1 | Energy Efficiency and Renewable Energy 

Energy Conservation Standards:

Notice of Proposed Rulemaking

forResidential Dehumidifiers

July 7, 2015

Bryan BerrDepartment of EnBuilding Technolo

EERE–2012–BT–SResDehumidifier2@ee.doe.gov
2

Welcome• Introductions (around the room)

• Role of the Facilitator• Ground Rules

– Speak one at a time.– Say your name for the record – there will be a complete transcrip

meeting.

– Be concise – share the ‘air‐time’.

– Keep the focus here – cell phones on silent; limit sidebar conversa

– Webinar participants turn phone on mute; ‘raise your hand’ to be 

to speak.

• Housekeeping Items• Agenda Review• Opening Remarks
3

Listening Via the Webcast• The Department is broadcasting this meeting live ov

Internet.

• DOE is providing the webcast to accommodate stake

that are unable to attend the public meeting in perso

• The web broadcast allows stakeholders to listen in an

the slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
4

Agenda

9:00 – 9:15 am Introduction

9:15 – 9:45 am Regulatory History, Test Procedures, Rulemaking Ov

Proposed Standards

9:45 – 10:15 am Market and Technology Assessment and Screening

10:15 – 10:30 am Break

10:30 – 11:00 am Engineering Analysis

11:00 – 11:45 pm Markups and Energy Use Analysis11:45 – 12:15 pm Life‐Cycle Cost and Payback Period Analysis

12:15 – 1:30 pm Break for Lunch

1:30 – 2:00 pm Shipments and National Impact Analysis

2:00 – 2:15 pm Break

2:15 – 2:45 pm Manufacturer Impact Analysis

2:45 – 3:15 pm Additional NOPR Analyses3:15 – 3:30 pm Closing Comments and Remarks
5

Purpose of the Public Meeting• Present the procedural and analytical approaches to 

energy conservation standards for residential dehum

• Invite comment on the energy conservation standard

of proposed rulemaking (NOPR) and technical suppo

document (TSD), including DOE’s proposed standard 

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or

statements and raise additional issues for discussion.
6

Issues for Discussion• Issue “boxes” correspond to the list of issues for which th

Department seeks comments.

• The list of issues is in the NOPR, available at:

http://www.regulations.gov/#!documentDetail;D=EERE‐2

0027‐0031

• The deadline for submitting comments is August 3, 2015, 

(ET).

Request for Comment

DOE welcomes comments, data, and information concerning 

NOPR for residential dehumidifiers. Issues that correspond to 

raised in DOE’s published material will be numbered in accor

with that material. Whether invited by an issue box or not,

comments are welcome on any part of DOE’s analysis.
7

Opening Remarks for Standards

Meeting participants are invited to provide open

remarks or statements at this time.
8

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
9

Regulatory History• Energy Policy and Conservation Act of 1975 (EPCA) 

– Amended by National Energy Conservation Policy Act of 19

619, to establish the “Energy Conservation Program for Cer

Equipment.”

• Energy Policy Act of 2005 (EPACT) P.L. 109‐58

– Amended EPCA to establish the initial energy conservation 

dehumidifiers.

• Energy Independence and Security Act of 2007 (EISA

140

– Further amended EPCA to prescribe new energy conservat

for dehumidifiers manufactured on or after October 1, 201

• DOE has published this NOPR in accordance with EP

look‐back provision and other statutory requiremen
10

Definition of Covered Products• EPCA defines a dehumidifier as follows:

The term “dehumidifier” means a self‐contained, electrically op

and mechanically encased assembly consisting of‐

(A) a refrigerated surface (evaporator) that condenses moisture 

atmosphere;(B) a refrigerating system, including an electric motor;

(C) an air‐circulating fan; and

(D) means for collecting or disposing of the condensate.

