1 | Building Technologies Program eere.energy.gov The Parker Ranch installation in Hawaii BUILDING TECHNOLOGIES PROGRAM



# Energy Conservation Standards for Residential Dehumidifiers: Framework Public Meeting September 24, 2012
Stephen Witkowski Department of Energy Energy Efficiency & Renewable Energy2 | Building Technologies Program eere.energy.gov



## Welcome and Introduction

 Introductions

 Role of the Facilitator

 Ground Rules (Norms)



# • Listen as an ally



# • Use short, succinct statements/keep to the point



# • Hold sidebar conversations outside the room



# • Focus on issues, not personalities



# • One person speak at a time (raise hand to be recognized; state your name for the record)



# • Set cell phones to silent/vibrate

 Housekeeping Items

 Agenda Review

 Opening Remarks3 | Building Technologies Program eere.energy.gov 

## Afternoon Agenda

1:00

– 1:15 pm Welcome, Opening Remarks, and Agenda Review

Doug Brookman

1:15

– 1:20 pm Rulemaking Introduction and Background

Stephen Witkowski

1:20

– 2:20 pm Test Procedure, Market and Technology Assessment, Screening Analysis, and

Engineering Analysis Judith Reich

2:20

– 2:30 pm Preliminary and NOPR Manufacturer Impact Analysis

Ben Barrington

2:30

– 2:45 pm Break

2:45

– 3:45 pm Markups for Equipment Price Determination, Energy Use Determination, Life

- Cycle

Cost and Payback Period Analysis, Shipments Analysis, National Impact Analysis, LCC Subgroup Analysis, Utility Impact Analysis, Employment Impact Analysis, Emissions Analysis, and Regulatory Impact Analysis Camilla Dunham

- Whitehead

3:45

– 4:00 pm Other Issues and Comments, Closing Remarks

Stephen Witkowski4 | Building Technologies Program eere.energy.gov 

## Opening Remarks

Interested parties who contacted DOE to request an opportunity to issue an opening statement may

speak now.5 | Building Technologies Program eere.energy.gov



### 4 3 2

Preliminary Analysis Background

Test Procedure 1 Introduction

5 NOPR Analysis 

## Public Meeting Agenda

6 Closing Remarks6 | Building Technologies Program eere.energy.gov 

## Purpose of the Framework Document Public Meeting

 Present the analytical approaches to be used to evaluate energy conservation standards for residential dehumidifiers

 Provide a forum for public discussion of rulemaking issues

 Encourage interested parties to submit data, information, and
written comments 

# Introduction7 | Building Technologies Program eere.energy.gov 

# Introduction

Request for Comment

Item # DOE solicits comment on a range of specific 

## issues throughout the Framework Document.

• Throughout this presentation, these issues will be highlighted for discussion in comment boxes such as this.

• Item numbers cor respond to those in the Framework Document

.

• DOE welcomes comments concerning these specific issues and any other issues related to the this rulemaking.8 | Building Technologies Program eere.energy.gov



## Instructions for Submitting Comments

 In all correspondence, please refer to this Residential Dehumidifiers Rulemaking by:

– Docket Number EERE

– 2012

– BT

– STD

– 0027

, and/or (RIN) 1904

- AC81

 Email: ResDehumidifier2012STD0027@ee.doe.gov

 Postal Mail: Ms. Brenda Edwards

U.S. Department of Energy Building Technologies Program, Mailstop EE

- 2J 1000 Independence Avenue, SW. Washington, D.C. 20585

- 0121

 Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., Suite 600

 Phone: (202) 586

- 2945 

# Introduction

Comment period closes October 17, 20129 | Building Technologies Program eere.energy.gov



### 4 3 2

Preliminary Analysis Background

Test Procedure 1 Introduction

5 NOPR Analysis 

## Public Meeting Agenda

6 Closing Remarks10 | Building Technologies Program eere.energy.gov 

## Legislative History

 Energy Policy and Conservation Act (EPCA) of 1975 established an energy conservation program for major household appliances (42 USC 6291 et seq.)

 The Energy Policy Act of 2005 (EPACT 2005), amended EPCA to establish energy conservation standards for dehumidifiers manufactured as of October 1, 2007.

 The Energy Independence and Security Act of 2007 (EISA 2007), subsequently amended EPCA to prescribe new energy conservation standards for dehumidifiers manufactured on or after October 1, 2012. DOE codified these standards in a final rule published March 23, 2009.

 EPCA requires that, not later than 6 years after the issuance of a final rule establishing or amending a standard, DOE publish a notice of proposed rulemaking (NOPR) proposing new standards or that the existing standards
need not be amended. 

# Regulatory History11 | Building Technologies Program eere.energy.gov



## Energy Conservation Standards 

# Dehumidifier Standards

Product Capacity EF (liters/kWh )
1. 25.00 pints/day or less 1.00

2. 25.01

– 35.00 pints/day 1.20

3. 35.01

– 54.00 pints/day 1.30

4. 54.01

– 74.99 pints/day 1.50

5. 75.00 pints/day or more 2.25 Product Capacity EF (liters/kWh )
1. Up to 35.00 pints/day 1.35

2. 35.01

– 45.00 pints/day 1.50

3. 45.01

– 54.00 pints/day 1.60

4. 54.01

– 75.00 pints/day 1.70

5. 75.00 pints/day or more 2.5 

### Dehumidifiers Manufactured On or After October 1, 2007 Dehumidifiers Manufactured On or After October 1, 201212 | Building Technologies Program eere.energy.gov Introduction 

## Current Rulemaking for Residential Dehumidifiers

• To meet the EISA 2007 deadline, DOE initiated the current rulemaking on Residential Dehumidifiers.

• Today’s public meeting is about the Framework Document.

