent a substantial portion of total industry value. The conversion costs are high 

relative to the base case INPV because the entire market in 2013 is projected to fall below 

an efficiency standard set at TSL 1. This means that all products in product class H would 

have to be redesigned to meet the efficiency level at TSL 1, leading to total conversion 

costs that are large relative to the base case industry value. In addition, the MPC at TSL 1 

declines by 21 percent compared to the baseline since the switching technology that 

would be required to meet this efficiency level is less costly to manufacture than baseline 

products that use linear technology. This situation results in a lower MSP and lower 

revenues for manufacturers of baseline products, which exacerbates the impacts on INPV 

from new energy conservation standards for these products. 

354 
 

 

At TSL 2, DOE estimates impacts on INPV to range from -$0.04 million to ­

$0.05 million, or a change in INPV of -33.8 percent to -44.0 percent. At this level, 

industry free cash flow is estimated to decrease by approximately 284.4 percent to -$0.01 

million, compared to the base-case value of $0.01 million in the year before the 

compliance date. 

The impacts on INPV at TSL 2 are similar to TSL 1. The conversion costs are the 

same since the entire market in 2013 would fall below the required efficiency at both 

TSL 1 and TSL 2. Also, the MPC is projected to decrease by 19 percent at TSL 2 

compared to the baseline, which is similar to the 21 percent decrease at TSL 1. Overall, 

the similar conversion costs and lower industry revenue for the minimally compliant 

products make the INPV impacts at TSL 2 similar to TSL 1. 

At TSL 3, DOE estimates impacts on INPV to range from -$0.03 million to ­

$0.05 million, or a change in INPV of -24.4 percent to -47.3 percent. At this level, 

industry free cash flow is estimated to decrease by approximately 284.4 percent to -$0.01 

million, compared to the base-case value of $0.01 million in the year leading up to when 

the new energy conservation standards would need to be met. 

Impacts on INPV range from moderately to substantially negative at TSL 3. As 

with TSL 1 and TSL 2, the entire market falls below the required efficiency and the total 

industry conversion costs estimated by DOE remain at $50,000. However, the MPC 

355 
 

 

increases at TSL 3 relative to the estimated cost of the baseline unit and changes the 

possible impacts on INPV at TSL 3. If ODMs can fully pass on the higher production 

cost of these products to the OEM at TSL 3, the decline in INPV is less severe. However, 

if the ODM cannot pass on these higher MPC to OEM then the loss in INPV is much 

more substantial. 

ii. Battery Charger Cash Flow Impacts 

DOE reports INPV impacts at each TSL for the six product class groupings 

below. When appropriate, DOE also discusses the results for groups of related 

applications that would experience impacts significantly different from the overall 

product class group to which they belong. 

In general, two major factors drive the INPV results: (1) the relative difference 

between a given application’s MSP and the incremental cost of improving its battery 

charger; and (2) the dominant base case battery charger technology that a given 

application utilizes, which is approximated by the application’s efficiency distribution. 

With respect to the first point, the higher the MSP of the application relative to the 

battery charger cost, the lower the impacts of battery charger standards on OEMs of the 

application. For example, an industry that sells an application for $500 would be less 

affected by a $2 increase in battery charger costs than one that sells its application for 

$10. On the second point regarding base case efficiency distribution, some industries, 

such as producers of laptop computers, already incorporate highly efficient battery 

356 
 

 

 

 

 

chargers. Therefore, a higher standard would be unlikely to impact the laptop industry as 

it would other applications using baseline technology in the same product class. 

As discussed in section IV.I, DOE analyzed three markup scenarios—constant 

price, pass through, and flat markup. These scenarios were described earlier. The constant 

price scenario analyzes the situation in which application manufacturers are unable to 

pass on any incremental costs of more efficient battery chargers to their customers. This 

scenario generally results in the most significant negative impacts76 because no 

incremental costs added to the application—whether driven by higher battery charger 

component costs or depreciation of required capital investments—can be recouped. 

In the pass through scenario, DOE assumes that manufacturers are able to pass the 

incremental costs of more efficient battery chargers through to their customers, but not 

with any markup to cover overhead and profit. Therefore, though less severe than the 

constant price scenario in which manufacturers absorb all incremental costs, this scenario 

results in negative cash flow impacts due to margin compression and greater working 

capital requirements. 

Finally, DOE considers a flat markup scenario to analyze the upper bound (most 

positive) of profitability impacts.77 In this scenario, manufacturers are able to maintain 

76 Notably, this is not the case with negative sloping cost-efficiency curves. When a higher efficiency level 

can be achieved at a lower product cost, the constant price scenario yields positive impacts because larger 

margins are realized by the manufacturer on each unit produced. 

77 While the Flat Markup scenario typically results in the most positive impacts of any scenario, a 

negatively sloping cost-efficiency curve will yield the opposite effect. When a higher efficiency level can 

357 
 

 

 

 

 

 

 

their base case gross margin, as a percentage of revenue, at higher CSLs, despite the 

higher product costs associated with more efficient battery chargers. In other words, 

manufacturers can fully pass on—and mark up—the higher incremental product costs 

associated with more efficient battery chargers. 

Product Class 1 

The following tables (Table V-20Table V.20 through Table V-23Table V.23) 

summarize information related to the analysis performed to project the potential impacts 

on product class 1 battery charger manufacturers. 

Table V-20 Applications in Product Class 1 

Product Class 1 

Rechargeable Toothbrushes 

Rechargeable Water Jets 

Table V-21 Cash Flow Results – Product Class 1 – Flat Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 491 492 496493 524520 

Change in INPV 2010$ Millions - 1 51 3329 

(%) - 0.1% 0.93% 6.65.9% 

Product Conversion Costs 2010$ Millions - 0.8 1.9 4.3 

Capital Conversion Costs 2010$ Millions - 0.0 1.8 2.0 

Total Investment Required 2010$ Millions - 0.8 3.7 6.3 

be achieved at a lower product cost, the margin on each unit produced is lower, in absolute terms, in the 

Flat Markup scenario. This effect leads to lower operating profit, cash flow, and INPV. 

358 
 

 

 

 

 

 

 

 

 

Table V-22 Cash Flow Results – Product Class 1 – Pass Through Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 491 479 464461 322318 

Change in INPV 

2010$ Millions - (12) (2731) (169173) 

(%) - -2.5% -5.56.2% 

-

34.535.3 

% 

Product Conversion Costs 2010$ Millions - 0.8 1.9 4.3 

Capital Conversion Costs 2010$ Millions - 0.0 1.8 2.0 

Total Investment Required 2010$ Millions - 0.8 3.7 6.3 

Table V-23 Cash Flow Results – Product Class 1 – Constant Price Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 491 450 394390 5551 

Change in INPV 

2010$ Millions - (41) (98101) (437441) 

(%) - -8.4% 

-

19.920.6 

% 

-

88.989.7 

% 

Product Conversion Costs 2010$ Millions - 0.8 1.9 4.3 

Capital Conversion Costs 2010$ Millions - 0.0 1.8 2.0 

Total Investment Required 2010$ Millions - 0.8 3.7 6.3 

Product class 1 has only two applications: rechargeable toothbrushes and water 

jets. Rechargeable toothbrushes represent 99.9 percent of the product class 1 shipments. 

DOE found the majority of these models include nickel-cadmium (Ni-Cd) battery 

chemistries, although products with NiMH and Li-ion chemistries exist in the market. 

More than three quarters of market shipments are at the baseline CSL. However, the 

efficiency distribution is not necessarily indicative of the distribution of retail price 

points. During interviews, manufacturers indicated that energy efficiency was not a 

primary selling point in this market. As a consequence, manufacturers expect that 

stringent standards would likely impact the low-end of the market, where price 

competition is most fierce and retail selling prices are lowest. 

359 
 

 

The incremental costs of meeting TSL 1 and TSL 2, which represent CSL 1 and 

CSL 2 for product class 1, respectively, are relatively minor compared to the average 

application MSP of $58.36. While most applications will have to be altered at these 

TSLs, the relatively small increase in battery charger costs do not greatly impact industry 

cash flow even if none of these incremental costs can be passed on to retailers. At maxtech, however, the battery charger is 3.3 times more expensive than the baseline charger. 

The baseline level is set at the CSL at which the majority of the market currently ships. 

Therefore, in addition to the R&D efforts necessary to prepare all product lines to 

incorporate the max-tech levels, the inability to pass those much higher battery charger 

costs down the distribution chain drive the negative impacts at max-tech in the worst-case 

constant price scenario. 

Product Classes 2, 3, and 4 

The following tables (Table V-24Table V.24 through Table V-30Table V.30) 

summarize information related to the analysis performed to project the potential impacts 

on manufacturers of devices falling into product classes 2, 3, and 4. 

360 
 

 

 

 

 

 

 

Table V-24 Applications in Product Classes 2, 3, and 4 

Product Class 2 Product Class 3 Product Class 4 

Answering Machines Air Mattress Pumps DIY Power Tools (External) 

Baby Monitors Blenders Flashlights/Lanterns 

Beard and Moustache Trimmers Camcorders Handheld Vacuums 

Bluetooth Headsets DIY Power Tools (External) Medical Nebulizers 

Can Openers DIY Power Tools (Integral) Netbooks 

Consumer Two-Way Radios Handheld Vacuums Notebooks 

Cordless Phones Mixers Portable Printers 

Digital Cameras Portable DVD Players Professional Power Tools 

DIY Power Tools (Integral) Portable Printers Professional Power Tools 

E-Books RC Toys Rechargeable Garden Care Products 

Hair Clippers Stick Vacuums Robotic Vacuums 

Handheld GPS Toy Ride-On Vehicles Sleep Apnea Machines 

Home Security Systems Universal Battery Chargers Stick Vacuums 

In-Vehicle GPS VoIP Adapters Universal Battery Chargers 

Media Tablets Wireless Speakers 

Mobile Internet Hotspots 

Mobile Phones 

MP3 Players 

MP3 Speaker Docks 

Personal Digital Assistants 

Portable Video Game Systems 

Shavers 

Smartphone 

Video Game Consoles 

Wireless Headphones 

Table V-25 Cash Flow Results – Product Classes 2, 3, and 4 – Flat Markup Scenario 

Units Base 

Case* 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 44,456 

492 

44,47650 

6 

44,62362 

5 45,113020 45,58946 7 

Change in INPV 2010$ Millions - 2015 167134 657528 1,133975 

(%) - 0.0% 0.43% 1.52% 2.52% 

Product Conversion Costs 2010$ Millions - 8.27.1 29.325.5 170.2160. 

8 

303.9294 

.5 

Capital Conversion Costs 2010$ Millions - 1.53 7.06.1 48.245.4 63.360.5 

Total Investment Required 2010$ Millions - 9.78.4 36.431.6 218.4206. 

2 

367.2355 

.0 

* The reason the Base Case INPV value varies for this product class grouping is because of the uncertainty 

of how manufacturers will markup their products sold in California due to the CEC standard. The markup 

scenario used in each table for the DOE standard is also applied to those products sold in California. 

Therefore in the Flat Markup table above a flat markup is applied to all products sold in California after the 

CEC standard goes into effect. 

361 
 

Table V-26 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through 

Markup Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 44,456 

268 

42,84967 

9 

42,49336 

0 40,937810 39,10638 ,949 

Change in INPV 2010$ Millions - (1,60758 

9) 

(1,96390 

8) 

(3,519458 

) 

(5,35131 

8) 

(%) - -3.6% -4.43% -7.98% -12.0% 

Product Conversion Costs 2010$ Millions - 8.27.1 29.325.5 170.2160. 

8 

303.9294 

.5 

Capital Conversion Costs 2010$ Millions - 1.53 7.06.1 48.245.4 63.360.5 

Total Investment Required 2010$ Millions - 9.78.4 36.431.6 218.4206. 

2 

367.2355 

.0 

Table V-27 Cash Flow Results – Product Classes 2, 3, and 4 – Constant Price 

Markup Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 44,456 

43,808 

39,43638 

,911 

38,11537 

,752 

33,14332, 

944 

29,47324 

6 

Change in INPV 

2010$ Millions - (5,0204,8 

97) 

(6,34105 

5) 

(11,31310 

,863) 

(14,9835 

62) 

(%) - -11.32% 

-

14.313.8 

% 

-

25.424.8 

% 

-33.72% 

Product Conversion Costs 2010$ Millions - 8.27.1 29.325.5 170.2160. 

8 

303.9294 

.5 

Capital Conversion Costs 2010$ Millions - 1.53 7.06.1 48.245.4 63.360.5 

Total Investment Required 2010$ Millions - 9.78.4 36.431.6 218.4206. 

2 

367.2355 

.0 

Taken together, product classes 2, 3, and 4 include the greatest number of 

applications and account for more than 75 percent of total battery charger shipments in 

2013, the anticipated compliance year for new energy conservation standards. These 

product classes also include a wide variety of applications, characterized by differing 

shipment volumes, base case efficiency distributions, and MSPs. Because of this variety, 

this product class grouping, more than any other, requires a greater level of 

disaggregation to evaluate specific industry impacts. Presented only on a product class 

basis, industry impacts are effectively shipment-weighted and mask impacts on certain 

362 
 

industry applications that vary substantially from the aggregate results. Therefore, in 

addition to the overall product class group results, DOE also presents results by industry 

subgroups—consumer electronics, small appliances, power tools, and high-energy 

applications—in the pass through scenario, which approximates the mid-point of the 

potential range of impacts. These results highlight impacts at various TSLs. 

TSL 1 would require battery chargers in product classes 2, 3 and 4 to each meet 

CSL 1. Impacts on INPV are relatively moderate at TSL 1 because a majority of 

application shipments in these product classes already meet CSL 1. However, those 

shipments already meeting CSL 1 are heavily weighted toward the consumer electronics 

sector. In most cases, CSL 1 could be met with incremental circuit design improvements 

and higher efficiency components. Satisfying this level would not require a full topology 

redesign or a move to Li-ion chemistry, although manufacturers of some applications 

indicated in interviews that they may elect such a design path. 

TSL 2 has the same efficiency requirements for product classes 3 and 4 as TSL 1 

(CSL 1). Product class 2 manufacturers would have to meet CSL 2 at TSL 2, which 

would likely require battery charger design changes (e.g., moving to switched-mode and 

Li-ion chemistries) that would likely cause application manufacturers to incur significant 

R&D expenditures relative to what is normally budgeted for battery chargers. However, 

the financial impact of this investment effect would be minor compared to the base case 

industry value, which is largely driven by consumer electronics applications. 

363 
 

Industry impacts would become more acute at TSL 3 and TSL 4, as best-inmarket or max-tech designs would be required for all battery chargers. The cost of a 

battery charger in product classes 3 and 4 rises sharply at CSL 2 (best in market) and 

further at CSL 3 (max-tech). For relatively inexpensive applications, the inability to fully 

pass on these substantially higher costs (as assumed in the pass through and, to a greater 

extent, the constant price scenario) leads to significant margin compression, working 

capital drains, and, ultimately, reductions in INPV at the max-tech TSL. 

As discussed above, these aggregated results can mask differentially impacted 

industries and manufacturer subgroups. Nearly 90 percent of shipments in product classes 

2, 3 and 4 fall under the broader consumer electronics category, with the remaining share 

split between small appliances and power tools. Consumer electronics applications have a 

much higher shipment-weighted average MSP ($175) than the other product categories 

($80 for power tools and $60 for small appliances). Consequently, consumer electronics 

manufacturers are better able to absorb higher battery charger costs than small appliance 

and power tool manufacturers. Further, consumer electronics typically incorporate higher 

efficiency battery chargers already, while small appliances and power tool applications 

tend to cluster around baseline and CSL 1 efficiencies. These factors lead to 

proportionally greater impacts on small appliance and power tool manufacturers in the 

event they are not able to pass on and markup higher battery charger costs. 

Table V-28Table V.28 through Table V-30Table V.30 present INPV impacts in 

the pass through markup scenario for consumer electronic, power tool, and small 

364 
 

 

 

appliance applications, respectively (for only those applications incorporating battery 

chargers in product class 2, 3 or 4). The results clearly indicate manufacturers of power 

tools and small appliances would face disproportionately adverse impacts, as compared to 

consumer electronics manufacturers and the overall product group’s results (shown above 

in Table V-25Table V.25 through Table V-27Table V.27), if they are not able to mark up 

the incremental product costs. 

Table V-28 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through 

Markup Scenario – Consumer Electronics 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 42,0574 

1,894 

40,80067 

9 

40,45837 

3 

39,2631 

60 

37,80968 

3 

Change in INPV 2010$ Millions - (1,25721 

5) 

(1,59952 

1) 

(2,7947 

34) 

(4,24821 

1) 

(%) - -3.02.9% -3.86% -6.65% -10.1% 

Product Conversion Costs 2010$ Millions - 5.54.8 26.122.7 147.514 

0.4 

256.4249 

.2 

Capital Conversion Costs 2010$ Millions - 1.32 6.75.8 38.036. 

1 50.048.1 

Total Investment Required 2010$ Millions - 6.85.9 32.828.5 185176. 

5 306297.3 

Table V-29 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through 

Markup Scenario - Power Tools 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 1,82481 

4 1,600566 1,594560 1,35734 

4 1,114098 

Change in INPV 

2010$ Millions - (224248) (230254) (467470 

) (710716) 

(%) -

-

12.313.7 

% 

-

12.614.0 

% 

-25.69% 

-

38.939.5 

% 

Product Conversion Costs 2010$ Millions - 1.97 2.1.8 12.110. 

5 28.226.7 

Capital Conversion Costs 2010$ Millions - 0.1 0.21 5.4.7 6.92 

Total Investment Required 2010$ Millions - 2.01.7 2.30 17.515. 

3 35.132.9 

365 
 

Table V-30 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through 

Markup Scenario – Small Appliances 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 575560 449435 441427 317305 183168 

Change in INPV 

2010$ Millions - (126125) (134133) (258255 

) (392) 

(%) -

-

21.922.4 

% 

-23.47% 

-

44.945. 

4% 

-

68.270.0 

% 

Product Conversion Costs 2010$ Millions - 0.7 1.10.9 10.69.9 19.318.6 

Capital Conversion Costs 2010$ Millions - 0.1 0.2 4.95 6.52 

Total Investment Required 2010$ Millions - 0.87 1.31 1514.5 2524.7 

Product Classes 5 and 6 

The following tables (Table V-31Table V.31 through Table V-34Table V.34) 

summarize information related to the analysis performed to project the potential impacts 

on manufacturers of devices falling into product classes 5 and 6. 

Table V-31 Applications in Product Classes 5 and 6 

Product Class 5 Product Class 6 

Marine/Automotive/RV Chargers Electric Scooters 

Mobility Scooters Lawn Mowers 

Portable O2 Concentrators Motorized Bicycles 

Ride-On Toy Vehicles Wheelchairs 

Wheelchairs 

Ride-on toy vehicles represent nearly three quarters of the combined shipment 

volume in product classes 5 and 6, with marine chargers and electric scooters accounting 

for the majority of the remaining share. DOE’s market survey and interviews found that 

nearly all of the higher energy applications incorporate battery chargers with lead acid 

battery chemistries. With the exception of battery chargers for toy ride-on vehicles and 

lawn mowers, the majority of products in these groupings use baseline battery chargers. 

366 
 

 

 

 

 

Table V-32 Cash Flow Results – Product Classes 5 and 6 – Flat Markup Scenario 

Units Base Case* Trial Standard Level 

1 2 3 

INPV 2010$ Millions 1,480584 1,487589 1,439543 2,285275 

Change in INPV 2010$ Millions - 6 (4240) 805692 

(%) - 0.43% -2.85% 54.443.7% 

Product Conversion Costs 2010$ Millions - 2.01.8 11.39.8 18.816.3 

Capital Conversion Costs 2010$ Millions - 0.0 2.41 5.34.6 

Total Investment Required 2010$ Millions - 2.01.8 13.611.9 24.020.9 

* The reason the Base Case INPV value varies for this product class grouping is because of the uncertainty 

of how manufacturers will markup their products sold in California due to the CEC standard. The markup 

scenario used in each table for the DOE standard is also applied to those products sold in California. 

Therefore in the Flat Markup table above a flat markup is applied to all products sold in California after the 

CEC standard goes into effect. 

Table V-33 Cash Flow Results – Product Classes 5 and 6 – Pass Through Markup 

Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 1,480549 1,437281 1,491324 245235 

Change in INPV 2010$ Millions - (43268) 11(225) (1,235314) 

(%) - -2.917.3% 0.7-14.5% -83.484.8% 

Product Conversion Costs 2010$ Millions - 2.01.8 11.39.8 18.816.3 

Capital Conversion Costs 2010$ Millions - 0.0 2.41 5.34.6 

Total Investment 

Required 2010$ Millions - 2.01.8 13.611.9 24.020.9 

Table V-34 Cash Flow Results – Product Classes 5 and 6 – Constant Price Markup 

Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 1,480552 1,348226 1,587429 419409 

Change in INPV 2010$ Millions - (133327) 106(123) (1,061143) 

(%) - -921.0% -7.29% -71.773.6% 

Product Conversion Costs 2010$ Millions - 2.01.8 11.39.8 18.816.3 

Capital Conversion Costs 2010$ Millions - 0.0 2.41 5.34.6 

Total Investment 

Required 2010$ Millions - 2.01.8 13.611.9 24.020.9 

TSL 1, TSL 2, and TSL 3 represent CSL 1, CSL 2, and CSL 3, respectively, for 

both product class 5 and product class 6. The battery charger cost associated with each 

CSL is the same for product classes 5 and 6. The industry impacts at TSL 1 are minor to 

367 
 

moderate because a large percentage of the market already meets the CSLs represented in 

that TSL and because the incremental battery charger product costs are minor relative to 

the average application MSP of $220. At TSL 2, the battery charger cost declines 

compared to the baseline because of the technology shift from a line-frequency power 

supply to a switch-mode power supply, and the resulting impacts are projected to remain 

moderate. The constant price scenario yields positive impacts at TSL 2 because the 

higher average operating margin (due to the lower product costs) outweighs the one-time 

conversion costs.fairly moderate. At TSL 3, however, the impacts on INPV are severe 

because the required max-tech battery chargers would cost nearly seven times the cost of 

a baseline charger. 

Under the flat markup scenario, which assumes manufacturers could fully mark 

up the product to recover this additional cost, such an increase generates substantially 

greater cash flow and industry value. However, as noted earlier, the greater the increase 

in product costs, the less likely DOE believes that manufacturers will be able to fully 

markup the substantially higher production costs (the flat markup scenario). DOE 

believes manufacturers would be forced to absorb much of this dramatic cost increase at 

max-tech, yielding the substantially negative industry impacts, as shown by the lowerbound results. 

Product Class 7 

368 
 

 

 

 

 

The following tables (Table V-35Table V.35 through Table V-38Table V.38) 

summarize information related to the analysis performed to project the potential impacts 

on manufacturers of devices falling into product class 7. 

Table V-35 Applications in Product Class 7 

Product Class 7 

Golf Cars 

Table V-36 Cash Flow Results – Product Class 7 – Flat Markup Scenario 

Units Base Case* Trial Standard Level 

1 2 

INPV 2010$ Millions 1,035034 1,030 1,060057 

Change in INPV 2010$ Millions - (4) 2523 

(%) - -0.4% 2.42% 

Product Conversion Costs 2010$ Millions - 0.76 2.76 

Capital Conversion Costs 2010$ Millions - 0.2 1.5 

Total Investment Required 2010$ Millions - 0.97 4.21 

* The reason the Base Case INPV value varies for this product class grouping is because of the uncertainty 

of how manufacturers will markup their products sold in California due to the CEC standard. The markup 

scenario used in each table for the DOE standard is also applied to those products sold in California. 

Therefore in the Flat Markup table above a flat markup is applied to all products sold in California after the 

CEC standard goes into effect. 

Table V-37 Cash Flow Results – Product Class 7 – Pass Through Markup Scenario 

Units Base Case Trial Standard Level 

1 2 

INPV 2010$ Millions 1,035036 1,050 1,006003 

Change in INPV 2010$ Millions - 1514 (2933) 

(%) - 1.54% -3.2.8% 

Product Conversion Costs 2010$ Millions - 0.76 2.76 

Capital Conversion Costs 2010$ Millions - 0.2 1.5 

Total Investment Required 2010$ Millions - 0.97 4.21 

Table V-38 Cash Flow Results – Product Class 7 – Constant Price Markup Scenario 

Units Base Case Trial Standard Level 

1 2 

INPV 2010$ Millions 1,035039 1,086 907903 

Change in INPV 2010$ Millions - 5147 (128136) 

(%) - 4.95% -12.413.1% 

Product Conversion Costs 2010$ Millions - 0.76 2.76 

Capital Conversion Costs 2010$ Millions - 0.2 1.5 

Total Investment Required 2010$ Millions - 0.97 4.21 

369 
 

Golf cars are the only application in product class 7. Approximately half the 

market incorporates baseline battery charger technology -- the other half employs 

technology that meets the efficiency requirements at CSL 1. The cost of a battery charger 

in product class 7, though higher relative to other product classes, remains a small portion 

of the overall selling price of a golf car. As such, large percentage increases in the cost of 

the battery charger, as in the case of max-tech, do not yield severe impacts on golf car 

OEMs, even in the constant price scenario. Note, however, this analysis focuses on the 

application manufacturer, or the OEM. DOE did identify a U.S. small business 

manufacturer of the golf car battery charger itself (as opposed to the application). DOE 

evaluates the impacts on standards on such manufacturers in the Regulatory Flexibility 

Analysis (see section VI.B for the results of that analysis). 

Product Class 8 

The following tables (Table V-39Table V.39 through Table V-42Table V.42) 

summarize information related to the analysis performed to project the potential impacts 

on manufacturers of devices falling into product class 8. 

Table V-39 Applications in Product Class 8 

Product Class 8 

Bluetooth Headsets 

Camcorders 

Digital Cameras 

E-Books 

Handheld GPS 

Handheld Image Scanners 

Mobile Phones 

MP3 Players 

Personal Digital Assistants 

370 
 

 

 

 

 

 

 

Table V-40 Cash Flow Results – Product Class 8 – Flat Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 5,703 5,628 5,718707 5,686672 

Change in INPV 2010$ Millions - (75) 164 (1730) 

(%) - -1.3% 0.31% -0.35% 

Product Conversion Costs 2010$ Millions - 13.2 35.8 79.5 

Capital Conversion Costs 2010$ Millions - 0.0 6.1 6.8 

Total Investment Required 2010$ Millions - 13.2 41.9 86.3 

Table V-41 Cash Flow Results – Product Class 8 – Pass Through Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 5,703 6,064 5,742730 5,676663 

Change in INPV 2010$ Millions - 361 3927 (2740) 

(%) - 6.3% 0.75% -0.57% 

Product Conversion Costs 2010$ Millions - 13.2 35.8 79.5 

Capital Conversion Costs 2010$ Millions - 0.0 6.1 6.8 

Total Investment Required 2010$ Millions - 13.2 41.9 86.3 

Table V-42 Cash Flow Results – Product Class 8 – Constant Price Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 5,703 7,002 5,793781 5,655642 

Change in INPV 2010$ Millions - 1,300 9078 (4861) 

(%) - 22.8% 1.64% -0.81.1% 

Product Conversion Costs 2010$ Millions - 13.2 35.8 79.5 

Capital Conversion Costs 2010$ Millions - 0.0 6.1 6.8 

Total Investment Required 2010$ Millions - 13.2 41.9 86.3 

Product class 8 includes 14 applications, mostly consumer electronics. MP3 

players and mobile phones make up the vast majority of product class 8 shipments (58 

percent and 31 percent, respectively). Approximately 50 percent of MP3 players meet 

CSL 1 or higher and 73 percent of mobile phones already incorporate best-in-market 

battery chargers that exceed CSL 2. For most other applications in this product class, 

roughly two-thirds of the incorporated battery chargers already meet or exceed CSL 1. 

Furthermore, because the manufacturer selling prices of these dominant applications 

371 
 

 

dwarf the incremental product costs associated with increasing the efficiency—even at 

max-tech—the overall industry impacts are projected to be minor for all TSLs for product 

class 8. 

Product Class 9 

Table V-43 Applications in Product Class 9 

Product Class 9 

Flashlights/Lanterns 

In-Vehicle GPS 

Medical Nebulizers 

Portable O2 Concentrators 

DOE did not examine any TSLs for product class 9 and did not conduct any 

downstream analyses for this product class. For product class 9, DOE is not proposing a 

standard level equivalent to TSL 1 proposed for product classes 2, 3, and 4.any energy 

conservation standards. Section V.B.2.fof this NOPR provides a more detailed reason for 

this decision. 

Product Class 10 

The following tables (Table V-44Table V.44 through Table V-47Table V.47) 

summarize information related to the analysis performed to project the potential impacts 

on manufacturers of devices falling into product class 10. 

Table V-44 Applications in Product Class 10 

Product Class 10 

Uninterruptible Power Supplies 

372 
 

 

Table V-45 Cash Flow Results – Product Class 10 – Flat Markup Scenario 

Units Base 

Case* 

Trial Standard Level 

1 2 3 

INPV 2010$ Millions 615614 615614 613612 612609 

Change in INPV 2010$ Millions - (10) (2) (35) 

(%) - -0.1% -0.34% -0.59% 

Product Conversion Costs 2010$ Millions - 0.97 2.62 4.5.1 

Capital Conversion Costs 2010$ Millions - 0.0 0.4 1.85 

Total Investment Required 2010$ Millions - 0.97 3.02.6 6.90 

* The reason the Base Case INPV value varies for this product class grouping is because of the uncertainty 

of how manufacturers will markup their products sold in California due to the CEC standard. The markup 

scenario used in each table for the DOE standard is also applied to those products sold in California. 

Therefore in the Flat Markup table above a flat markup is applied to all products sold in California after the 

CEC standard goes into effect. 

Table V-46 Cash Flow Results – Product Class 10 – Pass Through Markup Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 

INPV 2010$ Millions 615614 595593 588586 581577 

Change in INPV 2010$ Millions - (2021) (2728) (3437) 

(%) - -3.35% -4.45% -5.69% 

Product Conversion Costs 2010$ Millions - 0.97 2.62 4.5.1 

Capital Conversion Costs 2010$ Millions - 0.0 0.4 1.85 

Total Investment Required 2010$ Millions - 0.97 3.02.6 6.90 

Table V-47 Cash Flow Results – Product Class 10 – Constant Price Markup 

Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 

INPV 2010$ Millions 615612 538532 516512 490487 

Change in INPV 

2010$ Millions - (7781) (99100) (125126 

) 

(%) -

-

12.513. 

