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### PRELIMINARY ANALYSIS REQUESTS FOR COMMENT

DOE is interested in receiving comments on all aspe cts of this preliminary analysis. DOE especially invites comments and data to improve thi s preliminary analysis, including data or information that will respond to the following ques tions or concerns that were raised in response to the framework document and in preparation of the preliminary TSD.

The following list of requests for stakeholder com ment is reproduced from section four of the Executive Summary to the Battery Charger (BC) a nd External Power Supply (EPS) Preliminary Technical Support Document (preliminary TSD). Note that these comments correspond to the numbered items in the preliminary analysis public meeting slides. Following the list are several additional requests for commen t that are included in the public meeting slides but not in the preliminary TSD.

1. Criteria for Identifying Charge Control in Wall Ada pters

DOE is considering adopting the EPA criteria for es tablishing the presence of charge control in a wall adapter, which are: (1) not havin g batteries or battery packs that physically attach directly (including those that are removable ) to the power supply unit or (2) not having a battery chemistry or type selector switch AND an in dicator 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 lig ht is still covered by this specification). DOE welcomes comment on the appropriateness of these cr iteria. This issue is discussed in chapter 3 of the preliminary TSD.

2. Design Options for Battery Chargers and External Po wer Supplies

DOE requests comment and data regarding additional design options or variants of the considered design options that can increase the ran ge of considered efficiency improvements for either BCs or EPSs, including design options that m ay not yet be found in the market.

3. Product Classes for Battery Chargers

DOE seeks comment on its battery charger product cl asses. In particular DOE seeks comment on its decision to group BCs for both power tools and notebook computer into the same low energy, high voltage product class.

4. Dissimilarities Between Low Energy, High Voltage Ba ttery Chargers

The low energy, high voltage product class includes both power tools and notebook computers. Although these two products are shifting from nickel to lithium-ion batteries and using more similar charge rates, DOE is still aware that differences between BCs for the two products may exist. DOE welcomes comment on any dis similarities between BCs for these two types of low energy, high voltage products, and how best to address them in the analysis, e.g. , through the creation of additional product classes.2

5. Scaling Within Battery Charger Product Classes

During interviews, some manufacturers suggested usi ng the EPS ENERGY STAR specification equations to relate output power to e fficiency. Both BCs and EPSs are power conversion circuits with the same general designs a nd components, and this method is already being used in the EPS engineering analysis. DOE see ks comments on using the EPS ENERGY STAR curve to scale the active-mode efficiency of B Cs.

6. Medium Energy, Low Voltage Representative Unit for BCs

DOE seeks comment on whether the marine charger is the most appropriate application to focus its representative-unit analysis for the m edium energy, low voltage product class.

7. EPS Representative Units

DOE selected EPS representative units by focusing o n popular units in the market, which was straightforward for most representative units, except the low-power representative unit. Although DOE considered a 5-watt representative uni t because of its prevalence, DOE instead selected a 2.5-watt representative unit because it belonged to the representative product class A1 whereas the 5-watt EPS was in the non-analyzed prod uct class A2. DOE invites comment on this approach in general and on whether to perform a det ailed analysis for 5-watt, 5-volt EPSs in particular. See chapter 5 of the preliminary TSD fo r more detail.

8. EPS Max-Tech Value for 2.5-Watt Representative Unit

DOE verified the reasonableness of the aggregated m anufacturer max-tech data which it used to create curve fit equations for CSL 4 (max-t ech). To that end, DOE’s subject matter experts (SMEs) reviewed the data and confirmed that the data fell within the expected ranges of efficiencies based on their extensive experience wi th EPSs, other than the max-tech value for the 2.5W EPSs. The SMEs believe that 2.5W EPSs may be a ble to achieve a max tech efficiency of 80 percent rather than the 74.0 percent efficiency derived from manufacturers. DOE seeks comment on the 2.5W max tech efficiency value used. DOE also seeks comment on the cost of an 80 percent-efficient EPS, which it would need in order to use that as the max-tech efficiency

level for 2.5W EPSs in the NOPR.