• DOE expects to issue a test procedure soon to address standby mode and off mode energy use, as well as certain active mode updates. EISA 2007 Framework Document Preliminary

Analyses 1 Energy Conservation Standards for Residential Dehumidifiers NOPR 1 Final

Rule

1 NOPR : Notice of Proposed Rulemaking 

# Rulemaking Schedule

2012 2013 2015 2016 201413 | Building Technologies Program eere.energy.gov 

## Technological Feasibility and Economic Justification

 N ew or amended standards must be designed to achieve the maximum improvement in energy or water efficiency that is technologically feasible and economically justified

.
 DOE performs the following analyses to determine technological feasibility: 

# Rulemaking Process Overview

EPCA Requirement Corresponding DOE Analyses

Technological Feasibility  Market and Technology Assessment

 Screening Analysis

 Engineering Analysis14 | Building Technologies Program eere.energy.gov 

###  DOE must consider seven factors to determine whether new or amended standards are economically justified: 

# Rulemaking Process Overview

EPCA Requirement Corresponding DOE Analyses

1. Economic impact on consumers and manufacturers • Life

- Cycle Cost Analysis

• Manufacturer Impact Analysis

2. Lifetime operating cost savings compared to increased product cost • Life

- Cycle Cost Analysis

3. Total projected energy savings • National Impact Analysis

4. Impact on utility or performance • Engineering Analysis

• Screening Analysis
5. Impact of any lessening of competition • Manufacturer Impact Analysis
6. Need for national energy conservation • National Impact Analysis

7. Other factors the Secretary considers relevant • Emissions Analysis

• Utility Impact Analysis

• Employment Impact Analysis15 | Building Technologies Program eere.energy.gov



### 4 3 2

Preliminary Analysis Background

Test Procedure 1 Introduction

5 NOPR Analysis 

## Public Meeting Agenda

6 Closing Remarks16 | Building Technologies Program eere.energy.gov



## Dehumidifier Test Procedure

 The current DOE dehumidifier test procedure is codified at 10 CFR Part 430, Subpart B, Appendix X.

 As currently specified by EPCA (42 U.S.C. 6293(b)(13 )), the test procedure measures capacity and Energy Factor (EF) according to: 

# Test Procedure

• American National Standards Institute (ANSI)/Association of Home Appliance Manufacturers (AHAM) Standard DH

– 1 is used to measure capacity in pints of moisture removed per day.

• Canada’s CAN/ Canadian Standards Association (CSA)

– C749

– 94 is used to calculate the energy factor (EF) in terms of liters of moisture removed per kilowatt

- hour (kWh).17 | Building Technologies Program eere.energy.gov



## Standby Mode and Off Mode

 EPCA, as amended by EISA 2007, requires that DOE amend the test procedures for certain residential products, including dehumidifiers, to incorporate measures of standby mode and off mode energy use.

 DOE published a NOPR (75 FR 75290 (Dec. 2, 2010)) in which it 

### proposed to incorporate by reference the International Electrotechnical Commission (IEC) Standard 62301, for measuring dehumidifier standby mode and off mode power consumption,

 DOE subsequently published a Supplemental Notice of Proposed Rulemaking (SNOPR) to propose referencing the updated version of IEC Standard 62301. 76 FR 58346 (Sept. 20, 2011).



###  The final rule is expected to publish shortly. 

# Test Procedure18 | Building Technologies Program eere.energy.gov 

## Active Mode

 In the rulemaking, DOE also proposed to measure both capacity and EF for dehumidifiers according to ANSI/AHAM DH

- 1

- 2008. 77 FR 31444 (May 25, 2012).

 The final rule is expected to publish shortly. 

# Test Procedure19 | Building Technologies Program eere.energy.gov



### 4 3 2

Preliminary Analysis Background

Test Procedure 1 Introduction

5 NOPR Analysis 

## Public Meeting Agenda

6 Closing Remarks20 | Building Technologies Program eere.energy.gov

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis 

## Steps in the Standards Rulemaking: Preliminary Analysis 

# Preliminary Analysis21 | Building Technologies Program eere.energy.gov



## Market and Technology Assessment

 Purpose:

• Characterize residential dehumidifier industry and market

• Gather historical shipments and other relevant data

• Identify technology options for improving efficiency

 Method:

• Identify and characterize manufacturers of residential dehumidifiers

• Estimate shipments and trends in the market

• Identify technologies that could improve efficiency and

• Identify regulatory and non

- regulatory initiatives intended to improve the efficiency of the products covered under this rulemaking 

# Market and Technology Assessment22 | Building Technologies Program eere.energy.gov 

# Market and Technology Assessment

Request for Comment

Item 3

- 1 The Department requests information that would contribute to the market assessment ( e.g. , current product features and efficiencies, product

- feature and efficiency trends, historical product shipments and prices).23 | Building Technologies Program eere.energy.gov 

## Definition

 EPACT 2005, amended EPCA to add a definition of a residential dehumidifier (codified at 10 CFR 430.2) as : 

# Market and Technology Assessment

A self

- contained, electrically operated, and mechanically refrigerated encased assembly consisting of :

• A refrigerated surface (evaporator) that condenses moisture from the atmosphere;

• A refrigerating system, including an electric motor;

• An air

- circulating fan; and

• Means for collecting or disposing of the condensate.24 | Building Technologies Program eere.energy.gov



## Equipment Product Classes

 DOE will formulate a separate energy conservation standard for each product class.

 In general, DOE divides covered equipment into classes by:

• Type of energy used

• Capacity of the equipment

• Other performance

- related features such as those that provide utility to the consumer, or others deemed appropriate by the Secretary that justify different standard levels (42 USC 6295(q)) 

# Market and Technology Assessment25 | Building Technologies Program eere.energy.gov 

## Proposed Residential Dehumidifier Product Classes

 EPCA establishes product classes based on the capacity of the unit

 The Department is considering the following product classes, as
established in the EISA 2007 amendments to EPCA for dehumidifiers manufactured on or after October 1, 2012: 

# Market and Technology Assessment

Residential Portable Dehumidifiers*
1. Up to 35.00 pints/day 4. 54.01

– 75.00 pints/day

2. 35.01

– 45.00 pints/day 5. Greater than 75.00 pints/day

3. 45.01

– 54.00 pints/day

* The current product classes do not specify whether they apply only to portable dehumidifiers. DOE is considering such clarification because it may define a separate product class for whole

- home dehumidifiers.26 | Building Technologies Program eere.energy.gov



## Proposed Additional Whole

- Home Residential

Dehumidifier Product Class

 Whole

- home units generally use equivalent dehumidification technologies as portable units, but are designed to operate in a ducted installation, typically in conjunction with the home’s central air conditioning system.