2% 

-16.04% -20.35% 

Product Conversion Costs 2010$ Millions - 0.97 2.62 4.5.1 

Capital Conversion Costs 2010$ Millions - 0.0 0.4 1.85 

Total Investment Required 2010$ Millions - 0.97 3.02.6 6.90 

Product class 10 has only one application: uninterruptible power supplies. The 

vast majority of models on the market have sealed lead-acid battery chemistries. The 

efficiency distribution for product class 10 assumes all shipments are at the baseline CSL. 

Compared to the average application MSP of approximately $289, the incremental costs 

373 
of meeting the higher CSLs remain relatively low, despite increasing substantially on a 

percentage basis. Therefore, even in the constant price scenario, INPV impacts are 

projected to be limited. 

b. Impacts on Employment 

DOE’s research suggests that no EPSs are currently manufactured domestically. 

Most OEMs or their domestic distributors have employees in the United StatesAs part of 

the direct employment impact analysis, DOE attempted to quantify the number of 

domestic workers involved in EPS manufacturing. Based on manufacturer interviews and 

DOE’s research, DOE believes that all major EPS ODMs are foreign owned and 

operated. DOE did identify a few smaller niche EPS ODMs based in the U.S. and 

attempted to contact these companies. All of the companies DOE reached indicated their 

EPS manufacturing takes place abroad. During manufacturer interviews, large 

manufacturers also indicated the vast majority, if not all, EPS production takes place 

overseas. Due to DOE’s inability to identify any EPS ODMs with domestic 

manufacturing, DOE has tentatively concluded that there are no EPSs currently 

manufactured domestically. However, in recognition of the fragmented nature of this 

market, DOE seeks comment and input as to whether there are EPS manufacturers that 

have domestic production. 

DOE also recognizes there are several OEMs or their domestic distributors that 

have employees in the U.S. that work on design, technical support, sales, training, 

certification, and other requirements. However, DOEin interviews manufacturers 

374 
generally did not identifyexpect any domestic manufacturing activities for EPSs and 

DOE does not anticipate anynegative changes in the domestic production employment of 

the design, technical support, or other departments of EPS OEMs located in the U.S. in 

response to new or amended energy conservation standards. 

For battery chargers, DOE’s research indicates that golf cars are the major application 

with U.S.-based manufacturing. 

For battery chargers, DOE similarly attempted to quantify the number of domestic 

workers involved in battery charger production. Based on manufacturer interviews and 

DOE’s research, DOE believes that the vast majority of all small appliance and consumer 

electronic applications are manufactured abroad. When looking specifically at the battery 

charger component, which is typically designed by the application manufacturer but 

sourced for production, the same dynamic holds to an even greater extent. That is, in the 

rare instance when an application’s production occurs domestically, it is very likely that 

the battery charger component is still produced and sourced overseas. For example, DOE 

identified several power tool applications with some level of domestic manufacturing. 

However, based on more detailed information obtained during interviews, DOE believes 

the battery charger components for these applications are sourced from abroad. 

Also, DOE was able to find a few manufacturers of medium and high power 

applications with facilities in the U.S. However, only a limited number of these 

companies produce battery chargers domestically for these applications. Therefore, based 

on manufacturer interviews and DOE’s research, DOE believes that golf cars are the only 

375 
 

application with U.S.-based battery charger manufacturing. Any change in U.S. 

production employment due to new battery charger energy conservation standards is 

likely to come from changes involving these particular products. DOE seeks comment on 

the presence of any domestic battery charger manufacturing outside of the golf car 

industry and beyond prototyping for R&D purposes. 

At the proposed efficiency levels, domestic golf car manufacturers will face a 

difficult decision on whether to attempt to manufacture more efficient battery chargers inhouse and try to compete with a greater level of vertical integration than their 

competitors, move production to lower-wage regions abroad, or source their battery 

charger manufacturing. DOE believes one of the latter two strategies would be more 

likely for domestic golf car manufacturers. DOE describes the major implications for golf 

car employment in the regulatory flexibility section VI.B below because the major 

domestic manufacturer is also a small business manufacturer. Similar to EPSs, DOE does 

not anticipate any negative changes in the domestic employment of the design, technical 

support, or other departments of battery charger application manufacturers located in the 

U.S. in response to new energy conservation standards. Standards may require some 

companies to redesign their battery chargers, change marketing literature, and train some 

technical and sales support staff. However, during interviews, manufacturers generally 

agreed these changes would not lead to positive or negative changes in employment. 

376 

Comment [A35]: Changes recommended by 

OIRA. 
c. Impacts on Manufacturing Capacity 

DOE does not anticipate that the standards proposed in today’s rule would 

adversely impact manufacturer capacity. For EPSs, EISA has set a statutory compliance 

date. The EPS industry is characterized by rapid product development lifecycles. Most 

battery charger applications have similar design cycles. While there is no statutory 

compliance date for battery chargers, DOE believes the compliance date proposed in 

today’s rule provides sufficient time for manufacturers to ramp up capacity to meet the 

proposed standards for battery chargers and EPSs. DOE requests comment on the 

appropriate compliance date for battery charger (see section I). 

d. Impacts on Sub-Group of Manufacturers 

Using average cost assumptions to develop an industry cash-flow estimate is not 

adequate for assessing differential impacts among manufacturer subgroups. Small 

manufacturers, niche equipment manufacturers, and manufacturers exhibiting a cost 

structure substantially different from the industry average could be affected 

disproportionately. DOE addressed manufacturer subgroups in the battery charger MIA. 

Because certain applications are disproportionately impacted compared to the overall 

product class, DOE reports those results individually so they can be considered as part of 

the overall MIA. DOE did not identify any EPS manufacturer subgroups that would 

require a separate analysis in the MIA. 

377 
 

DOE also identified small businesses as a subgroup that could potentially be 

disproportionally impacted. DOE discusses the impacts on the small business subgroup in 

the regulatory flexibility analysis (section VI.B). 

e. Cumulative Regulatory Burden 

While any one regulation may not impose a significant burden on manufacturers, 

the combined effects of several impending regulations may have serious consequences 

for some manufacturers, groups of manufacturers, or an entire industry. Assessing the 

impact of a single regulation may overlook this cumulative regulatory burden. In addition 

to energy conservation standards, other regulations can significantly affect 

manufacturers’ financial operations. Multiple regulations affecting the same 

manufacturer can strain profits and can lead companies to abandon product lines or 

markets with lower expected future returns than competing products. For these reasons, 

DOE conducts an analysis of cumulative regulatory burden as part of its rulemakings 

pertaining to appliance efficiency. DOE received many comments about the potential 

cumulative regulatory burden (see section IV.I.4.a) that may result from a standard for 

battery chargers and EPSs. The regulatory burdens described in those comments, 

however, generally fall outside of the scope of the cumulative regulatory burden analysis, 

which generally focuses on the impacts related to Federal regulations with a compliance 

date within three years of the anticipated compliance date of today’s proposal. DOE notes 

that the potential for duplicative testing requirements raised by some commenters were 

addressed above. 

378 
 

 

 

 

i. Impact Due to CEC Battery Charger Standard 

Table V-48Table V.48 presents the range of impacts on all battery charger 

product classes due to the CEC battery charger standards. 

Table V-48 – Base Case Manufacturer Impact Analysis for All Battery Charger 

Product Classes Due to the CEC Standard 

With California Standard* No Pass Constant Units California Flat Through Price Standard Markup Markup Markup 

INPV 2010$ Millions 53,780 53,918 53,660 53,205 

2010$ Millions - 137 -120 -575 Change in INPV (%) - 0.3 (0.2) (1.1) 

Product Conversion Costs 2010$ Millions - 12.6 12.6 12.6 

Capital Conversion Costs 2010$ Millions - 3.8 3.8 3.8

Total Investment Required 2010$ Millions - 16.4 16.4 16.4 

* The reason the Base Case INPV value varies for battery chargers is because of the uncertainty of how 

manufacturers will markup their products sold in California due to the CEC standard. The markup scenario 

used in each column is applied to those products sold in California. Therefore in the Constant Price column 

a constant price markup is applied to all products sold in California after the CEC standard goes into effect. 

DOE quantitatively assessed the impact of the CEC battery charger standard on 

battery charger application manufacturers. This standard affects applications using a 

battery charger that are sold in California beginning in 2013. DOE estimates the impacts 

on manufacturers to range from $137 million to -$575 million, or a change in INPV of 

0.3 percent to -1.1 percent. This range depends on manufacturers’ ability to pass on the 

incremental price increases to consumers in the California markets caused by the CEC 

standard. DOE also estimated manufacturers will have to invest $12.6 million in product 

conversion costs and $3.8 million in capital conversion costs in order to have all battery 

charger applications sold in California meet the CEC standard by 2013. 

379 
 

 

 

 

3. National Impact Analysis 

a. Significance of Energy Savings 

To estimate the energy savings during the analysis period attributable to potential 

standards for battery chargers and EPSs, DOE compared the energy consumption of these 

products in the base case to their anticipated energy consumption with standards set at 

each TSL. 

Table V-49Table V.49 and Table V-50Table V.50 present DOE’s forecasts of the 

national energy savings at each TSL for battery chargers and EPSs. The savings were 

calculated using the approach described in section IV.G. Chapter 10 of the NOPR TSD 

presents tables that also show the magnitude of the energy savings if the savings are 

discounted at rates of 3 and 7 percent. Discounted energy savings represent a policy 

perspective in which energy savings realized farther in the future are less significant than 

energy savings realized in the nearer term. 

Table V-49 External Power Supplies: Cumulative National Energy Savings in 

Quads 

Product Class Trial Standard Level 

1 2 3 

B 0.458 0.724725 1.316 

B,C,D, E 0.562585 0.881916 1.562604 

X 0.063 0.072 0.147 

H 0.001 0.001 0.002 

Table V-50 Battery Chargers: Cumulative National Energy Savings in Quads 

Product Class Trial Standard Level 

1 2 3 4 

1 0.056 0.130 0.178 N/A 

2, 3, 4 0.340309 0.857759 1.922797 2.1101.997 

5, 6 0.308268 0.685596 0.898781 N/A 

7 0.008007 0.021 N/A N/A 

380 
 

8 0.011010 0.048041 0.053045 N/A 

10 0.265231 0.308268 0.359312 N/A 

b. Net Present Value of Consumer Costs and Benefits 

DOE estimated the cumulative NPV to the Nation of the total costs and savings 

for consumers that would result from potential standard levels for battery chargers and 

EPSs. In accordance with the OMB’s guidelines on regulatory analysis (OMB Circular 

A-4, section E, September 17, 2003), DOE calculated NPV using both a 3-percent and a 

7-percent real discount rate. 

Table V-51 

Formatted: Normal, Line spacing: Double 

Table V.51 and Table V-52Table V.52 show the consumer NPV results for each 

TSL DOE considered for EPSs, using both a 3-percent and a 7-percent discount rate. 

Table V-53Table V.53 and Table V-54Table V.54 show the corresponding results for 

battery chargers. In each case, the impacts cover the lifetime of products purchased in 

2013–2042. See chapter 10 of the TSD for more detailed NPV results. 

Table - Cumulative Net Present Value of Consumer Benefits for External Power 

Supplies, 3-Percent Discount Rate (2010$ millions) 

Product Class Trial Standard Level 

1 2 3 

B 1,227.4 1,137.7 (3,293.5) 

B,C,D, E 1,388.0 1,294.5 (3,266.9) 

X 329.2 330.3 (533.2) 

H 9.4 9.7 7.6 

381 
 

Table V-51 Cumulative Net Present Value of Consumer Benefits for External Power 

Supplies, 3-Percent Discount Rate (2010$ millions) 

Product Class 

B 

B,C,D, E 

X 

H 

Trial Standard Level 

1 2 

1,227.7 1,138.4 

1,542.2 1,525.4 

329.2 330.3 

9.4 9.7 

3 

(3,292.3) 

(2,982.9) 

(533.2) 

7.6 

Table V-52 Cumulative Net Present Value of Consumer Benefits for External Power 

Supplies, 7-Percent Discount Rate (2010$ millions) 

Product Class Trial Standard Level 

1 2 3 

B 596.02 463.03 (2,357.5356.8) 

B,C,D, E 646.6729.7 489.1613.5 (2,454301.4) 

X 177.7 175.5 (363.5) 

H 4.8 5.0 3.6 

Table V-53 Cumulative Net Present Value of Consumer Benefits for Battery 

Chargers, 3-Percent Discount Rate (2010$ millions) 

Product Class Trial Standard Level 

1 2 3 4 

1 294.0 605.6 (781.2) N/A 

2, 3, 4 1,349.5255.1 (517.2366.9) 

(15,216.314,1 

59.0) 

(39,581.238, 

442.7) 

5, 6 1,871.2627.9 5,342.24,647.7 

(12,78411,12 

2.7) N/A 

7 137.2119.4 (478.1493.2) N/A N/A 

8 2,791.3780.5 (1,610.2654.5) 

(2,001.1,953. 

0) N/A 

10 1,370.6192.4 1,556.8354.4 1,781.0549.5 N/A 

Table V-54 Cumulative Net Present Value of Consumer Benefits for Battery 

Chargers, 7-Percent Discount Rate (2010$ millions) 

Product Class Trial Standard Level 

1 2 3 4 

1 156.8 317.9 (527.2) N/A 

2, 3, 4 711.3663.8 (517.2434.7) (9,641.08,973 

.2) 

(24,254.92 

3,542.1) 

5, 6 996.9867.3 5,342.2,539.4 (8,001.6,961. 

4) N/A 

7 80.369.8 (478.1299.5) N/A N/A 

8 1665.1,659.3 (1,610.2999.9) (1,182.5208.3 

) N/A 

382 
10 702.6611.3 1,556.8691.9 906.8788.9 N/A 

DOE conducted NPV sensitivity analysis using three alternative price trends. The 

NPV results from the associated sensitivity cases are described in appendix 10-X of the 

NOPR TSD. 

c. Indirect Impacts on Employment 

DOE develops estimates of the indirect employment impacts of potential 

standards on the economy in general. As discussed above, DOE expects energy 

conservation standards for battery chargers and EPSs to reduce energy bills for 

consumers of these products, and the resulting net savings to be redirected to other forms 

of economic activity. These expected shifts in spending and economic activity could 

affect the demand for labor. As described in section IV.J, to estimate these effects DOE 

used an input/output model of the U.S. economy. and present the estimated net indirect 

employment impacts in 2020 and 2042 for the TSLs that DOE considered in this 

rulemaking. Chapter 13 of the TSD presents more detailed results DOE understands that 

there are uncertainties involved in projecting employment impacts generated by an 

input/output model, especially changes in the later years of the analysis. Therefore, DOE 

generated results for near-term timeframes, such as 2015, where these uncertainties are 

reduced. 

Comment [A36]: Changes recommended by 

OIRA. 

Table - Net Increase in Jobs from Indirect Employment Effects Under External 

Power Supply TSLs 

TSL 1 TSL 2 TSL 3 

Thousands 

383 
 

Product Class B 

 2020 

 2042 

0.89 

1.23 

1.36 

1.90 

2.23 

3.16 

Product Classes B, C, D, and E 

 2020 

 2042 

1.06 

1.51 

1.62 

2.31 

2.62 

3.79 

Product Class X

 2020 

 2042 

0.12 

0.16 

0.13 

0.19 

0.21 

0.31 

Product Class H 

 2020 

 2042 

0.00 

0.00 

0.00 

0.01 

0.00 

0.01 

Table -Net Increase in Jobs from Indirect Employment Effects Under Battery 

Charger TSLs 

TSL 1 TSL 2 TSL 3 TSL 

4 

Thousands 

Product Class 1 

 2020 

 2042 

0.12 

0.16 

0.28 

0.38 

0.31 

0.43 

n.a. 

Product Classes 2, 3, 4

 2020 

 2042 

0.71 

0.98 

1.56 

2.20 

2.88 

4.19 

2.14 

3.40 

Product Classes 5, 6

 2020 

 2042 

0.64 

0.92 

1.44 

2.06 

1.04 

1.71 

n.a. 

Product Class 7 

 2020 

 2042 

0.01 

0.02 

0.01 

0.02 

n.a. n.a. 

Product Class 8 

 2020 

 2042 

0.02 

0.02 

0.00 

0.02 

0.26 

0.38 

n.a. 

Product Class 10 

 2020 

 2042 

0.18 

0.24 

0.61 

0.84 

0.71 

0.98 

n.a. 

The input/output model suggests that today’s results suggest the proposed 

standards are likely to increasehave negligible impact on the net demand for labor in the 

economy. These gainsThe net change in jobs is so small that it would most likely be 

small relative to total imperceptible in national labor statistics and might be offset by 

384 
 

 

other, unanticipated effects on employment. Neither the BLS data nor Chapter 13 of the 

input/output model DOE uses include the quality or wage level of these newly created 

jobs. Therefore, DOE has tentatively concluded that the proposed standards are likely to 

produce employment benefits sufficient to fully offset any adverse impacts on 

employment in the manufacturing industries for the products that are the subject of this 

rulemakingNOPR TSD presents more detailed results. Comment [A37]: Changes recommended by 

OIRA. 

4. Impact on Utility or Performance of Products 

As presented in section III.BIII.B of this notice, DOE has tentatively concluded 

that none of the TSLs considered in this notice would reduce the utility or performance of 

the products under consideration in this rulemaking. Furthermore, manufacturers of these 

products currently offer EPSs and battery chargers that meet or exceed the proposed 

standards. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) 

5. Impact of Any Lessening of Competition 

DOE has also considered any lessening of competition that is likely to result from 

amended standards. The Attorney General determines the impact, if any, of any lessening 

of competition likely to result from a proposed standard, and transmits such 

determination to the Secretary, together with an analysis of the nature and extent of such 

impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) 

To assist the Attorney General in making such determination, DOE will provide 

DOJ with copies of this NOPR and the TSD for review. DOE will consider DOJ’s 

Formatted: Font color: Black 

385 
 

 

comments on the proposed rule in preparing the final rule, and DOE will publish and 

respond to DOJ’s comments in that document. 

6. Need of the Nation to Conserve Energy 

An improvement in the energy efficiency of the products subject to today’s NOPR 

is likely to improve the security of the Nation’s energy system by reducingand reduce the 

overall demand for costs of energy production. Reduced electricity demand may also 

improve the reliability of the electricity system, particularly during peak-load periods. (42 

U.S.C. 6295(o)(2)(B)(i)(VI)) As a measure of this reduced demand, and present the 

estimated reduction in generating capacity in 2042 for the TSLs that DOE considered in 

this rulemaking for EPSs and battery chargers, respectively. 

Table - Reduction in Electric Generating Capacity in 2042 Under Considered External 

Power Supply TSLs 

TSL 1 TSL 2 TSL 3 

Gigawatts 

Product Class B 0.255 0.404 0.734 

Product Classes B, C, D, and E 0.313 0.490 0.870 

Product Class X 0.035 0.040 0.082 

Product Class H 0.001 0.001 0.001 

Table - Reduction in Electric Generating Capacity in 2042 Under Considered 

Battery Charger TSLs 

TSL 1 TSL 2 TSL 3 TSL 4 

Gigawatts 

Product Class 1 0.031 0.072 0.099 NA 

Product Classes 2, 3, 4 0.190 0.478 1.072 1.177 

Product Classes 5, 6 0.171 0.380 0.498 NA 

Product Class 7 0.004 0.010 NA NA 

Product Class 8 0.006 0.027 0.029 NA 

Product Class 10 0.122 0.141 0.165 NA 

386 
 

 

 

 

 

 

 

Energy savings from amended standards for Class A EPSs and new 

standards for non-Class A EPSs and battery chargers could also produce environmental 

benefits in the form of reduced emissions of air pollutants and greenhouse gases 

associated with electricity production. Table V-55Table V-54 and Table V-56Table V-55 

provide DOE’s estimate of cumulative CO2, NOX, and Hg emissions reductions that 

would be expected to result from each of the TSLs considered in this rulemaking for 

EPSs and battery chargers, respectively. In the environmental assessment (chapter 15 in 

the NOPR TSD), DOE reports annual CO2, NOX, and Hg emissions reductions for each 

considered TSL. 

As discussed in section IV.L, DOE has not reported SO2 emissions reductions 

from power plants, because there is uncertainty about the effect of energy conservation 

standards on the overall level of SO2 emissions in the United States due to SO2 emissions 

caps. DOE also did not include NOX emissions reduction from power plants in States 

subject to CAIR because an amended energy conservation standard would not affect the 

overall level of NOX emissions in those States due to the emissions caps mandated by 

CAIR. 78 

Table V-55 Cumulative Emissions Reduction for 2013- 2042 Under External Power 

Supply TSLs 

Comment [A38]: Changes recommended by 

OIRA. 

Formatted: Font: Not Bold 

TSL 1 TSL 2 TSL 3 

Product Class B 

CO2 (Mt) 21.7 34.3 62.5 

78 EPA issued the final Cross-State Air Pollution Rule on July 6, 2011. [INSERT CITE – not in FR at the 

moment]. The Cross-State Air Pollution Rule will replace CAIR. In the Environmental Assessment for 

this proposal to amend energy conservation standards, DOE’s discussion and conclusions about NOx 

emissions assume the implementation of CAIR and associated trading schemes and do not take into account 

the very recently issued Cross-State Air Pollution Rule. In future rulemakings, DOE will adjust its relevant 

models to assume the implementation of the Cross-State Air Pollution Rule. 

387 
 

NOX (kt) 

Hg(t) 

17.9 

0.115 

28.4 

0.182 

51.6 

0.331 

Product Classes B, C, 

D, and E 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

26.427.5 

21.822.7 

0.139145 

41.443.0 

34.235.5 

0.218227 

73.575.4 

60.662.3 

0.388398 

Product Class X 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

2.95 

2.43 

0.015 

3.38 

2.79 

0.018 

6.92 

5.71 

0.036 

Product Class H 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

0.054 

0.045 

0.000 

0.058 

0.048 

0.000 

0.065 

0.053 

0.000 

Table V-56 Cumulative Emissions Reduction for 2013- 2042 Under Battery Charger 

TSLs 

TSL 1 TSL 2 TSL 3 TSL 4 

Product Class 1 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

2.62 

2.17 

0.014 

6.11 

5.05 

0.032 

8.36 

6.90 

0.044 

NAN/A 

NAN/A 

NAN/A 

Product Classes 2, 3, 4 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

16.214.7 

13.312.1 

0.086078 

40.635.9 

33.529.7 

0.215191 

9185.1 

75.270.3 

0.483452 

10094.6 

82.678.1 

0.531502 

Product Classes 5, 6 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

14.212.4 

11.710.2 

0.074065 

31.527.4 

26.022.6 

0.164143 

41.335.9 

34.029.6 

0.215187 

NaN/A 

NaN/A 

NaN/A 

Product Class 7 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

0.359312 

0.298259 

0.002 

0.964975 

0.799808 

0.006 

NaN/A 

NaN/A 

naN/A 

NaN/A 

NaN/A 

NaN/A 

Product Class 8 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

0.535457 

0.442378 

0.003002 

2.261.95 

1.8761 

0.012010 

2.5016 

2.071.78 

0.013011 

NaN/A 

NaN/A 

NaN/A 

Product Class 10 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

11.810.3 

9.728.46 

0.078068 

13.711.9 

11.39.81 

0.091079 

16.013.9 

13.211.5 

0.106092 

NaN/A 

NaN/A 

NaN/A 

388 
 

 

 

DOE also estimated monetary benefits likely to result from the reduced emissions 

of CO2 and NOX that DOE estimated for each of the TSLs considered for battery chargers 

and EPSs. In order to make this calculation similar to the calculation of the NPV of 

consumer benefits, DOE considered the reduced emissions expected to result over the 

lifetime of products shipped in the forecast period for each TSL. 

As discussed in section IV.M, a Federal interagency group selected four SCC 

values for use in regulatory analyses, which DOE used in the NOPR analysis. The four 

SCC values (expressed in 2007$) are $4.7/ton (the average value from a distribution that 

uses a 5-percent discount rate), $21.4/ton (the average value from a distribution that uses 

a 3-percent discount rate), $35.1/ton (the average value from a distribution that uses a 

2.5-percent discount rate), and $64.9/ton (the 95th-percentile value from a distribution 

that uses a 3-percent discount rate). These values correspond to the value of CO2 

emission reductions in 2010; the values for later years are higher due to increasing 

damages as the magnitude of climate change increases. For each of the four cases, DOE 

calculated a present value of the stream of annual values using the same discount rate as 

was used in the studies upon which the dollar-per-ton values are based. 

Table V-57Table V-56 to Table V-60Table V-59 and Table V-61Table V-60 to 

Table V-66Table V-65 present the global values of CO2 emissions reductions at each TSL 

considered for energy efficiency for EPSs and battery chargers, respectively. As 

explained in section IV.M.1, DOE calculated domestic values as a range from 7 percent 

to 23 percent of the global values, and these results are presented in Table V-67Table 

389 
 

 

 

 

 

 

 

 

 

 

 

V-66to Table V-70Table V-69 and Table V-71Table V-70 to Table V-76Table V-75 for 

EPSs and battery chargers, respectively. 

Table V-57 External Power Supply Product Class B: Estimates of Global Present 

Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 91 448 752 1,368369 

2 145 709710 1,189190 2,164166 

3 263 1,289 2,161162 3,933936 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-58 External Power Supply Product Classes B, C, D, and E: Estimates of 

Global Present Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 112116 549572 921960 1,676746 

2 175182 860895 1,444501 2,626731 

3 311319 1,526568 2,560631 4,657785 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-59 External Power Supply Product Class X: Estimates of Global Present 

Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 12 61 103 187 

2 14 70 118 215 

3 29 144 242 440 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

390 
 

 

 

 

 

 

 

 

 

 

Table V-60 External Power Supply Product Class H: Estimates of Global Present 

Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 0 1 2 4 

2 0 1 2 4 

3 0 1 2 4 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-61 Battery Charger Product Class 1: Estimates of Global Present Value of 

Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 11 55 92 167 

2 26 127 213 388 

3 35 174 292 531 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-62 Battery Chargers Product Classes 2, 3, 4: Estimates of Global Present 

Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 6862 333302 558506 1,015921 

2 171151 836740 1,402242 2,552260 

3 383358 1,876753 3,1462,940 5,726352 

4 420398 2,0591,949 3,453268 6,2845,949 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table - Battery Chargers Product Classes 5, 6: Estimates of Global Present Value of 

Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% 3% 2.5% 3% discount 

391 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

discount rate, 

average* 

discount rate, 

average* 

discount rate, 

average* 

rate, 95th 

percentile* 

1 61 300 503 914 

2 135 667 1,119 2,034 

3 177 873 1,466 2,664 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table - Battery Chargers Product Class 7: Estimates of Global Present Value of 

Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% 

discount rate, 

average* 

3% 

discount rate, 

average* 

2.5% 

discount rate, 

average* 

3% discount 

rate, 95th 

percentile* 

1 1 7 12 22 

2 4 20 33 60 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-63 Battery Chargers Product Class 8Classes 5, 6: Estimates of Global 

Present Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 253 11261 18438 34795 

2 10118 47580 78974 1421,770 

3 11154 52760 861,276 1572,318 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-64 Battery Chargers Product Class 107: Estimates of Global Present Value 

of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 511 2536 42611 77319 

2 594 29420 49433 89661 

3 69 343 576 1,046 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

392 
 

 

 

 

 

 

 

 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-65 External Power Supply Battery Chargers Product Class B8: Estimates 

of DomesticGlobal Present Value of Cumulative CO2 Emissions Reduction Under 

TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 6 to 212 31 to 1039 53 to 17316 96 to 31529 

2 10 to 338 50 to 16340 83 to 27467 151 to 498122 

3 18 to 609 90 to 29644 151 to 49774 275 to 905136 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-66 External Power Supply Battery Chargers Product Classes B, C, D, 

EClass 10: Estimates of DomesticGlobal Present Value of Cumulative CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 8 to 2645 38 to 126220 64 to 212370 117 to 385672 

2 12 to 4052 60 to 198256 101 to 332430 184 to 604780 

3 22 to 7160 107 to 351298 179 to 589501 326 to 1071910 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-67 External Power Supply Product Class XB: Estimates of Domestic 

Present Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 6 to 21 31 to 103 53 to 173 96 to 315 

2 10 to 33 50 to 163 83 to 274 152 to 498 

3 18 to 60 90 to 297 151 to 497 275 to 905 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

393 
 

 

 

 

 

 

 

 

Table V-68 External Power Supply Product Classes B, C, D, E: Estimates of 

Domestic Present Value of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 8 to 27 40 to 132 67 to 221 122 to 402 

2 13 to 42 63 to 206 105 to 345 191 to 628 

3 22 to 73 110 to 361 184 to 605 335 to 1,101 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-69 External Power Supply Product Class X: Estimates of Domestic Present 

Value of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 1 to 3 4 to 14 7 to 24 13 to 43 

2 1 to 3 5 to 16 8 to 27 15 to 49 

3 2 to 7 10 to 33 17 to 56 31 to 101 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-70 External Power Supply Product Class H: Estimates of Domestic Present 

Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 0.017 to 0.056 0.085 to 0.280 0.144 to 0.472 0.260 to 0.854 

2 0.018 to 0.060 0.092 to 0.301 0.154 to 0.507 0.279 to 0.918 

3 0.020 to 0.067 0.102 to 0.334 0.171172 to 

0.563564 

0.310 to 1.020 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

394 
 

 

 

 

 

 

 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-71 Battery Charger Product Class 1: Estimates of Domestic Present Value 

of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 1 to 3 4 to 13 6 to 21 12 to 38 

2 2 to 6 9 to 29 15 to 49 27 to 89 

3 2 to 8 12 to 40 20 to 67 37 to 122 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table - Battery Charger Product Classes 2, 3, 4: Estimates of Domestic Present 

Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% 

discount rate, 

average* 

3% 

discount rate, 

average* 

2.5% 

discount rate, 

average* 

3% 

discount rate, 

95th percentile* 

1 5 to 16 23 to 76 39 to 128 71 to 233 

2 12 to 39 59 to 192 98 to 323 179 to 587 

3 27 to 88 131 to 431 220 to 724 401 to 1317 

4 29 to 97 144 to 474 242 to 794 440 to 1445 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-72 Battery Charger Product Classes 5, 62, 3, 4: Estimates of Domestic 

Present Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 4 to 14 21 to 69 35 to 116 64 to 210 

2 9 to 31 47 to 153 78 to 257 142 to 468 

3 12 to 41 61 to 201 103 to 337 186 to 613 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

395 
 

 

 

 

 

 

 

Table - Battery Charger Product Class 7: Estimates of Domestic Present Value of 

Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 4 to 14 21 to 69 35 to 116 64 to 212 

2 11 to 35 52 to 170 87 to 286 158 to 520 

13 025 to 082 1123 to 2403 1206 to 3676 2375 to 51,231 

24 028 to 191 1136 to 5448 2229 to 8752 4416 to 141,368 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-73 Battery Charger Product Class 8Classes 5, 6: Estimates of Domestic 

Present Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 04 to 112 118 to 360 131 to 4101 256 to 8183 

2 18 to 227 341 to 11133 568 to 18224 10124 to 33407 

3 111 to 235 453 to 12175 689 to 20293 11162 to 36533 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-74 Battery Charger Product Class 107: Estimates of Domestic Present 

Value of Cumulative CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 0.091 to 0.300 0.446 to 1 1 to 2 1 to 4 

2 0 to 1 1 to 5 2 to 8 4 to 14 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-75 Battery Charger Product Class 8: Estimates of Domestic Present Value 

of CO2 Emissions Reduction Under TSLs 

TSL Million 2010$ 

396 
 

 

 

 

 

 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 0.135 to 0.442 0.658 to 2 1 to 4 2 to 7 

2 1 to 2 3 to 9 5 to 15 9 to 28 

3 1 to 2 3 to 10 5 to 17 9 to 31 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

Table V-76 Battery Charger Product Class 10: Estimates of Domestic Present Value 

of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 43 to 1210 1815 to 5851 3026 to 9885 5447 to 178155 

2 4 to 1412 2118 to 6859 3530 to 11499 6355 to 206179 

3 54 to 1614 2421 to 7969 4035 to 132115 7364 to 241209 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or 

drawn from a different part of the distribution. Values presented in the table are based on escalating the 

SCC values in 2007$ to 2010$ for consistency with other values presented in this notice, and incorporate 

the escalation of the SCC over time. 