9. Efficiency Metrics for Multiple-Voltage EPSs

On April 2, 2010, DOE proposed a test procedure for multiple-voltage EPSs that would yield five values: no-load power consumption as wel l as efficiency at 25 percent, 50 percent, 75 percent, and 100 percent of maximum load. 75 FR 169 58. If DOE finalizes that proposal, DOE would then propose to integrate the four efficiency values into an average efficiency metric in the standard. Specifically, DOE proposes to use the no-load power consumption and an average of the four efficiency values as metrics to set can didate standard levels for multiple-voltage EPSs, similar to those set for single-voltage EPSs. Alternatively, DOE is also considering approaches to integrate the four active mode measur ements in a way that may better indicate the typical efficiency of multiple-voltage EPSs during typical use. For instance, DOE could average only the efficiency values at 50 percent and 75 per cent, since those values are closest to the operating conditions described by a stakeholder (Mi crosoft, EERE

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1-2). Overall, DOE faces the same challenge with mu ltiple-voltage EPSs as it does with singlevoltage EPSs: products change continuously, so the test metric should be robust enough to be valid for all applicable products. DOE is seeking s takeholder comment on alternative methods for using the five metrics to set candidate standar d levels for EPSs.

10. Representative Product Classes and Units for MADB E PSs

DOE chose to treat only MADB EPS product class B1 a s representative because there are significant similarities between the MADB product c lasses. Specifically, the MADB EPS product classes have the same product class structu re as the Class A EPS product classes, as explained in chapter 3. To that end, DOE applied th e same structure as Class A EPS for the MADB EPS representative product classes and represe ntative units. Since DOE can apply all Class A EPS analysis to MADB EPSs, it intends also to include a 120-watt representative unit. However, DOE has not identified an associated appli cation for that unit. DOE is seeking stakeholder comment on any applications that use a 120-watt MADB EPS and whether to analyze that unit if it cannot identify any associa ted applications.

11. Baseline Candidate Standard Level of Efficiency for Medical and MADB EPSs

In the determination analysis DOE defined the effic iency values for each CSL based on existing efficiency levels in the market, test data and manufacturer data. For the NOPR, DOE is considering gathering more data for medical and MAD B EPSs with which to develop specific efficiency values for the baseline CSL 0. This woul d allow DOE to characterize the benefits of higher standards to consumers purchasing EPSs with efficiencies below EISA requirements. However, DOE believes that consumers of medical and MADB EPSs with efficiencies below EISA constitute a small and shrinking part of the m arket, based on information from manufacturer interviews. Therefore, DOE is also con sidering accounting for the lowest part of the market in the “EISA qualified” CSL as a simplif ying alternative. Under this alternate approach, there would be no difference between CSL 0 for Class A EPSs and CSL 0 for medical and MADB EPSs in the engineering analysis. DOE is s eeking stakeholder comment on which approach to pursue or whether standard levels for m edical EPSs should continue to be considered in light of their critical lifesaving role.

12. Scaling for EPS Representative Units and CSLs

DOE developed scaling relationships that it used bo th to analyze EPS representative unit data as well as to scale CSLs from product class A1 to other product classes. In general, the scaling methods for representative unit data were d etailed whereas the scaling methods for CSLs were simpler. For the representative unit data, DOE adopted the more detailed approach because the detailed methods provide enhanced accuracy, whi ch was paramount as it was the basis for later analyses, including the LCC and NIA. For the CSL equations, DOE adopted the simpler approach so that stakeholders could more easily eva luate the CSLs. DOE is seeking comment on these approaches in general and whether to develop more detailed CSL equations in particular.

To analyze representative unit data, DOE developed and applied the following scaling relationships:

• Efficiency by nameplate output power4 • Efficiency by nameplate output voltage

• Efficiency by output cord length

• Cost by nameplate output power

• Cost by output cord length

• Markups to MSP

DOE did not develop scaling relationships related t o no-load mode power consumption or cost by production volume. DOE is seeking comment o n the scaling relationships in general and its decision on which scaling relationships to deve lop.