(42 U.S.C. 6291(34))
11

Energy Conservation Standards History• EPACT established the following energy conservatio

standards for residential dehumidifiers, effective O

2007:

Product Capacity

(pints/day)

Minimum Energy Facto

(liters/kWh)

25.00 or less 1.00

25.01 to 35.00 1.2035.01 to 54.00 1.3054.01 to 74.99 1.50

75.00 or more 2.25
12

Energy Conservation Standards History• EISA established the following (current) energy con

standards for residential dehumidifiers, effective O

2012:

Product Capacity

(pints/day)

Minimum Energy Facto

(liters/kWh)

Up to 35.00 1.35

35.01 to 45.00 1.5045.01 to 54.00 1.6054.01 to 75.00 1.70

Greater than 75.00 2.5
13

DOE Test Procedure• Test Procedure Overview:

– In 2012, DOE established the test procedure currently at 10 

430, subpart B, appendix X (Appendix X), which is used to d

compliance with the current energy conservation standard

– DOE recently issued a final rule to establish a new test proc

CFR part 430, subpart B, appendix X1 (Appendix X1).

– The NOPR analyses are based on the test procedure in App

Compliance with any future amended energy conservation 

would be determined according to Appendix X1.
14

Dehumidifier Standards Rulemaking Timeline

2012 2015 2013 2014 2016 

Milestone D

NOPR Publication June 

NOPR Public Meeting July 7

Comment Period Ends August 
15

Rulemaking Process Overview• New or amended standards must be designed to ach

maximum improvement in energy or water efficienc

technologically feasible and economically justified.

• DOE performs the following analyses to determine

technological feasibility:

EPCA Requirement Corresponding DOE Ana

Technological Feasibility

 Market and Technology Asse

 Screening Analysis

 Engineering Analysis
16

Rulemaking Process Overview

EPCA Factor Corresponding DOE Ana

1. Economic impact on consumers and

manufacturers

• Life‐cycle cost analysis

• Manufacturer impact analys

2. Lifetime operating cost savings • 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 analys

6. Need for national energy conservation • National impact analysis7. Other factors the Secretary considers

relevant

• Emissions analysis• Emissions monetization ana• Utility, employment, and reg

impact analyses

EPCA directs DOE to consider seven factors to determine whether 

amended standards are economically justified. (42 U.S.C 6295(o)(2
17

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
18

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
19

Proposed StandardsThe proposed standards are based on capacity (for portable dehum

case volume (for whole‐home dehumidifiers), and integrated ener

as measured by the Appendix X1 established by the 2015 Test Proc

Rule.

Trial

Standard

Level

(TSL)

Product Class (PC) 1 PC2 PC3 PC4 

Portable

≤ 30.00 pints/day

Portable

30.01 – 45.00

pints/day

Portable

> 45.00

pints/day

Whole‐Home

≤ 8.0 ft3

EL IEF (L/kWh) EL IEF (L/kWh) EL IEF (L/kWh) EL IEF (L/kWh) 

‐‐ 0 0.77 0 0.94 0 2.07 0 1.77 

1 1 1.10 1 1.20 1 2.40 1 2.09 2 2 1.20 2 1.40 2 2.80 1 2.09 3 3 1.30 3 1.60 2 2.80 1 2.09 4 4 1.57 4 1.80 3 3.66 2 2.53 
20

Proposed StandardsThe table below presents the estimated annual energy use values 

with products at the analyzed efficiency levels for each product cla

on the previous slide.

Trial

Standard

Level

(TSL)

Product Class (PC) 1 PC2 PC3 PC4 

Portable

≤ 30.00 pints/day

Portable

30.01 – 45.00

pints/day

Portable

> 45.00

pints/day

Whole‐Home

≤ 8.0 ft3

EL AEU (kWh/year) EL AEU (kWh/year) EL AEU (kWh/year) EL AEU (kWh/year) 

‐‐ 0 720 0 1,030 0 905 0 951 

1 1 505 1 808 1 781 1 809 2 2 463 2 693 2 670 1 809 3 3 428 3 607 2 670 1 809 4 4 355 4 540 3 513 2 671 
21

Rationale for Adopting the Proposed Standard

TSL Benefits Burden

3

• 0.32 quads of energy saved from 2019–2048

• Net benefits of $1.04 billion in NPV at 7%

discount rate and $2.27 billion at 3% discount

rate

• Emission reductions:

‐ 19.3 MMt CO2 valued at up to $1.9 billion

‐ 28.8 kt of NOX valued at up to $0.10 billion

• For all product classes, the average LCC savings

are positive, ranging from $64 to $416

• The payback period ranges from 0.2 years to

2.8 year depending upon product class

• Net decrease in INPV 

18.7% ($34.9 million

residential dehumidi
22

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
23

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
24

Market and Technology AssessmentPurpose• Define product classes

• Characterize the residential dehumidifier industry

• Identify existing regulatory and voluntary efficiency p

• Gather historical shipments and other relevant mark

• Identify technology options for improving efficiencySee chapter 3 of the TSD for further discussion of the m

technology assessment.
25

Market and Technology AssessmentProduct Classes• Due to similarities in construction and trends observ

performance, DOE combined four of the portable de

product classes considered in the preliminary analysproduct classes.

• The proposed standards would apply to the followin

classes for residential dehumidifiers:

Portable Product Classes

Capacity (pints/day)

30.00 or less

30.01 to 45.00

45.01 or more

Whole‐Home Prod

Case Volume (cu

8.0 or les

More than 
26

Request for Comment

Item 1: DOE requests comment on the proposed product clasresidential dehumidifiers: (1) portable, 30.00 pints/day or les

portable, 30.01 to 45.00 pints/day; (3) portable, 45.01 or mor

/day; (4) whole‐home, case volume 8.0 cubic feet or less; and 

whole‐home, case volume more than 8.0 cubic feet.

Market and Technology Assessment
27

Market and Technology AssessmentTechnology Assessment• Purpose

– To develop a preliminary list of technology options that cou

the efficiency of dehumidifiers.

– To examine the list in greater detail, including removing ina

technologies, in subsequent analyses.

• Method

– DOE identified technology options from:

• Technical support documents from previous rulemakings

• Literature review and manufacturer specification sheets

• Product teardowns

• The full list of technologies that DOE identified can b

Chapter 3 of the TSD.
28

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
29

Screening Analysis• Purpose

– To determine which technology options will be considered 

downstream analyses.

• Technology options are “screened out” if they:

– Are not technologically feasible

– Are not practicable to manufacture, install, and service

– Have adverse impacts on equipment utility or availability to 

– Have adverse impacts on health or safety

• Screened‐Out Technologies:

– For portable dehumidifiers with capacity up to 45.00 pints/

• Pre‐cooling air‐to‐air heat exchangers

• Heat pipes

– No technology options screened out for other product clas

• The remaining technology options were considered 

engineering analysis.
30

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
31

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
32

Engineering AnalysisPurpose• Evaluate design options that improve efficien• Characterize manufacturer production cost (M

versus efficiency for higher‐efficiency dehum

Downstream Ana

• Life‐Cycle Cost an

Payback Period A

• National Impact A

• Manufacturer Im

Analysis

Manufacturer Production Cost–

Efficiency Relationship

Manufacturer

Production Cost

Efficiency Level
33

Engineering Analysis ProcessThe engineering analysis for dehumidifiers was condufollows:

1. Select Test Sample

Choose market

representative units

for testing.

2. Product Testing

Conduct testing according

to the DOE test procedure

in Appendix X1

3. Effic

Determi

baseline 

effici

4. T

Perform 

determ

des

manufa

5. Numerical Model

Use a numerical model to

estimate performance and

associated designs beyond

the teardown sample.

6. Cost‐Efficiency Curves

Determine cost‐

efficiency

relationships.
34

Product Selection and Testing• DOE used the same test sample from the preliminary 

for the NOPR analysis.

• 24 portable units (<45 pints/day)

• 13 high‐capacity portable (>45 pints/day) and refrigerant‐o

home units

• 2 refrigerant‐desiccant whole‐home units for testing.

• 20 of the 24 portable units and all high‐capacity and 

home units were tested at the reduced ambient tem(65°F) proposed in the May 2014 Test Procedure NO

• For portable units, these test results are representat

obtained from the new Appendix X1 test procedure.

• For whole‐home units, results were adjusted to refle

different ambient dry‐bulb temperature (73°F) and Ew.c.) in Appendix X1 as compared to the May 2014 p
35

Baseline Efficiency Levels• Where portable product classes were combined , DO

the lower of the two baseline IEF levels that were co

the preliminary analysis.