DOE is well aware that scientific and economic knowledge about the contribution 

of CO2 and other GHG emissions to changes in the future global climate and the potential 

resulting damages to the world economy continues to evolve rapidly. Thus, any value 

placed in this rulemaking on reducing CO2 emissions is subject to change. DOE, together 

with other Federal agencies, will continue to review various methodologies for estimating 

the monetary value of reductions in CO2 and other GHG emissions. This ongoing review 

will consider any comments on this subject that are part of the public record for this and 

other rulemakings, as well as other methodological assumptions and issues. However, 

consistent with DOE’s legal obligations, and taking into account the uncertainty involved 

397 
 

 

with this particular issue, DOE has included in this NOPR the most recent values and 

analyses resulting from the ongoing interagency review process. 

DOE also estimated a range for the cumulative monetary value of the economic 

benefits associated with NOX emissions reductions anticipated to result from amended 

standards for Class A EPSs and new standards for non-Class A EPSs and battery 

chargers. The dollar-per-ton values that DOE used are discussed in section IV.M. Table 

V-77Table V-76 presents the cumulative present values for each TSL considered for 

EPSs, calculated using 7-percent and 3-percent discount rates. Table V-78Table V-77 

presents similar results for the TSLs considered for battery chargers. 

Table V-77 Estimates of Present Value of Cumulative NOX Emissions Reduction 

Under External Power Supply TSLs 

TSL 1 TSL 2 TSL 3 

Million 2010$ 

Product Class B 

3% discount rate 

7% discount rate 

5 to 5253 

3 to 29 

8 to 83 

5 to 47 

15 to 151 

8 to 85 

Product Classes B, C, D, E 

3% discount rate 

7% discount rate 

6 to 6467 

34 to 3637 

10 to 100104 

56 to 5658 

1718 to 178183 

10 to 99102 

Product Class X 

3% discount rate 

7% discount rate 

1 to 7 

0 to 4 

1 to 8 

0 to 5 

2 to 17 

1 to 9 

Product Class H 

3% discount rate 

7% discount rate 

0.013 to 0.135 

0.007 to 0.069 

0.014 to 0.145 

0.007 to 0.074 

0.016 to 0.161 

0.008 to 0.082 

398 
 

 

 

 

Table V-78 Estimates of Present Value of Cumulative NOX Emissions Reduction 

Under Battery Charger TSLs 

TSL 1 TSL 2 TSL 3 TSL 4 

Million 2010$ 

Product Class 1 

3% discount rate 

7% discount rate 

1 to 6 

0.344 to 4 

1 to 15 

1 to 8 

2 to 20 

1 to 11 

NAN/A. 

NAN/A. 

Product Classes 2, 3, 4 

3% discount rate 

7% discount rate 

43 to 3935 

2 to 2220 

108 to 9887 

5 to 5549 

2120 to 

220206 

1211 to 

124116 

2422 to 

242229 

13 to 136129 

Product Classes 5, 6 

3% discount rate 

7% discount rate 

3 to 3530 

2 to 1916 

7 to 7767 

4 to 4237 

109 to 10188 

5 to 5548 

NAN/A. 

NAN/A. 

Product Class 7 

3% discount rate 

7% discount rate 

0.073 to 1 

0.042 to 0.431 

0.229 to 2 

0.131 to 1 

NAN/A. 

NAN/A. 

NAN/A. 

NAN/A. 

Product Class 8 

3% discount rate 

7% discount rate 

0.108 to 1 

0.061 to 1 

10.459 to 5 

0.260 to 3 

1 to 65 

0.288 to 3 

NAN/A 

 NAN/A. 

Product Class 10 

3% discount rate 

7% discount rate 

32 to 2925 

21 to 1614 

3 to 3429 

2 to 1816 

43 to 3934 

2 to 2118 

NAN/A 

NAN/A. 

The NPV of the monetized benefits associated with emissions reductions can be 

viewed as a complement to the NPV of the consumer savings calculated for each TSL 

considered in this rulemaking. Table V-79Table V-78 shows an example of the 

calculation of the combined NPV, including benefits from emissions reductions for the 

case of TSL 1 for battery chargers product classes 2, 3, 4. Table V-80Table V-79 and 

Table V-81Table V-80 present the NPV values that result from adding the estimates of 

the potential economic benefits resulting from reduced CO2 and NOX emissions in each 

of four valuation scenarios to the NPV of consumer savings calculated for each TSL 

considered for EPSs, at both a 7-percent and a 3-percent discount rate. The CO2 values 

Formatted: Indent: First line: 0.5", Line 

spacing: Double, Don't keep with next 

399 
used in the columns of each table correspond to the four scenarios for the valuation of 

CO2 emission reductions presented in section IV.M. Formatted: Font: 12 pt 

Formatted: Indent: First line: 0.5", Line 

spacing: Double, Widow/Orphan control, 

Adjust space between Latin and Asian text, 

Adjust space between Asian text and numbers 

Table V-82Table V-81 and Table V-83Table V-82 present similar results for the 

TSLs considered for battery chargers. 

400 
 

 

 

 

 

 

 

 

 

Table V-79 Adding Net Present Value of Consumer Savings to Present Value of 

Monetized Benefits from CO2 and NOX Emissions Reductions Under TSL 1 for 

Battery Chargers Product Classes 2, 3, 4 

Category Present Value 

billion 2010$ 

Discount 

Rate 

Benefits 

Operating Cost Savings 1.249132 7% 

2.245038 3% 

CO2 Reduction Monetized Value 

(at $4.9/Metric Ton)* 

0.068062 5% 

CO2 Reduction Monetized Value 

(at $22.3/Metric Ton)* 

0.333302 3% 

CO2 Reduction Monetized Value 

 (at $36.5/Metric Ton)* 

0.558506 2.5% 

CO2 Reduction Monetized Value 

(at $67.6/Metric Ton)* 

1.0150.921 3% 

NOX Reduction Monetized Value 

(at 2,537 /Ton)* 

0.012011 7% 

0.021019 3% 

Total Monetary Benefits ** 

1.594445 7% 

2.603360 3% 

Costs 

Incremental Installed Costs‡ 

0.538468 7% 

0.900783 3% 

Net Benefits/Costs 

Including CO2 and NOX** 1.0560.977 7% 

1.703576 3% 

* These values represent global values (in 2010$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.9, $22.3 and $36.5 per ton are the averages of SCC distributions calculated 

using 5%, 3%, and 2.5% discount rates, respectively. The value of $67.6 per ton represents the 95th 

percentile of the SCC distribution calculated using a 3% discount rate. See section IV.M for details. The 

value for NOX (in 2010$) is the average of the low and high values used in DOE’s analysis. 

** Total Monetary Benefits and Net Benefits/Costs for both the 3% and 7% cases utilize the central 

estimate of social cost of CO2 emissions calculated at a 3% discount rate, which is equal to $22.3/ton in 

2010 (in 2010$). 

‡ Incremental Product Costs represent the total present value (in 2010$) of costs borne by consumers due to 

increased manufacturing costs from efficiency improvements. 

401 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-80 Results of Adding Net Present Value of Consumer Savings (at 7% 

Discount Rate) to Net Present Value of Monetized Benefits from CO2 and NOX 

Emissions Reductions Under External Power Supply TSLs 

Product 

Class 

TSL 

Consumer NPV at 7% Discount Rate added to: 

SCC Value of 

$4.9/metric ton CO2 * 

and Low Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$22.3/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$36.5/metric ton CO2 * 

and Medium Value 

for NOX ** 

billion 2010$ 

SCC Value of 

$67.6/metric ton CO2 * 

and High Value for 

NOX ** 

billion 2010$ 

B 1 0.69026905 1.06020608 1.36373645 1.99319944 

2 0.61216126 1.19771986 1.67786792 2.67396761 

3 (2.08640855) (1.02230208) (0.14991477) 1.6220 6637 

B, C, D, 

and E 1 0.7618 8498 1.2153 3222 1.5875 7100 2.3581 5128 

2 0.66978013 1.38015402 1.96332.1467 3.17084026 

3 (2.13401.9722) (0.87396775) 0.16043851 2.25745857 

X 1 0.1905 0.2411 0.2826 0.3686 

2 0.1903 0.2483 0.2960 0.39463947 

3 (0.3333) (0.2144) (0.1167) 0.08120854 

H 1 0.0051 0.0061 0.0069 0.0086 

2 0.0052 0.0063 0.0072 0.0090 

3 0.0039 0.0051 0.0061 0.0081 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been 

calculated with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of 

these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per 

ton of NOX emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

402 
 

 

 

 

 

 

 

 

 

 

 

 

Table V-81 Results of Adding Net Present Value of Consumer Savings (at 3% 

Discount Rate) to Net Present Value of Monetized Benefits from CO2 and NOX 

Emissions Reductions External Power Supply TSLs 

Product 

Class 

TSL 

Consumer NPV at 3% Discount Rate added to: 

SCC Value of 

$4.9/metric ton CO2 * 

and Low Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$22.3/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$36.5/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$67.6/metric ton CO2 * 

and High Value for 

NOX ** 

billion 2010$ 

B 1 1.3239 3243 1.7043 7050 2.0077 0087 2.6475 6490 

2 1.2904 2912 1.8924 8937 2.3726 3743 3.3851 3876 

3 (3.01600146) (1.92219199) (1.04960469) 0.7905 7944 

B, C, D, 

and E 

1 1.5060 6651 1.9722 2.1509 2.3444 5387 3.1279 3549 

2 1.4794 7177 2.2100 4775 2.7931 3.0840 4.0207 3607 

3 (2.93896459) (1.64323146) (0.60902519) 1.5684 9852 

X 1 0.3423 0.3943 0.4358 4359 0.5232 5233 

2 0.3454 0.4051 0.4527 0.5530 5531 

3 (0.5022) (0.3799) (0.2823) (0.0768) 

H 1 0.0096 0.0106 0.0115 0.0132 

2 0.0100 0.0111 0.0120 0.0139 

3 0.0079 0.0091 0.0101 0.0122 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been 

calculated with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of 

these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per 

ton of NOX emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been 

calculated with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of 

these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per 

ton of NOX emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

403 
 

 

 

 

 

 

 

 

 

Table V-82 Results of Adding Net Present Value of Consumer Savings (at 7% 

Discount Rate) to Net Present Value of Monetized Benefits from CO2 and NOX 

Emissions Reductions Under Battery Charger TSLs 

Product 

Class 

TSL 

Consumer NPV at 7% Discount Rate added to: 

SCC Value of 

$4.9/metric ton CO2 * 

and Low Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$22.3/metric ton CO2 * 

and Medium Value 

for NOX ** 

billion 2010$ 

SCC Value of 

$36.5/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$67.6/metric ton CO2 * 

and High Value for 

NOX ** 

billion 2010$ 

1 1 0.1682 0.2133 0.2503 0.3269 

2 0.3445 0.4496 0.5358 0.7142 7143 

3 (0.4907) (0.3471) (0.22932292) 0.0148 

2, 3, 4 1 0.7813 7274 1.0559 0.9767 1.2809 1810 1.7482 6052 

2 (0.37662789) 0.3139 3325 0.8799 8337 2.0549 1.8741 

3 (9.24618.6041) (7.69691561) (6.42715.9692) (3.79125054) 

4 (23.82141317) (22.121021.5222) (20.72742029) (17.83404641) 

5, 6 1 1.0595 0.9217 1.3069 1370 1.5104 3141 1.9301 6792 

2 3.0580 2.6605 3.6084 1394 4.0613 3.5334 4.9948 3456 

3 (7.81936.8028) (7.09856.1757) (6.50535.6596) (5.28294.5960) 

7 1 0.0818 0712 0.0879 0764 0.0928 0807 0.1031 0897 

2 (0.28632953) (0.27002788) (0.25682654) (0.22912375) 

8 1 1.6674 6613 1.6765 6690 1.6840 6754 1.6994 6886 

2 (0.96649914) (0.92799584) (0.89649313) (0.83108750) 

3 (1.17171989) (1.12911622) (1.09431322) (1.02180697) 

10 1 0.7553 6571 0.9644 8390 1.1368 0.9890 1.4909 2971 

2 0.8564 7451 1.0989 0.9561 1.2989 1301 1.7096 4874 

3 0.9781 8509 1.2610 0971 1.4943 3001 1.9735 7170 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been 

calculated with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of 

these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per 

ton of NOX emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been 

calculated with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of 

these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per 

ton of NOX emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

404 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-83 Results of Adding Net Present Value of Consumer Savings (at 3% 

Discount Rate) to Net Present Value of Monetized Benefits from CO2 and NOX 

Emissions Reductions Under Battery Charger TSLs 

Product 

Class 

TSL 

Consumer NPV at 3% Discount Rate added to: 

SCC Value of 

$4.9/metric ton CO2 * 

and Low Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$22.3/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$36.5/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$67.6/metric ton CO2 * 

and High Value for 

NOX ** 

billion 2010$ 

1 1 0.3057 0.3521 0.3891 0.4669 

2 0.6329 0.7409 0.8271 1.0086 

3 (0.7438) (0.5962) (0.4783) (0.2301) 

2, 3, 4 1 1.42113202 1.7034 5765 1.9285 7808 2.4034 2120 

2 (0.33702073) 0.37294212 0.93909224 2.1333 1.9799 

3 (14.812013.7811) (13.219512.2925) (11.94971057) (9.27038.6012) 

4 (39.137438.0226) (37.389536.3680) (35.99580488) (33.054832.2648) 

5, 6 1 1.9353 6837 2.1898 1.9051 2.3933 0822 2.8200 4535 

2 5.48474.7717 6.05095.2643 6.50385.6584 7.45306.4842 

3 (12.598010.9602) (11.856510.3152) (11.26349.7991) (10.02038.7176) 

7 1 0.13881207 0.14501261 0.14991304 0.16041395 

2 (0.47394889) (0.45724720) (0.44394586) (0.41584302) 

8 1 2.7937 7825 2.80307905 2.81057969 2.8262 8103 

2 (1.60026458) (1.56066118) (1.52915847) (1.46265275) 

3 (1.94199915) (1.89819538) (1.86339238) (1.78968603) 

10 1 1.42462394 1.63974266 1.81215765 2.17221.8898 

2 1.61954089 1.86906260 2.06891.8000 2.48671635 

3 1.85416131 2.14521.8664 2.37850693 2.86594933 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been 

calculated with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of 

these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per 

ton of NOX emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

Although adding the value of consumer savings to the values of emission 

reductions provides a valuable perspective, two issues should be considered. First, the 

national operating savings are domestic U.S. consumer monetary savings that occur as a 

result of market transactions, while the value of CO2 reductions is based on a global 

405 
 

 

value. Second, the assessments of operating cost savings and CO2 savings are performed 

with different methods that use quite different time frames for analysis. The national 

operating cost savings is measured for the lifetime of products shipped in the 30-year 

period after the compliance date. The SCC values, on the other hand, reflect the present 

value of all future climate-related impacts resulting from the emission of one ton of 

carbon dioxide in each year. These impacts go well beyond 2100. 

7. Other Factors 

In determining whether a standard is economically justified, DOE may consider 

any other factors that it deems relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VI))) The California 

IOUs asked that DOE consider adopting the standard levels proposed by the State of 

California. (California IOUs, No. 43 at p. 2) In March 2011January 2012, the CEC 

published proposedfinalized its battery charger energy conservation standards and 

published energy conservation standards for battery chargers in . Prior to finalizing these 

standards, CEC published a draft staff report.

79 The proposal includes separate outlining 

the requirements that were ultimately adopted.80 The standards consist of two metrics; 

one is a maximum allowance for 24-hour charge and maintenance energy, while the other 

is a maximum allowance for the combination of maintenance power, and no battery mode 

power. DOE analyzed the CEC's proposal and determined, for each of DOE's product 

classes, which CSL aligns most closely with the CEC's proposed standards., as explained 

79 Singh, Harinder; Rider, Ken. 2011. Staff Report for Proposed Efficiency Regulations for 

Battery Chargers and Lighting Controls. 2011 California Energy Commission, Efficiency and 

Renewable Energy Division, Appliances and Process Energy Office. CEC-400-2011-001-SD. 80 Singh, Harinder; Rider, Ken. 2011. Staff Report Staff Analysis of Battery Chargers and Self-Contained 

Lighting Controls. 2011 California Energy Commission, Efficiency and 

Renewable Energy Division, Appliances and Process Energy Office. CEC-400-2011-001-SF. 

406 
 

in section IV.C.2.d above. Table Table V.84 shows this mapping and the corresponding 

NES and NPV values DOE used in its analysis. The CEC did not propose standards for 

battery chargers with DC input (product classes 8national energy savings and 9). net 

benefits that could be expected to result from federal standards at these levels. Additional 

results for these CSLs are presented elsewhere in section V.B and in the TSD. 

Table V-84 CSLs that Most Closely Align Selected National Impacts of Aligning 

Federal Standards with California Proposed Standards 

Product CSL that NES NPV 3% NPV 7% NPV 3% NPV 7% 

Class Aligns Best to 

CEC's 

ProposedAppr 

oximates the 

CEC Standard 

(Quad) (Million 

2010$) 

(Million 

2010$) 

added to SCC 

Value of 

$22.3/metric 

ton CO2* and 

Medium 

Value for 

NOX at 3%** 

(Million 

2010$) 

added to SCC 

Value of 

$22.3/metric 

ton CO2* and 

Medium 

Value for 

NOX at 7%** 

(Million 

2010$) 

1 CSL 20 0.130 6060 3180 7410 4500 

2 CSL 2 0.672585 (986855) (782679) -288(247) -103(88) 

3 CSL 2 0.194169 (1,111966) (722628) 297(791) 183(457) 

4 CSL 2 0.315301 (4,6883,909) (2,884415) 364(3,595) 234(2,110) 

5 Between CSL 2 

and CSL 3 

0.592 to 

0.767668 

4,671 to 

(11,494)(10,00 

0) 

2,567 to 

(7,161)(6,230) 

5,284 to 

(10,699)(­

9,308) 

3,164 to 

(6,388)(5,557) 

6 CSL 23 0.093113 671(1,123) 352(731) 766(1,007) 445(618) 

7 CSL 1 0.007 119 70 126 76 

78 CSL 0 0 0 0 0 0 

10 CSL 23 0.308312 1,557550 795789 1,869866 1,099097 

* Social Cost of CO2 (SCC) in 2010, in 2010$. 

** Medium value corresponds to $2,537 per ton of NOX emissions, in 2010$. 

DOE incorporated the CEC's battery charger standards into its analysis by 

adjusting its base case efficiency distributions, as explained in section IV.G.4 above. It 

did not choose proposed standard levels with the explicit intention of aligning its 

standards with the CEC's. Rather, as in all such rulemakings, the proposed levels were 

407 
 

 

selected to meet a number of criteria specified in EPCA. These decisions for each product 

class grouping are explained in detail in the following section. 

C. Proposed Standards 

When considering proposed standards, the new or amended energy conservation 

standard that DOE adopts for any type (or class) of covered product shall be designed to 

achieve the maximum improvement in energy efficiency that the Secretary determines is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In 

determining whether a standard is economically justified, the Secretary must determine 

whether the benefits of the standard exceed its burdens by considering, to the greatest 

extent practicable, the seven statutory factors discussed previously. (42 U.S.C. 

6295(o)(2)(B)(i)) The new or amended standard must also result in the significant 

conservation of energy. (42 U.S.C. 6295(o)(3)(B)) 

For today’s NOPR, DOE considered the impacts of standards at each TSL, 

beginning with the maximum technologically feasible level, to determine whether that 

level was economically justified. Where the max-tech level was not justified, DOE then 

considered the next most efficient level and undertook the same evaluation until it 

reached the most efficient level that is both technologically feasible and economically 

justified and saves a significant amount of energy. 

DOE separately discusses the benefits and burdens of each TSL for each group of 

products. To aid the reader in its discussion of the benefits and burdens of each TSL, 

408 
 

DOE presents summary tables containing the results of DOE’s quantitative analysis for 

each TSL. 

In addition to the quantitative results presented in the tables, DOE also considers 

other burdens and benefits that impact whether a given efficiency level is economically 

justified. These factors include the impacts on identifiable subgroups of consumers, such 

as low-income households and seniors, who may be disproportionately affected by a 

national standard. Section V.B.1 presents the estimated impacts of each TSL on these 

subgroups. DOE also considers impacts on employment stemming from the manufacture 

of the products subject to standards (see section V.B.2.b), as well as potential indirect 

impacts in the national economy (see section V.B.3.c). 

DOE notes that the economics literature provides a wide-ranging discussion of 

how consumers trade off upfront costs and energy savings in the absence of government 

intervention. Much of this literature attempts to explain why consumers appear to 

undervalue energy efficiency improvements. This undervaluation suggests that regulation 

that promotes energy efficiency can produce significant net private gains (as well as 

producing social gains by, for example, reducing pollution). There is evidence that 

consumers undervalue future energy savings as a result of (1) a lack of information,; (2) a 

lack of sufficient salience of the long-term or aggregate benefits; (3) a lack of sufficient 

savings to warrant delaying or altering purchases (e.g. an inefficient ventilation fan; (4) 

excessive focus on the short term, in a new building or the delayed replacement of a 

water pump), (3) the form of inconsistent (e.g. excessive short-term) weighting of future 

Comment [A39]: Change recommended by 

OIRA. 

409 
 

energy cost savings relative to available returns on other investments, (4; (5) 

computational or other difficulties associated with the evaluation of relevant tradeoffs,; 

and (56) a divergence in incentives (e.g.that is, renter versus owner,; builder versusvs. 

purchaser). Other literature indicates that with less than perfect foresight and a high 

degree of uncertainty about the future, consumers may trade off these types of 

investments at a higher than expected rate between current consumption and uncertain 

future energy cost savings. While DOE is not prepared at present to provide a fuller 

quantifiable framework for this discussion at this time, DOE seeks comments on how to 

assess these possibilities. 

In DOE’s current regulatory analysis, potential changes in the benefits and costs 

of a regulation due to changes in consumer purchase decisions are included in two ways. 

First, if consumers forego a purchase of a product in the standards case, this decreases 

sales for product manufacturers and the cost to manufacturers is included in the MIA. 

Second, DOE accounts for energy savings attributable only to products actually used by 

consumers in the standards case; if a regulatory option decreases the number of products 

used by consumers, this decreases the potential energy savings from an energy 

conservation standard. DOE provides detailed estimates of shipments and changes in the 

volume of product purchases in chapter 9 of the NOPR TSD. However, DOE’s current 

analysis does not explicitly control for heterogeneity in consumer preferences, 

preferences across subcategories of products or specific features, or consumer price 

sensitivity variation according to household income. 

410 
 

 

 

 

 

 

While DOE is not prepared at present to provide a fuller quantifiable framework 

for estimating the benefits and costs of changes in consumer purchase decisions due to an 

energy conservation standard, DOE is committed to developing a framework that can 

support empirical quantitative tools for improved assessment of the consumer welfare 

impacts of appliance standards. DOE has posted a paper that discusses the issue of 

consumer welfare impacts of appliance energy efficiency standards, and potential 

enhancements to the methodology by which these impacts are defined and estimated in 

the regulatory process.81 DOE welcomes comments on approaches for improved 

assessment of the consumer welfare impacts of appliance standards. 

1. External Power Supplies 

a. Product Class B -- Direct Operation External Power Supplies 

Table V-85Table V.85 presents a summary of the quantitative impacts estimated 

for each TSL for EPSs in product class B. As outlined in section V.A.1, DOE is 

extending the TSLs for product class B to product classes C, D, and E since product class 

B was the only one directly analyzed and interested parties supported this approach 

because of the technical similarities among these products. The efficiency levels 

contained in each TSL are described in section V.A.1. 

Table V-85 Summary of Results for Product Class B External Power Supplies 

Comment [A40]: Changes recommended by 

OIRA. 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 

0.45784579 0.72457246 

1.3162 

3164 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 1,227228 1,138 (3,2942 

81 Alan Sanstad. Notes on the Economics of Household Energy Consumption and Technology Choice. 

Lawrence Berkeley National Laboratory. 2010. Available online at: 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf 

411 
 

 

 

 

 

 

Category TSL 1 TSL 2 TSL 3 

92) 

7% discount rate 

596 463 

(2,3583 

57) 

NPV of Consumer Benefits added to SCCthe Value of 21.4/metric ton CO2Emissions Reductions Using 

Medium Assumptions i and medium value for NOx 

ii(2010$ million) 

3% discount rate 

1,704705 1,892894 

(1,9229 

20) 

7% discount rate 

1,060061 1,198199 

(1,0220 

21) 

Industry Impacts 

2.5 W, 18 W, 60 W, and 120 W Rep Units* 

Industry NPV Change (2010$ million) (5762.5) - (38.9) -

(34.3) 

(76.5) - (30.3) (81.4) 

- (35.2) 

(118.4) 

- 23.0 

(123.5) 

– 17.9 

Industry NPV (% change) (2426.9) - (1416.8) (33.0) - (1335.1) -

(15.2) 

(51.1) - 

9.9 

53.2) – 

7.7 

Cumulative Emissions Reduction 

CO2 (Mt) 21.7 34.3 62.5 

NOX (kt) 17.9 28.4 51.6 

Hg (t) 0.115 0.182 0.331 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)** 0.091 to 1.368369 0.145 to 2.164166 

0.263 

to 

3.9339 

36 

NOX – 3% discount rate (2010$ million) 

5 to 5253 8 to 83 

15 to 

151 

NOX – 7% discount rate (2010$ million) 3 to 29 5 to 47 8 to 85 

Mean LCC Savings*** (2010$) 

2.5 W rep unit 0.10 0.04 0.02 

18 W rep unit 0.68 0.69 (1.19) 

60 W rep unit (0.33) (0.45) (1.38) 

120 W rep unit 0.60 0.61 (5.49) 

Median PBP (years) 

2.5 W rep unit 3.5 4.3 4.3 

18 W rep unit 1.2 3.1 8.1 

60 W rep unit 6.3 5.4 6.4 

120 W rep unit 1.4 1.9 9.1 

Distribution of Consumer LCC Impacts 

2.5 W rep unit 

Net Cost (%) 45.9 59.1 61.3 

No Impact (%) 8.3 2.4 0.0 

Net Benefit (%) 45.8 38.6 38.7 

18 W rep unit 

Net Cost (%) 16.7 37.5 74.4 

No Impact (%) 28.5 10.2 0.0 

Net Benefit (%) 54.9 52.3 25.6 

412 
 

 

 

 

 

Category TSL 1 TSL 2 TSL 3 

60 W rep unit 

Net Cost (%) 73.7 85.2 92.8 

No Impact (%) 18.0 1.3 0.0 

Net Benefit (%) 8.3 13.6 7.2 

120 W rep unit 

Net Cost (%) 0.1 8.6 100.0 

No Impact (%) 21.2 3.0 0.0 

Net Benefit (%) 78.7 88.4 0.0 

Generation Capacity Reduction (GW)† 0.255 0.404 0.734 

Employment Impacts 

Total Potential Changes in 

Domestic Production Workers in 

2014 (thousands) 

0 0 0 

 Indirect Domestic Jobs 

(thousands) † 

1.23 1.90 3.16 

Comment [A41]: Deletion recommended by 

OIRA. 

Parentheses indicate negative (-) values. 

* For the MIA impacts, DOE conservatively presents the impacts for product classes B, C, D, and E as a group 

versus only the results for product class B for the other analyses. Because there are no technical differences 

between product class B and the scaled product classes C, D, and E from a manufacturing perspective, there is no 

product class B “industry” that would be impacted differently than product classes C, D, and E. 

** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

*** For LCCs, a negative value means an increase in LCC by the amount indicated.

i This value representsCalculations based on the global SCC series corresponding to a value of CO2$22.3/ton in 

2010, in 2007$. iiand a medium value correspondsfor NOx corresponding to $2,519 per ton of NOx emissions, in 2009$. 

†

537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 

3 would save 1.316 quads of energy, an amount DOE considers significant. Under TSL 3, 

the NPV of consumer benefits would be -$2.358357 billion, using a discount rate of 7 

percent, and -$3.294292 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 62.5 Mt of CO2, 51.6 kt of 

NOX, and 0.331 t of Hg. The estimated monetary value of the cumulative CO2 emissions 

reductions at TSL 3 ranges from $0.263 billion to $3.933 billion. Total generating 

capacity in 2043 is estimated to decrease by 0.734 GW under TSL 3936 billion. Comment [A42]: Deletion of sentence 

recommended by OIRA. 

