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 Energy
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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 Remarks
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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 Witkowski
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Opening Remarks

Interested parties who contacted DOE to request 

an opportunity to issue an opening statement may 

speak now.
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4

3

2

Preliminary Analysis

Background

Test Procedure

1 Introduction

5 NOPR Analysis

Public Meeting Agenda

6 Closing Remarks
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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

Introduction
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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 correspond to those in the Framework Document.

• DOE welcomes comments concerning these specific issues and 

any other issues related to the this rulemaking.
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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, 2012
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4

3

2

Preliminary Analysis

Background

Test Procedure

1 Introduction

5 NOPR Analysis

Public Meeting Agenda

6 Closing Remarks
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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 History
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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, 2012
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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 

Analyses1

Energy Conservation 

Standards for 

Residential 

Dehumidifiers

 NOPR1 Final

Rule

1 NOPR: Notice of Proposed Rulemaking

Rulemaking Schedule

2012 2013 2014 2015 2016
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Technological Feasibility and Economic Justification

 New 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 Analysis
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 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 Analysis
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4

3

2

Preliminary Analysis

Background

Test Procedure

1 Introduction

5 NOPR Analysis

Public Meeting Agenda

6 Closing Remarks
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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).
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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 Procedure
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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 Procedure
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4

3

2

Preliminary Analysis

Background

Test Procedure

1 Introduction

5 NOPR Analysis

Public Meeting Agenda

6 Closing Remarks
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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 Analysis
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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 Assessment
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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).
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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.
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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 Assessment
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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 Assessment
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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 Assessment
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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?
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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 technology
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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?
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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).
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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 Analysis
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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 Analysis
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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 Analysis
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Engineering Analysis

 Purpose:

• Determine the relationship between manufacturer 

cost and energy efficiency

Engineering Analysis

Efficiency

Cost
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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/day
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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.
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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 Analysis
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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.
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Request for Comment 

Item 5-4 DOE requests feedback on the use of a designoption approach to determine the relationship between 

manufacturer cost and energy efficiency for residential 

dehumidifiers.

Engineering Analysis
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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 Analysis
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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 Analysis
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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. Units 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/day are excluded.

† The baseline efficiency for the whole home product class is specified as the DOE standard effective October 1, 2012, for dehumidifiers 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

WholeHome

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 4.17
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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 Analysis
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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 Analysis
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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?
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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 Analysis
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Engineering Analysis

Request for Comment

Item 5-7 Are there outside regulatory issues that DOE should 

consider in its analysis of residential dehumidifiers?
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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 

Analysis
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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 Analysis
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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 analysis 
52 | 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 Analysis
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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 netpresent 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 Analysis
54 | 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 Analysis
55 | 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 Analysis
56 | 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 Analysis
57 | 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 

Analysis
58 | Building Technologies Program eere.energy.gov

LCC and PBP Analysis Inputs

Baseline

Manufacturer

Price

Std-Level

Manufacturer

Price

Installation

Cost

From 

Engineering 

Analysis

(Price is a 

Function of 

Efficiency)

From Markups 

for Equipment 

Price 

Determination 

Analysis

Repair Cost

Maintenance

Cost

Lifetime

Discount Rate

Electricity

Price Trend

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 Inputs
59 | 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 Analysis
60 | 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 Analysis
61 | 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 

Analysis
62 | 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-home
63 | 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 Characterization
64 | Building Technologies Program eere.energy.gov

Energy Use Determination Approach

Energy Use Characterization
65 | 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 6-2The 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 

Analysis
67 | Building Technologies Program eere.energy.gov

LCC and PBP Analysis Inputs

Baseline

Manufacturer

Price

Std-Level

Manufacturer

Price

Installation

Cost

From 

Engineering 

Analysis

(Price is a 

Function of 

Efficiency)

From Markups 

for Equipment 

Price 

Determination 

Analysis

Repair Cost

Maintenance

Cost

Lifetime

Discount Rate

Electricity

Price Trend

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
68 | 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 

Analysis
69 | 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 

Analysis
70 | Building Technologies Program eere.energy.gov

Efficiency Distributions Example from Dishwasher LCC 

Analysis

Life-Cycle Cost and Payback Period 

Analysis
71 | 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 

Analysis
72 | 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 

Analysis
73 | 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 

Analysis
74 | 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 

Analysis
75 | 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 

Analysis
76 | 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 wholehome. Specifically, DOE seeks data sources for establishing 

product lifetimes.

Life-Cycle Cost and Payback Period 

Analysis
77 | 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 

Analysis
78 | 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 

Analysis
79 | 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 

Analysis
80 | 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 

Analysis
81 | 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 

Analysis
82 | 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 Analysis
83 | 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 Analysis
84 | 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 

<35 35 – 45 45 (pints / day) -54 54-75 >75

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

Shipments Analysis
85 | 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 Analysis
86 | 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 Analysis
87 | Building Technologies Program 87 eere.energy.gov

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 

Analysis
88 | 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 Analysis
89 | Building Technologies Program eere.energy.gov

National Energy Savings Flow Diagram

National Impact Analysis
90 | Building Technologies Program eere.energy.gov

National Consumer Net Present Value Flow Diagram

National Impact Analysis
91 | 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 Analysis
92 | 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 Analysis
93 | 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 Analysis
94 | 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 Analysis
95 | Building Technologies Program eere.energy.gov

4

3

2

Preliminary Analysis

Background

Test Procedure

1 Introduction

5 NOPR Analysis

Public Meeting Agenda

6 Closing Remarks
96 | 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 Analysis
97 | 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 Analysis
98 | 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 Analysis
100 | 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 Analysis
101 | 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

Date
103 | 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 Analysis
104 | 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 

analysis
105 | 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

Date
106 | 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 (CO2)

– Sulfur dioxide (SO2) 

• SO2 emissions from affected electric generating units are subject to nationwide and regional emissions 

cap and trading programs

– Nitrogen oxides (NOx)

• Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern States and DC

– Methane (CH4)

– Nitrous Oxide (N2O)

– Mercury (Hg)

Emissions Analysis

Emissions Analysis
107 | 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 

NOx 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

Date
110 | 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 Analysis
111 | 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 Analyses
112 | 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