• DOE modified the whole‐home baseline efficiency le

those analyzed in the preliminary analysis due to the 

temperature and ESP in Appendix X1.

Product Class

(Capacity)

IEF

(L/kWh)

30.00 pints/day or less 0.77

30.01 – 45.00 pints/day 0.94

45.01 pints/day or more 2.07

Product Class

(Case Volume)

8.0 ft3 or less 

More than 8.0 ft3 
36

Incremental Efficiency Levels – Portable

Efficiency

Level Efficiency Level Source

IEF Efficiency Levels (L/kWh

30.00 pints/day

or less

30.01–45.00

pints/day

45

Baseline Baseline with fan‐only operation 0.77 0.94 

1 Baseline with no fan‐only operation 1.10 1.2 

2 Gap Fill 1 1.20 1.4 

3 Gap Fill 2/Max‐Tech 1.30 1.6 

4 Max‐Tech 1.57 1.8 

• DOE revised the max‐tech efficiency levels from the 

analysis to incorporate additional design options bey

observed in its test sample.

• For the combined portable product classes, the inter

efficiency levels from the preliminary analysis were gconsistent.
37

Incremental Efficiency Levels – Whole‐Home• DOE revised the efficiency levels to account for the h

ambient temperature (73°F) and reduced ESP (0.20 icompared to the preliminary analysis.

• DOE further revised the max‐tech efficiency levels fr

preliminary analysis to incorporate additional design beyond those observed in its test sample.

Efficiency Level Efficiency Level Source

IEF Efficiency Levels (L/kWh)

8.0 ft3 or less

(Case Volume)

More than 8.0 

(Case Volume

Baseline Minimum Available 1.77 2.41

1 Gap Fill 1 2.09 2.70

2 Gap Fill 2/Max‐Tech 2.53 3.52

3 Max‐Tech N/A 4.50
38

Request for Comment

Item 2: DOE requests feedback on the efficiency levels considthis analysis. DOE specifically seeks information from interest

parties on whether the revised max‐tech levels, which incorp

savings associated with permanent‐magnet fan motors, are

technologically feasible, and on whether the updated whole‐h

dehumidifier efficiency levels, which account for the updated 

conditions, are appropriate. DOE also seeks comment on pote

utility impacts at any of the analyzed efficiency levels.

Efficiency Levels
39

Product Teardowns• DOE calculated MPCs by disassembling dehumidifier

multiple manufacturers and creating bills of materia

• BOMs describe the product components in detail an

estimates of materials, labor, capital equipment, and 

costs.

• Chapter 5 of the TSD provides additional details on D

teardown and cost model methodology.
40

Engineering AnalysisManufacturing Cost Model

Raw

Materials

Finished

Materials

P

Tea

Sele

Fabrication

Processes

Bill of 

As

Pro

Manu

• Physical teardown analysis

conducted with representativeproducts.

• Bills of material were generated

during the product teardowns

and were entered into the costmodel.

• Cost model generated

manufacturing, material, labor,and overhead costs.
41

Engineering Analysis

Structure/Classification of Manufacturing Cos

Full Manufacturer Selling

Price (MSP)

Non‐Production Cost **

Selling General & Admin. R & D 

Full Manufacturing Production Cost (MPC)*

Direct Labor Direct Material Overhead

Full Manufacturing Production Cost (MPC)*

Direct Labor Direct Material Overhead

Indirect laborIndirect materialMaintenanceDepreciationTaxesInsurance related

to assets

Market research

AdvertisingPOS promotionSales person

compensation &

travelLogistics‐ Warehousing‐ Delivery‐ Record keeping

Costs of

service &staff unitsGeneralcorporatecosts –

comp., etc.

Costsassociate

efforts to 

new or

improvedequipme

productiprocesse

* Tax Reform Act of 1986 essentially requires companies to measure cost of goods sold as the full production cos

** In a company’s income statement, many of these costs are reported as a lump sum, under SG&A expenses.
42

Product Teardowns• Because the preliminary analysis test units spanned 

capacities and efficiencies from multiple manufactur

did not conduct further teardowns for the NOPR.