413 
 

 

At TSL 3, the average LCC impact is a gain (consumer savings) of $0.02 for the 

2.5W unit and a cost (LCC savings decrease) of $1.19 for the 18W unit, $1.38 for the 

60W unit, and $5.49 for the 120W unit. The median payback period is 4.3 years for the 

2.5W unit, 8.1 years for the 18W unit, 6.4 years for the 60W unit, and 9.1 years for the 

120W unit. The fraction of consumers experiencing an LCC benefit is 38.7 percent for 

the 2.5W unit, 25.6 percent for the 18W unit, 7.2 percent for the 60W unit, and 0 percent 

for the 120W unit. The fraction of consumers experiencing an LCC cost is 61.3 percent 

for the 2.5W unit, 74.4 percent for the 18W unit, 92.8 percent for the 60W unit, and 100 

percent for the 120W unit. 

At TSL 3, the projected change in INPV for direct operation product classes B, C, 

D, and E as a group ranges from a decrease of $118.4123.5 million to an increase of 

$23.017.9 million. At TSL 3, DOE recognizes the risk of very large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high 

end of the range of impacts is reached, as DOE expects, TSL 3 could result in a net loss 

of 51.153.2 percent in INPV to manufacturers of EPSs in these product classes. However, 

as DOE has not identified any domestic manufacturers of direct operation EPSs, it does 

not project any immediate negative impacts on direct domestic jobs. 

The Secretary tentatively concludes that at TSL 3 for EPSs in product class B, the 

negative NPV of consumer benefits, the economic burden on a significant fraction of 

consumers due to the large increases in product cost, and the capital conversion costs and 

profit margin impacts that could result in a very large reduction in INPV, outweigh the 

Comment [A43]: Change recommended by 

OIRA. 

414 
 

 

 

benefits of energy savings, generating capacity reductions, emission reductions, and the 

estimated monetary value of the CO2 emissions reductions. Consequently, the Secretary 

has tentatively concluded that TSL 3 is not economically justified. 

DOE then considered TSL 2. TSL 2 would save 0.72457246 quads of energy, an 

amount DOE considers significant. Under TSL 2, the NPV of consumer benefits would 

be $463 million, using a discount rate of 7 percent, and $1.138 billion, using a discount 

rate of 3 percent. Additionally, TSL 2 yields the maximum NPV of consumer benefits 

added to the social cost of carbon and monetized NOx emissions reductions82 with a value 

of $1.198199 billion at a 7-percent discount rate and $1.892894 billion at a 3-percent 

discount rate. 

The cumulative emissions reductions at TSL 2 are 34.3 Mt of CO2, 28.4 kt of 

NOX, and 0.182 t of Hg. The estimated monetary value of the cumulative CO2 emissions 

reductions at TSL 2 ranges from $0.145 billion to $2.164 billion. Total generating 

capacity in 2043 is estimated to decrease by 0.404 GW under TSL 2. 166 billion. 

At TSL 2, the average LCC impact is a gain (consumer savings) of $0.04 for the 

2.5W unit, $0.69 for the 18W unit, $0.61 for the 120W unit, and a cost (LCC savings 

decrease) of $0.45 for the 60W unit. The median payback period is 4.3 years for the 2.5W 

unit, 3.1 years for the 18W unit, 5.4 years for the 60W unit, and 1.9 years for the 120W 

unit. The fraction of consumers experiencing an LCC benefit is 38.6 percent for the 2.5W 

82 Assuming the social cost of carbon equal to $21.4 per metric ton and NOx calculated with a medium 

value of $2,514 per short ton. These values are applied throughout the TSL discussion that follows. 

Comment [A44]: Deletion recommended by 

OIRA. 

Comment [A45]: Deletion of sentence 

recommended by OIRA. 

415 
 

unit, 52.3 percent years for the 18W unit, 13.6 percent for the 60W unit, and 88.4 percent 

for the 120W unit. The fraction of consumers experiencing an LCC cost is 59.1 percent 

for the 2.5W unit, 37.5 percent for the 18W unit, 85.2 percent for the 60W unit, and 8.6 

percent for the 120W unit. 

At TSL 2, the projected change in INPV for product classes B, C, D, and E as a 

group ranges from a decrease of $76.581.4 million to a decrease of $30.335.2 million. 

DOE recognizes the risk of large negative impacts if manufacturers’ expectations 

concerning reduced profit margins are realized. If the high end of the range of impacts is 

reached, as DOE expects, TSL 2 could result in a net loss of 33.035.1 percent in INPV to 

manufacturers of EPSs in these product classes. 

The Secretary tentatively concludes that at TSL 2 for EPSs in product class B, the 

benefits of energy savings, positive NPV of consumer benefits, generating capacity 

reductions, emission reductions, and the estimated monetary value of the CO2 emissions 

reductions outweigh the economic burden on a significant fraction of consumers due to 

the increases in product cost and the capital conversion costs and profit margin impacts 

that could result in a reduction in INPV to manufacturers. 

After considering the analysis, comments to the preliminary analysis and TSD, 

and the benefits and burdens of TSL 2, the Secretary tentatively concludes that this TSL 

will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, 

Comment [A46]: Deletion recommended by 

OIRA. 

416 
 

 

 

 

 

 

 

DOE today proposes to adopt TSL 2 for EPSs in product class B and, by extension, for 

EPSs in product classes C, D, and E because of the technical similarities among all of 

these devices. The proposed new and amended energy conservation standards for these 

EPSs, expressed as equations for minimum average active-mode efficiency and 

maximum no-load input power, are shown in Table V-86Table V.86. 

Table V-86 Proposed Standards for EPSs in Product Classes B, C, D, and E 

External Power Supplies – Product Class B: AC-DC, Basic-Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.100 

> 49 watts ≥ 0.880 ≤ 0.210 

External Power Supplies – Product Class C: AC-DC, Low-Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.100 

> 49 watts ≥ 0.870 ≤ 0.210 

External Power Supplies – Product Class D: AC-AC, Basic-Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.210 

> 49 watts ≥ 0.880 ≤ 0.210 

417 
 

 

External Power Supplies – Product Class E: AC-AC, Low-Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.210 

> 49 watts ≥ 0.870 ≤ 0.210 

b. Product Class X -- Multiple-Voltage External Power Supplies 

Table V-87Table V.87 presents a summary of the quantitative impacts estimated 

for each TSL for multiple-voltage EPSs. The efficiency levels contained in each TSL are 

described in section V.A. 

418 
 

 

 

 

 

 

 

 

 

 

Table V-87 Proposed Standards for Product Class X External Power Supplies 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.0625 0.0718 0.1470 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 329 330 (533) 

7% discount rate 178 175176 (364) 

NPV of Consumer Benefits added to SCCthe Value of 21.4/metric ton CO2 

i and medium value for NOx iiEmissions Reductions Using Medium Assumptioni (2010$ million) 

3% discount rate 394 405 (380) 

7% discount rate 241 248 (214) 

Industry Impacts 

Product Class X 

Industry NPV Change (2010$ million) (0.7) - (0.4) (12.8) ­

(12.0) (17.9) - (4.6) 

Industry NPV (% change) (1.7) - (1.0) (28.9) ­

(27.1) (40.5) - (10.3) 

Cumulative Emissions Reduction 

CO2 (Mt) 2.95 3.38 6.92 

NOX (kt) 2.43 2.79 5.71 

Hg (t) 0.015 0.018 0.036 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.012 to 0.187 0.014 to 

0.215 

0.029 to 

0.440 

NOX – 3% discount rate (2010$ million) 1 to 7 1 to 8 2 to 17 

NOX – 7% discount rate (2010$ million) 0 to 4 0 to 5 1 to 9 

Mean LCC Savings** (2010$) 2.05 2.07 (3.09) 

Median PBP (years) 0.4 4.7 13.2 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 51.0 95.0 

No Impact (%) 95.0 0.0 0.0 

Net Benefit (%) 5.0 49.0 5.0 

Generation Capacity Reduction (GW)

† 0.035 0.04040 0.082 

Employment Impacts 

Total Potential Changes in Domestic Production Workers 

in 2014 (thousands) 0 0 0 

Indirect Domestic Jobs (thousands) † 0.16 0.19 0.31 

Comment [A47]: Deletion recommended by 

OIRA. 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i This value representsCalculations based on the global SCC series corresponding to a value of 

CO2$22.3/ton in 2010, in 2007$. iiand a medium value correspondsfor NOx corresponding to $2,519 per ton of NOx emissions, in 2009$. 

†

537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 

3 would save 0.147 quads of energy, an amount DOE considers significant. Under TSL 3, 

419 
 

 

the NPV of consumer benefits would be -$364 million, using a discount rate of 7 percent, 

and -$533 million, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 6.92 Mt of CO2, 5.71 kt of NOX, and 

0.036 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions 

at TSL 3 ranges from $0.029 billion to $0.440 billion. Total generating capacity in 2043 

is estimated to decrease by 0.082 GW under TSL 3. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $3.09. The 

median payback period is 13.2 years. The fraction of consumers experiencing an LCC 

benefit is 5 percent while the fraction of consumers experiencing an LCC cost is 95 

percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $17.9 million 

to a decrease of $4.6 million. At TSL 3, DOE recognizes the risk of very large negative 

impacts if manufacturers’ expectations concerning reduced profit margins are realized. If 

the high range of impacts is reached, as DOE expects, TSL 3 could result in a net loss of 

40.5 percent in INPV to manufacturers of multiple-voltage EPSs. However, as DOE has 

not identified any domestic manufacturers of multiple-voltage EPSs, it does not project 

any immediate negative impacts on direct domestic jobs. 

The Secretary tentatively concludes that at TSL 3 for multiple-voltage EPSs, the 

negative NPV of consumer benefits, the economic burden on a significant fraction of 

Comment [A48]: Deletion recommended by 

OIRA. 

Comment [A49]: Change recommended by 

OIRA. 

420 
 

 

 

consumers due to the large increases in product cost, and the capital conversion costs and 

profit margin impacts that could result in a very large reduction in INPV outweigh the 

benefits of energy savings, generating capacity reductions, emission reductions, and the 

estimated monetary value of the CO2 emissions reductions. Consequently, the Secretary 

has tentatively concluded that TSL 3 is not economically justified. 

DOE then considered TSL 2. TSL 2 would save 0.0718 quads of energy, an 

amount DOE considers significant. Under TSL 2, the NPV of consumer benefits would 

be $176 million, using a discount rate of 7 percent, and $330 million, using a discount 

rate of 3 percent. Additionally, TSL 2 yields the maximum NPV of consumer benefits 

added to the social cost of carbon and monetized NOx emissions reductions with a value 

of $248.3 million at a 7-percent discount rate and $405.1 million at a 3-percent discount 

rate. 

At TSL 2, the average LCC impact is a gain (consumer savings) of $2.07. The 

median payback period is 4.7 years. The fraction of consumers experiencing an LCC 

benefit is 49 percent while the fraction of consumers experiencing an LCC cost is 51 

percent. 

The cumulative emissions reductions at TSL 2 are 3.38 Mt of CO2, 2.79 kt of 

NOX, and 0.018 t of Hg. The estimated monetary value of the cumulative CO2 emissions 

reductions at TSL 2 ranges from $0.014 billion to $0.2158 billion. Total generating 

capacity in 2043 is estimated to decrease by 0.04 GW under TSL 2215 billion. 

Comment [A50]: Deletion recommended by 

OIRA. 

Comment [A51]: Deletion of sentence 

recommended by OIRA. 

421 
 

At TSL 2, the projected change in INPV ranges from a decrease of $12.8 million 

to a decrease of $12.0 million. At TSL 2, DOE recognizes the risk of large negative 

impacts if manufacturers’ expectations concerning reduced profit margins are realized. If 

the high end of the range of impacts is reached, as DOE expects, TSL 2 could result in a 

net loss of 28.9 percent in INPV to manufacturers of multiple-voltage EPSs. 

The Secretary tentatively concludes that at TSL 2 for multiple-voltage EPSs, the 

benefits of energy savings, positive NPV of consumer benefits, generating capacity 

reductions, emission reductions, and the estimated monetary value of the CO2 emissions 

reductions outweigh the economic burden on a significant fraction of consumers due to 

the increases in product cost and the capital conversion costs and profit margin impacts 

that could result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the preliminary analysis and TSD, 

and the benefits and burdens of TSL 2, the Secretary tentatively concludes that this TSL 

will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, 

DOE today proposes to adopt TSL 2 for multiple-voltage EPSs. The proposed new and 

amended energy conservation standard for multiple-voltage EPSs, expressed as an 

equation for minimum average active-mode efficiency and maximum no-load input 

power, is shown in Table V-88Table V.88. 

Comment [A52]: Deletion recommended by 

OIRA. 

422 
 

 

Table V-88 Proposed Standards for Multiple-Voltage External Power Supplies 

External Power Supplies – Product Class X: Multiple Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.497 * Pout + 0.067 ≤ 0.300 

> 1 to ≤ 49 watts ≥ 0.075 * ln (Pout) + 0.561 ≤ 0.300 

> 49 watts ≥ 0.860 ≤ 0.300 

c. Product Class H – High-Power External Power Supplies 

Table V-89Table V.89 presents a summary of the quantitative impacts estimated 

for each TSL for high-power EPSs. The efficiency levels contained in each TSL are 

described in section V.A. 

423 
 

 

 

 

 

 

 

 

 

Table V-89 Proposed Standards for High-Power External Power Supplies 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.0013 0.0014 0.0015 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 9.4 9.7 7.6 

7% discount rate 4.8 5.0 3.6 

NPV of Consumer Benefits added to SCCthe Value of 21.4/metric ton CO2 

i and medium value for 

NOx 

iiEmissions Reductions Using Medium Assumptioni (2010$ million) 

3% discount rate 10.6 11.1 9.1 

7% discount rate 6.1 6.3 5.1 

Industry Impacts 

Product Class H 

Industry NPV Change (2010$ million) (0.05) - (0.04) (0.05) - 

(0.04) 

(0.05) 

-

(0.03) 

Industry NPV (% change) (45.5) - (32.7) (44.0) -

(33.8) 

(47.3) 

-

(24.4) 

Cumulative Emissions Reduction 

CO2 (Mt) 0.054 0.058 0.065 

NOX (kt) 0.045 0.048 0.053 

Hg (t) 0.000 0.000 0.000 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.000 to 0.004 0.000 to 

0.004 

0.000 

to 

0.004 

NOX – 3% discount rate (2010$ million) 

0.013 to 0.135 

0.014 to 

0.145 

0.016 

to 

0.161 

NOX – 7% discount rate (2010$ million) 

0.007 to 0.069 

0.007 to 

0.074 

0.008 

to 

0.082 

Mean LCC Savings** (2010$) 124.82 129.08 92.96 

Median PBP (years) 0.0 0.2 2.5 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 0.0 16.9 

No Impact (%) 0.0 0.0 0.0 

Net Benefit (%) 100.0 100.0 83.1 

Generation Capacity Reduction (GW)

† 0.001 0.001 0.001 

Employment Impacts 

Total Potential Changes in Domestic Production 

Workers in 2014 (thousands) 0 0 0 

Indirect Domestic Jobs (thousands) † 0.00 0.01 0.01 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i This value representsCalculations based on the global SCC series corresponding to a value of 

CO2$22.3/ton in 2010, in 2007$. iiand a medium value correspondsfor NOx corresponding to $2,519 per ton of NOx emissions, in 2009$. 

†

537/t in 2010$† Changes in 2042. 

424 

Formatted Table 

Comment [A53]: Deletion recommended by 

OIRA. 

Formatted Table 
 

 

 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 

3 would save 0.0015 quads of energy, an amount DOE considers significant. Under TSL 

3, the NPV of consumer benefits would be $3.6 million, using a discount rate of 7 

percent, and $7.6 million, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 0.065 Mt of CO2, 0.053 kt of NOX, 

and less than 0.0001 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 3 ranges from less than $0.0001 to $0.004 billion. Total 

generating capacity in 2043 is estimated to decrease by 0.001 GW under TSL 3. 

At TSL 3, the average LCC impact is a gain (consumer savings) of $92.96. The 

median payback period is 2.5 years. The fraction of consumers experiencing an LCC 

benefit is 83.1 percent while the fraction of consumers experiencing an LCC cost is 16.9 

percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $0.05 million 

to a decrease of $0.03 million. At TSL 3, DOE recognizes the risk of very large negative 

impacts if manufacturers’ expectations concerning reduced profit margins are realized. If 

the high end of the range of impacts is reached, as DOE expects, TSL 3 could result in a 

net loss of 47.3 percent in INPV to manufacturers of high-power EPSs. However, as 

DOE has not identified any domestic manufacturers of high power EPSs, it does not 

project any immediate negative impacts on direct domestic jobs. 

Comment [A54]: Deletion recommended by 

OIRA. 

Comment [A55]: Change recommended by 

OIRA. 

425 
 

 

 

The Secretary tentatively concludes that at TSL 3 for high-power EPSs, the 

additional considerations of the potential negative impacts of a standard at this max-tech 

TSL outweigh the benefits of energy savings, generating capacity reductions, emission 

reductions, and the estimated monetary value of the CO2 emissions reductions. DOE 

notes that it scaled results for product class B to estimate the cost and efficiency of this 

max-tech CSL. Consequently, DOE is unaware of any product that can achieve this CSL 

in either product class B or H. Thus, although DOE’s analysis indicates that the max-tech 

efficiency level is achievable, there is a risk that unforeseen obstacles remain to creating 

an EPS at this TSL. 

Additionally, setting a standard at TSL 3 would create a discontinuity in the 

average efficiency standards for EPSs. For product class B devices, the average 

efficiency standard is constant for nameplate output power ratings greater than 49 watts 

up to 250 watts. At 250 watts, where product class H begins, the average efficiency 

standard would increase by 4 percent if DOE set standards for this product class at the 

max-tech TSL. This discontinuity in efficiency between the two product classes would be 

the result of the proposed standards for product class B EPSs being equivalent to the bestin-market CSL equation while the proposed standards for product class H would be 

equivalent to the max-tech CSL equation for high-power EPSs. DOE believes that setting 

a standard with a large discontinuity between these product classes is not consistent with 

EPS design trends. 

Comment [A56]: Deletion recommended by 

OIRA. 

426 
 

In contrast, by applying the same level of stringency, scaled for the representative 

unit voltage, to all EPSs with output power greater than 250 watts, the achievable 

efficiency in EPS designs that have an output power above 49 watts remains nearly 

constant. This result occurs because the switching and conduction losses associated with 

the EPS remain proportionally the same with the increase in output power, which creates 

a relatively flat achievable efficiency above 49 watts. If DOE were to adopt a level that 

created a discontinuity in the efficiency levels, it would ignore this trend and set a higher 

efficiency standard between two product classes despite numerous technical similarities. 

Consequently, the Secretary has tentatively concluded that TSL 3 is not justified. 

DOE then considered TSL 2. TSL 2 would save 0.0014 quads of energy, an 

amount DOE considers significant. Under TSL 2, the NPV of consumer benefits would 

be $5.0 million, using a discount rate of 7 percent, and $9.7 million, using a discount rate 

of 3 percent. 

At TSL 2, the average LCC impact is a gain (consumer savings) of $129.08. The 

median payback period is 0.2 years. The fraction of consumers experiencing an LCC 

benefit is 100 percent while the fraction of consumers experiencing an LCC cost is 0 

percent. 

The cumulative emissions reductions at TSL 2 are 0.058 Mt of CO2, 0.048 kt of 

NOX, and less than 0.0001 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 2 ranges from less than $0.0001 to $0.004 billion. Total 

427 

Comment [A57]: Deletion recommended by 

OIRA. 
 

 

 

 

generating capacity in 2043 is estimated to decrease by 0.001 GW under TSL 2. 

Additionally, TSL 2 yields the maximum NPV of consumer benefits added to the social 

cost of carbon and monetized NOx emissions reductions with a value of $6.3 million at a 

7-percent discount rate and $11.1 million at a 3-percent discount rate. 

At TSL 2, the projected change in INPV ranges from a decrease of $0.0504 

million to a decrease of $0.04 million. At TSL 2, DOE recognizes the risk of large 

negative impacts if manufacturers’ expectations concerning reduced profit margins are 

realized. If the high end of the range of impacts is reached, as DOE expects, TSL 2 could 

result in a net loss of 44.0 percent in INPV to manufacturers of high-power EPSs. 

The Secretary tentatively concludes that at TSL 2 for high-power EPSs, the 

benefits of energy savings, positive NPV of consumer benefits, positive LCC savings for 

all consumers, generating capacity reductions, emission reductions, and the estimated 

monetary value of the CO2 emissions reductions outweigh the economic burden of the 

capital conversion costs and profit margin impacts that could result in a reduction in 

INPV for manufacturers. The Secretary also tentatively concludes that this TSL will offer 

the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, 

DOE today proposes to adopt TSL 2 for high-power EPSs. The proposed new and 

amended energy conservation standards for high-power EPSs, expressed as a discrete 

standard for minimum average active-mode efficiency and maximum no-load input 

power, are shown in Table V-90Table V.90. 

Comment [A58]: Deletion recommended by 

OIRA. 

428 
 

 

Table V-90 Proposed Standards for High-Power External Power Supplies 

External Power Supplies – Product Class H: High-Power 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

> 250 watts 0.875 0.500 

d. Product Class N -- Indirect-Operation External Power Supplies 

Product class N consists of indirect-operation EPSs, which are EPSs that serve 

only as battery charger components and do not operate an end-use consumer product or 

power any auxiliary functions of an end-use consumer product on their own. See section 

IV.A.3 above. The applications that use these EPSs consist of applications using motors 

and detachable batteries, which correspond to MADB non-Class A EPSs and other 

applications that use Class A EPSs. DOE believes that the Class A and non-Class A 

devices in product class N are technically equivalent. Because of this technical 

equivalency, DOE believes that EPSs of both types can achieve the same efficiency level 

for the same cost and, thus, grouped these EPSs into one product class for analysis. DOE 

is not aware of any capacity- or performance-related features of the non-Class A devices 

in product class N that would enable DOE to create a separate class for this group of 

devices. 42 U.S.C. 6295(q) 

Of the estimated 75 million EPSs in this product class sold annually, 46 percent 

are Class A and are already subject to the Federal standards prescribed by EISA 2007. 

The remaining 54 percent are non-Class A EPSs, which are not currently subject to 

Federal standards. Table V-91Table V.91 lists those applications that DOE has identified 

as product class N EPSs and indicates how many of each are subject to the current 

429 
Federal standard for Class A EPSs and how many are non-Class A devices. DOE seeks 

comment on the accuracy of its estimates regarding the proportions of these applications 

that ship with indirect-operation EPSs versus direct-operation EPSs. (See Issue 17 under 

“Issues on Which DOE Seeks Comment” in Section VII.E of this notice.) 

Table V-91 Applications of Indirect Operation External Power Supplies 

Status Application Estimated EPS Shipment 

Volume in 2009 

(thousands of units) 

Indirect 

Operation 

(Product 

Class N) 

Direct 

Operation 

(Other 

Product 

Classes) 

Currently 

Subject to 

Federal 

Standards 

(Class A) 

MP3 Players 3,609 401 

Personal Digital Assistants 525 1,225 

In-Vehicle GPS 2,845 316 

Handheld GPS 136 15 

Bluetooth Headsets 13,900 0 

Mobile Phones 4,712 42,408 

Smartphones 6,174 14,407 

Digital Cameras 2,470 1,567 

Not Currently 

Subject to 

Federal 

Standards 

(Non-Class A) 

RC Toys 350 0 

Handheld Vacuums 4,000 0 

Stick Vacuums 1,000 0 

Robotic Vacuums 2,615 0 

Air Mattress Pumps 250 0 

Flashlights/Lanterns 100 0 

Rechargeable Garden Care 

Products 

8 0 

Lawn Mowers 15 0 

Rechargeable Toothbrushes 15,000 0 

Rechargeable Water Jets 100 0 

Beard and Moustache 

Trimmers 

1,763 5,288 

Hair Clippers 3,413 1,138 

430 
 

Shavers 6,492 2,164 

DIY Power Tools (Integral) 4,675 0 

DIY Power Tools (External) 351 0 

Electric Scooters 175 0 

Motorized Bicycles 105 0 

First, DOE considered setting standards for EPSs in product class N at an 

efficiency level greater than the level prescribed by EISA for all Class A EPSs. While 

such a standard would theoretically yield energy savings, DOE tentatively believes that 

these savings would not be cost justified. In the case of these particular devices, DOE 

believes that a more effective way to obtain additional energy savings is to regulate the 

battery chargers of which product class N EPSs are a part, since all of the power flowing 

through an indirect-operation EPS flows to the battery charger. In contrast, a directoperation EPS's output power flows to both a battery charger and an end-use consumer 

product, which means that regulating only the battery charger would not adequately 

address the entire system. Thus, by not setting new standards for product class N EPSs 

beyond the existing EISA standard level, DOE believes that manufacturers will have 

greater flexibility in designing more efficient battery chargers without adversely 

impacting their utility and performance. This approach would help ensure that consumers 

and the Nation as a whole will realize cost-effective savings either through improvements 

to the EPS or other components in the battery charger. Thus, DOE tentatively believes 

that any cost-effective energy savings for these products will be realized through the 

battery charger standard itself. 

431 
 

 

 

Next, DOE considered standards equivalent to the current EISA standards for 

Class A EPSs. This approach would represent no change in standards for Class A devices 

and a new standard for non-Class A devices in product class N. (Note that all Class A 

EPSs, including those in product class N, cannot, by virtue of EPCA’s anti-backsliding 

provision, be subject to a standard less stringent than the current Class A standard 

prescribed by EISA 2007 (see 42 U.S.C. 6295(o)(1)).) 

As indicated in section IV.A.1 above, DOE has not identified any non-Class A 

EPSs in product class N that are not already subject to the California EPS standard. As a 

result, all of these non-Class A EPSs that fall into product class N must already comply 

with the California standard. The California standard for non-Class A EPSs is at the same 

efficiency level as the Federal Class A EPS standard. California also relies on the Federal 

test procedure to verify compliance with its EPS standards. Since California requires 

identical standards and test methods for non-Class A EPSs as DOE does for Class A, 

DOE considers these standards to be equivalent. 

Additionally, manufacturers have alluded informally to DOE that the California 

standard is the "de facto" national standard for their non-Class A EPSs because they 

typically sell the same EPS for a given product line throughout the country. The 

California IOUs concurred with this view. (California IOUs, No. 43 at p. 9) Thus, DOE 

believes that the non-Class A EPSs in product class N already meet the Federal standards 

currently in place for Class A EPSs and seeks comment on the accuracy of this belief. 

432 
 

(See Issue 18 under “Issues on Which DOE Seeks Comment” in section VII.E of this 

notice.) 

Under the assumption that all non-Class A EPSs in product class N already meet 

the Federal standards currently in place for Class A EPSs, a new standard at the EISA 

level for these products would not yield significant energy savings and, therefore, would 

not be cost-justified. Therefore, DOE is not proposing new standards for indirect 

operation EPSs today. If DOE receives new information indicating that this assumption is 

incorrect, i.e., that manufacturers are not producing all indirect operation EPSs at or 

above the EISA efficiency levels, DOE will reconsider this decision and evaluate 

potential new standards for this product class. 

2. Battery Chargers 

a. Low-Energy, Inductive Charging Battery Chargers, Product Class 1 

Table V-92Table V.92 presents a summary of the quantitative impacts estimated 

for each TSL for low-energy, inductive charging battery chargers. The efficiency levels 

contained in each TSL are described in section V.AV.A. Formatted: Font color: Black 

433 
 

 

 

 

 

 

 

 

Table V-92 Summary of Results for Battery Charger Product Class 1 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.0557 0.1298 0.1775 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 294 606 (781) 

7% discount rate 157 318 (527) 

NPV of Consumer Benefits added to SCCthe Value of 21.4/metric ton CO2 

i and medium value for 

NOx 

iiEmissions Reductions Using Medium Assumptioni (2010$ million) 

3% discount rate 352 741 (596) 

7% discount rate 213 450 (347) 

Industry Impacts 

Battery Charger-Product Class 1 

Industry NPV Change (2010$ million) (41) - 1 (98) - 5101) – 1 

(437) – 

33441) 

– 29 

Industry NPV (% change) (8.4) - 0.1 (19.9) -20.6) – 

0.93 

(8889.7) 

– 5.9) -

6.6 

Cumulative Emissions Reduction 

CO2 (Mt) 2.62 6.11 8.36 

NOX (kt) 2.17 5.05 6.9 

Hg (t) 0.014 0.032 0.044 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.011 to 

0.167 0.026 to 0.388 0.035 to 0.531 

NOX – 3% discount rate (2010$ million) 1 to 6 1 to 15 2 to 20 

NOX – 7% discount rate (2010$ million) 0 to 4 1 to 8 1 to 11 

Mean LCC Savings** (2010$) 0.76 1.52 (2.87) 

Median PBP (years) 1.2 1.7 8.5 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 0.0 98.2 

No Impact (%) 22.2 11.1 0.0 

Net Benefit (%) 77.8 88.9 1.8 

Generation Capacity Reduction (GW)

† 0.031 0.072 0.099 

Employment Impacts 

Total Potential Changes in Domestic 

Production Workers in 2014 (thousands) 0 0 0 

Indirect Domestic Jobs (thousands) † 0.16 0.38 0.43 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i This value representsCalculations based on the global SCC series corresponding to a value of 

CO2$22.3/ton in 2010, in 2007$. iiand a medium value correspondsfor NOx corresponding to $2,519 per ton of NOx emissions, in 2009$. 

†

537/t in 2010$† Changes in 2042. 

Comment [A59]: Deletion recommended by 

OIRA. 

434 
 

 

 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 

3 would save 0.178 quads of energy, an amount DOE considers significant. Under TSL 3, 

the NPV of consumer benefits would be -$527 million, using a discount rate of 7 percent, 

and -$781 million, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 8.36 Mt of CO2, 6.90 kt of 

NOX, and 0.044 t of Hg. The estimated monetary value of the cumulative CO2 emissions 

reductions at TSL 3 ranges from $0.035 billion to $0.531 billion. Total generating 

capacity in 2043 is estimated to decrease by 0.099 GW under TSL 3. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $2.87 for 

low-energy inductive charging battery chargers. The median payback period is 8.5 years. 