13. Cost Estimates for Product Classes not Fully Analyz ed

DOE developed estimates of incremental costs for BC product classes not fully analyzed using the extrapolation methods described in chapte r 5. For EPS product classes not fully analyzed, DOE used the cost estimates it developed for the representative units as follows: for product classes A2 and A4 DOE used engineering resu lts for the 2.5 W representative unit, and for product class A3 DOE used engineering resul ts for the 18 W representative unit. The underlying assumption is that the incremental costs associated with improving the efficiency of products in a non-analyzed product class are equal to those associated with improving the corresponding representative unit. DOE invites comm ent on these approaches.

14. Market Data

DOE based its estimates of BC and EPS shipments on the estimated shipments of the applications they power. DOE relied on published re ports, comments from stakeholders, and its own estimates to estimate shipments for each applic ation. DOE also conducted a market survey of over 50 common applications to determine the pre valence of BCs and EPSs and their

characteristics. DOE used these characteristics to estimate BC and EPS shipments for each product class and representative unit. DOE seeks co mments on its estimates of BC and EPS shipments for each application and also the shipmen ts in each product class and for each representative unit.

15. Product Lifetimes

DOE developed estimates of the average lifetime of each BC and EPS application examined in the preliminary analysis. DOE welcomes comment on these estimates and on the use of individual application lifetimes to generate LCC results. In particular, DOE seeks comment on the accuracy of using the distribution o f lifetimes from various applications as opposed to sampling from a continuous distribution of lifetime values for a given representative

unit.

16. Estimated Markups and Incremental Markup Assumption s

The confidential nature of the markups applied to B Cs and EPSs necessitated that DOE estimate markups using data from publicly available corporate financial filings. DOE seeks comment on the accuracy of its estimated markups an d specifically seeks comment on the5

assumptions and methods used to calculate markups a pplied to baseline product costs (baseline markups) and markups applied to cost increases resu lting from standards (incremental markups).

17. Sensitivity Analysis Methodology and Results

DOE conducted sensitivity analyses to quantify the relationship between certain critical inputs to the life-cycle cost (LCC) analysis and th e resultant weighted-average LCC savings for BCs and EPSs. DOE conducted a similar analysis as p art of the national impact analysis. DOE seeks comment on the sensitivity analysis results a nd methodology.

18. Use in the Commercial Sector

DOE recognizes that some BC and EPS applications un der consideration in this rulemaking, notably notebook computers, are also us ed extensively in the commercial sector. The preliminary analysis does not differentiate bet ween applications used in the commercial and

residential sectors. DOE intends to examine the ext ent to which applications are used in the commercial sector during the NOPR stage of the anal ysis. DOE requests comments on the nature of the commercial share of application shipments, a nd the BC and EPS shipments that are made for those applications in the commercial sector. DO E also seeks comment on how usage profiles

differ between residential and commercial users. DO E also recognizes that many portable BC applications, such as MP3 players and mobile phones , may be sold to residential users but charged in the commercial sector and thus incur cos ts associated with commercial utility rates. DOE proposes to ignore usage of residential product s in the commercial sector in its energy cost savings estimations. DOE seeks comments on this pro posal.

19. Prospects for Substitution in Response to Standards

DOE assumed that prescribing a standard for BCs and EPSs will not result in competing technologies being substituted for them. Competing technologies include fuel cells, internal power supplies (IPS), primary batteries, Universal Serial Bus (USB) systems, and others. DOE believes that because application and device portab ility is important to consumers they will generally not substitute competing technologies for BCs. DOE addresses the use of USB power for BC applications, but requests comments on the d egree to which an amended EPS standard might cause USB power to be substituted for EPS pow er. DOE also seeks comment on its assumption that substitution to other technologies will not occur in response to BC and EPS

standards.

20. Usage Profiles

DOE developed usage profiles to help estimate the e nergy consumption of BCs and EPSs and the energy savings potential of standards for t hose products. EPS usage profiles consist of time spent in active and no-load mode. Because an a pplication can demand different levels of power, time in active mode was further divided by a pplication state. Each application state was associated with a loading point, expressed as a per centage of nameplate output power. In chapter 7 of the preliminary TSD, DOE identified fi ve loading points to apply to applications if

test data were not available. DOE seeks comments on the usage profiles and loading points used for each EPS application. BC usage profiles consist of time spent in active, maintenance, nobattery, and off mode and the number of complete ch arge cycles completed over 24 hours.6

Application-specific BC usage profiles were develop ed for each application. DOE welcomes comment on all of these usage profiles.