• As concluded for the preliminary analysis, DOE obse

three design options are used to increase dehumidif

efficiency in each of the product classes for products 

on the market.

– Increasing compressor efficiency– Improving condenser and evaporator performance

– Incorporating a pre‐cooling air‐to‐air heat exchanger

• DOE did not specifically consider the remaining desig

that met the screening criteria for various reasons de

Chapter 5 of the TSD.
43

Numerical Model• To supplement the data points in the teardown samp

the entire range of potential capacities and efficiencused a numerical model to estimate the design chan

necessary to reach different efficiency levels and cap

– The numerical model is based on the MarkN program deve

in the most recent room air conditioners direct final rule (A

– DOE modified the room air conditioner program to set the 

inlet air conditions (typically outdoor air for room air condi

to the evaporator outlet air conditions (typically the indoor 

air conditioners).

– DOE first increased compressor efficiencies, then increased 

exchanger sizes to estimate the changes necessary to reach 

• DOE also estimated the improvements associated w

fan motor efficiencies for products at the max‐tech elevel.
44

Cost‐Efficiency Relationships• Using actual teardowns and estimated manufacturin

modeled units, DOE created cost‐efficiency curves fomajor manufacturer.

• DOE combined manufacturer curves based on estim

share to develop a weighted‐average cost‐efficiency 

each product class.

Weighted Avera

$MPC

Efficiency Leve

Manufacturer Curves

$MPC

Efficiency Level

Manuf. #1Manuf. #2Manuf. #3
45

Cost‐Efficiency RelationshipsIncremental Manufacturer Production Cost Estimates• Costs updated to 2013 dollars.

• $0 incremental cost from baseline to EL1 for portabl

classes ≤45 pints/day represents the elimination of f

operation.1

• For combined portable product classes, costs were a

using market weighting.

• EL4 costs increased due to added technology option

Efficiency

Level

Portable Capacity (pints/day) Whole‐Home Cas

≤ 30.00 30.01‐45.00 > 45.00 ≤ 8.0 

EL1 $‐ $‐ $42.81 $15.30 

EL2 $1.69 $2.39 $53.66 $129.22 EL3 $4.27 $8.07 $120.33 N/A 

EL4 $19.38 $22.42 N/A N/A 

1Note, DOE did not observe fan‐only mode operation for portable units >45.00

pints/day or whole‐home dehumidifiers.
46

Request for Comment

Item 3: DOE requests comment on the determination thatmanufacturers would likely rely on improved compressor effi

and increased heat exchanger sizes to achieve efficiencies bel

max‐tech level, and may incorporate permanent‐magnet mot

further improve efficiency. DOE also requests feedback on the

incremental manufacturer production costs DOE estimated at 

efficiency level.

Engineering Analysis
47

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
48

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
49

Markups Analysis

Total Installed Cost

Payback Period

Lifetime Op

Expen

Energy Consumption

Electricity Prices

Annual Energy

Expense

Repair Costs

Maintenance Costs

Electricity Price

Trend

Annual Operating

Expense

Lifetime

Discount Rates

Customer Price

Installation Cost

From EngineeringAnalysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups

Analysis

Baseline MSP

Std‐level MSP

From EngineeringAnalysisPrice is a function

of efficiency

From Energy UseAnalysis
50 50

• Purpose

– Determine customer prices under a standards scenario base

manufacturer costs.

– Characterize product distribution channels and market segm

– Describe dehumidifier retailer direct costs, expenses, and p

• Output

– Manufacturer markups and baseline and incremental marku

both portable and whole‐home dehumidifiers.

Markups Analysis Markups Analysis

Overview
51

Markups Analysis

• Manufacturer Markups

– DOE used 10‐K reports of dehumidifier manufacturing compan

2008 to 2012.

– DOE assumed baseline dehumidifier units have the same mark

efficient units.