 Differentiating characteristics of whole

- home units:

• Performance is affected by the air flow and pressure impacts resulting from the ducting

• May be installed with a fresh air intake rather than having conditioned air at the intake side

• Capacity ranges from approximately 65 to 200 pints/day, with no distinct correlation between capacity and EF 

# Market and Technology Assessment27 | Building Technologies Program eere.energy.gov 

## Classification of Portable Dehumidifiers With Optional Ducting

 Certain portable dehumidifiers may be operated in a ducted
installation

 Several options exist for classification of such units:

• Portable (no ducting, least energy

- intensive configuration)

• Whole

- home (ducted, most energy

- intensive configuration)

• Some other alternative or combination 

# Market and Technology Assessment28 | Building Technologies Program eere.energy.gov 

# Market and Technology Assessment

Request for Comment

Item 3

- 2 The Department requests input from stakeholders on the proposed classes and criteria used for creating these product classes. Specifically, should additional or fewer criteria beyond those identified above be used as a basis for developing product classes? Should DOE consider separate product class(es) for whole

- home dehumidifiers? How should DOE classify portable dehumidifiers that can be operated in a ducted installation?29 | Building Technologies Program eere.energy.gov



## Initial Technology Options for Residential

Dehumidifiers

 DOE will consider technology options from previous rulemaking, plus any new available technologies 

# Market and Technology Assessment

• Built

- in hygrometer/humidistat

• Improved compressor efficiency

• Improved condenser performance

• Improved controls

• Improved defrost methods

• Improved demand

- defrost controls

• Improved evaporator performance

• Improved fan

- motor efficiency

• Improved fan efficiency



### • Improved flow

- control devices

• Low

- standby

- loss electronic controls

• Washable air filters

• Heat pipe technology30 | Building Technologies Program eere.energy.gov 

# Market and Technology Assessment

Request for Comment

Item 3

- 3 Of the technologies listed, are there any that DOE 

### should not consider because of their impacts on safety, performance, or consumer utility of the product ?

Item 3

- 4 Are there other unlisted technologies that DOE should consider as design options and what, if any, impacts do the design options have on safety, performance, and consumer utility?31 | Building Technologies Program eere.energy.gov 

# Market and Technology Assessment

Request for Comment

Item 3

- 5 The Department seeks input from stakeholders on 

### the selection of representative product classes for the engineering and LCC analyses, and on possible methods of extrapolating the engineering and LCC analyses from the representative dehumidifier product classes to the other two product classes ( e.g. , maintaining relative incremental energy use specified in EPCA across product classes).32 | Building Technologies Program eere.energy.gov 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis 

## Screening Analysis33 | Building Technologies Program eere.energy.gov 

## Screening Analysis

 Purpose:

• Screen out technology options that DOE will not consider during the rulemaking

 Criteria:

• Technological feasibility

• Practicability to manufacture, install, and service

• Adverse impacts on product utility or availability



## • Adverse impacts on health or safety 

# Screening Analysis34 | Building Technologies Program eere.energy.gov 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis 

## Engineering Analysis35 | Building Technologies Program eere.energy.gov 

## Engineering Analysis

 Purpose:

• Determine the relationship between manufacturer cost and energy efficiency 

# Engineering Analysis

Efficiency Cost36 | Building Technologies Program eere.energy.gov



## Residential Dehumidifier Baseline Models 

# Engineering Analysis

Product Class EF (liters/kWh )

1. Portable , up to 35.00 pints/day 1.35

2. Portable , 35.01

– 45.00 pints/day 1.50

3. Portable , 45.01

– 54.00 pints/day 1.60

4. Portable , 54.01

– 75.00 pints/day 1.70

5. Portable , greater than 75.00 pints/day 2.5

6. Whole

- home 2.5*

* Based on October 1, 2012 standards for dehumidifiers with a capacity greater than 75 pints/day37 | Building Technologies Program eere.energy.gov 

# Engineering Analysis

Request for Comment

Item 5

- 1 DOE seeks input from stakeholders on whether the 

### proposed energy efficiency levels are appropriate for characterizing the performance of baseline units.

Item 5

- 2 DOE seeks input on an appropriate baseline unit efficiency for whole

- home dehumidifiers and whether the DOE test procedure is capable of measuring the performance of these units.

Item 5

- 3 DOE seeks information regarding the specific technological 

### characteristics of the baseline model for each product class, including the technologies described for the Technology Assessment.38 | Building Technologies Program eere.energy.gov 

## Approach for Determining Cost

- Efficiency Relationship

 DOE proposes to use design

- option approach using reverse engineering, because data suggests that there is little variation in EF within most product classes.

 Reverse

- engineering will be used to identify cost and efficiency 

### impacts from design options.

 DOE will conduct limited testing to establish what control strategies are being used by manufacturers in conjunction with design options and platform design.

 DOE will seek incremental cost data from manufacturers for each efficiency level, supplemented with stakeholder interviews and 

### publicly available data.

 Cost

- efficiency curves will be generated from incremental costs for each efficiency level. 

# Engineering Analysis39 | Building Technologies Program eere.energy.gov



## Industry Cost Submittal 

# Engineering Analysis

• Direct material

• Direct labor

• Factory overhead



### • Depreciation • Sales & marketing

• Research & development

• Building



### • Tooling/Equipment Full Production Cost Conversion Costs (Non

- Production Costs) Manufacturer Cost Data 

# + =

• Costs will be provided on a shipment

- weighted, industry

- aggregated basis.

• Data will not be provided for product classes and/or efficiency levels representing fewer than three manufacturers.



### • DOE will request information about the depreciation method manufacturers use to expense conversion capital.40 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 5

- 4 DOE requests feedback on the use of a design

option approach to determine the relationship between manufacturer cost and energy efficiency for residential dehumidifiers

. 

# Engineering Analysis41 | Building Technologies Program eere.energy.gov



## Product Classes Analyzed

 DOE will conduct the engineering analysis (and LCC and PBP analyses) on the product classes for which it suggests efficiency levels.