The fraction of consumers experiencing an LCC benefit is 1.8 percent and the fraction of 

consumers experiencing an LCC cost is 98.2 percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $437441 

million to an increase of $3329 million. At TSL 3, DOE recognizes the risk of very large 

negative impacts if manufacturers’ expectations concerning reduced profit margins are 

realized. If the high end of the range of impacts is reached, as DOE expects, TSL 3 could 

result in a net loss of 88.989.7 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for low-energy, inductive 

charging battery chargers, the benefits of energy savings, generating capacity reductions, 

Comment [A60]: Deletion recommended by 

OIRA. 

Comment [A61]: Deletion recommended by 

OIRA. 

435 
 

 

emission reductions, and the estimated monetary value of the CO2 emissions reductions 

would be outweighed by the negative NPV of consumer benefits, the economic burden on 

a significant fraction of consumers due to the large increases in product cost, and the 

capital conversion costs and profit margin impacts that could result in a very large 

reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 3 is not economically justified. 

DOE then considered TSL 2. TSL 2 would save 0.130 quads of energy, an 

amount DOE considers significant. Under TSL 2, the NPV of consumer benefits would 

be $318 million, using a discount rate of 7 percent, and $606 million, using a discount 

rate of 3 percent. 

The cumulative emissions reductions at TSL 2 are 6.11 Mt of CO2, 5.05 kt of 

NOX, and 0.032 t of Hg. The estimated monetary value of the cumulative CO2 emissions 

reductions at TSL 2 ranges from $0.026 billion to $0.388 billion. Total generating 

capacity in 2043 is estimated to decrease by 0.072 GW under TSL 2. Additionally, the 

NPV of consumer benefits added to the social cost of carbon and monetized NOx 

emissions reductions is maximized with a value of $740.9741 million at a 3-percent 

discount rate and $449.6450 million at a 7-percent discount rate at TSL 2. 

At TSL 2, the average LCC impact is a savings of $1.52 for low-energy inductive 

charging battery chargers. The median payback period is 1.7 years. The fraction of 

consumers experiencing an LCC benefit is 88.9 percent and the fraction of consumers 

experiencing an LCC cost is 0 percent. 

Comment [A62]: Deletion recommended by 

OIRA. 

436 
 

At TSL 2, the projected change in INPV ranges from a decrease of $98101 

million to an increase of $51 million. DOE recognizes the risk of large negative impacts 

if manufacturers’ expectations concerning reduced profit margins are realized. If the high 

end of the range of impacts is reached, as DOE expects, TSL 2 could result in a net loss 

of 19.920.6 percent in INPV to manufacturers of low-energy inductive charging battery 

chargers. 

The Secretary tentatively concludes that at TSL 2 for low-energy, inductive 

charging battery chargers, the benefits of energy savings, positive NPV of consumer 

benefits, positive mean LCC savings, generating capacity reductions, emission 

reductions, and the estimated monetary value of the CO2 emissions reductions outweigh 

the economic burden of the capital conversion costs and profit margin impacts that could 

result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 2, the Secretary tentatively 

concludes that this TSL will offer the maximum improvement in efficiency that is 

technologically feasible and economically justified and will result in the significant 

conservation of energy. Therefore, DOE today proposes to adopt TSL 2 for low-energy 

inductive charging battery chargers.After considering the analysis, comments to the 

September 2010 notice and the preliminary TSD, and the benefits and burdens of TSL 2, 

the Secretary tentatively concludes that this TSL will offer the maximum improvement in 

Comment [A63]: Deletion recommended by 

OIRA. 

437 
efficiency that is technologically feasible and economically justified and will result in the 

significant conservation of energy. Therefore, DOE today proposes to adopt TSL 2 for 

low-energy inductive charging battery chargers. The proposed new energy conservation 

standard for low-energy inductive charging battery chargers is shown in Table V-97. 

Table V-93 Proposed Standard for Product Class 1 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

1 (Low-Energy, Inductive) 3.04 

b. Low-Energy, Non-Inductive Charging Battery Chargers, Product Classes 2, 3, and 4 

Table Table V.94 presents a summary of the quantitative impacts estimated for 

each TSL for low-energy, non-inductive charging battery chargers. The efficiency levels 

contained in each TSL are described in section V.AV.A. Formatted: Font color: Black 

438 
 

 

 

 

 

 

 

 

 

Table V-94 Summary of Results for Battery Charger Product Classes 2, 3, and 4 

Category TSL 1 TSL 2 TSL 3 TSL 4 

National Energy Savings (quads) 0.3091 0.7588 1.7967 1.9971 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 1,349 (517) (15,216) (39,581) 

7% discount rate 711 (553) (9,641) (24,255) 

NPV of Consumer Benefits added to SCC Value of 21.4/metric ton CO2 

i

 and 

medium value for NOx 

ii(2010$ million) 

3% discount rate 1,703 373 (13,220) (37,390) 

7% discount rate 1,056 314 (7,697) (22,121) 

3% discount rate 1,255 (367) (14,159) (38,442.72) 

7% discount rate 664 (435) (8,973) (23,542.09) 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium 

Assumptionsi (2010$ million) 

3% discount rate 1,576 421 (12,293) (36,368) 

7% discount rate 977 333 (7,156) (21,522) 

Industry Impacts 

Battery Charger -Product Classes 2, 3, and 4 

Industry NPV Change 

(2010$ million) 

(5,020) - 

20 

(6,341) - 

167 

(11,313) - 

657 

(14,983) 

- 1,133 

Industry NPV 

(% change) 

(11.3) ­

0.0 

(14.3) ­

0.4 

(25.4) ­

1.5 

(33.7) ­

2.5 

Industry NPV Change (2010$ million) (4,897) 

– 15 

(6,055) 

– 134 (10,863) – 528 (14,562) - 975 

Industry NPV (% change) (11.2) - 

0.0 

(13.8) – 

0.3 (24.8) – 1.2 (33.2) – 2.2 

Cumulative Emissions Reduction 

CO2 (Mt) 16.2 40.6 91.1 100 

NOX (kt) 13.3 33.5 75.2 82.6 

Hg (t) 0.086 0.215 0.483 0.531 

CO2 (Mt) 14.7 35.9 85.1 94.6 

NOX (kt) 12.1 29.7 70.3 78.1 

Hg (t) 0.078 0.191 0.452 0.502 

Value of Cumulative Emissions Reduction

 CO2 (2010$ billion)* 0.068 to 

1.015 

0.171 to 

2.552 

0.383 to 

5.726 

0.420 to 

6.284

 NOX – 3% discount rate (2010$ million) 4 to 39 10 to 98 21 to 220 24 to 242

 NOX – 7% discount rate (2010$ million) 2 to 22 5 to 55 12 to 124 13 to 136 

CO2 (2010$ billion)* 0.062 to 

0.921 

0.151 to 

2.260 0.358 to 5.352 0.398 to 5.949 

NOX – 3% discount rate (2010$ 

million) 

3 to 35 8 to 87 20 to 206 22 to 229 

NOX – 7% discount rate (2010$ 

million) 

2 to 20 5 to 49 11 to 116 13 to 129 

Mean LCC Savings** (2010$) 

PC2 – Low-Energy, Low-Voltage 0.18 (0.16) (1.85) (4.58) 

PC3 – Low-Energy, Medium-Voltage 0.40 0.40 (2.45) (2.48) 

PC4 – Low-Energy, High-Voltage 0.41 0.41 (3.32) (10.76) 

PC2 – Low-Energy, Low-Voltage 0.16 (0.12) (1.81) (4.54) 

PC3 – Low-Energy, Medium-Voltage 0.35 0.35 (2.12) (2.15) 

Formatted Table 

439 
 

 

 

 

PC4 – Low-Energy, High-Voltage 0.43 0.43 (2.73) (10.14) 

Median PBP (years) 

PC2 – Low-Energy, Low-Voltage 0.5 5.2 8.4 15.6 

PC3 – Low-Energy, Medium-Voltage 3.6 3.6 21.9 21.7 

PC4 – Low-Energy, High-Voltage 2.9 2.9 14.1 34.7 

PC2 – Low-Energy, Low-Voltage 0.5 5.2 8.5 16.9 

PC3 – Low-Energy, Medium-Voltage 3.9 3.9 21.9 21.5 

PC4 – Low-Energy, High-Voltage 3.0 3.0 13.8 37.6 

Distribution of Consumer LCC Impacts 

PC2 – Low-Energy, Low-Voltage 

Net Cost (%) 1.0 31.5 86.2 96.8 

No Impact (%) 79.5 53.5 3.1 0.0 

Net Benefit (%) 19.5 15.0 10.7 3.2 

Net Cost (%) 1.0 26.8 87.1 96.8 

No Impact (%) 82.0 60.1 2.9 0.0 

Net Benefit (%) 17.0 13.1 10.0 3.2 

PC3 – Low-Energy, Medium-Voltage 

Net Cost (%) 9.6 9.6 75.6 84.6 

No Impact (%) 80.8 80.8 9.5 0.0 

Net Benefit (%) 9.6 9.6 14.9 15.4 

Net Cost (%) 8.9 8.9 65.8 85.8 

No Impact (%) 82.8 82.8 20.9 0.0 

Net Benefit (%) 8.3 8.3 13.3 14.2 

PC4 – Low-Energy, High-Voltage 

Net Cost (%) 6.0 6.0 53.5 97.8 

No Impact (%) 89.4 89.4 44.1 0.0 

Net Benefit (%) 4.6 4.6 2.4 2.2 

Generation Capacity Reduction (GW)

† 0.19 0.478 1.072 1.177 

Employment Impacts 

Total Potential Changes in Domestic 

Production Workers in 2014 (thousands) 0 0 0 0 

Indirect Domestic Jobs (thousands) † 0.98 2.2 4.19 3.4 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global 

benefit of reduced CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 This value represents the global SCC of CO2 in 2010, in 2007$. ii Medium value corresponds to $2,519 per ton of NOx emissions, in 2009$. 

† Changes in 2042. 

440 
 

 

 

 

Net Cost (%) 3.4 3.4 46.4 98.2 

No Impact (%) 90.7 90.7 51.5 0.0 

Net Benefit (%) 5.8 5.8 2.2 1.8 

Generation Capacity Reduction (GW)

† 0.17 0.42 1.00 1.11 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value 

for NOx corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 4, which represents the max-tech efficiency level. TSL 

4 would save 2.1101.9971 quads of energy, an amount DOE considers significant. Under 

TSL 4, the NPV of consumer benefits would be -$22.2523.54 billion, using a discount 

rate of 7 percent, and -$39.5838.44 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 4 are 10094.6 Mt of CO2, 82.678.1 

kt of NOX, and 0.531502 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 4 ranges from $0.420398 billion to $6.2845.949 billion. 

Total generating capacity in 2043 is estimated to decrease by 1.177 GW under TSL 4. 

At TSL 4, the average LCC impact is a cost (LCC savings decrease) of $4.5854, 

$2.4815, and $10.5714 for low-energy non-inductive charging battery charger product 

classes 2, 3, and 4 respectively. The median payback period is 15.616.9, 21.75, and 

34.837.6 years for product classes 2, 3, and 4 respectively. The fraction of consumers 

experiencing an LCC benefit is 3.2, 15.414.2, and 2.21.8 percent for each product class 

and the fraction of consumers experiencing an LCC cost is 96.8, 84.685.8, and 97.898.2 

percent for each product class. 

Comment [A64]: Deletion of sentence 

recommended by OIRA. 

441 
 

 

At TSL 4, the projected change in INPV ranges from a decrease of $14.9856 

billion to an increase of $1.130.98 billion. At TSL 4, DOE recognizes the risk of very 

large negative impacts if manufacturers’ expectations concerning reduced profit margins 

are realized. If the high end of the range of impacts is reached, as DOE expects, TSL 4 

could result in a net loss of 33.72 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 4 for low-energy, non-inductive 

charging battery chargers, the benefits of energy savings, generating capacityemission 

reductions, and the estimated monetary value of the CO2 emissions reductions would be 

outweighed by the negative NPV of consumer benefits, the economic burden on a 

significant fraction of consumers due to the large increases in product cost, and the 

capital conversion costs and profit margin impacts that could result in a very large 

reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 4 is not economically justified. 

DOE then considered TSL 3, which represents the best-in-market efficiency level. 

TSL 3 would save 1.797 quads of energy, an amount DOE considers significant. Under 

TSL 3, the NPV of consumer benefits would be -$8.97 billion, using a discount rate of 7 

percent, and -$14.16 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 85.1 Mt of CO2, 70.3 kt of 

NOX, and 0.452 t of Hg. The estimated monetary value of the cumulative CO2 emissions 

reductions at TSL 3 ranges from $0.358 billion to $5.352 billion. 

Comment [A65]: Deletion recommended by 

OIRA. 

442 
 

 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $1.81, 

$2.12, and $2.73 for low-energy non-inductive charging battery charger product classes 

2, 3, and 4 respectively. The median payback period is 8.5, 21.9, and 13.8 years for 

product classes 2, 3, and 4 respectively. The fraction of consumers experiencing an LCC 

benefit is 10.0, 13.3, and 2.2 percent for each product class and the fraction of consumers 

experiencing an LCC cost is 87.1, 65.8, and 46.4 percent for each product class. 

At TSL 3, the projected change in INPV ranges from a decrease of $10.86 billion 

to an increase of $0.53 billion. At TSL 3, DOE recognizes the risk of large negative 

impacts if manufacturers’ expectations concerning reduced profit margins are realized. If 

the high end of the range of impacts is reached, as DOE expects, TSL 3 could result in a 

net loss of 24.8 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for low-energy, non-inductive 

charging battery chargers, the benefits of energy savings, emission reductions, and the 

estimated monetary value of the CO2 emissions reductions would be outweighed by the 

negative NPV of consumer benefits, the economic burden on a significant fraction of 

consumers due to the large increases in product cost, and the capital conversion costs and 

profit margin impacts that could result in a very large reduction in INPV for the 

manufacturers. Consequently, the Secretary has tentatively concluded that TSL 4 is not 

economically justified. 

DOE then considered TSL 3, which represents the best-in-market efficiency level. 

TSL 3 would save 1.922 quads of energy, an amount DOE considers significant. Under 

443 
 

 

TSL 3, the NPV of consumer benefits would be -$9.64 billion, using a discount rate of 7 

percent, and -$15.22 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 91.1 Mt of CO2, 75.2 kt of 

NOX, and 0.483 t of Hg. The estimated monetary value of the cumulative CO2 emissions 

reductions at TSL 3 ranges from $0.383 billion to $5.726 billion. Total generating 

capacity in 2043 is estimated to decrease by 1.072 GW under TSL 3. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $1.85, 

$2.45, and $3.16 for low-energy non-inductive charging battery charger product classes 

2, 3, and 4 respectively. The median payback period is 8.4, 21.9, and 14.1 years for 

product classes 2, 3, and 4 respectively. The fraction of consumers experiencing an LCC 

benefit is 10.7, 14.9, and 2.4 percent for each product class and the fraction of consumers 

experiencing an LCC cost is 86.2, 75.6, and 53.5 percent for each product class. 

At TSL 3, the projected change in INPV ranges from a decrease of $11.31 billion 

to an increase of $0.66 billion. At TSL 3, DOE recognizes the risk of large negative 

impacts if manufacturers’ expectations concerning reduced profit margins are realized. If 

the high end of the range of impacts is reached, as DOE expects, TSL 3 could result in a 

net loss of 25.4 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for low-energy, non-inductive 

charging battery chargers, the benefits of energy savings, generating capacity reductions, 

444 
 

 

emission reductions, and the estimated monetary value of the CO2 emissions reductions 

would be outweighed by the negative NPV of consumer benefits, the economic burden on 

a significant fraction of consumers due to the large increases in product cost, and the 

capital conversion costs and profit margin impacts that could result in a very large 

reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 3 is not economically justified. 

DOE then considered TSL 2, which represents an intermediate efficiency level. 

TSL 2 would save 0.857759 quads of energy, an amount DOE considers significant. 

Under TSL 2, the NPV of consumer benefits would be -$553435 million, using a 

discount rate of 7 percent, and -$517 million367million, using a discount rate of 3 

percent. 

The cumulative emissions reductions at TSL 2 are 40.635.9 Mt of CO2, 33.529.7 

kt of NOX, and 0.215191 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 2 ranges from $0.171151 billion to $2.552260 billion. Total 

generating capacity in 2043 is estimated to decrease by 0.478 GW under TSL 2. 

At TSL 2, the average LCC impact is a cost (LCC savings decrease) of $0.1612 

for product class 2 and a savings (LCC savings increase) of $0.4035 and $0.5043 product 

classes 3 and 4 respectively. The median payback period is 5.2, 3.69, and 2.93.0 years for 

product classes 2, 3, and 4 respectively. The fraction of consumers experiencing an LCC 

benefit is 1517.0, 9.68.3, and 6.65.8 percent for each product class and the fraction of 

Comment [A66]: Deletion of sentence 

recommended by OIRA. 

445 
 

 

 

consumers experiencing an LCC cost is 31.5, 26.8, 8.9.6, and 3.4.0 percent for each 

product class. 

At TSL 2, the projected change in INPV ranges from a decrease of $6.3406 

billion to an increase of $0.1713 billion. At TSL 2, DOE recognizes the risk of large 

negative impacts if manufacturers’ expectations concerning reduced profit margins are 

realized. If the high end of the range of impacts is reached, as DOE expects, TSL 2 could 

result in a net loss of 14.313.8 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 2 for low-energy, non-inductive 

charging battery chargers, the benefits of energy savings, generating capacity reductions, 

emission reductions, and the estimated monetary value of the CO2 emissions reductions 

would be outweighed by the negative NPV of consumer benefits, the economic burden on 

a significant fraction of consumers due to the increases in product cost, and the capital 

conversion costs and profit margin impacts that could result in a large reduction in INPV 

for the manufacturers. Consequently, the Secretary has tentatively concluded that TSL 2 

is not economically justified. 

DOE then considered TSL 1, which represents another intermediate efficiency 

level. Relative to TSL 2, the efficiency level for product class 2 has decreased, while the 

efficiency levels for product classes 3 and 4 are the same. TSL 1 would save 0.341309 

quads of energy, an amount DOE considers significant. Under TSL 1, the NPV of 

Comment [A67]: Deletion recommended by 

OIRA. 

446 
 

 

consumer benefits would be $711664 million, using a discount rate of 7 percent, and 

$1.35255 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 1 are 16.214.7 Mt of CO2, 13.312.1 

kt of NOX, and 0.086078 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 1 ranges from $0.068062 billion to $1.0150.921 billion. 

Total generating capacity in 2043 is estimated to decrease by 0.190 GW under TSL 1. 

Additionally, the NPV of consumer benefits added to the social cost of carbon and 

monetized NOx emissions reductions is maximized with a value of $1.703576 billion at a 

3-percent discount rate and $1.0560.977 billion at a 7-percent discount rate at TSL 1. 

At TSL 1, the average LCC impact is a savings (LCC savings increase) of 

$0.1816, $0.4035, and $0.5043 for low-energy non-inductive charging battery charger 

product classes 2, 3, and 4 respectively. The median payback period is 0.5, 3.69, and 

2.93.0 years for product classes 2, 3, and 4 respectively. The fraction of consumers 

experiencing an LCC benefit is 19.5, 9.617.0, 8.3, and 6.65.8 percent for each product 

class and the fraction of consumers experiencing an LCC cost is 1.0, 8.9.6, and 3.4.0 

percent for each product class. 

At TSL 1, the projected change in INPV ranges from a decrease of $5.024.90 

billion to an increase of $0.02 billion. DOE recognizes the risk of negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high 

Comment [A68]: Deletion of sentence 

recommended by OIRA. 

447 
 

 

end of the range of impacts is reached, TSL 1 could result in a net loss of 11.32 percent in 

INPV to manufacturers of low-energy non-inductive charging battery chargers. 

The Secretary tentatively concludes that at TSL 1 for low-energy, non-inductive 

charging battery chargers, the benefits of energy savings, positive NPV of consumer 

benefits, positive mean LCC savings, generating capacity reductions, emission 

reductions, and the estimated monetary value of the CO2 emissions reductions outweigh 

the economic burden of the capital conversion costs and profit margin impacts that could 

result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 1, the Secretary tentatively 

concludes that this TSL will offer the maximum improvement in efficiency that is 

technologically feasible and economically justified and will result in the significant 

conservation of energy. Therefore, DOE today proposes to adopt TSL 1 for low-energy 

non-inductive charging battery chargers. The proposed new energy conservation 

standards for low-energy, non-inductive charging battery chargers, expressed as 

equations for minimum unit energy consumption, are shown in Table V-99. 

Table V-95 Proposed Standard for Product Classes 2, 3, and 4 

Comment [A69]: Deletion recommended by 

OIRA. 

Product Class Maximum Unit Energy Consumption(kWh/yr) 

2 (Low-Energy, Low-Voltage) = 0.2095(Ebatt*) + 5.87 

3 (Low-Energy, Medium-Voltage For Ebatt < 9.74 Wh, = 4.68 

For Ebatt ≥ 9.74 Wh, = 0.0933(Ebatt) + 3.77 

4 (Low-Energy, High-Voltage) For Ebatt < 9.71 Wh, = 9.03 

For Ebatt ≥ 9.71 Wh, = 0.2411(Ebatt) + 6.69 

448 
 

c. Medium-Energy Battery Chargers, Product Classes 5 and 6 

Table V-96Table V.96 presents a summary of the quantitative impacts estimated 

for each TSL for medium-energy battery chargers. The efficiency levels contained in 

each TSL are described in section V.AV.A. Formatted: Font color: Black 

449 
 

 

 

 

 

Table V-96 Summary of Results for Battery Charger Product Classes 5 and 6 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 

0.30792679 0.68535962 

0.8975780 

9 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 

18711,628 5,3424,648 

(12,78411, 

123) 

7% discount rate 

997867 2,919539 

(8,0016,96 

1) 

NPV of Consumer Benefits added to SCCthe Value of 21.4/metric ton CO2 

i and medium value for NOx iiEmissions Reductions Using Medium Assumptionsi (2010$ million) 

3% discount rate 

2,1901,905 6,0515,264 

(11,85710, 

315) 

7% discount rate 

1,307 137 3,608 139 

(7,0996,17 

6) 

Industry Impacts 

Battery Charger -Product Classes 5 and 6 

Industry NPV Change (2010$ million) (133) -327) – 

6 (42) - 106225) – (40) 

(1,235) ­

805314) – 

692 

Industry NPV (% change) (921.0) -– 0.43 (14.5) – (2.8) - 7.25) 

(83.4) - 

54.484.8) – 

43.7 

Cumulative Emissions Reduction 

CO2 (Mt) 14.212.4 31.527.4 41.335.9 

NOX (kt) 11.710.2 2622.6 3429.6 

Hg (t) 0.074065 0.164143 0.215187 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.061053 to 

0.914795 

0.135118 to 

2.0341.770 

0.177154 

to 

2.664318 

NOX – 3% discount rate (2010$ million) 3 to 3530 7 to 7767 109 to 

10188 

NOX – 7% discount rate (2010$ million) 2 to 1916 4 to 4237 5 to 5548 

Mean LCC Savings** (2010$) 

PC5 – Medium-Energy, Low-Voltage 11.389.69 39.1533.79 (119.78104 

.58) 

PC6 – Medium-Energy, High-Voltage 11.499.96 46.9940.78 (103.4986. 

76) 

Median PBP (years) 

PC5 – Medium-Energy, Low-Voltage 1.7 0.0 53.4 

PC6 – Medium-Energy, High-Voltage 1.2 0.0 21.520.8 

Distribution of Consumer LCC Impacts 

PC5 – Medium-Energy, Low-Voltage 

Net Cost (%) 1.43 0.0 90.178.6 

No Impact (%) 67.572.0 8.220.1 013.0 

Net Benefit (%) 31.126.8 91.879.9 9.98.4 

PC6 – Medium-Energy, High-Voltage 

Net Cost (%) 0.0 0.0 98.685.4 

No Impact (%) 59.264.6 25.735.2 013.0 

Net Benefit (%) 40.835.4 74.364.8 1.46 

Formatted Table 

450 
3

 

 

 

 

 

 

 

Category TSL 1 TSL 2 TSL 3 

Generation Capacity Reduction (GW)

† 0.17115 0.3833 0.4984 

Employment Impacts 

Total Potential Changes in Domestic 

Production Workers in 2014 (thousands) 0 0 0 

Indirect Domestic Jobs (thousands) † 0.92 2.06 1.71 

Formatted Table 

Comment [A70]: Deletion recommended by 

OIRA. 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i This value representsCalculations based on the global SCC series corresponding to a value of CO2$22.3/ton in 2010, 

in 2007$. iiand a medium value correspondsfor NOx corresponding to $2,519 per ton of NOx emissions, in 2009$. 

†

537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 

3 would save 0.898781 quads of energy, an amount DOE considers significant. Under 

TSL 3, the NPV of consumer benefits would be -$8.006.96 billion, using a discount rate 

of 7 percent, and -$11.12.78 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 41.335.9 Mt of CO2, 34.029.6 

kt of NOX, and 0.215187 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 3 ranges from $0.177154 billion to $2.664318 billion. Total 

Comment [A71]: Deletion of sentence 

recommended by OIRA. 

generating capacity in 2043 is estimated to decrease by 0.50 GW under TSL 3. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of 

$119.78104.58 and $103.9086.76 for medium-energy battery charger product classes 5 

and 6 respectively. The median payback period is 53.4 and 21.520.8 years for product 

classes 5 and 6 respectively. The fraction of consumers experiencing an LCC benefit is 

9.98.4 and 1.56 percent for product classes 5 and 6, respectively, and the fraction of 

451 
 

consumers experiencing an LCC cost is 90.178.6 and 98.685.4 percent for product classes 

5 and 6, respectively. 

At TSL 3, the projected change in INPV ranges from a decrease of $1.2431 

billion to an increase of $0.8169 billion. At TSL 3, DOE recognizes the risk of very large 

negative impacts if manufacturers’ expectations concerning reduced profit margins are 

realized. If the high end of the range of impacts is reached, as DOE expects, TSL 3 could 

result in a net loss of 83.484.8 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for medium-energy battery 

chargers, the benefits of energy savings, generating capacity reductions, emission 

reductions, and the estimated monetary value of the CO2 emissions reductions would be 

outweighed by the negative NPV of consumer benefits, the economic burden on a 

significant fraction of consumers due to the large increases in product cost, and the 

capital conversion costs and profit margin impacts that could result in a very large 

reduction in INPV for manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 3 is not economically justified. 

DOE then considered TSL 2, which represents the best-in-market efficiency level. 

TSL 2 would save 0.685596 quads of energy, an amount DOE considers significant. 

Under TSL 2, the NPV of consumer benefits would be $2.9254 billion, using a discount 

rate of 7 percent, and $5.344.65 billion, using a discount rate of 3 percent. 

Comment [A72]: Deletion recommended by 

OIRA. 

452 
 

 

The cumulative emissions reductions at TSL 2 are 31.527.4 Mt of CO2, 26.022.6 

kt of NOX, and 0.164143 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 2 ranges from $0.135118 billion to $2.0341.770 billion. 

Total generating capacity in 2043 is estimated to decrease by 0.380 GW under TSL 2. 

Additionally, the NPV of consumer benefits added to the social cost of carbon and 

monetized NOx emissions reductions is maximized with a value of $5.187264 billion at a 

3-percent discount rate and $2.7283.139 billion at a 7-percent discount rate at TSL 2. 

At TSL 2, the average LCC impact is a savings (LCC savings increase) of 

$39.1533.79 and $47.1140.78 for medium-energy battery charger product classes 5 and 6, 

respectively. The median payback period is 0.0 and 0.0 years for product classes 5 and 6, 

respectively. The fraction of consumers experiencing an LCC benefit is 91.879.9 and 

74.464.8 percent for each product class and the fraction of consumers experiencing an 

LCC cost is 0.0 and 0.0 percent for each product class. 

At TSL 2, the projected change in INPV ranges from a decrease of $42225 

million to an increasea decrease of $10640 million. DOE recognizes the risk of negative 

impacts if manufacturers’ expectations concerning reduced profit margins are realized. If 

the high end of the range of impacts is reached, TSL 2 could result in a net loss of 2.814.5 

percent in INPV to manufacturers of medium-energy battery chargers. 

The Secretary tentatively concludes that at TSL 2 for medium-energy battery 

chargers, the benefits of energy savings, positive NPV of consumer benefits, positive 

Comment [A73]: Deletion of sentence 

recommended by OIRA. 

453 
 

 

mean LCC savings, generating capacity reductions, emission reductions, and the 

estimated monetary value of the CO2 emissions reductions outweigh the economic burden 

of the capital conversion costs and profit margin impacts that could result in a reduction 

in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 2, the Secretary tentatively 

concludes that this TSL will offer the maximum improvement in efficiency that is 

technologically feasible and economically justified and will result in the significant 

conservation of energy. After considering the analysis, comments to the September 2010 

notice and the preliminary TSD, and the benefits and burdens of TSL 2, the Secretary 

tentatively concludes that this TSL will offer the maximum improvement in efficiency 

that is technologically feasible and economically justified and will result in the significant 

conservation of energy.Therefore, DOE today proposes to adopt TSL 2 for mediumenergy battery chargers. The proposed new energy conservation standards for mediumenergy battery chargers, expressed as equations for minimum unit energy consumption, 

are shown in Table V-101. 