– DOE assumed whole‐home manufacturers have the same mark

portable manufacturing companies. The markup accounts for t

sourcing structure of the lower‐capacity portable segment, in a

the traditional one‐step structure of the whole‐home segment

• Retail Markups for Portable Dehumidifiers

– DOE used U.S. Census Bureau Business Expenses Survey for “Ho

Appliance Stores”

• Distributor Markups for Whole‐home Dehumidifiers

– DOE used 2012 Economic Census industrial cost data.

– DOE derived the baseline and incremental markups for both re

and first time owner markets.
52

Markups MarkupsAnalysis Analysis

• Baseline Markups

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

– Baseline markups relate price to cost prior to a change in ef

– Baseline markups indicate a consumer price that covers all 

distributor’s or contractor’s expenses plus profit.

• Incremental Markups

– Incremental markups relate the incremental change in cons

to the incremental change in CGS.

– Certain costs, such as direct labor costs (salaries, payroll, re

occupancy), do not vary with efficiency induced changes in 

remain constant in the calculation of incremental markups.

– Incremental markups cover only expenses that vary with CG

case, expenses that increase due to an increase in product e

Markup Types
53

Markups Analysis

• DOE applies markups to product MSP to determine th

customer purchase price of analyzed products.

• DOE used baseline and incremental markups, applied 

MSP in the base case, and the incremental difference 

in each standards case for portable and whole‐home

dehumidifiers.

Markup Baseline Incremental

Manufacturer 1.45

Retailer 1.39 1.13Sales Tax 1.071Overall 2.16 1.75

Markup Replacement 

Baseline Incremental B

Manufacturer 1.45 Wholesaler 1.35 1.10 MechanicalContractor 1.53 1.22 GeneralContractor

‐‐ 

Sales Tax 1.071 Overall 3.21 2.08 

Portable Dehumidifiers

Whole‐Home Dehumidifiers
54

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
55

Energy Use Analysis

Total Installed Cost

Payback Period

Lifetime Op

Expen

Energy Consumption

Electricity Prices

Annual Energy

Expense

Repair Costs

Maintenance Costs

Electricity Price

Trend

Annual Operating

Expense

Lifetime

Discount Rates

Customer Price

Installation Cost

From EngineeringAnalysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups

Analysis

Baseline MSP

Std‐level MSP

From EngineeringAnalysisPrice is a function

of efficiency

From Energy UseAnalysis
56

Purpose• Develop annual energy use data for the life‐cycle cost and payb

analyses to calculate annual operating costs.

Method• Develop household samples from DOE‐EIA’s Residential Energy

Consumption Survey (RECS) for the five product classes to be a

• Use research studies, RECS data along with Engineering Analys

develop annual energy use on a per‐household basis.

Energy Use Analysis

Overview
57

Energy Use Analysis

Energy Use Calculation Flow
58

Calculation Flow

Energy Use Analysis

  

   

         Fan Fan 

Dehum ENERGY X kW 

Eff CAP X Year TotalHours ofUse DEH 24 0.473

X

Annual Operating Hours

(hours/year)

Annual Operating Hours

(hours/year)

Dehum

Power (kW)

X

Dehum

Mode (%)

Fan Power

(kW)

X

Fan Mode

(%)

SB Power

(kW)

X

SB Mode

(%)

+ +
59

Energy Use Analysis

Portable

Study / Source Dehumidification Mode Operatin

Average Hours / Year

ADL (1998)AHAM (2005)ENERGY STAR (2006)

ENERGY STAR calculator

The Cadmus Group (2012)

1,6201,0951,6202,8512,160

Willem (2013a) CCB

CCDDNCCBNCCDD

Whole‐HomeWillem (2013b) Whole‐home 

CCB = Climate controlled space, bucket for condensateCCDD = Climate controlled space, direct drain for

condensate

NCCB = Non‐climate controlled space, buck

condensateNCCDD = Non‐climate controlled space, dir

condensate

Energy Use Inputs: Literature Review of Operating 

DOE augmented RECS household data with data from the research studies and compared the researcwith estimates used in the previous standards rulemaking in 2006 to estimate annual hours and a ran

energy use values.Source: AHAM 2006, ENERGY STAR 2006, The Cadmus Group 2012, Willem et al., 2013a, 2013b.
60