 DOE proposes to analyze four product classes:

• Portable, 35.01

– 45.00 pints/day

• Portable, 45.01

– 54.00 pints/day

• Portable, 54.01

– 75.00 pints/day

• Whole

- home



###  DOE will extrapolate results to the other product classes. 

# Engineering Analysis42 | Building Technologies Program eere.energy.gov



## Max

- Tech Efficiency Levels

 DOE is required to analyze maximum technologically feasible (“max tech”) efficiency levels

• In some cases, DOE defines the highest efficiency level based on maximum available efficiency currently on the market.

• “Max available” may not correspond to “max tech” if, for example, some design options are not yet commercially available.

• DOE will seek stakeholder input to resolve this potential discrepancy. 

# Engineering Analysis43 | Building Technologies Program eere.energy.gov 

## Efficiency Levels for Residential Dehumidifiers 

# Engineering Analysis

* ENERGY STAR qualification criteria effective October 1, 2012, require all portable and whole

- home dehumidifiers less than 75 pints per day to have an EF of at least 1.85 liters/kWh, which is greater than the maximum available efficiency of 35.01

– 45.00 pints/day units. U nits with 75

– 185 pints/day capacity must have an EF of at least 2.80 liters/kWh, while dehumidifiers with a capacity greater than 185 pints/da y a re excluded. † The baseline efficiency for the whole home product class is specified as the DOE standard effective October 1, 2012, for de hum idifiers with a capacity greater than 75.00 pints/day. Level Efficiency Level Source Efficiency Levels (liters/kWh) Portable, 35.01

– 45.00 pints/day Portable,

45.01

– 54.00 pints/day Portable,

54.01

– 75.00 pints/day Whole

Home

Baseline DOE Standard 1.50 1.60 1.70 2.50 †

1 ENERGY STAR* (Max Available for 35.01

– 45.00 pints/day, Gap Fill for 45.01

– 54.00 pints/day) 1.62 1.70 1.85 2.80

2 Gap Fill (Max Available for 45.01

– 54.00 pints/day -- 1.8 2.10 3.50

3 Maximum Available

-- -- 2.47 4.1744 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 5

- 5 DOE seeks input from stakeholders concerning the efficiency levels it proposes to use for collecting incremental cost data from manufacturers of residential dehumidifiers. DOE also seeks input from stakeholders on appropriate maximum technologically feasible efficiency levels. 

# Engineering Analysis45 | Building Technologies Program eere.energy.gov 

## Proprietary Designs

 DOE will evaluate all design options that are commercially available or present in a working prototype, including proprietary designs and technologies.

 Proprietary designs will only be considered if they do not present a unique path to a given efficiency level.

 The confidentiality of manufacturers will be maintained 

# Engineering Analysis46 | Building Technologies Program eere.energy.gov 

# Engineering Analysis

Request for Comment

Item 5

- 6 Are there proprietary designs or technologies of which DOE should be aware for any of the dehumidifiers under consideration in this rulemaking? If so, how should DOE acquire the cost data necessary for evaluating these designs?47 | Building Technologies Program eere.energy.gov



## Outside Regulatory Changes

 Consider the effects on manufacturers of other regulatory changes outside of the standards rulemaking process.

 Example: Some manufacturers in the residential dehumidifier industry are subsidiaries of larger parent companies that manufacture other products subject to Federal regulations

• Recent DOE standards for residential dishwashers, clothes washers, clothes dryers and room air conditioners

• Reduction of Hazardous Substances (RoHS) EU directive 

# Engineering Analysis48 | Building Technologies Program eere.energy.gov 

# Engineering Analysis

Request for Comment

Item 5

- 7 Are there outside regulatory issues that DOE should consider in its analysis of residential dehumidifiers?49 | Building Technologies Program eere.energy.gov



## Markups for Product Price Determination 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis50 | Building Technologies Program eere.energy.gov



## Legislative Requirements

 The Manufacturer Impact Analysis (MIA) partially fulfills EPCA requirement to determine if a proposed standard is economically justified:

• Economic impact of standards on manufacturers

• Impacts of any lessening of competition in the industry

 MIA format changes are described in the 2006 report to Congress, at : 

## http :// www1.eere.energy.gov/buildings/appliance_standards/ pdfs/congressional_report_013106.pdf 

# Manufacturer Impact Analysis51 | Building Technologies Program eere.energy.gov 

## Preliminary Analysis (Phase I) MIA Methodology 

# Manufacturer Impact Analysis

Develop Framework for Analysis Develop

NOPR MIA Interview Guides Conduct

NOPR MIA Interviews Assess

Impacts to Industry Develop Industry Profile Conduct

Preliminary Interviews



###  Industry Profile

• Identify current and past industry structure

• Evaluate market characteristics and current trends

• Develop industry average financial parameters using publicly available information

• Identify manufacturer sub

- groups including small business manufacturers



###  Preliminary Interviews

• Conducted in conjunction with the Pre

- NOPR Phase Engineering 

### Analysis interviews

• Identify key issues for manufacturers

• Inform preliminary analysis52 | Building Technologies Program eere.energy.gov 

## Preliminary Analysis (Phase II) MIA Methodology

Develop Industry Profile Conduct

Preliminary Interviews Conduct NOPR MIA Interviews Assess

Impacts to Industry Develop Framework for Analysis Develop

NOPR MIA Interview Guides



###  Framework for Analysis

• DOE will tailor the Governmental Regulatory Impact Model (GRIM) to reflect the industry structure

• DOE will use this framework to determine what additional information is required to fully analyze the potential impacts to manufacturers



###  MIA Interview Guides

• DOE will develop an interview guide designed to collect responses that will help inform further analyses and develop key inputs to the GRIM

• Topics include: key issues, market share, markup structure, shipments, financial parameters, capital and non

- capital expenditures, cumulative regulatory burden, direct employment, manufacturing capacity, and the anticipated impacts to competition and manufacturer subgroups 

# Manufacturer Impact Analysis53 | Building Technologies Program eere.energy.gov



## NOPR (Phase III) MIA Methodology

 MIA Interviews

• DOE will conduct confidential interviews with manufacturers to discuss the topics outlined in the interview guide, as well as any other relevant topics that manufacturers would like to address



###  Impacts to Industry

• Key quantitative metrics include the estimated impacts to industry net

present value (INPV) and domestic employment

• Additionally, DOE will assess the cumulative regulatory burden associated with this rulemaking, the effect of the rulemaking on competition in the industry, and the disproportionate effects of the rulemaking on any previously identified manufacturer subgroups including small