Table V-97 Proposed Standard for Product Classes 5 and 6 

Comment [A74]: Deletion recommended by 

OIRA. 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

5 (Medium-Energy, Low-Voltage) For Ebatt < 355.18 Wh, = 20.06 

For Ebatt ≥ 355.18 Wh, = 0.0219(Ebatt) + 12.28 

6 (Medium-Energy, High-Voltage) For Ebatt < 239.48 Wh, = 30.37 

For Ebatt ≥ 239.48 Wh, = 0.0495(Ebatt) + 18.51 

454 
d. High-Energy Battery Chargers, Product Class 7 

Table V-98Table V.98 presents a summary of the quantitative impacts estimated 

for each TSL for high-energy battery chargers. The efficiency levels contained in each 

TSL are described in section V.AV.A. Formatted: Font color: Black 

455 
 

 

 

 

 

Table V-98 Summary of Results for Battery Charger Product Class 7 

Category TSL 1 TSL 2 

National Energy Savings (quads) 0.00770067 0.02070209 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 137119 (478493) 

7% discount rate 8070 (290299) 

NPV of Consumer Benefits added to SCCthe Value of 21.4/metric ton CO2 

i

 and 

medium value for NOx 

iiEmissions Reductions Using Medium Assumptionsi (2010$ 

billionmillion) 

3% discount rate 145 126 (457472) 

7% discount rate 88 76 (270279) 

Industry Impacts 

Battery Charger-Product Class 7 

Industry NPV Change 

(2010$ million) (4) - 51– 47 (128) - 25136) 

– 23 

Industry NPV 

(% change) (0.4) -– 4.95 (12.4) -13.1) – 

2.42 

Cumulative Emissions Reduction 

CO2 (Mt) 0.359312 0.964975 

NOX (kt) 0.298259 0.799808 

Hg (t) 0.002 0.006 

Value of Cumulative Emissions Reduction

 CO2 (2010$ billion)* 0.001 to 

0.022019 

0.004 to 

0.060061

 NOX – 3% discount rate (2010$ million) 0.073 to 1 0.229 to 2

 NOX – 7% discount rate (2010$ million) 0.042 to 0.431 0.131 to 1 

Mean LCC Savings** (2010$) 43.9238.26 (120.64127.30) 

Median PBP (years) 0.0 20.827.2 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 100.0 

No Impact (%) 50.056.6 0.0 

Net Benefit (%) 50.043.5 0.0 

Generation Capacity Reduction (GW)

† 0.004003 0.010 

Employment Impacts 

Total Potential Changes in Domestic 

Production Workers in 2014 (thousands) (200) - 0 (200) - 0 

Indirect Domestic Jobs (thousands) † 0.02 0.02 

Comment [A75]: Deletion recommended by 

OIRA. 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global 

benefit of reduced CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i This value representsCalculations based on the global SCC series corresponding to a 

value of CO2$22.3/ton in 2010, in 2007$. iiand a medium value correspondsfor NOx corresponding to $2,519 per ton of NOx 

emissions, in 2009$. 

†

537/t in 2010$† Changes in 2042. 

DOE first considered TSL 2, which represents the max-tech efficiency level. TSL 

2 would save 0.021 quads of energy, an amount DOE considers significant. Under TSL 2, 

456 
 

 

 

the NPV of consumer benefits would be -$290299 million, using a discount rate of 7 

percent, and -$478493 million, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 2 are 0.964975 Mt of CO2, 0.799808 

kt of NOX, and 0.006 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 2 ranges from $0.004 billion to $0.060 billion. Total 

generating capacity in 2043 is estimated to decrease by 0.010 GW under TSL 2.061 

billion. 

At TSL 2, the average LCC impact is a cost (LCC savings decrease) of 

$120.64127.30 for high-energy battery chargers. The median payback period is 20.827.2 

years. The fraction of consumers experiencing an LCC benefit is 0.0 percent and the 

fraction of consumers experiencing an LCC cost is 100.0 percent. 

At TSL 2, the projected change in INPV ranges from a decrease of $128136 

million to an increase of $2523 million. At TSL 2, DOE recognizes the risk of large 

negative impacts if manufacturers’ expectations concerning reduced profit margins are 

realized. If the high end of the range of impacts is reached, as DOE expects, TSL 2 could 

result in a net loss of 12.413.1 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 2 for high-energy battery 

chargers, the benefits of energy savings, generating capacity reductions, emission 

reductions, and the estimated monetary value of the CO2 emissions reductions would be 

Comment [A76]: Deletion of sentence 

recommended by OIRA. 

Comment [A77]: Deletion recommended by 

OIRA. 

457 
 

 

 

outweighed by the negative NPV of consumer benefits, the economic burden on a 

significant fraction of consumers due to the large increases in product cost, and the 

capital conversion costs and profit margin impacts that could result in a large reduction in 

INPV for the manufacturers. Consequently, the Secretary has tentatively concluded that 

TSL 2 is not economically justified. 

DOE then considered TSL 1, which is the best-in-market efficiency level. TSL 1 

would save 0.008007 quads of energy, an amount DOE considers significant. Under TSL 

1, the NPV of consumer benefits would be $8070 million, using a discount rate of 7 

percent, and $137119 million, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 1 are 0.359312 Mt of CO2, 0.298259 

kt of NOX, and 0.002 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 1 ranges from $0.001 billion to $0.022019 billion. Total 

generating capacity in 2043 is estimated to decrease by 0.004 GW under TSL 1. 

Additionally, the NPV of consumer benefits added to the social cost of carbon and 

monetized NOx emissions reductions is maximized with a value of $145.0126 million at a 

3-percent discount rate and $87.976 million at a 7-percent discount rate at TSL 1. 

At TSL 1, the average LCC impact is a savings of $43.9238.26 for high-energy 

battery chargers. The median payback period is 0.0 years. The fraction of consumers 

experiencing an LCC benefit is 50.043.5 percent and the fraction of consumers 

experiencing an LCC cost is 0.0 percent. 

Comment [A78]: Deletion of sentence 

recommended by OIRA. 

458 
 

 

 

At TSL 1, the projected change in INPV ranges from a decrease of $4 million to 

an increase of $5147 million. DOE recognizes the risk of negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high 

end of the range of impacts is reached, as DOE expects, TSL 1 could result in a net loss 

of 0.4 percent in INPV to manufacturers of high-energy battery chargers. 

The Secretary tentatively concludes that at TSL 1 for high-energy battery 

chargers, the benefits of energy savings, positive NPV of consumer benefits, positive 

mean LCC savings, generating capacity reductions, emission reductions, and the 

estimated monetary value of the CO2 emissions reductions outweigh the economic burden 

associated with the potential direct employment losses, capital conversion costs and profit 

margin impacts that could result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 1, the Secretary tentatively 

concludes that this TSL will offer the maximum improvement in efficiency that is 

technologically feasible and economically justified and will result in the significant 

conservation of energy. Therefore, DOE today proposes to adopt TSL 1 for high-energy 

battery chargers. The proposed new energy conservation standard for high-energy battery 

chargers, expressed as an equation for minimum unit energy consumption, is shown in 

Table V-103. 

Comment [A79]: Deletion recommended by 

OIRA. 

Comment [A80]: Change recommended by 

OIRA. 

459 
Product Class Maximum Unit Energy Consumption (kWh/yr) 

7 (High-Energy) = 0.502(Ebatt) + 4.53 

Table V-99 Proposed Standard for Product Class 7 

e. Battery Chargers with a DC Input of Less than 9 V, Product Class 8 

Table V-100Table V.100 presents a summary of the quantitative impacts 

estimated for each TSL for battery chargers with a DC input less than 9 V. The efficiency 

levels contained in each TSL are described in section V.AV.A. Formatted: Font color: Black 

460 
 

 

 

 

 

 

 

 

 

 

Table V-100 Summary of Results for Battery Charger Product Class 8 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.01120096 0.04750408 0.05250453 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 2,791780 (1,610654) (1,9532,001) 

7% discount rate 1,665659 (9761,000) (1,183208) 

NPV of Consumer Benefits added to SCCthe Value of 21.4/metric ton CO2 

i and medium value for 

NOx 

iiEmissions Reductions Using Medium Assumptionsi (2010$ million) 

3% discount rate 2,803790 (1,561612) (1,898954) 

7% discount rate 1,677 669 (928958) (1,129162) 

Industry Impacts 

Battery Charger -Product Class 8 

Industry NPV change (2010$ million) (75) - 1,300 16 - 904 – 78 (48) - (1761) 

- (30) 

Industry NPV (% change) (1.3) - 22.8 0.3 - 1.6 – 1.4 (1.1) - (0.8) 

- (0.35) 

Cumulative Emissions Reduction 

CO2 (Mt) 0.53546 2.261.95 2.516 

NOX (kt) 0.44238 1.8761 2.071.78 

Hg (t) 0.003002 0.012010 0.013011 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.002 to 0.034029 0.010008 to 

0.142122 

0.011009 to 

0.157136 

NOX – 3% discount rate (2010$ million) 0 to 1 10 to 5 1 to 65 

NOX – 7% discount rate (2010$ million) 0 to 1 0 to 3 0 to 3 

Mean LCC Savings** (2010$) 3.0504 (1.9396) (2.2831) 

Median PBP (years) 0.0 0.0 26.124.9 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 40.0 55.14 

No Impact (%) 50.0 10.0 0.0 

Net Benefit (%) 50.0 50.0 44.96 

Generation Capacity Reduction (GW)

† 0.006005 0.027023 0.029025 

Employment Impacts 

Total Potential Changes in 

Domestic Production Workers in 

2014 (thousands) 

0 0 0 

Indirect Domestic Jobs (thousands)

† 

0.02 0.02 0.38 

Comment [A81]: Deletion recommended by 

OIRA. 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i This value representsCalculations based on the global SCC series corresponding to a value of 

CO2$22.3/ton in 2010, in 2007$. iiand a medium value correspondsfor NOx corresponding to $2,519 per ton of NOx emissions, in 2009$. 

†

537/t in 2010$† Changes in 2042. 

461 
 

 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 

3 would save 0.053045 quads of energy, an amount DOE considers significant. Under 

TSL 3, the NPV of consumer benefits would be -$1.1821 billion, using a discount rate of 

7 percent, and -$1.952.00 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 2.5016 Mt of CO2, 2.071.78 kt 

of NOX, and 0.013011 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 3 ranges from $0.011009 billion to $0.157136 billion. Total 

generating capacity in 2043 is estimated to decrease by 0.029 GW under TSL 3. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $2.2831 

for battery chargers with a DC input of less than 9 V. The median payback period is 

26.124.9 years. The fraction of consumers experiencing an LCC benefit is 44.96 percent 

and the fraction of consumers experiencing an LCC cost is 55.14 percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $4861 million 

to a decrease of $1730 million. At TSL 3, DOE recognizes the risk of large negative 

impacts if manufacturers’ expectations concerning reduced profit margins are realized. If 

the high end of the range of impacts is reached, as DOE expects, TSL 3 could result in a 

net loss of 0.81.1 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for battery chargers with a DC 

input of less than 9 V, the benefits of energy savings, generating capacity reductions, 

Comment [A82]: Deletion of sentence 

recommended by OIRA. 

Comment [A83]: Deletion recommended by 

OIRA. 

462 
 

emission reductions, and the estimated monetary value of the CO2 emissions reductions 

would be outweighed by the negative NPV of consumer benefits and the economic 

burden on a significant fraction of consumers due to the large increases in product cost, 

and the capital conversion costs and profit margin impacts that could result in a reduction 

in INPV for the manufacturers. Consequently, the Secretary has tentatively concluded 

that TSL 3 is not economically justified. 

DOE then considered TSL 2, which represents the best-in-market efficiency level. 

TSL 2 would save 0.048041 quads of energy, an amount DOE considers significant. 

Under TSL 2, the NPV of consumer benefits would be -$976 million1.00 billion, using a 

discount rate of 7 percent, and -$1.6165 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 2 are 2.261.95 Mt of CO2, 1.8761 kt 

of NOX, and 0.012010 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 2 ranges from $0.010008 billion to $0.142122 billion. Total 

generating capacity in 2043 is estimated to decrease by 0.027 GW under TSL 2. 

At TSL 2, the average LCC impact is a cost (LCC savings decrease) of $1.9396 

for battery chargers with a DC input of less than 9 V. The median payback period is 0.0 

years. The fraction of consumers experiencing an LCC benefit is 50.0 percent and the 

fraction of consumers experiencing an LCC cost is 40.0 percent. 

Comment [A84]: Deletion recommended by 

OIRA. 

463 
 

 

 

At TSL 2, the projected change in INPV ranges from an increase of $164 million 

to an increase of $9078 million. At TSL 2, DOE believes there are minimal risks of 

negative impacts on manufacturers and expects that TSL 2 could result in a net gain of 

0.31 percent in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 2 for battery chargers with a DC 

input of less than 9 V, the benefits of energy savings, generating capacity reductions, 

emission reductions, and the estimated monetary value of the CO2 emissions reductions 

would be outweighed by the negative NPV of consumer benefits and the economic 

burden on a significant fraction of consumers due to the large increases in product cost. 

Consequently, the Secretary has tentatively concluded that TSL 2 is not economically 

justified. 

DOE then considered TSL 1, which is an intermediate efficiency level. TSL 1 

would save 0.011010 quads of energy, an amount DOE considers significant. Under TSL 

1, the NPV of consumer benefits would be $1.6766 billion, using a discount rate of 7 

percent, and $2.7978 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 1 are 0.53546 Mt of CO2, 0.44238 kt 

of NOX, and 0.003002 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 1 ranges from $0.002 billion to $0.034 billion. Total 

generating capacity in 2043 is estimated to decrease by 0.006 GW under TSL 1.029 

billion. Additionally, the NPV of consumer benefits added to the social cost of carbon 

Comment [A85]: Deletion recommended by 

OIRA. 

Comment [A86]: Deletion of sentence 

recommended by OIRA. 

464 
 

 

 

 

and monetized NOx emissions reductions is maximized with a value of $2.803790 billion 

at a 3-percent discount rate and $1.677669 billion at a 7 percent discount rate at TSL 1. 

At TSL 1, the average LCC impact is a savings of $3.0504 for battery chargers 

with a DC input of less than 9 V. The median payback period is 0.0 years. The fraction of 

consumers experiencing an LCC benefit is 50.0 percent and the fraction of consumers 

experiencing an LCC cost is 0.0 percent. 

At TSL 1, the projected change in INPV ranges from a decrease of $75 million to 

an increase of $1,300 million. DOE recognizes the risk of negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high 

end of the range of impacts is reached, as DOE expects, TSL 1 could result in a net loss 

of 1.3 percent in INPV to manufacturers of battery chargers with a DC input less than 9 

V. 

The Secretary tentatively concludes that at TSL 1 for battery chargers with a DC 

input of less than 9 V, the benefits of energy savings, positive NPV of consumer benefits, 

positive mean LCC savings, generating capacity reductions, emission reductions, and the 

estimated monetary value of the CO2 emissions reductions outweigh the economic burden 

associated with the capital conversion costs and profit margin impacts that could result in 

a reduction in INPV for manufacturers. 

Comment [A87]: Deletion recommended by 

OIRA. 

465 
After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 1, the Secretary tentatively 

concludes that this TSL will offer the maximum improvement in efficiency that is 

technologically feasible and economically justified and will result in the significant 

conservation of energy. Therefore, DOE today proposes to adopt TSL 1 for battery 

chargers with a DC input less than 9 V. The proposed new energy conservation standard 

for battery chargers with a DC input less than 9 V is shown in Table V-105. 

Table V-101 Proposed Standard for Product Class 8 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

8 (Low-Voltage DC Input) 0.66 

DOE is also considering an alternative approach for product class 8 because of the 

considerations expressed in section IV.C.2.i above. This approach is same as the proposal 

that DOE has for product class 9, discussed in the following section. 

466 
 

f. Battery Chargers with a DC Input Greater than 9 V, Product Class 9 

DOE ran a number of analyses in an attempt to ascertain whether an appropriate 

efficiency level could be created for product class 9. A battery charger is in product class 

9 if it operates using a DC input source greater than 9 V, it is unable to operate from a 

universal serial bus (USB) connector, and a manufacturer does not package, recommend, 

or sell a wall adapter for the device. Such products would be in-vehicle battery chargers 

that can operate outside of a vehicle. After completing its engineering analysis for these 

products, DOE ran the LCC analysis. These analyses projected that no efficiency level 

would be likely to exhibit a positive LCC savings. The LCC results showed a cost (LCC 

savings decrease) of $0.08 and $0.24 for CSLs 1 and 2 respectively. That fact, combined 

with the minimal UECs found for products in this category, leads DOE to tentatively 

believe that there would be no economically justifiable TSLs that correspond to the 

efficiency levels found in the engineering analysis for this product class. 

g. AC Output Battery Chargers, Product Class 10 

Table V-102Table V.102 presents a summary of the quantitative impacts 

estimated for each TSL for battery chargers with an AC output. The efficiency levels 

contained in each TSL are described in section V.AV.A. Formatted: Font color: Black 

467 
 

 

 

 

 

 

 

Table V-102 Summary of Results for Battery Charger Product Class 10 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.26532308 0.30782678 0.35913124 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 1,371192 1,557354 1,781550 

7% discount rate 703611 795692 907789 

NPV of Consumer Benefits added to SCCthe Value of 21.4/metric ton CO2 

i and medium value for 

NOx 

iiEmissions Reductions Using Medium Assumptionsi (2010$ million) 

3% discount rate 1,640427 1,869626 2,145 1,866 

7% discount rate 964 839 1,099956 1,261097 

Industry Impacts 

Battery Charger-Product Class 10 

Industry NPV Change (2010$ million) (77) - (181) - (0) (99100) -

(2) 

(125) ­

(3126) - (5) 

Industry NPV (% change) (12.513.2) - (0.1) (16.4) - (0) 

- (0.3.4) 

(20.35) -

(0.59) 

Cumulative Emissions Reduction 

CO2 (Mt) 11.810.3 13.711.9 1613.9 

NOX (kt) 9.728.46 11.39.81 13.211.5 

Hg (t) 0.078068 0.091079 0.106092 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.051045 to 0.773672 

0.059052 

to 

0.896780 

0.069060 

to 

1.0460.910 

NOX – 3% discount rate (2010$ million) 32 to 2925 3 to 3429 43 to 3934 

NOX – 7% discount rate (2010$ million) 21 to 1614 2 to 1816 02 to 2118 

Mean LCC Savings** (2010$) 6.6141 7.4726 8.5230 

Median PBP (years) 1.3 1.4 1.5 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 0.0 0.0 

No Impact (%) 013.0 013.0 013.0 

Net Benefit (%) 10087.0 10087.0 10087.0 

Generation Capacity Reduction (GW)

† 0.12211 0.14112 0.16514 

Employment Impacts 

Total Potential Changes in Domestic Production 

Workers in 2014 (thousands) 0 0 0 

Indirect Domestic Jobs (thousands) † 0.24 0.84 0.98 

Comment [A88]: Deletion recommended by 

OIRA. 

Formatted Table Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced 

CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i This value representsCalculations based on the global SCC series corresponding to a value of 

CO2$22.3/ton in 2010, in 2007$. iiand a medium value correspondsfor NOx corresponding to $2,519 per ton of NOx emissions, in 2009$. 

†

537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which is the max-tech efficiency level. TSL 3 would 

save 0.359312 quads of energy, an amount DOE considers significant. Under TSL 3, the 

468 
 

 

 

NPV of consumer benefits would be $907789 million, using a discount rate of 7 percent, 

and $1.7855 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 16.013.9 Mt of CO2, 13.211.5 

kt of NOX, and 0.106092 t of Hg. The estimated monetary value of the cumulative CO2 

emissions reductions at TSL 3 ranges from $0.069060 billion to $1.0460.910 billion. 

Total generating capacity in 2043 is estimated to decrease by 0.165 GW under TSL 3. 

Additionally, the NPV of consumer benefits added to the social cost of carbon and 

monetized NOx emissions reductions is maximized with a value of $2.1451.866 billion at 

a 3-percent discount rate and $1.261097 billion at a 7-percent discount rate at TSL 3. 

At TSL 3, the average LCC impact is a savings of $8.5230 for AC battery output 

battery chargers. The median payback period is 1.5 years. The fraction of consumers 

experiencing an LCC benefit is 10087.0 percent and the fraction of consumers 

experiencing an LCC cost is 013.0 percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $125126 

million to a decrease of $35 million. DOE recognizes the risk of large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high 

end of the range of impacts is reached, as DOE expects, TSL 3 could result in a net loss 

of 20.35 percent in INPV to manufacturers of AC output battery chargers. 

Comment [A89]: Deletion of sentence 

recommended by OIRA. 

469 
 

 

The Secretary tentatively concludes that at TSL 3 for AC output battery chargers, 

the benefits of energy savings, positive NPV of consumer benefits, positive mean LCC 

savings, generating capacity reductions, emission reductions, and the estimated monetary 

value of the CO2 emissions reductions outweigh the economic burden associated with the 

capital conversion costs and profit margin impacts that could result in a reduction in 

INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 3, the Secretary tentatively 

concludes that this TSL will offer the maximum improvement in efficiency that is 

technologically feasible and economically justified and will result in the significant 

conservation of energy. Therefore, DOE today proposes to adopt TSL 3 for AC output 

battery chargers. The proposed new energy conservation standards for AC output battery 

chargers is shown in Table V-108. 

Table V-103 Proposed Standard for Product Class 10 

Comment [A90]: Deletion recommended by 

OIRA. 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

10a (AC Input, AC Output, 

without AVR) 

For Ebatt < 37.2 Wh, = 2.54 

For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt) – 0.18 

10b (AC Input, AC Output, 

with AVR) 

For Ebatt < 37.2 Wh, = 6.18 

For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt) + 3.45 

3. Summary of Benefits and Costs (Annualized) of Proposed Standards for External 

Power Supplies 

The benefits and costs of today’s proposed standards for EPSs can also be 

expressed in terms of annualized values over the 2013-2042 period. The annualized 

470 
 

 

 

 

 

 

 

 

monetary values are the sum of: (1) the annualized national economic value (expressed in 

2010$) of the benefits from operating products that meet the proposed standards 

(consisting primarily of operating cost savings from using less energy, minus increases in 

equipment purchase costs, which is another way of representing consumer NPV); and (2) 

the monetary value of the benefits of emission reductions, including CO2 emission 

reductions.83 The value of the CO2 reductions, otherwise known as the Social Cost of 

Carbon (SCC), is calculated using a range of values per metric ton of CO2 developed by a 

recent Federal interagency process. The monetary costs and benefits of cumulative 

emissions reductions are reported in 2010$ to permit comparisons with the other costs 

and benefits in the same dollar units. 

Although combining the values of operating savings and CO2 reductions provides 

a useful perspective, two issues should be considered. First, the national operating 

savings are domestic U.S. consumer monetary savings that occur as a result of market 

transactions, while the value of CO2 reductions is based on a global value. Second, the 

assessments of operating cost savings and CO2 savings are performed with different 

methods that use quite different time frames for analysis. The national operating cost 

savings is measured for the lifetime of products shipped in 2013–2042. The SCC values, 

on the other hand, reflect the present value of future climate-related impacts resulting 

83 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized 

values. First, DOE calculated a present value in 20102011, the year used for discounting the NPV of total 

consumer costs and savings, for the time-series of costs and benefits using discount rates of three and seven 

percent for all costs and benefits except for the value of CO2 reductions. For the latter, DOE used a range of 

discount rates. From the present value, DOE then calculated the fixed annual payment over a 30-year 

period, starting in 2013, which yields the same present value. The fixed annual payment is the annualized 

value. Although DOE calculated annualized values, this does not imply that the time-series of cost and 

benefits from which the annualized values were determined would be a steady stream of payments. 

471 
 

from the emission of one metric ton of carbon dioxide in each year. These impacts go 

well beyond 2100. 

Estimates of annualized benefits and costs of the proposed standards for EPSs are 

shown in Table V-104Table V.104. Using a 7-percent discount rate and the SCC value of 

$22.3/ton in 2010 (in 2010$), the cost of the energy efficiency standards proposed in 

today’s NOPR is $220.0251.9 million per year in increased equipment installed costs, 

while the annualized benefits are $274.0325.2 per year in reduced equipment operating 

costs, $47.552.3 in CO2 reductions, and $3.2.7 million in reduced NOX emissions. In this 

case, the net benefit amounts to $104.2128.7 million per year. Using a 3-percent discount 

rate and the SCC value of $22.3/metric ton in 2010 (in 2010$), the cost of the energy 

efficiency standards proposed in today’s NOPR is $233.1247.3 million per year in 

increased equipment installed costs, while the benefits are $316.5348.2 million per year 

in reduced operating costs, $47.552.3 million in CO2 reductions, and $3.03 million in 

reduced NOX emissions. At a 3-percent discount rate, the net benefit amounts to 

$134.0156.6 million per year. 

472 
 

 

 

 

Table V-104 Annualized Benefits and Costs of Proposed Standards for EPSs 

Discount 

Rate 

Primary 

Estimate* 

Low Net 

Benefits 

Estimate* 

High Net 

Benefits 

Estimate* 

Monetized (million 2010$/year) 

Benefits 

Operating Cost Savings 

7% 274.0325.2 260.4309.1 287.4341.1 

3% 316.5348.2 299.4329.5 333.8367.3 

CO2 Reduction at $4.9/t** 5% 12.314.1 12.314.1 12.314.1 

CO2 Reduction at $222.3/t** 3% 47.552.3 47.552.3 47.552.3 

CO2 Reduction at $36.5/t** 2.5% 74.781.4 74.781.4 74.781.4 

CO2 Reduction at $67.6/t** 3% 145.1159.6 145.1159.6 145.1159.6 

NOX Reduction at $2,537/t** 

7% 3.2.7 3.2.7 3.2.7 

3% 3.03 3.03 3.03 

Total (Operating Cost 

Savings, CO2 Reduction and 

NOx Reduction)†Total† 

7% plus 

CO2 range 

289.0342.5 to 

421.8488.0 

275326.4 to 

408.2471.9 

302.5358.4 

to 

435.2503.9 

7% 324.2380.7 310364.6 337.7396.6 

3% 367.1403.9 350.0385.1 384.4422.9 

3% plus 

CO2 range 

331.9365.7 to 

464.6511.2 

314.8346.9 to 

447.6492.5 

349.2384.7 

to 

481.9530.3 

Costs 

Incremental Product Costs‡ 

7% 220.0251.9 220.0251.9 220.0251.9 

3% 233.1247.3 233.1247.3 233.1247.3 

Total Net Benefits/Costs 

Total (Operating Cost 

Savings, CO2 Reduction and 

NOx Reduction, minus 

Incremental Product 

Costs)†Total† 

7% plus 

CO2 range 

69.090.5 to 

201.8236.1 

5574.4 to 

188.2220.0 

82.4106.5 to 

215.2252.0 

7% 104.2128.7 90112.6 117.6144.7 

3% 134.0156.6 116137.9 151.3175.7 

3% plus 

CO2 range 

98.8118.4 to 

231.6264.0 

8199.7 to 

214.5245.2 

116.1137.5 

to 

248.9283.0 

* The difference betweenresults include benefits to consumers which accrue after 2042 from the products 

purchased from 2013 through 2042. Costs incurred by manufacturers, some of which may be incurred prior 

to 2013 in preparation for the rule, are indirectly included as part of incremental equipment costs. The 

Primary, Low Benefits, and High Benefits Estimates is the utilization ofutilize forecasts of energy prices 

from the AEO2010 Reference case, Low Economic Growth caseEstimate, and High Economic Growth 

caseEstimate, respectively. 

Formatted Table 

473 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 

2010 under several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC 

distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value 

of $67.6 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount 

rate. The value for NOX (in 2010$) is the average of the low and high values used in DOE’s analysis. 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 

3-percent discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as “7% plus CO2 range” 

and “3% plus CO2 range,” the operating cost and NOX benefits are calculated using the labeled discount 

rate, and those values are added to the full range of CO2 values. 

‡ Incremental Product Costs represent the total present value (in 2010$) of costs borne by consumers due to 

increased manufacturing costs from efficiency improvements. 

4. Summary of Benefits and Costs (Annualized) of Proposed Standards for Battery 

Chargers 

The benefits and costs of today’s proposed standards for battery chargers can also 

be expressed in terms of annualized values over the 2013-2042 period. The annualized 

monetary values are the sum of: (1) the annualized national economic value (expressed in 

2010$) of the benefits from operating products that meet the proposed standards 

(consisting primarily of operating cost savings from using less energy, minus increases in 

equipment purchase costs, which is another way of representing consumer NPV); and (2) 

the monetary value of the benefits of emission reductions, including CO2 emission 

reductions.84 The value of the CO2 reductions, otherwise known as the Social Cost of 

Carbon (SCC), is calculated using a range of values per metric ton of CO2 developed by a 

recent Federal interagency process. The monetary costs and benefits of cumulative 

84 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized 

values. First, DOE calculated a present value in 20102011, the year used for discounting the NPV of total 

consumer costs and savings, for the time-series of costs and benefits using discount rates of three and seven 

percent for all costs and benefits except for the value of CO2 reductions. For the latter, DOE used a range of 

discount rates, as shown in Table I.3. From the present value, DOE then calculated the fixed annual 

payment over a 30-year period, starting in 2013 that yields the same present value. The fixed annual 

payment is the annualized value. Although DOE calculated annualized values, this does not imply that the 

time-series of cost and benefits from which the annualized values were determined would be a steady 

stream of payments. 

Comment [A91]: Changes recommended by 

OIRA. 

474 
 

 

emissions reductions are reported in 2010$ to permit comparisons with the other costs 

and benefits in the same dollar units. 

Although combining the values of operating savings and CO2 reductions provides 

a useful perspective, two issues should be considered. First, the national operating 

savings are domestic U.S. consumer monetary savings that occur as a result of market 

transactions, while the value of CO2 reductions is based on a global value. Second, the 

assessments of operating cost savings and CO2 savings are performed with different 

methods that use quite different time frames for analysis. The national operating cost 

savings is measured for the lifetime of products shipped in 2013–2042. The SCC values, 

on the other hand, reflect the present value of future climate-related impacts resulting 

from the emission of one metric ton of carbon dioxide in each year. These impacts go 

well beyond 2100. 

Estimates of annualized benefits and costs of the proposed standards for battery 

chargers are shown in Table V-104Table V.104. Using a 7-percent discount rate and the 

SCC value of $22.3/ton in 2010 (in 2010$), the cost of the energy efficiency standards 

proposed in today’s NOPR is -$92.8 million per yearresult in increased $110.0 million 

per year in equipment installed costs, while savings, and the annualized benefits are 

$439.0447.2 million per year in reduced equipment operating costs, $75.971.6 million in 

CO2 reductions, and $4.23 million in reduced NOX emissions. In this case, the net benefit 

amounts to $611.9633.0 million per year. Using a 3-percent discount rate and the SCC 

value of $22.3/metric ton in 2010 (in 2010$), the cost of the energy efficiency standards 

475 
proposed in today’s NOPR is -$98.3 result in $107.9 million per year in increased 

equipment installed costs, while savings, and the benefits are $514485.2 million per year 

in reduced operating costs, $75.971.6 in CO2 reductions, and $4.85 million in reduced 

NOX emissions. At a 3-percent discount rate, the net benefit amounts to $693669.3 

million per year. 