Energy Use Analysis

Portable Whole‐Home

≤30.00

Pints/Day

30.01–45.00

Pints/Day

>45.00

Pints/Day

≤8.0 ft3 Case

Volume

>8.0 ft3 Case

Volume

Average

Capacity 21 38 73 56 92

Average Capacity (pints/day) for Dehumidifier Product Classes

Efficiency

Level

Portable Whole‐Home

≤30.00

Pints/Day

30.01–45.00

Pints/Day

>45.00

Pints/Day

≤8.0 ft3 Case

Volume

>8.0 ft3 Case

Volume

Baseline 0.77 0.94 2.07 1.77 2.41

1 1.10 1.20 2.40 2.09 2.702 1.20 1.40 2.80 2.53 3.523 1.30 1.60 3.66 ‐ 4.50

4 1.57 1.80 ‐‐‐

Integrated Energy Factor (L/kWh) for Dehumidifier Product Classes
61

Energy Use Analysis

Mode

Portable Whole‐Home

≤30.00

Pints/Day

30.01–45.00

Pints/Day

>45.00

Pints/Day

≤8.0 ft3 Case

Volume

>8.0 ft

Vol

Dehumidification 35% 35% 35% 50% 50

Fan‐only 6% 6% 6% 0.2% 0.

Standby 58% 58% 58% 49% 49

Percentage of Operating Hours by Mode

Power Demand for Fan and Standby Modes

Mode

Portable (W) Whole‐Home (W)

Min Median Max Min Median M

Fan‐only 21.4 51.2 80.9 50.2 141.7 4

Standby 0.3 1.0 12.3 1.0 4.5 4

Source: Willem et al., 2013a, 2013b.

Source: Willem et al., 2013a, 2013b.
62

Request for Comment

Item 4: DOE requests comments and information relating to inputs to the energy use determination for residential portab

whole‐home dehumidifiers, specifically the fraction of opera

hours and power demand by each mode.

Energy Use Analysis
63

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
64

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
65

Total Installed Cost

Payback Period

Lifetime Op

Expen

Energy Consumption

Electricity Prices

Annual Energy

Expense

Repair Costs

Maintenance Costs

Electricity Price

Trend

Annual Operating

Expense

Lifetime

Discount Rates

Customer Price

Installation Cost

From EngineeringAnalysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups

Analysis

Baseline MSP

Std‐level MSP

From EngineeringAnalysisPrice is a function

of efficiency

From Energy UseAnalysisLife‐Cycle Cost and Payback Period Analysis
66

Life‐Cycle Cost (LCC) and

Payback Period (PBP) Analysis Purpose

• Assess the net LCC and PBP for different efficiency levels compared to 

• LCC equals consumer price plus the sum of annual operating costs dis

particular base year.

• Economic evaluation performed from the consumer perspective.

• Results expressed as LCC difference (baseline minus efficiency standa

• Simple payback equals the incremental first cost divided by the opera

savings for 1 year.

Life‐Cycle Cost and Payback Period Analysis
67

Method

• Monte Carlo simulation analysis used.

‒ Characterize the variability and uncertainty associated with 

using probability distributions.

‒ RECS household samples used to characterize the variabilit

energy use and energy prices.

‒ Probability distributions used to characterize the uncertain

operating cost inputs (e.g., discount rates, product lifetime

manufacturing costs.

• One LCC and PBP analysis result per product class.

‒ Analysis conducted for each proposed product class analyz

in the Engineering Analysis.

• Base case efficiency distributions developed to avoid overstatin

benefits from increasing product efficiency.