- business manufacturers Develop Industry Profile Conduct

Preliminary Interviews Develop

Framework for Analysis Develop

NOPR MIA Interview Guides Conduct

NOPR MIA Interviews Assess

Impacts to Industry 

# Manufacturer Impact Analysis54 | Building Technologies Program eere.energy.gov



## Manufacturer Subgroups

 Groups of manufacturers that may be disproportionately affected by efficiency standards:

• DOE has identified five small business manufacturers of residential dehumidifiers

 Regulations that could affect the industries impacted by this rulemaking include:

• DOE standards for residential dehumidifiers (October 2012), dishwashers, clothes washers, clothes dryers, and room air 

### conditioners (existing and upcoming)

• EPA

- mandated phase

- out of HCFCs

• Reduction of Hazardous Substances (RoHS) directive



## Cumulative Regulatory Burden 

# Manufacturer Impact Analysis55 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 12

- 1 DOE seeks comment on appropriate manufacturer subgroups, if any, that DOE should consider in a manufacturer subgroup analysis for residential dehumidifiers.

Item 12

- 2 DOE seeks comment on small businesses that could be impacted by energy conservation standards for dehumidifiers, and what the impacts on small businesses of potential standards might be.



## 55 

# Manufacturer Impact Analysis56 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 12

- 3 What other regulations or pending regulations should DOE consider in its examination of cumulative regulatory burden?



## 56 

# Manufacturer Impact Analysis57 | Building Technologies Program eere.energy.gov



## Markups for Product Price Determination 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis58 | Building Technologies Program eere.energy.gov 

## LCC and PBP Analysis Inputs From Engineering Analysis (Price is a Function of Efficiency)

From Markups for Equipment Price Determination Analysis

From Energy Use Characterization Analysis Energy

Consumption

Power Demand Distributor Markup

Sales Tax Mechanical Contractor Markup Consumer Price

Data Inputs

Intermediate Analysis

Output Results Total Installed Cost

Annual Energy Expense Annual Operating Expense Lifetime Operating Expense Payback Period Life

- Cycle Cost

Electricity Prices 

# Life

- Cycle Cost and Payback Period Analysis Inputs59 | Building Technologies Program eere.energy.gov



## Types of Markups in Distribution Chain

 Baseline Markups:

• Markups relate consumer price to cost of goods sold (CGS).

• Baseline markups relate price to cost prior to a change in efficiency.

• Baseline markups indicate a consumer price that covers all of a 

### distributor’s or contractor’s expenses plus profit.

 Incremental Markups:

• Incremental markups relate the incremental change in consumer price to the incremental change in CGS.

• Certain costs, such as direct labor costs (salaries, payroll, rental and occupancy), do not vary with efficiency induced changes in CGS and remain constant in the calculation of incremental markups.



### • Incremental markups cover only expenses that vary with CGS in this case, expenses that increase due to an increase in equipment efficiency. 

# Markups Analysis60 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 7

- 1 DOE welcomes suggestions and comments concerning its proposed approach for developing estimates of retail prices. 

# Markups Analysis61 | Building Technologies Program eere.energy.gov



## Energy Use Determination 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis62 | Building Technologies Program eere.energy.gov



## Energy Use Characterization

 Purpose:

• Develop annual energy use data for the life

- cycle cost and payback period analyses to calculate annual operating costs.

 Method:



### • Develop household samples from DOE

- EIA’s Residential Energy Consumption Survey (RECS) for the six product class to be analyzed in detail in the Engineering Analysis.

• Use RECS data along with Engineering Analysis, CEC, ENERGY STAR data to develop annual energy use on a per

- household basis. 

# Energy Use Characterization

1. Portable, up to 35.00 pints/day
2. Portable, 35.01

– 45.00 pints/day
3. Portable, 45.01

– 54.00 pints/day
4. Portable, 54.01

– 75.00 pints/day 5. Portable, greater than 75.00 pints/day
6. Whole

- home63 | Building Technologies Program eere.energy.gov



## Energy Use Characterization Issues

 Typically, DOE relies on the RECS to estimate the appliance’s annual energy consumption; RECS 2009 has additional, but still limited, information about dehumidifiers.

 DOE will augment the RECS household data with data from the California Energy Commission (CEC), ENERGY STAR, research reports, and possibly NPD Group sales data to estimate a range of annual energy use values and capacities for dehumidifiers.

 Additionally, DOE may rely on in situ field measurements as a means to characterize dehumidifier energy

use.

 Usage Sources from 2007 ANOPR

Source Jan

- Mar Apr May June July Aug Sept Oct Nov

- Dec Annual
Hours/month Hours/year

AHAM Low 0 0 70 210 245 245 70 35 0 875
AHAM Mid 0 14 86 231 288 288 130 58 0 1095 AHAM High 0 37 110 256 329 329 183 73 0 1315

ADL* 0 0 180 360 360 360 180 180 0 1620 Energy Star # 0 0 475 475 475 475 475 475 0 2851

LBNL

- High † 1080 360 360 360 360 360 360 360 720 4320 * Based on peak dehumidification period of three months (at 360 hours/month) with half the usage (180 hours/month) during the remaining three months.

# Based on six

- month operation with 0.66 duty cycle.

† Monthly operation equal to ADL peak dehumidification period. 

# Energy Use Characterization64 | Building Technologies Program eere.energy.gov



## Energy Use Determination Approach 

# Energy Use Characterization65 | Building Technologies Program eere.energy.gov 

# Energy Use Characterization

Request for Comment

Item 6

- 1 DOE seeks stakeholder input on its proposed approaches for specifying typical annual energy consumption. Most importantly, the Department is interested in sources of data that can assist in characterizing the annual energy consumption of dehumidifiers

.