476 
 

 

 

 

 

Table V-105 Annualized Benefits and Costs of Proposed Standards for Battery 

Chargers 

Discount 

Rate 

Primary 

Estimate* 

Low Net 

Benefits 

Estimate* 

High Net 

Benefits 

Estimate* 

Monetized (million 2010$/year) 

Benefits 

Operating Cost Savings 

7% 439.0447.2 417.8425.6 460.3468.8 

3% 514485.2 487.2459.7 541.9511.2 

CO2 Reduction at $4.9/t** 5% 19.63 19.63 19.63 

CO2 Reduction at $22.3/t** 3% 75.971.6 75.971.6 75.971.6 

CO2 Reduction at $36.5/t** 2.5% 119.3111.5 119.3111.5 119.3111.5 

CO2 Reduction at $67.6/t** 3% 231.6218.5 231.6218.5 231.6218.5 

NOX Reduction at 

$2,537/t** 

7% 4.23 4.23 4.23 

3% 4.85 4.85 4.85 

Total (Operating Cost 

Savings, CO2 Reduction 

and NOx 

Reduction)†Total† 

7% plus 

CO2 range 

462.9470.7 to 

674.8670.0 

441.6449.1 to 

653.6648.4 

484.1492.4 to 

696.0691.6 

7% 519523.1 497.9501.5 540.3544.7 

3% 594.9561.3 567.9535.8 622.6587.4 

3% plus 

CO2 range 

538.7509.0 to 

750.6708.2 

511.7483.5 to 

723.6682.7 

566.3535.0 to 

778734.3 

Costs 

Incremental Product Costs‡ 

7% (92.8110.0) (92.8110.0) (92.8110.0) 

3% (98.3107.9) (98.3)107.9) (98.3)107.9) 

Total Net Benefits/Costs 

Total (Operating Cost 

Savings, CO2 Reduction 

and NOx Reduction, minus 

Incremental Product 

Costs)†Total † 

7% plus 

CO2 range 

555580.7 to 

767.6780.0 

534.5559.1 to 

746.4758.3 

576.9602.3 to 

788.8801.6 

7% 611.9633.0 590.7611.4 633.2654.7 

3% 693669.3 666.3643.8 720.9695.3 

3% plus 

CO2 range 

637.0616.9 to 

849.0816.2 

610.0591.4 to 

821.9790.7 

664.7643.0 to 

876.6842.2 

* The difference betweenresults include benefits to consumers which accrue after 2042 from the products 

purchased from 2013 through 2042. Costs incurred by manufacturers, some of which may be incurred prior 

to 2013 in preparation for the rule, are indirectly included as part of incremental equipment costs. The 

Primary, Low Benefits, and High Benefits Estimates is the utilization ofutilize forecasts of energy prices 

from the AEO2010 Reference case, Low Economic Growth caseEstimate, and High Economic Growth 

case, Estimate, respectively. 

477 
 

 

 

 

 

 

 

 

 

 

 

** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 

2010 under several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC 

distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value 

of $67.6 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount 

rate. The value for NOX (in 2010$) is the average of the low and high values used in DOE’s analysis. 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 

3-percent discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as “7% plus CO2 range” 

and “3% plus CO2 range,” the operating cost and NOX benefits are calculated using the labeled discount 

rate, and those values are added to the full range of CO2 values. 

‡ Incremental Product Costs represent the total present value (in 2010$) of costs borne by consumers due to 

increased manufacturing costs from efficiency improvements. 

VI. Procedural Issues and Regulatory Review 

A. Review Under Executive Order 12866 and 13563 

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 

FR 51735 (Oct. 4, 1993), requires each agency to identify the problem that it intends to 

address, including, where applicable, the failures of private markets or public institutions 

that warrant new agency action, as well as to assess the significance of that problem. The 

problems that today’s standards address are as follows: 

(1) There is a lack of consumer information and/or information processing capability 

about energy efficiency opportunities in the home appliance market. 

(2) There is asymmetric information (one party to a transaction has more and better 

information than the other) and/or high transactions costs (costs of gathering 

information and effecting exchanges of goods and services) in the home appliance 

market. 

(3) There are external benefits resulting from improved energy efficiency of battery 

chargers and EPSs that are not captured by the users of such equipment. These 

benefits include externalities related to environmental protection and energy 

Comment [A92]: Changes recommended by 

OIRA. 

478 
 

 

 

 

security that are not reflected in energy prices, such as reduced emissions of 

greenhouse gases. 

In addition, DOE has determined that today’s regulatory action is an 

“economically significant regulatory action” under section 3(f)(1) of Executive Order 

12866. Accordingly, section 6(a)(3) of the Executive Order requires that DOE prepare a 

regulatory impact analysis (RIA) on today’s rule and that the Office of Information and 

Regulatory Affairs (OIRA) in the Office of Management and Budget (OMB) review this 

rule. In the RIA, DOE identified and analyzed six alternatives to standards, including 

consumer rebates, consumer tax credits, manufacturer tax credits, voluntary energy 

efficiency targets, an early replacement program, and a bulk government purchasing 

program. DOE quantified the NES and NPV for these alternatives and did not find any 

alternatives to be more beneficial than standards for any BC or EPS product class. 

DOE presented to OIRA for review the draft rule and other documents prepared 

for this rulemaking, including the RIA85, and has included these documents in the 

rulemaking record. The assessments prepared pursuant to Executive Order 12866 can be 

found in the technical support document for this rulemaking. They are available for 

public review in the Resource Room of DOE’s Building Technologies Program, 950 

L’Enfant Plaza, SW., Suite 600, Washington, DC 20024, (202) 586-2945, between 9:00 

a.m. and 4:00 p.m., Monday through Friday, except Federal holidays. 

85 The Regulatory Impact Analysis is also available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external_preliminaryanalys 

is_tsd.html#tsd 

Comment [A93]: Change recommended by 

OIRA. 

479 
 

 

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued 

on January 18, 2011 (76 FR 3281 (Jan. 21, 2011)). EO 13563 is supplemental to, and 

explicitly reaffirms the principles, structures, and definitions governing regulatory review 

established in, Executive Order 12866. To the extent permitted by law, agencies are 

required by Executive Order 13563 to: (1) propose or adopt a regulation only upon a 

reasoned determination that its benefits justify its costs (recognizing that some benefits 

and costs are difficult to quantify); (2) tailor regulations to impose the least burden on 

society, consistent with obtaining regulatory objectives, taking into account, among other 

things, and to the extent practicable, the costs of cumulative regulations; (3) select, in 

choosing among alternative regulatory approaches, those approaches that maximize net 

benefits (including potential economic, environmental, public health and safety, and other 

advantages; distributive impacts; and equity); (4) to the extent feasible, specify 

performance objectives, rather than specifying the behavior or manner of compliance that 

regulated entities must adopt; and (5) identify and assess available alternatives to direct 

regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can 

be made by the public. 

We emphasize as well that Executive Order 13563 requires agencies “to use the 

best available techniques to quantify anticipated present and future benefits and costs as 

accurately as possible.” In its guidance, the Office of Information and Regulatory Affairs 

has emphasized that such techniques may include “identifying changing future 

compliance costs that might result from technological innovation or anticipated 

480 
 

 

 

behavioral changes.” For the reasons stated in the preamble, DOE believes that today’s 

notice of proposed rulemaking is consistent with these principles, including that, to the 

extent permitted by law, agencies adopt a regulation only upon a reasoned determination 

that its benefits justify its costs and select, in choosing among alternative regulatory 

approaches, those approaches that maximize net benefits. 

B. Review Under the Regulatory Flexibility Act 

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an 

initial regulatory flexibility analysis (IRFA) for any rule that by law must be proposed for 

public comment, unless the agency certifies that the rule, if promulgated, will not have a 

significant economic impact on a substantial number of small entities. As required by 

Executive Order 13272, “Proper Consideration of Small Entities in Agency Rulemaking,” 

67 FR 53461 (August 16, 2002), DOE published procedures and policies on February 19, 

2003, to ensure that the potential impacts of its rules on small entities are properly 

considered during the rulemaking process. 68 FR 7990. DOE has made its procedures 

and policies available on the Office of the General Counsel’s website (www.gc.doe.gov ). 

DOE reviewed the potential standard levels considered in today’s NOPR under the 

provisions of the Regulatory Flexibility Act and the procedures and policies published on 

February 19, 2003. 

As a result of this review, DOE has prepared an IRFA addressing the impacts on 

small manufacturers with respect to the battery charger portion of this proposal. DOE will 

transmit a copy of the IRFA to the Chief Counsel for Advocacy of the Small Business 

481 
 

 

Administration (SBA) for review under 5 U.S.C 605(b). As presented and discussed 

below, the IFRA describes potential impacts on small business manufacturers of battery 

chargers associated with the required capital and product conversion costs at each TSL 

and discusses alternatives that could minimize these impacts. Because DOE did not find 

any small business EPS manufacturers, DOE did not prepare an IRFA regarding the 

impacts on EPS manufacturers from this proposal. 

A statement of the reasons for the proposed rule, and the objectives of, and legal 

basis for, the proposed rule, are set forth elsewhere in the preamble and not repeated here. 

1. Description and Estimated Number of Small Entities Regulated 

a. Methodology for Estimating the Number of Small Entities 

For manufacturers of EPSs and battery chargers, the SBA has set a size threshold, 

which defines those entities classified as “small businesses” for the purposes of the 

statute. DOE used the SBA’s small business size standards to determine whether any 

small entities would be subject to the requirements of the rule. 65 FR 30836, 30850 (May 

15, 2000), as amended at 65 FR 53533, 53545 (Sept. 5, 2000) and codified at 13 CFR 

part 121. The size standards are listed by North American Industry Classification System 

(NAICS) code and industry description and are available at 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf . 

EPS and battery charger manufacturing is classified under NAICS 335999, “All Other 

Miscellaneous Electrical Equipment and Component Manufacturing.” The SBA sets a 

482 
 

threshold of 500 employees or less for an entity to be considered as a small business for 

this category. 

To estimate the number of companies that could be small business manufacturers 

of products covered by this rulemaking, DOE conducted a market survey using all 

available public information to identify potential small manufacturers. DOE’s research 

involved industry trade association membership directories, product databases, individual 

company websites, and the SBA’s Small Business Database to create a list of every 

company that could potentially manufacture products covered by this rulemaking. DOE 

also asked stakeholders and industry representatives if they were aware of any other 

small manufacturers during manufacturer interviews and at previous DOE public 

meetings. DOE contacted companies on its list, as necessary, to determine whether they 

met the SBA’s definition of a small business manufacturer of covered EPSs and battery 

chargers. DOE screened out companies that did not offer products covered by this 

rulemaking, did not meet the definition of a “small business,” or are foreign-owned and 

operated. 

Based on this screening, DOE identified 30 companies that could potentially 

manufacture EPSs or battery chargers. DOE eliminated most of these companies from 

consideration as small business manufacturers based on a review of product literature and 

websites. When those steps yielded inconclusive information, DOE contacted the 

companies directly. As part of these efforts, DOE identified Lester Electrical, Inc. 

483 
 

 

 

(Lincoln, Nebraska), a manufacturer of golf car battery chargers, as the only small 

business that appears to produce covered battery chargers domestically. 

DOE did not identify any small business manufacturers of EPSs. DOE also did 

not identify any domestic manufacturers of EPSs, which indicates that all residential 

EPSs sold in the United States are imported. Because there are no small business 

manufacturers of EPSs, DOE certifies that the standards for EPSs set forth in the 

proposed rule, if promulgated, would not have a significant economic impact on a 

substantial number of small entities. Accordingly, DOE has not prepared a regulatory 

flexibility analysis for the EPS portion of this rulemaking. DOE will transmit the 

certification and supporting statement of factual basis to the Chief Counsel for Advocacy 

of the Small Business Administration for review under 5 U.S.C. 605(b). 

DOE requests comment on the above analysis, as well as any information 

concerning small businesses that could be impacted by this rulemaking and the nature 

and extent of those potential impacts of the proposed energy conservation standards on 

small EPS manufacturers. (See Issue 30 under “Issues on Which DOE Seeks Comment” 

in section VII.E of this NOPR.) 

The following sections address the IFRA for small business manufacturers of 

battery chargers. 

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b. Manufacturer Participation 

Before issuing this NOPR, DOE contacted the potential small business 

manufacturers of battery chargers it had identified. One small business consented to 

being interviewed during the MIA interviews. DOE also obtained information about 

small business impacts while interviewing large manufacturers. 

c. Battery Charger Industry Structure 

With respect to battery chargers, industry structure is typically defined by the 

characteristics of the industry of the application(s) for which the battery chargers are 

produced. In the case of the small business DOE identified, however, the battery charger 

itself is the product the small business produces. That is, the company does not also 

produce the applications with which the battery charger is intended to be used. 

Specifically, the company manufactures battery chargers predominantly intended for golf 

cars (product class 7) and wheelchairs (product classes 5 and 6). 

A high level of concentration exists in both battery charger markets. Two players 

account for the vast majority of the golf car battery charger market and each has a similar 

share. Both competitors in the golf car battery charger market are small businesses: one is 

foreign-owned and operated, while the other is a domestic small business. Despite this 

concentration, there is considerable competition for three main reasons. First, each 

manufacturer sells into a market that is almost as equally concentrated: three golf car 

manufacturers supply the majority of the golf cars sold domestically. Second, while there 

are currently only two major suppliers of battery chargers to the domestic market, the 

485 
 

constant prospect of potential entry from other foreign countries has ceded substantial 

buying power to the three golf car OEMs. Third, golf car manufacturers have the everpresent option of not building electric golf cars altogether (and thus the need for the 

battery charger) by opting to build gas-powered products. DOE examines a price 

elasticity sensitivity scenario for this in chapter 12 of the TSD to assess this possibility. 

Currently, roughly three-quarters of the golf car market is electric, with the remainder 

gas-powered. 

The majority of industry shipments flow to the “fleet” segment -- i.e. battery 

chargers sold to golf car manufacturers who then lease the cars to golf courses. Most cars 

are leased for the first few years before being sold to smaller golf courses or other 

individuals for personal use. A smaller portion of golf cars are sold as new through dealer 

distribution. 

Further upstream, approximately half of the battery chargers intended for golf car 

use is manufactured domestically, while the other half is foreign-sourced. These lattersourced battery chargers are typically high frequency designs, while line frequency 

designs, which are usually less efficient, are made domestically. During the design cycle 

of the golf car, the battery charger supplier and OEM typically work closely together 

when designing the battery charger. 

The small business manufacturer is also a relatively smaller player in the markets 

for wheelchair and industrial lift battery chargers. Most wheelchair battery chargers and 

486 
the wheelchairs themselves are manufactured overseas. Three wheelchair manufacturers 

supply the majority of the U.S. market, but do not have domestic manufacturing. 

d. Comparison Between Large and Small Entities 

As discussed above, there are two major suppliers in the golf car battery charger 

market. Both are small businesses, although one is foreign-owned and operated. DOE did 

not identify any large businesses with which to compare the projected impacts on small 

businesses. 

2. Description and Estimate of Compliance Requirements 

The U.S.-owned small business DOE identified manufactures battery chargers for 

golf cars (product class 7) and wheelchairs (product classes 5 and 6), as well as industrial 

lifts (which are not covered by this rulemaking). DOE anticipates the proposed rule will 

require both capital and product conversion costs to achieve compliance. Various 

combinations of selected TSLs for product classes 5 and 6 (which are combined under a 

single TSL) and product class 7 will drive different levels of small business impacts. The 

compliance costs associated with this combination of potential TSLs are present in tables 

Table VI-1Table VI.1. Compared to the product development (R&D) efforts required to 

achieve the proposed levels, DOE does not expect the various potential combinations of 

TSLs to require significant capital expenditures. Although some replacement of fixtures, 

new assembly equipment and tooling would be required, the magnitude of these 

expenditures would be unlikely to cause significant adverse financial impacts. Product 

487 
class 7 drives the majority of these costs. See Table VI.1 below for the estimated capital 

conversion costs for a typical small business. 

Table VI-1Compared to the product development (R&D) efforts required to 

achieve the proposed levels, DOE does not expect the various potential combinations of 

TSLs to require significant capital expenditures. Although some replacement of fixtures, 

new assembly equipment and tooling would be required, the magnitude of these 

expenditures would be unlikely to cause significant adverse financial impacts. Product 

class 7 drives the majority of these costs. See Table VI.1 below for the estimated capital 

conversion costs for a typical small business. 

The product conversion costs associated with standards are more significant for 

the small business manufacturer at issue than the projected capital costs. As discussed in 

section V.B.2.a.ii of this notice, TSL 1 for product class 7 reflects a technology change 

from a linear battery charger at the baseline to a switch-mode or high-frequency design. 

This change would require manufacturers that produce linear battery chargers to invest 

heavily in the development of a new product design, which would require investments in 

engineering resources for R&D, testing, and certification, and marketing and training 

changes. Again, the level of expenditure at each TSL is driven almost entirely by the 

changes required for product class 7 at each TSL. See the table below for estimated 

product conversion costs for a typical small business. 

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Table VI-2The product conversion costs associated with standards are more 

significant for the small business manufacturer at issue than the projected capital costs. 

As discussed in section V.B.2.a.ii of this notice, TSL 1 for product class 7 reflects a 

technology change from a linear battery charger at the baseline to a switch-mode or highfrequency design. This change would require manufacturers that produce linear battery 

chargers to invest heavily in the development of a new product design, which would 

require investments in engineering resources for R&D, testing, and certification, and 

marketing and training changes. Again, the level of expenditure at each TSL is driven 

almost entirely by the changes required for product class 7 at each TSL. See the table 

below for estimated product conversion costs for a typical small business. 

Table VI.2, and Table VI-3Table VI.3 below, accompanied by a description of 

these and other impacts. 

a. Capital Conversion Costs 

Compared to the product development (R&D) efforts required to achieve the 

proposed levels, DOE does not expect the various potential combinations of TSLs to 

require significant capital expenditures. Although some replacement of fixtures, new 

assembly equipment and tooling would be required, the magnitude of these expenditures 

would be unlikely to cause significant adverse financial impacts. Product class 7 drives 

the majority of these costs. See Table VI.1 below for the estimated capital conversion 

costs for a typical small business. 

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Table VI-1 Estimated Capital Conservation Costs for a Typical Small Business 

(2010$ million) 

Alternatives 1 2* 3 4** 

If the TSL for PC 5 & 6 is... TSL 1 TSL 2 TSL 2 TSL 3 

And the TSL for PC 7 is... TSL 1 TSL 1 TSL 2 TSL 2 

Estimated Capital Conversion Costs $0.1 $0.1 $0.1 $0.1 

*This alternative reflects the combination of TSLs proposed in today’s rulemaking. 

**Reflects max-tech. 

b. Product Conversion Costs 

The product conversion costs associated with standards are more significant for 

the small business manufacturer at issue than the projected capital costs. As discussed in 

section V.B.2.a.ii of this notice, TSL 1 for product class 7 reflects a technology change 

from a linear battery charger at the baseline to a switch-mode or high-frequency design. 

This change would require manufacturers that produce linear battery chargers to invest 

heavily in the development of a new product design, which would require investments in 

engineering resources for R&D, testing, and certification, and marketing and training 

changes. Again, the level of expenditure at each TSL is driven almost entirely by the 

changes required for product class 7 at each TSL. See the table below for estimated 

product conversion costs for a typical small business. 

Table VI-2 Estimated Product Conversion Costs for a Typical Small Business 

(2010$ million) 

Alternatives 1 2* 3 4** 

If the TSL for PC 5 & 6 is... TSL 1 TSL 2 TSL 2 TSL 3 

And the TSL for PC 7 is... TSL 1 TSL 1 TSL 2 TSL 2 

Estimated Product Conversion Costs $2.5 $2.7 $4.8 $5.1 

*This alternative reflects the combination of TSLs proposed in today’s rulemaking. 

**Reflects max-tech. 

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c. Summary of Compliance Impacts 

Table VI-3 Estimated Total Conversion Costs for a Typical Small Business (2010$ 

million) 

Alternatives 1 2* 3 4** 

If the TSL for PC 5 & 6 is... TSL 1 TSL 2 TSL 2 TSL 3 

And the TSL for PC 7 is... TSL 1 TSL 1 TSL 2 TSL 2 

Estimated Total Conversion Costs $2.6 $2.8 $4.9 $5.2 

*This alternative reflects the combination of TSLs proposed in today’s rulemaking. 

**Reflects max-tech. 

Based on its engineering analysis, manufacturer interviews and public comments, 

DOE believes TSL 1 for product class 7 would establish an efficiency level that standard 

linear battery chargers could not cost-effectively achieve. Not only would the size and 

weight of such chargers potentially conflict with end-user preferences, but the additional 

steel and copper needs would make such chargers cost-prohibitive in the marketplace. 

Baseline linear designs are already significantly more costly to manufacture than the 

more-efficient switch-mode designs, as DOE’s cost efficiency curve shows (see Table 

IV-22Table IV.22). Because, in this case, the small business manufacturer is positioned 

as a vertically integrated supplier of linear battery chargers, any energy conservation 

standard that effectively required switch-mode technology would likely cause significant 

adverse impacts on that manufacturer. All products currently manufactured in-house by 

this manufacturer would likely require complete redesigns. 

The potential impacts of a standard on the small business manufacturer are not 

entirely captured by the conversion costs estimates, however. While standard linear 

battery chargers typically have much higher associated material costs relative to the 

switch-mode battery chargers, the manufacturing process of switch-mode designs is more 

491 
 

 

 

labor intensive. Therefore, in high-wage countries like the United States, a manufacturer 

is at a relative cost-disadvantage in producing switch-mode battery chargers. It is most 

likely for this reason that DOE was unable to identify any domestic manufacturing of 

switch-mode battery chargers. 

At the proposed efficiency levels, the small business manufacturer will face a 

difficult decision on whether to attempt to manufacture switch-mode battery chargers inhouse and likely compete on factors other than price, move production to lower-wage 

regions, or source their battery charger manufacturing to a foreign company and rebrand 

these battery chargers. Given the lack of domestic switch-mode battery charger 

manufacturers, one of the latter two strategies would appear the more likely course. 

3. Duplication, Overlap, and Conflict with Other Rules and Regulations 

DOE is not aware of any rules or regulations that duplicate, overlap, or conflict 

with the rule being considered today. 

4. Significant Alternatives to the Proposed Rule 

The discussion above analyzes impacts on small businesses that would result from 

the other TSLs DOE considered. Though TSLs lower than the proposed TSLs are 

expected to reduce the impacts on small entities, DOE is required by EPCA to establish 

standards that achieve the maximum improvement in energy efficiency that are 

technically feasible and economically justified, and result in a significant conservation of 

492 
 

energy. Once DOE determines that a particular TSL meets those requirements, DOE 

adopts that TSL in satisfaction of its obligations under EPCA. 

In addition to the other TSLs being considered, the NOPR TSD includes a 

regulatory impact analysis in chapter 17. For battery chargers, this report discusses the 

following policy alternatives: (1) no standard, (2) consumer rebates, (3) consumer tax 

credits, (4) manufacturer tax credits, and (5) early replacement. DOE does not intend to 

consider these alternatives further because they are either not feasible to implement, or 

not expected to result in energy savings as large as those that would be achieved by the 

standard levels under consideration. 

DOE continues to seek input from businesses that would be affected by this 

rulemaking and will consider comments received in the development of any final rule. 

C. Review Under the Paperwork Reduction Act 

Manufacturers of battery chargers and EPSs must certify to DOE that their 

product complies with any applicable energy conservation standard. In certifying 

compliance, manufacturers must test their products according to the DOE test procedure 

for battery chargers and EPSs, including any amendments adopted for that test procedure. 

DOE has proposed regulations for the certification and recordkeeping requirements for 

all covered consumer products and commercial equipment, including EPSs 75 FR 56796 

(Sept. 16, 2010). The collection-of-information requirement for the certification and 

recordkeeping is subject to review and approval by OMB under the Paperwork Reduction 

493 
 

 

Act (PRA). This requirement has been submitted to OMB for approval and only applies 

to Class A EPSs. As discussed, new reporting requirements for battery chargers and nonClass A EPSs will be proposed and a collection-of-information requirement for the 

certification and recordkeeping subject to review and approval by OMB under the PRA 

will be submitted as part of a future certification, compliance, and enforcement rule 

promulgated by DOE. Public reporting burden for the certification is estimated to average 

20 hours per response, including the time for reviewing instructions, searching existing 

data sources, gathering and maintaining the data needed, and completing and reviewing 

the collection of information. 

Public comment is sought regarding: whether this proposed collection of 

information is necessary for the proper performance of the functions of the agency, 

including whether the information shall have practical utility; the accuracy of the burden 

estimate; ways to enhance the quality, utility, and clarity of the information to be 

collected; and ways to minimize the burden of the collection of information, including 

through the use of automated collection techniques or other forms of information 

technology. Send comments on these or any other aspects of the collection of information 

to Victor Petrolati (see ADDRESSES) and by e-mail to 

Chad_S_Whiteman@omb.eop.gov. 

Notwithstanding any other provision of the law, no person is required to respond 

to, nor shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the PRA, unless that collection of information 

displays a currently valid OMB Control Number. 

494 
D. Review Under the National Environmental Policy Act of 1969 

DOE has prepared a draft environmental assessment (EA) of the impacts 

of the proposed rule Pursuant to the National Environmental Policy Act of 1969 (42 

U.S.C. 4321, et seq.), the regulations of the Council on Environmental Quality (40 CFR 

parts 1500–1508),(NEPA) of 1969, DOE has determined that the proposed rule fits 

within the category of actions included in Categorical Exclusion (CX) B5.1 and DOE’s 

regulationsotherwise meets the requirements for compliance with the National 

Environmental Policy Act of 1969 (application of a CX. See 10 CFR Part 1021). This 

assessment includes an examination of the potential effects of emission reductions likely 

to result from the, App. B, B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). The proposed 

rule in the context of global climate change, as well as other types of environmental 

impacts. The draft EA has been included as chapter 15 of the NOPR TSD. Before 

issuingfits within the category of actions because it is a final rule settingrulemaking that 

establishes energy conservation standards for battery chargers and EPSsconsumer 

products or industrial equipment, and for which none of the exceptions identified in CX 

B5.1(b) apply. Therefore, DOE will consider public comments and, as appropriate, 

determine whether to issuehas made a finding of no significant impact (FONSI) as part of 

a final EA or CX determination for this rulemaking, and DOE does not need to prepare 

an Environmental Assessment or Environmental Impact Statement for this proposed rule. 

DOE’s CX determination for this proposed rule is available at 

http://cxnepa.energy.gov/impact statement (EIS) for this rulemaking.. 

495 
 

 

E. Review Under Executive Order 13132 

Executive Order 13132, "Federalism," 64 FR 43255 (August 10, 1999) imposes 

certain requirements on agencies formulating and implementing policies or regulations 

that preempt State law or that have Federalism implications. The Executive Order 

requires agencies to examine the constitutional and statutory authority supporting any 

action that would limit the policymaking discretion of the States and to carefully assess 

the necessity for such actions. The Executive Order also requires agencies to have an 

accountable process to ensure meaningful and timely input by State and local officials in 

the development of regulatory policies that have Federalism implications. On March 14, 

2000, DOE published a statement of policy describing the intergovernmental consultation 

process it will follow in the development of such regulations. 65 FR 13735. EPCA 

governs and prescribes Federal preemption of State regulations as to energy conservation 

for the products that are the subject of today’s proposed rule. States can petition DOE for 

exemption from such preemption to the extent, and based on criteria, set forth in EPCA. 

(42 U.S.C. 6297) No further action is required by Executive Order 13132. 

F. Review Under Executive Order 12988 

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, "Civil Justice Reform," imposes on 

Federal agencies the general duty to adhere to the following requirements: (1) eliminate 

drafting errors and ambiguity; (2) write regulations to minimize litigation; and (3) 

provide a clear legal standard for affected conduct rather than a general standard and 

promote simplification and burden reduction. 61 FR 4729 (Feb. 7, 1996). Section 3(b) of 

496 
 

 

 

Executive Order 12988 specifically requires that Executive agencies make every 

reasonable effort to ensure that the regulation: (1) clearly specifies the preemptive effect, 

if any; (2) clearly specifies any effect on existing Federal law or regulation; (3) provides 

a clear legal standard for affected conduct while promoting simplification and burden 

reduction; (4) specifies the retroactive effect, if any; (5) adequately defines key terms; 

and (6) addresses other important issues affecting clarity and general draftsmanship under 

any guidelines issued by the Attorney General. Section 3(c) of Executive Order 12988 

requires Executive agencies to review regulations in light of applicable standards in 

section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to 

meet one or more of them. DOE has completed the required review and determined that, 

to the extent permitted by law, this proposed rule meets the relevant standards of 

Executive Order 12988. 

G. Review Under the Unfunded Mandates Reform Act of 1995 

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each 

Federal agency to assess the effects of Federal regulatory actions on State, local, and 

Tribal governments and the private sector. Pub. L. No. 104-4, sec. 201 (codified at 2 

U.S.C. 1531). For a proposed regulatory action likely to result in a rule that may cause 

the expenditure by State, local, and Tribal governments, in the aggregate, or by the 

private sector of $100 million or more in any one year (adjusted annually for inflation), 

section 202 of UMRA requires a Federal agency to publish a written statement that 

estimates the resulting costs, benefits, and other effects on the national economy. (2 

U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to develop an effective 

497 
 

process to permit timely input by elected officers of State, local, and Tribal governments 

on a proposed “significant intergovernmental mandate,” and requires an agency plan for 

giving notice and opportunity for timely input to potentially affected small governments 

before establishing any requirements that might significantly or uniquely affect small 

governments. On March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR 12820; also available at 

http://www.gc.doe.gov. 

Although today’s proposed rule does not contain a Federal intergovernmental 

mandate, it may impose expenditures of $100 million or more on the private sector. 

Specifically, the proposed rule will likely result in a final rule that could impose 

expenditures of $100 million or more. Such expenditures may include (1) investment in 

research and development and in capital expenditures by battery charger and EPS 

manufacturers in the years between the final rule and the compliance date for the new 

standard, and (2) incremental additional expenditures by consumers to purchase higherefficiency battery chargers and EPSs, starting in 2013. 