21. Selecting Battery Charger Usage Profiles for Use in Determining Compliance with
Standards

To create an integrated energy performance metric f or BCs requires that DOE identify a single usage profile for each product class. DOE se eks comment on how these usage profiles

should be determined.

22. Shipment Trends

In forecasting future shipments of BCs and EPSs, D OE assumed that current per-capita consumption of BCs and EPSs would remain constant. In other words, shipment growth is set equal to expected population growth during the next 33 years. DOE seeks comment on this assumption.

23. Base Case Efficiency Distributions

To estimate what proportion of the BC and EPS marke ts would be affected by a standard at a particular level, DOE developed a base case ef ficiency forecast. Based on a consideration of several factors discussed in chapter 9, DOE forecas ts modest improvement in the efficiency of Class A EPSs between now and 2013 and no improvemen t thereafter (in the absence of amended Federal standards). DOE forecasts no improvement in BC efficiency between now and 2013 because it identified no significant drivers of eff iciency. DOE welcomes comment on this forecast for use in calculating NES and NPV.

24. Quantifying Non-Consumer Benefits

DOE acknowledges that there may be certain benefits resulting from the improved efficiency of BCs and EPSs that are not captured di rectly by the products' users. These include both environmental and energy security-related exte rnalities that are not reflected in energy prices, such as reduced emissions of greenhouse gas es and reduced use of fossil fuels for electricity generation. DOE invites comments on the nature and magnitude of such benefits.

25. Impact on Manufacturers

DOE requests comment on its identification of key i ssues and requests data and information from interested parties that can assist in evaluating the potential impact of standards on manufacturers presented in chapter 12.

26. Cumulative Regulatory Burdens

DOE recognizes and seeks to mitigate the overlappin g effects on manufacturers of new or amended DOE standards and other regulatory actions affecting the same equipment. DOE will analyze and consider the impact on manufacturers of multiple, product-specific regulatory actions in the NOPR. DOE invites comment on how reg ulations applicable to BCs and EPSs may contribute to manufacturers’ cumulative regulatory burden. DOE also requests information on7

the cost of low- and high-efficiency BCs and EPSs t hat are expected to be compliant with these regulations so that DOE can assess how these requir ements may affect payback calculations.

27. Valuing Airborne Emission Reductions

DOE will conduct an environmental assessment as par t of the next phase of the standards rulemaking, the NOPR. The primary environmental eff ects of energy conservation standards for BCs and EPSs are to reduce power plant emissions re sulting from reduced consumption of electricity. DOE will assess these environmental ef fects by using NEMS-BT to provide key inputs to its analysis. The portion of the environm ental assessment that will be produced by NEMS-BT considers carbon dioxide (CO2), sulfur diox ide (SO2), nitrogen oxides (NOX), and mercury (Hg). DOE also plans to monetize the emissi on reductions due to standards consistent

with methods used in recent DOE standards rulemakin gs pertaining to commercial clothes washers and other consumer products and commercial equipment. For example, in the case of CO2, the most recent interagency estimates of the p otential global benefits resulting from reduced CO2 emissions in 2010 were $4.7, $21.4, $35 .1, and $64.9 per metric ton in 2007 dollars. DOE invites comment on possible approaches to monetizing the emission reductions expected to result from energy conservation standar ds.

ADDITIONAL REQUESTS FOR COMMENT

In addition to the above issues, which were identi fied in the preliminary TSD, DOE also seeks comment on the following issues.

A. MADB EPS Shipments DOE seeks comment on the percent of wall adapters f or MADB applications that lack charge control and thus are EPSs under the ENERGY S TAR criteria.

B. EPS Representative Units and CSLs DOE seeks comment on the appropriateness of its EPS representative units and CSLs. In particular, DOE requests comment on whether 2.5W EP Ss may be able to achieve a maxtech efficiency higher than 73.9 percent.

C. Aggregation Methodology As detailed in the TSD, manufacturers’ data was agg regated into a three-dimensional equation. DOE seeks comment on this aggregation me thodology.

D. Scaling CSLs within BC Product Classes DOE seeks comment on suggested methodologies to sca le CSLs from representative units to all units within each BC product class.