Item 6

- 2 The Department seeks stakeholder input on data sources that it can use to characterize the variability in 

### annual energy consumption for dehumidifiers. The Department is particularly interested in field monitoring studies and data.66 | Building Technologies Program eere.energy.gov



## Life

- Cycle Cost and Payback Analysis 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis67 | Building Technologies Program eere.energy.gov 

## LCC and PBP Analysis Inputs From Engineering Analysis (Price is a Function of Efficiency)

From Markups for Equipment Price Determination Analysis

From Energy Use Characterization Analysis Energy

Consumption

Power Demand Distributor Markup

Sales Tax Mechanical Contractor Markup Consumer Price

Data Inputs

Intermediate Analysis

Output Results Total Installed Cost

Annual Energy Expense Annual Operating Expense Lifetime Operating Expense Payback Period Life

- Cycle Cost

Electricity Prices 

# Life

- Cycle Cost and Payback Period Analysis68 | Building Technologies Program eere.energy.gov 

## Life

- Cycle Cost (LCC) and Payback Period ( PBP)

Analysis Purpose

 Assess the net LCC and PBP for different efficiency levels

.

 LCC equals consumer price plus the sum of annual operating costs discounted to a particular base year.

 Economic evaluation performed from the consumer perspective.

 Analysis implemented in an Excel spreadsheet.



###  Results expressed as LCC difference (baseline minus standard level).

 Simple payback equals the incremental first cost divided by the operating cost savings for 1 year. 

# Life

- Cycle Cost and Payback Period Analysis69 | Building Technologies Program eere.energy.gov 

## Approach

 Monte Carlo simulation analysis to be used.

• Characterize the variability and uncertainty associated with the inputs using probability distributions.

• RECS household samples will be used to characterize the variability in annual energy use and energy prices.

• Probability distributions will be used to characterize the uncertainty in other operating cost inputs (e.g., discount rates, equipment lifetimes) and manufacturing costs.

 One LCC and PBP analysis result per product class.

• Analysis to be conducted for each proposed product class to be 

### analyzed in detail in the Engineering Analysis.

 Base case efficiency distributions developed to avoid overstating the benefits from increasing product efficiency. 

# Life

- Cycle Cost and Payback Period Analysis70 | Building Technologies Program eere.energy.gov 

## Efficiency Distributions Example from Dishwasher LCC Analysis 

# Life

- Cycle Cost and Payback Period Analysis71 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 8

- 1 DOE seeks stakeholder input on the planned approach of using probability distributions and Monte Carlo simulation to conduct the LCC and PBP analysis.

Item 8

- 2 DOE requests data from stakeholders to characterize the current mix of dehumidifier efficiencies in the market. 

# Life

- Cycle Cost and Payback Period Analysis72 | Building Technologies Program eere.energy.gov 

## Electricity Prices

 Electricity prices are used to convert energy use to energy

costs.

 DOE will develop electricity prices from DOE

- Energy Information Administration (EIA) Form 861 data.

 DOE will use the DOE

- EIA Annual Energy Outlook (AEO) for projections of future average energy prices (reference, high, and low scenarios).

 DOE may evaluate other quantitative price projections provided by stakeholders as sensitivities. 

# Life

- Cycle Cost and Payback Period Analysis73 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 8

- 3 DOE seeks stakeholder input on the planned approach for estimating current and projected energy prices. 

# Life

- Cycle Cost and Payback Period Analysis74 | Building Technologies Program eere.energy.gov



## Installation, Maintenance, and Repair Costs

 DOE bases repair costs on annualized costs of key components and frequency of replacement in the field

.
 Typically, small incremental changes in product efficiency incur little or no changes in repair and maintenance costs over baseline products.

 Unless the efficiency increases considered for this rulemaking result in significantly larger or heavier products, DOE expects
that more

- efficient dehumidification products will not incur
increased installation costs. 

# Life

- Cycle Cost and Payback Period Analysis75 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 8

- 4 DOE seeks stakeholder input on whether it is correct to assume that changes in maintenance, repair, and installation costs will be negligible for more

- efficient residential dehumidifiers. If it is incorrect, DOE is interested in the reasons why this is so and in specific ways in which to correct this assumption. 

# Life

- Cycle Cost and Payback Period Analysis76 | Building Technologies Program eere.energy.gov 

## Product Lifetimes

 DOE will use information from available literature sources as well as input from manufacturers and other stakeholders to establish specific dehumidifier lifetimes.



## Request for Comment

Item 8

- 5 DOE seeks stakeholder input on appropriate product lifetimes for dehumidifiers both portable unit and whole



### home. Specifically, DOE seeks data sources for establishing product lifetimes. 

# Life

- Cycle Cost and Payback Period Analysis77 | Building Technologies Program eere.energy.gov 

## Discount Rates

 Discount rates are used to convert streams of annual operating expenses to present value in the LCC analysis.

 DOE will use similar approach as for other residential product standards rulemakings.

• Derived from estimates of the “finance cost” to purchase residential products.

• Finance cost based on:

- Financial cost of any debt incurred to purchase products ( e.g. , credit cards, home equity loans)

- Opportunity cost of any equity to purchase products ( e.g. , stocks, bonds, savings accounts)



### • Federal Reserve Board’s Survey of Consumer Finances is a source of much of the equity and debt data. 

# Life

- Cycle Cost and Payback Period Analysis78 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 8

- 6 DOE seeks stakeholder input on the planned approach for estimating discount rates for residential

consumers. 

# Life

- Cycle Cost and Payback Period Analysis79 | Building Technologies Program eere.energy.gov



## Energy Efficiency in the Base Case

 Share of consumers affected by particular efficiency level captured by projected distributions of product efficiencies in first compliance year under base case.

 When market shares are not available, DOE will base efficiency distributions on available models as a proxy

. 

# Life

- Cycle Cost and Payback Period Analysis80 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 8

- 7 DOE seeks stakeholder input on dehumidifier efficiency in the base case, historical efficiency data on dehumidifiers, and projected trends in dehumidifier efficiency. DOE is especially interested in any data pertaining to whole

- home dehumidifiers. 

# Life

- Cycle Cost and Payback Period Analysis81 | Building Technologies Program eere.energy.gov 

## Shipments Analysis 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis82 | Building Technologies Program eere.energy.gov 

## Shipments Analysis

 Purpose:

• Quantify changes in product shipments due to potential new energy efficiency standards.

 Method :

• The shipments model will rely on a range of data sources.

• The model will only consider shipments of covered products. 

# Shipments Analysis83 | Building Technologies Program eere.energy.gov



## Base

- Case Shipments Projection Approach

 Approach depicts the situation where new standards are not adopted.