Section 202 of UMRA authorizes an agency to respond to the content 

requirements of UMRA in any other statement or analysis that accompanies the proposed 

rule. 2 U.S.C. 1532(c). The content requirements of section 202(b) of UMRA relevant to 

a private sector mandate substantially overlap the economic analysis requirements that 

apply under section 325(o) of EPCA and Executive Order 12866. The Supplementary 

498 
 

 

Information section of the notice of proposed rulemaking and the “Regulatory Impact 

Analysis” section of the TSD for this proposed rule respond to those requirements. 

Under section 205 of UMRA, the Department is obligated to identify and consider 

a reasonable number of regulatory alternatives before promulgating a rule for which a 

written statement under section 202 is required. 2 U.S.C. 1535(a). DOE is required to 

select from those alternatives the most cost-effective and least burdensome alternative 

that achieves the objectives of the rule unless DOE publishes an explanation for doing 

otherwise or the selection of such an alternative is inconsistent with law. As required by 

42 U.S.C. 6295(u), today’s proposed rule would establish energy conservation standards 

for battery chargers and EPSs that are designed to achieve the maximum improvement in 

energy efficiency that DOE has determined to be both technologically feasible and 

economically justified. A full discussion of the alternatives considered by DOE is 

presented in the “Regulatory Impact Analysis” section of the TSD for today’s proposed 

rule. 

H. Review Under the Treasury and General Government Appropriations Act, 1999 

Section 654 of the Treasury and General Government Appropriations Act, 1999 

(Pub. L. 105-277) requires Federal agencies to issue a Family Policymaking Assessment 

for any rule that may affect family well-being. This proposed rule would not have any 

impact on the autonomy or integrity of the family as an institution. Accordingly, DOE 

has concluded that it is not necessary to prepare a Family Policymaking Assessment. 

499 
 

I. Review Under Executive Order 12630 

DOE has determined, under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights” 53 FR 8859 (March 18, 

1988), that this proposed regulation would not result in any takings that might require 

compensation under the Fifth Amendment to the U.S. Constitution. 

J. Review Under the Treasury and General Government Appropriations Act, 2001 

Section 515 of the Treasury and General Government Appropriations Act, 2001 

(44 U.S.C. 3516, note) provides for agencies to review most disseminations of 

information to the public under guidelines established by each agency pursuant to general 

guidelines issued by OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 

2002), and DOE’s guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has 

reviewed today’s NOPR under the OMB and DOE guidelines and has concluded that it is 

consistent with applicable policies in those guidelines. 

K. Review Under Executive Order 13211 

Executive Order 13211, “Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use” 66 FR 28355 (May 22, 2001), requires 

Federal agencies to prepare and submit to OIRA at OMB, a Statement of Energy Effects 

for any proposed significant energy action. A “significant energy action” is defined as 

any action by an agency that promulgates or is expected to lead to promulgation of a final 

rule, and that (1) is a significant regulatory action under Executive Order 12866, or any 

successor order; and (2) is likely to have a significant adverse effect on the supply, 

500 
 

 

 

distribution, or use of energy, or (3) is designated by the Administrator of OIRA as a 

significant energy action. For any proposed significant energy action, the agency must 

give a detailed statement of any adverse effects on energy supply, distribution, or use 

should the proposal be implemented, and of reasonable alternatives to the action and their 

expected benefits on energy supply, distribution, and use. 

DOE has tentatively concluded that today’s proposed regulatory action, which 

sets forth proposed energy conservation standards for battery chargers and EPSs, is not a 

significant energy action because the proposed standards are not likely to have a 

significant adverse effect on the supply, distribution, or use of energy, nor has it been 

designated as such by the Administrator at OIRA. Accordingly, DOE has not prepared a 

Statement of Energy Effects on the proposed rule. 

L. Review Under the Information Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in consultation with the Office of Science and 

Technology (OSTP), issued its Final Information Quality Bulletin for Peer Review (the 

Bulletin). 70 FR 2664 (Jan. 14, 2005). The Bulletin establishes that certain scientific 

information shall be peer reviewed by qualified specialists before it is disseminated by 

the Federal Government, including influential scientific information related to agency 

regulatory actions. The purpose of the bulletin is to enhance the quality and credibility of 

the Government’s scientific information. Under the Bulletin, the energy conservation 

standards rulemaking analyses are “influential scientific information,” which the Bulletin 

defines as “scientific information the agency reasonably can determine will have or does 

501 
 

have a clear and substantial impact on important public policies or private sector 

decisions.” 70 FR 2667. 

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews 

of the energy conservation standards development process and analyses and has prepared 

a Peer Review Report pertaining to the energy conservation standards rulemaking 

analyses. Generation of this report involved a rigorous, formal, and documented 

evaluation using objective criteria and qualified and independent reviewers to make a 

judgment as to the technical/scientific/business merit, the actual or anticipated results, 

and the productivity and management effectiveness of programs and/or projects. The 

“Energy Conservation Standards Rulemaking Peer Review Report” dated February 2007 

has been disseminated and is available at the following Web site: 

http://www1.eere.energy.gov/buildings/appliance_standards/peer_review.html. 

VII. Public Participation 

A. Attendance at Public Meeting 

The time, date and location of the public meeting are listed in the DATES and 

ADDRESSES sections at the beginning of this document. If you plan to attend the public 

meeting, please notify Ms. Brenda Edwards at (202) 586-2945 or 

Brenda.Edwards@ee.doe.gov. As explained in the ADDRESSES section, foreign 

nationals visiting DOE Headquarters are subject to advance security screening 

procedures. 

502 
 

In addition, you can attend the public meeting via webinar. Webinar registration 

information, participant instructions, and information about the capabilities available to 

webinar participants will be published on DOE’s website 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external. 

html. Participants are responsible for ensuring their systems are compatible with the 

webinar software. 

B. Procedure for Submitting Prepared General Statements For Distribution 

Any person who has plans to present a prepared general statement may request 

that copies of his or her statement be made available at the public meeting. Such persons 

may submit requests, along with an advance electronic copy of their statement in PDF 

(preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to the 

appropriate address shown in the ADDRESSES section at the beginning of this notice. 

The request and advance copy of statements must be received at least one week before 

the public meeting and may be emailed, hand-delivered, or sent by mail. DOE prefers to 

receive requests and advance copies via email. Please include a telephone number to 

enable DOE staff to make a follow-up contact, if needed. 

C. Conduct of Public Meeting 

DOE will designate a DOE official to preside at the public meeting and may also 

use a professional facilitator to aid discussion. The meeting will not be a judicial or 

evidentiary-type public hearing, but DOE will conduct it in accordance with section 336 

503 
of EPCA (42 U.S.C. 6306). A court reporter will be present to record the proceedings and 

prepare a transcript. DOE reserves the right to schedule the order of presentations and to 

establish the procedures governing the conduct of the public meeting. After the public 

meeting, interested parties may submit further comments on the proceedings as well as on 

any aspect of the rulemaking until the end of the comment period. 

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

present summaries of comments received before the public meeting, allow time for 

prepared general statements by participants, and encourage all interested parties to share 

their views on issues affecting this rulemaking. Each participant will be allowed to make 

a general statement (within time limits determined by DOE), before the discussion of 

specific topics. DOE will permit, as time permits, other participants to comment briefly 

on any general statements. 

At the end of all prepared statements on a topic, DOE will permit participants to 

clarify their statements briefly and comment on statements made by others. Participants 

should be prepared to answer questions by DOE and by other participants concerning 

these issues. DOE representatives may also ask questions of participants concerning other 

matters relevant to this rulemaking. The official conducting the public meeting will 

accept additional comments or questions from those attending, as time permits. The 

presiding official will announce any further procedural rules or modification of the above 

procedures that may be needed for the proper conduct of the public meeting. 

504 
 

A transcript of the public meeting will be included in the docket, which can be 

viewed as described in the Docket section at the beginning of this notice. In addition, any 

person may buy a copy of the transcript from the transcribing reporter. 

D. Submission of Comments 

DOE will accept comments, data, and information regarding this proposed rule 

before or after the public meeting, but no later than the date provided in the DATES 

section at the beginning of this proposed rule. Interested parties may submit comments 

using any of the methods described in the ADDRESSES section at the beginning of this 

notice. 

Submitting comments via regulations.gov. The regulations.gov web page will 

require you to provide your name and contact information. Your contact information will 

be viewable to DOE Building Technologies staff only. Your contact information will not 

be publicly viewable except for your first and last names, organization name (if any), and 

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505 
 

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506 
 

 

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be publicly viewable as long as it does not include any comments 

Include contact information each time you submit comments, data, documents, 

and other information to DOE. Email submissions are preferred. If you submit via mail or 

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Comments, data, and other information submitted to DOE electronically should 

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Confidential Business Information. According to 10 CFR 1004.11, any person 

submitting information that he or she believes to be confidential and exempt by law from 

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copies: one copy of the document marked confidential including all the information 

507 
 

believed to be confidential, and one copy of the document marked non-confidential with 

the information believed to be confidential deleted. Submit these documents via email or 

on a CD, if feasible. DOE will make its own determination about the confidential status 

of the information and treat it according to its determination. 

Factors of interest to DOE when evaluating requests to treat submitted 

information as confidential include: (1) A description of the items; (2) whether and why 

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It is DOE’s policy that all comments may be included in the public docket, 

without change and as received, including any personal information provided in the 

comments (except information deemed to be exempt from public disclosure). 

E. Issues on Which DOE Seeks Comment 

Although DOE welcomes comments on any aspect of this proposal, DOE is 

particularly interested in receiving comments and views of interested parties concerning 

the following issues: 

508 
 

 

 

 

 

 

 

 

 

 

 

1.	 DOE requests interested party feedback, including any substantive data, regarding 

today’s proposed standard levels and the potential for lessening of utility or 

performance related features. 

2.	 DOE requests interested party feedback on whether the standards proposed in 

today’s rule would necessitate the use of any proprietary designs or patented 

technologies. 

3.	 DOE seeks comment on its analysis of the costs and benefits of the standards 

proposed in this rulemaking, including but not limited to DOE’s analytic 

assumptions as highlighted in the list of issues herein. More specifically, DOE 

seeks comment on the Agency’s estimate that the proposed standard for battery 

chargers lead to between $92.8 million and $98.3 million in cost savings (i.e. 

negative costs) relative to the assumed baseline. Recognizing that the cost models 

used for this analysis have certain limitations, DOE seeks comment on the 

assumed market failure the agency has identified as the underlying reason that 

private markets have not taken advantage of these cost savings in the absence of 

this proposed rulemaking. DOE also seeks comment on key assumptions that 

contributed to this estimate, including but not limited to assumptions regarding 

energy consumption, shipments, and manufacturer costs, treatment of existing 

regulatory requirements for battery chargers and EPSs, and treatment of Energy 

Star and other emerging technologies in both the baseline and standards cases. 

Finally, DOE seeks comment on the assumption that incremental product costs 

for battery chargers are negative because of a shift in technology from linear 

509 
 

 

 

power supplies to switch mode power for the larger battery chargers in product 

classes 5, 6, and 7. 

2.4.DOE seeks comment on its estimates of battery charger and EPS shipments, 

lifetimes, and efficiency distributions for each application and product class. 

DOE is especially interested in receiving comment on its assumption that 

EPSs for mobile phones and smartphones are likely to standardize around a 

common connection standard and, as a result, remain in use beyond the 

lifetimes of their associated applications (an average lifetime of 4 years as 

opposed to an average lifetime of 2 years). 

3.5.DOE seeks comment and related data on which battery charger and EPS 

applications are used in the commercial sector, what fraction of shipments are 

to the commercial sector, and how product lifetimes and usage may differ 

between residential and commercial settings. 

4.6.DOE seeks comment on its proposed approach in classifying EPSs that 

indirectly operate consumer products and whether that approach requires 

modifications. If changes are required, DOE seeks specific suggestions on 

how the proposed approach should be altered. 

5.7.DOE welcomes comment on whether there are any performance-related 

features characteristic of either Class A or non-Class A devices (but not both) 

in product class N that would justify different standard levels for the two 

groups. DOE also seeks comment on the merits of applying a standard to 

EPSs falling into product class N. DOE also welcomes comment on the 

proposed compliance dates for non-Class A EPSs. 

Comment [A94]: Changes recommended by 

OIRA. 

Comment [A95]: Change recommended by 

OIRA. 

510 
 

 

 

 

 

8.	 DOE seeks comment, information, and/or data on whether the proposed 

standards would impact any features in the regulated products or in their 

associated complimentary applications. If so, DOE seeks comment as to 

whether these impacts would impact the utility of either the product or the 

application, and on whether, how, and to what degree consumer welfare might 

be impacted by the proposed standards. 

6.9.DOE requests any information regarding existing products that may seem to 

be able to be classified in multiple product classes. 

7.10.	 DOE seeks comment on possible issues of electromagnetic interference 

and/or radio frequency interference associated with switch-mode power 

supplies (SMPS) used with amateur radios, including design options for 

reducing or eliminating interference. 

8.11.	 DOE would like to request any feedback on the proposed approach to 

determining the average efficiency for multiple-voltage EPSs. 

9.12.	 DOE seeks comment on its methodology for generating CSL3 and CSL4 

for high-power EPSs. 

10.13.	 DOE seeks comment on its proposal to set a standard for multiple-voltage 

EPSs as a continuous function of output power. 

11.14.	 DOE seeks comment on its proposed approach in calculating unit energy 

consumption for battery chargers and the appropriateness of the various 

equations to calculate this consumption that are presented in today’s proposal. 

Comment [A96]: Change recommended by 

OIRA. 

511 
 

 

 

12.15.	 DOE seeks information, including any substantive data, to help it assess 

factors of durability, reliability, and preference of transformer based battery 

chargers versus those incorporating switch-mode power supplies. 

13.16.	 DOE seeks comment on its proposed approach in developing a costefficiency relationship for battery charger product class 6. 

17. DOE requests comment on the results of its LCC and PBP analyses, 

particularly with respect to the projected results for multiple voltage EPSs 

(i.e., product class X). In addition, DOE requests comment regarding the 

Agency’s approach of calculating LCC by averaging estimated installation 

costs within subproduct categories. Further, DOE requests comment on the 

household debt equity discount rate applied specifically to the LCC cost 

analysis. Finally, DOE requests comment regarding the segregation of the 

LCC analysis and consumer price impacts, which are separately addressed in a 

shipment-based analysis. 

18. DOE seeks comment on its treatment of the market path, markups, and MSP 

estimates. 

14.19. DOE seeks comment on its use of a roll-up market response, which 

projects that only those products which fall below a standard will improve in 

efficiency, and that the same products will only improve in efficiency so as to 

meet, but not exceed, the efficiency required by the standard. DOE further 

seeks comments on the assumptions regarding efficiency distributions in the 

baseline, such as the extent to which the worst and best energy performers are 

and are not represented in the baseline. 

Comment [A97]: Change recommended by 

OIRA. 

Comment [A98]: Change recommended by 

OIRA. 

512 
 

 

 

15.20.	 DOE seeks comment on whether, and to what extent, battery charger 

efficiency would be likely to improve in the absence of standards, including 

the assumption that battery charger efficiency will not improve between today 

and the compliance date in 2013. 

16.21.	 DOE seeks comment on its assumptions about the extent to which, if at 

all, EPS efficiency will improve for product classes B, C, D, E, X and H in the 

absence of mandatory standards, both prior to and after 2013. 

17.22.	 DOE recognizes that significant variation in use exists for battery 

chargers, EPSs, and the applications they power. In an effort to ensure the 

accuracy of its assumed usage profiles, DOE seeks substantiated estimates, 

with supporting data, of usage profiles for battery chargers, EPSs, and the 

applications they power. 

18.23.	 DOE seeks comment on its EPS loading points, as well as test results that 

will allow it to improve the accuracy of those loading points. 

19.24. DOE seeks comment on its estimate that shipments of EPSs and battery 

chargers are inelastic and on other elasticity assumptions DOE has made. 

DOE further seeks comment, information, and data regarding DOE’s market 

assessment of EPSs and battery chargers via complimentary applications with 

which these products are nearly always bundled. 

20.25.	 DOE seeks comment on its estimate that substitution impacts for EPSs and 

battery chargers are negligible. 

Comment [A99]: Change recommended by 

OIRA. 

513 
 

 

21.26.	 DOE seeks comment on the methodology employed for conducting the 

National Impact Analysis, including the calculations of National Inventory, 

National Energy Savings, and Net Present Value. 

22.27.	 DOE seeks comment on its estimates regarding the proportions of certain 

applications – including mobile phones, MP3 players, GPS equipment, and 

personal care products – that ship with EPSs designed to directly operate the 

application versus indirectly operate the application. 

23.28.	 DOE seeks comment on what level of efficiency EPSs in product class N 

already meet and whether EPSs sold in California are different in terms of 

their energy efficiency than EPSs sold in other States. 

24.29.	 DOE seeks comment on the accuracy of its distribution models for battery 

chargers and EPSs, as well as its estimates off battery charger and EPS 

markups. To the extent that these models and estimates can be improved, 

DOE seeks specific suggestions and supporting data. 

25.30. DOE seeks information concerning small businesses that could be 

impacted by this rulemaking and the nature and extent of those potential 

impacts. For example, DOE is interested in information concerning impacts 

on the golf cart industry that have not been captured in the current rulemaking 

analysis. Further, DOE seeks further information and data regarding the 

‘double jeopardy’ EPS and battery charger impacts on small businesses as 

raised by commenters. 

31. DOE seeks comment on whether the proposed standards would lead to 

lessening of market competition in the regulated industries. 

514 

Comment [A100]: Changes recommended by 

OIRA. 
 

 

26.32.	 DOE seeks comment on whether there are any products on the market that 

are not already subject to California or Federal energy efficiency standards 

that would be covered by the new EPS standards being proposed for product 

class N today. DOE welcomes specific examples of such products, if they 

exist. 

27.33.	 DOE invites comment on solid-state lighting EPSs, specifically on 

whether there are any differences between SSL EPSs and other EPSs that 

might warrant treating them as a separate product class, the size of the market 

for these products, what proportion of SSL luminaires use EPSs, the 

efficiency of those EPSs, and usage patterns. 

28.34.	 DOE seeks comment on whether any battery chargers exist that can only 

be operated on 12V input, whether a device that can be powered only from a 

12V power outlet can be assumed to be designed solely for use in recreational 

vehicles (RVs) and other mobile equipment, and whether there are battery 

chargers with DC inputs other than 5V and 12V. 

29.35.	 DOE welcomes comment on any and all issues related to efficiency 

markings for battery chargers and EPSs. 

36. DOE is interested in receiving comments from industry, states, and other 

interested parties on the best ways to ensure a smooth transition from the 

battery charger standards established in California to the national standards 

addressed in this proposed rule. Comment [A101]: Change recommended by 

OIRA. 

515 
 

________________________________ 

 

VIII. Approval of the Office of the Secretary 

The Secretary of Energy has approved publication of today’s proposed rule. 

List of Subjects in 10 CFR Part 430 

Administrative practice and procedure, Confidential business information, Energy 

conservation, Household appliances, [Reporting and recordkeeping requirements,] and 

Small businesses. 

Issued in Washington, DC, on 

Henry Kelly 

Acting Assistant Secretary of Energy 

Energy Efficiency and Renewable Energy 

516 
For the reasons set forth in the preamble, DOE proposes to amend chapter II, subchapter 

D, of title 10 of the Code of Federal Regulations, as set forth below: 

PART 430 - ENERGY CONSERVATION PROGRAM FOR CONSUMER 

PRODUCTS 

* * * * * 

1. The authority for part 430 continues to read as follows: 

Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note. 

2. Section 430.2 is amended by: 

a. Adding new definitions for AC-AC EPS, AC-DC EPS, basic-voltage EPS, 

direct operation EPS, indirect operation EPS, low-voltage EPS, and multiple-voltage 

EPS; The modifications read as follows: 

§430.2 Definitions. 

* * * * * 

AC-AC external power supply means an external power supply that is used to convert 

household electric current into a single lower-voltage AC current. 

* * * * * 

AC-DC external power supply means an external power supply that is used to convert 

household electric current into a single lower-voltage DC current. 

* * * * * 

517 
 

 

 

Basic-voltage external power supply means an external power supply that is not a lowvoltage power supply. 

Direct operation external power supply means an external power supply that can operate 

a consumer product that is not a battery charger without the assistance of a battery. 

* * * * * 

Indirect operation external power supply means an external power supply that cannot 

operate a consumer product that is not a battery charger without the assistance of a 

battery as determined by the following steps: 

If a product can be connected to an end-use consumer product and that the consumer 

product can be operated using battery power, the method for determining if an EPS can 

directly power an application is as follows: 

i. Charge the battery in the application via the EPS such that the application can 

operate as intended before taking any additional steps. 

ii. Disconnect the EPS from the application. From an off mode state, turn on the 

application and record the time necessary for it to become operational to the 

nearest five second increment (5 sec, 10 sec, etc.). 

iii. Operate the application using power only from the battery until the application 

stops functioning due to the battery discharging. 

iv. Connect the EPS first to mains and then to the application. Immediately 

attempt to operate the application. Record the time for the application to 

become operational to the nearest five second increment (5sec, 10sec, etc.). 

518 
 

If the time recorded in (iv) is less than or equal to the summation of the time recorded in 

(ii) and five seconds, the EPS can operate the application directly and is not in product 

class N. Otherwise, it is an indirect operation EPS and is subject to the standards of 

product class N in §430.32 (w). 

* * * * * 

Low-voltage external power supply means an external power supply with a nameplate 

output voltage is less than 6 volts and nameplate output current greater than or equal to 

550 milliamps. 

* * * * * 

Multiple-voltage external power supply means an external power supply that is used to 

convert household electric current into multiple simultaneous output currents. 

* * * * * 

3. Section 430.32 is amended by revising paragraphs (w) and (y). The modifications read 

as follows: 

§430.32 Energy and water conservation standards and their effective dates. 

* * * * * 

(w) External Power Supplies. (1)(i) * * 

* * * * * 

(iii)(iv) Except as provided in paragraph (w)(1)(iii) of this section, all direct operation 

external power supplies manufactured on or after July 1, 2013, shall meet the following 

standards: 

AC-DC, Basic-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

519 
 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.100 

> 49 watts to ≤

250 watts ≥ 0.880 ≤ 0.210 

> 250 watts ≥ 0.875 ≤ 0.500 

AC-DC, Low-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.100 

> 49 watts to ≤

250 watts ≥ 0.870 ≤ 0.210 

> 250 watts ≥ 0.875 ≤ 0.500 

AC-AC, Basic-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.210 

> 49 watts to ≤

250 watts ≥ 0.880 ≤ 0.210 

> 250 watts ≥ 0.875 ≤ 0.500 

AC-AC, Low-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.210 

> 49 watts to ≤

250 watts ≥ 0.870 ≤ 0.210 

> 250 watts ≥ 0.875 ≤ 0.500 

520 
 

Multiple-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.497 * Pout + 0.067 ≤ 0.300 

> 1 to ≤ 49 watts ≥ 0.075 * ln (Pout) + 0.561 ≤ 0.300 

> 49 watts ≥ 0.860 ≤ 0.300 

(2) The standards described in paragraph (w)(1)(i) and (w)(1)(iiiiv) shall not constitute an 

energy conservation standard for the separate end-use product to which the external 

power supply is connected. 

(3) Any external power supply subject to the standards in paragraphs (w)(1)(i) and 

(w)(1)(iiiiv) 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,’ (incorporated by reference; see §430.3), published by the Environmental 

Protection Agency. 

(4) Any indirect operation external power supply subject to the standards in paragraph 

(w)(1)(i) and not labeled with a Roman numeral VI in accordance with the marking 

protocol referred to in paragraph (w)(3): 

(i) Shall be permanently marked with the capital letter "N" as a superscript to the circle 

that contains the Roman numeral; and, for example, 

521 
and 

(ii) If sold separately from the battery charger or end-use consumer product with which it 

is intended to be used, shall be marked with the manufacturer and model number of that 

battery charger or end-u se consumer product. 

(5) Any indirect operation externa l power supply not subject to the standards in 

paragraph (w)(1)(i) and not labeled with a Roman numeral VI in accordance with the 

marking protocol referred to in par agraph (w)(3): 

(i) Shall be permanently marked w ith the abbreviation "EPS-N"; and", for example, 

and 

(ii) If sold separately from the battery charger or end-use consumer product with which it 

is intended to be used, shall be marked with the manufacturer and model number of that 

battery charger or end-u se consumer product. 

(y) Battery Chargers. (1) Battery chargers manufactured on or afte r July 1, 2013, shall 

have a unit energy consumption (UEC) less than or equal to the standard calculated using 

522 
 

 

 

 

 

the equations for the appropriate product class and corresponding measured battery 

energy as shown below: 

Product Class 

# 

Input / Output 

Type 

Battery 

Energy (Wh) 

Special 

Characteristic or 

Battery Voltage 

Maximum UEC 

(kWh/yr) 

1 

AC In, 

DC Out 

< 100 

Inductive 

Connection* 3.04 

2 < 4 V = 0.2095(Ebatt**) + 5.87 

3 4 – 10 V 

For Ebatt < 9.74 Wh, 

= 4.68 

For Ebatt ≥ 9.74 Wh, 

= 0.0933(Ebatt) + 3.77 

4 > 10 V 

For Ebatt < 9.71 Wh, 

= 9.03 

For Ebatt ≥ 9.71 Wh, 

= 0.2411(Ebatt) + 6.69 

5 

100–3000 

< 20 V 

For Ebatt < 355.18 Wh, 

= 20.06 

For Ebatt ≥ 355.18 Wh, 

= 0.0219(Ebatt) + 12.28 

6 ≥ 20 V 

For Ebatt < 239.48 Wh 

= 30.37 

For Ebatt ≥ 239.48 Wh 

= 0.0495(Ebatt) + 18.51 

7 > 3000 - = 0.502(Ebatt) + 4.53 

8 DC In, 

DC Out 

- < 9 V Input 0.66 

9 - ≥ 9 V Input No Standard 

10a 

AC In, 

AC Out 

- Basic (i.e. no Automatic 

Voltage Regulation) 

For Ebatt < 37.2 Wh, = 

2.54 

For Ebatt ≥ 37.2 Wh, = 

0.0733(Ebatt) – 0.18 

10b - Contains Automatic 

Voltage Regulation 

For Ebatt < 37.2 Wh, = 

6.18 

For Ebatt ≥ 37.2 Wh, = 

0.0733(Ebatt) + 3.45 

11 AC In, DC Out < 100 Wh 

Wireless Charging 

Capability (for dry 

environments) 

Reserved 

* Inductive connection and designed for use in a wet environment (e.g. electric toothbrushes) 

**Ebatt = Measured battery energy as determined in section 5.6 of Appendix Y to Subpart B of Part 430. 

523 
 

 

 

(2) Unit energy consumption shall be calculated for a device seeking certification using 

one of the two equations listed below. If a device is tested and its charge test duration as 

determined in section 5.2 of Appendix Y to Subpart B of Part 430 minus 5 hours exceeds 

the threshold charge time listed in the table below, equation (ii) shall be used to calculate 

UEC; otherwise a device’s UEC shall be calculated using equation (i). 

൅ ൫ܲ௠ሺݐ ௠&௔െ ଶସ ሻ ܧ24 െ 5ܲ௠ െ ܧ௔௕௧௧ ሻሺ ܧଶସ െ 5ܲ௠ െ ܧ௔௕௧௧ (i) ܷܥܧ ൌ 365ሺ݊ሺ ௧೎೏

ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯ሻ or, ܲ௦௕ݐ௦௕ െ 5ሻ݊ሻ൯ ൅ ሺ ݐ௖ௗ ሺ

ଶସ ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯ሻ ܲ௦௕ݐ௦௕ ൅ ሺ ሺ௧೎೏ିହሻ ሻ ܧଶସ െ 5ܲ௠ െ ܧ௔௕௧௧ (ii) ܷܥܧ ൌ 365ሺ݊ሺ

Where: 

E24 = 24-hour energy as determined in section 5.10 of Appendix Y to Subpart B of Part 

430, 

Ebatt = Measured battery energy as determined in section 5.6 of Appendix Y to Subpart B 

of Part 430, 

Pm = Maintenance mode power as determined in section 5.9 of Appendix Y to Subpart B 

of Part 430, 

Psb = Standby mode power as determined in section 5.11 of Appendix Y to Subpart B of 

Part 430, 

Poff = Off mode power as determined in section 5.12 of Appendix Y to Subpart B of Part 

430, 

tcd = Charge test duration as determined in section 5.2 of Appendix Y to Subpart B of 

Part 430, 

524 
And 

ta&m, n, tsb, and toff, are constants used depending upon a device’s product clas s and found 

in the following table: 

Pr 

C 

roduct 

Class M 

Active + 

Maintenan 

(ta&m) 

+ 

nce 

Stan 

(t 

ndby 

tsb) 

Off 

(toff) 

Cha 

(n 

arges 

n) 

Threshold 

Charge 

Time* 

- Hours per Day** Numb 

Da 

ber per 

ay 

Hours 

1 20.66 0.10 0.00 0.15 135.41 

2 8.82 4.56 0.00 0.54 19.00 

3 6.85 0.29 0.00 0.10 67.21 

4 16.35 0.95 0.00 0.49 33.04 

5 6.29 1.07 0.00 0.11 56.83 

6 17.17 6.83 0.00 0.34 50.89 

7 8.14 7.30 0.00 0.32 25.15 

8 6.34 6.93 0.00 0.54 19.00 

10 24.00 0.00 0.00 0.00 N/A*** 

*If 

Ap 

to c 

**I 

unp 

cal 

*** 

f the duratio 

ppendix Y t 

calculate U 

If the total 

plugged tim 

lculation is 

*Because n 

on of the ch 

to Subpart B 

UEC otherw 

time does n 

me, which m 

needed. 

n = 0 for PC 

harge test (m 

B of Part 4 

wise use equ 

not sum to 

means there 

C 10, UEC 

minus 5 ho 

30 exceeds 

uation (ii). 

24 hour pe 

e is 0 powe 

should alw 

ours) as det 

s the thresh 

er day, the r 

er consump 

ways be calc 

ermined in 

old charge 

remaining t 

tion and no 

culated usin 

section 5.2 

time, use e 

time is alloc 

o changes to 

ng equation 

2 of 

equation (ii 

cated to 

o the UEC 

n (i). 

i) 

(3) Any battery charger subject to the standards in paragraph (y)(1) shall be clearly and 

permanently marked on the outside of its housing with the encircled upper case letters 

"BC" coupled with the Roman numeral "III" or a Roman numeral having a greater value , 

for example, 

525