 Shipment projection accounts for: (1) product sales to new construction and (2) replacements for failed units.

• New construction product sales

• Replacements

 Historical projections (“backcasts”) calibrated to historical shipments.

 Base

- case projections to be developed for four product categories 

# Shipments Analysis84 | Building Technologies Program eere.energy.gov 

## Residential Dehumidifier Historical Shipments Data

 DOE requests historical shipments data in order to calibrate its base

- case shipments projections

.

Year Shipments, Domestic + Imports (Thousands of Units) Portable Units (pints / day) Whole Home (pints / day) <35 35

– 45 45

- 54 54

- 75 >75

1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011 

# Shipments Analysis85 | Building Technologies Program eere.energy.gov



## Standards Impacts on Shipments

 DOE develops Standards

- Case Projections from the same data it used to develop the Base

- Case Projection.

 Standards

- Case Projections also use purchase price increases and operating cost savings to estimate shipments impacts.

 It is difficult to obtain data showing sensitivity of shipments to purchase price and operating costs.

• DOE may project Standards

- Case shipments projections with scenarios (i.e. specific percentage drops in annual shipments for particular efficiency levels).



###  DOE will consider impacts from market

- pull programs. 

# Shipments Analysis86 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 9

- 1 DOE seeks historical shipments data from stakeholders. If such data are provided, DOE requests that market share data be provided showing the percentage of product shipments in each of the dehumidifier product classes

.

Item 9

- 2 If stakeholders are unable to provide historical shipments data, DOE seeks comment on which data source is more representative of historical shipments, the AHAM shipments data or possible NPD Group sales data.

Item 9

- 3 DOE seeks input on the types of approaches it should use to project base

- case shipments.

Item 9

- 4 DOE also seeks input from other stakeholders on the potential impact of standards on product shipments

.

Item 9

- 5 DOE also requests input on any market

- pull programs that currently exist to promote the adoption of more

- efficient dehumidifiers. 

# Shipments Analysis87 | Building Technologies Program eere.energy.gov 

## 87 National Impact Analysis 

# Preliminary Analysis

Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use

Characterization

Shipments Analysis National Impact Analysis Markups for Product Price Determination Life

- Cycle Cost and Payback Period Analysis

Preliminary Manufacturer Impact Analysis88 | Building Technologies Program eere.energy.gov



## National Impact Analysis

 Purpose:

• Determine the projected national energy savings and consumer national net present value.

 Method :

• Develop annual series of national energy and economic impacts.

• Use the shipments model to estimate the total stock of appliances in service each year.

• Aggregate the costs and energy use per unit in any given year.

• Report estimates for economic impact as change in consumer National Net Present Value (NPV) (in constant year dollars).



### • Account for the time

- value of money through defined discount rates. 

# National Impact Analysis89 | Building Technologies Program eere.energy.gov



## National Energy Savings Flow Diagram 

# National Impact Analysis90 | Building Technologies Program eere.energy.gov 

## National Consumer Net Present Value Flow Diagram 

# National Impact Analysis91 | Building Technologies Program eere.energy.gov 

## Shipment

- Weighted and Market Share Efficiency Data

 Shipment

- weighted efficiency data:

• Key components of the national impact analysis are dependent on shipment

- weighted efficiencies.

- Per

- unit annual energy consumption

— needed to determine NES, NWS.

- Retail price and per

- unit annual operating costs

— needed to determine NPV.



###  Market share efficiency data:

• Historical market share efficiency data help estimate how standards will impact base

- case efficiencies and reveals the distribution of product efficiencies for a given year by product class.

• Market share data (or base

- case efficiency distributions) are requested in the LCC and PBP analysis and will also be used in the national impact analysis.

• Market share data DOE has assumed a “roll up” scenario to project standards impacts in past standards rulemakings. 

# National Impact Analysis92 | Building Technologies Program eere.energy.gov 

### Dehumidifier Historical Shipment

- Weighted Efficiency Data

Portable Units (pints / day) Whole Home <35 35

– 45 45

- 54 54

- 75 >75

Year / Efficiency Level 1.50 1.62 1.60 1.70 1.80 1.70 1.85 2.10 2.47 2.50 2.80 3.50 4.17

1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011 

# National Impact Analysis93 | Building Technologies Program eere.energy.gov



## National Impact Analysis (cont.)

 Full fuel cycle (FFC) measure of energy and greenhouse gas
and other emissions will now be measured in this and future conservation standards rulemakings.

• NEMS will be the model used to determine FFC

• FFC multipliers will be presented and discussed in the preliminary analysis Technical Support Document (TSD). 

# National Impact Analysis94 | Building Technologies Program eere.energy.gov



## Request for Comment

Item 10

- 1 DOE seeks historical SWEF data for dehumidifiers. DOE also seeks historical market share data showing the percentage of product shipments by efficiency level

.

Item 10

- 2 DOE seeks input on its plan to develop NES spreadsheet models for estimating national impacts of amended energy conservation standards for dehumidifiers

. For example, are spreadsheet models still the preferred 

### approach for estimating national impacts? 

# National Impact Analysis95 | Building Technologies Program eere.energy.gov



### 4 3 2

Preliminary Analysis Background

Test Procedure 1 Introduction

5 NOPR Analysis 

## Public Meeting Agenda

6 Closing Remarks96 | Building Technologies Program eere.energy.gov Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Consumer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis Regulatory

Impact Analysis

Engineering Analysis Life

- Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date 

## Consumer Subgroup Analysis 

# NOPR Analysis97 | Building Technologies Program eere.energy.gov



## Consumer Subgroup Analysis

 Purpose:

• Analyze the economic impacts of standards on consumers, including subgroups who may be disproportionately impacted compared with the general user population

. 

###  Method:

• Extend the LCC analysis to examine the impacts for defined subgroups. 

# NOPR Analysis98 | Building Technologies Program eere.energy.gov 

# NOPR Analysis

Request for Comment

Item 11

- 1 DOE requests input as to which consumer subgroups, if any, it should consider when devising standards for residential dehumidifiers.99 | Building Technologies Program eere.energy.gov



## Utility Impact Analysis

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Consumer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis Regulatory

Impact Analysis

Engineering Analysis Life

- Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date 

# NOPR Analysis100 | Building Technologies Program eere.energy.gov



## Utility Impact Analysis

 Purpose:

• Assess the overall impacts on domestic energy supplies that would result from the imposition of standards.

 Method:

• DOE proposes to use NEMS

- BT, a variant of the NEMS (National Energy Modeling System) developed and used by DOE/EIA for their Annual Energy Outlook (AEO) report, as the basis of the Utility Impact Analysis.

• Outputs of the utility impact analysis include projections of electricity sales, price, and avoided capacity resulting from a 

### comparison of base and standards cases.

• DOE will model the energy savings impacts from amended energy conservation standards using NEMS

- BT to generate projections that deviate from the AEO reference case. 

# Utility Impact Analysis101 | Building Technologies Program eere.energy.gov 

# Utility Impact Analysis

Request for Comment

Item 13

- 1 DOE seeks input from stakeholders on its plans to use NEMS

- BT to conduct the utility impact analysis. Examples of the type of input sought by DOE include, but are not limited to, whether the NEMS

- BT model is appropriate for assessing the utility impacts of efficiency standards

— and if not, what would be a more appropriate model to use?102 | Building Technologies Program eere.energy.gov



## Employment Impact Analysis 

# NOPR Analysis

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Consumer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis Regulatory

Impact Analysis

Engineering Analysis Life

- Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date103 | Building Technologies Program eere.energy.gov



## Employment Impact Analysis

 Purpose:

• Assess the overall impact on national employment from the imposition of efficiency standards at differing levels.

• Include both direct and indirect employment impacts.

- Direct employment impacts are estimated in the manufacturer impact analysis.

- Indirect employment impacts result from shifting consumer expenditures among goods and services ( “substitution effect”) and changing equipment and energy costs (“income effect ”).



###  Method:

• DOE intends to use the ImSET (Impact of Sector Energy Technologies) model for the evaluation of indirect employment impacts. 

# Employment Impact Analysis104 | Building Technologies Program eere.energy.gov 

# Employment Impact Analysis

Request for Comment

Item 14

- 1 DOE welcomes feedback on its planned approach for assessing national employment impacts, both direct and indirect, and it is interested in whether other tools or factors should be considered as part of its analysis. If other tools or factors should be considered, please identify them and explain why, and how, they should be integrated into DOE's analysis105 | Building Technologies Program eere.energy.gov 

## Emissions Analysis 

# NOPR Analysis

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Consumer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis Regulatory

Impact Analysis

Engineering Analysis Life

- Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date106 | Building Technologies Program eere.energy.gov 

### Environmental Assessment



##  Purpose:

– Estimate environmental impacts from amended energy conservation standards for dehumidifiers including changes in Full Fuel Cycle (FFC) emissions



##  Method:

– DOE will base the emission factors for FFC on EIA’s Annual Energy 

### Outlook, supplemented by data from other sources. The following emissions are assessed:

– Carbon dioxide (CO 2 )

– Sulfur dioxide (SO 2 )

• SO 2 emissions from affected electric generating units are subject to nationwide and regional emissions cap and trading programs

– Nitrogen oxides (NO x )

• Clean Air Interstate Rule (CAIR) permanently caps NO x emissions in 28 eastern States and DC

– Methane (CH 4 )

– Nitrous Oxide (N 2 O)

– Mercury (Hg) 

# Emissions Analysis

Emissions Analysis107 | Building Technologies Program eere.energy.gov 

# Monetization of Emission Reductions

 DOE intends to use the most current Social Cost of Carbon (SCC) values developed by interagency reviews.

– SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including but not limited to agricultural productivity loss, human health effects, property damage from rising sea level, and changes in the ecosystem.



#  At present, the most recent interagency estimates of the potential global benefits resulting from reduced CO2 emissions in 2015, expressed in 2011$, were $6.1, $25.4, $41.0, and $77.7 per metric ton avoided.

– For emission reductions that occur in later years, these values grow in real terms over time.



#  DOE will also estimate the potential monetary benefit of reduced 

### NO x 

### emissions resulting from the considered standard levels

.108 | Building Technologies Program eere.energy.gov 

# Emissions Analysis and Monetization of Emission Reductions

Request for Comment

Item 15

- 1 DOE seeks input on its plans to use NEMS

- BT to conduct the environmental assessment for the products covered by this rulemaking

.

Item 16

- 1 Are there any other environmental factors the Department should consider in this rulemaking?

Item 16

- 2 Are there other approaches to the emissions 

### analysis that the Department should consider?109 | Building Technologies Program eere.energy.gov



## Regulatory Impact Analysis 

# NOPR Analysis

Manufacturer Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Consumer Subgroup Analysis Revise Preliminary Analysis Emissions Analysis Regulatory

Impact Analysis

Engineering Analysis Life

- Cycle

Cost & Payback Period Analysis National

Impact Analysis Framework Document Preliminary

Analysis NOPR Final Rule Effective

Date110 | Building Technologies Program eere.energy.gov



## Regulatory Impact Analysis

 Purpose:

• Explore the potential for non

- regulatory alternatives to new energy efficiency standards.

 Method:

• Base the assessment on the actual impacts of any such initiatives to date, but consider information presented regarding the impacts that any existing initiative might have in the future. 

# Regulatory Impact Analysis111 | Building Technologies Program eere.energy.gov



### 5 Closing Remarks 

## Public Meeting Agenda

3 2 1

Energy Conservation Standards Introduction

Test Procedure

4 Preliminary and NOPR Analyses112 | Building Technologies Program eere.energy.gov



## Instructions for Submitting Comments

 In all correspondence, please refer to this Residential Dehumidifiers Rulemaking by:

– Docket Number EERE

– 2012

– BT

– STD

– 0027, and/or (RIN) 1904

- AC81

 Email: ResDehumidifier2012STD0027@ee.doe.gov

 Postal Mail: Ms. Brenda Edwards

U.S. Department of Energy Building Technologies Program, Mailstop EE

- 2J 1000 Independence Avenue, SW. Washington, D.C. 20585

- 0121

 Courier: Ms. Brenda Edwards, 950 L’Enfant Plaza, SW., Suite 600

 Phone: (202) 586

- 2945 

# Closing Remarks

Comment period closes October 17, 2012