Life‐Cycle Cost and Payback Period Analysis
68

Total Installed Cost

• Total Installed Cost = Retail Price + Installation Cost

• Equipment Retail Price = Manufacturing Cost x Markup x Sales Ta

‒ Manufacturing cost vs. efficiency relationships developed in 

Engineering Analysis

‒ Markups and Sales Taxes developed in the Markups to Deter

Equipment Price analysis

• Installation costs represent the labor and materials necessary to 

appliance

‒ DOE did not consider or calculate installation costs for porta

dehumidifiers

‒ Whole‐home dehumidifier installation costs do not vary with 

Life‐Cycle Cost and Payback Period Analysis
69

Lifetime Operating Cost

• Lifetime Operating Cost = f(annual operating cost, lifetime, disco

electricity price trend)

• Annual Operating Cost = Annual Energy Cost + Repair Cost + Ma

• Annual Energy Cost = f(energy use, electricity prices)

‒ Energy use by mode developed in the Energy Use Analysis

‒ Frequency of use by mode developed in the Energy Use Ana

‒ Electricity prices developed from DOE Energy Information A

(EIA) Form 861

Life‐Cycle Cost and Payback Period Analysis
70

Operating Cost Inputs: Electricity Prices

• Electricity prices are used to convert energy use to energy cost

• DOE developed electricity prices from EIA Form 861 data.

• DOE used the DOE‐EIA Annual Energy Outlook (AEO) for projec

future average energy prices (reference, high, and low scenario

Life‐Cycle Cost and Payback Period Analysis
71

Operating Cost Inputs: Electricity Price Trend

• DOE used the AEO for projections of future average energy pric

(reference, high, and low scenarios).

Life‐Cycle Cost and Payback Period Analysis
72

Operating Cost Inputs: Average Residential Electricit

Life‐Cycle Cost and Payback Period Analysis
73

Operating Cost Inputs: Maintenance and Repair C

• DOE bases repair costs on annualized costs of key components 

frequency of replacement in the field.

• Typically, small incremental changes in product efficiency incur 

changes in repair and maintenance costs over baseline product

• DOE did not include maintenance and repair costs differences 

efficiency level.

Life‐Cycle Cost and Payback Period Analysis
74

Operating Cost Inputs: Product Lifetimes

• DOE used information from available literature sources to esta

specific residential dehumidifier lifetimes.

• Average lifetime for portable dehumidifiers: 11 years

• Average lifetime for whole‐home dehumidifiers: 19 years

0%

10%20%30%40%50%60%70%80%90%

100%

Lifetime Dist.for Portable Dehumidifiers

% of Retiring% of Surviving

0%

10%20%30%40%50%60%70%80%90%

100%

Lifetime Dist.for Whole‐home 

Life‐Cycle Cost and Payback Period Analysis
75

Operating Cost Inputs: Discount Rates

• Discount rates are used to convert streams of annual operating 

to present value in the LCC analysis.

• DOE used a similar approach as for other residential product st

rulemakings.

‒ Derived from estimates of the “finance cost” to purchase r

products.

‒ Finance cost based on:

• Financial cost of any debt incurred to purchase products (e.g

cards, home equity loans)

• Opportunity cost of any equity to purchase products (e.g., sto

savings accounts)

‒ Federal Reserve Board’s Survey of Consumer Finances is a s

much of the equity and debt data.

Life‐Cycle Cost and Payback Period Analysis
76

Operating Cost Inputs: Energy Efficiency in the Bas

• Share of consumers affected by particular efficiency level captu

projected distributions of product efficiencies in first complian

under base case.

• When market shares were not available, DOE based efficiency

distributions on available models as a proxy for 2019.

Life‐Cycle Cost and Payback Period Analysis

Efficiency

Level

≤30.00

Pints/Day

30.01–45.00

Pints/Day

>45.00

Pints/Day

≤8.0 ft3 Case

Volume

Market Share (%)

Baseline 11 0 57 75 

1 23 0 20 25 2 0 94 23 0 3 66 2 0 ‐ 40 4 ‐‐ 
77

Request for Comment

Item 5: DOE requests comments, information and data on thcase efficiency distribution for each product class.

Life‐Cycle Cost and Payback Period Analysis
78

LCC Results: Example from the LCC Analysis

Life‐Cycle Cost and Payback Period Analysis
79

Results: Range of LCC Savings for Portable Dehumi

Life‐Cycle Cost and Payback Period Analysis
80

Results: Range of LCC Savings for Whole‐Home Dehu

Life‐Cycle Cost and Payback Period Analysis
81

Request for Comment

Item 6: DOE invites comments and recommendations from inparties on any other aspects related to the Life‐Cycle Cost anPayback Period Analysis.

Life‐Cycle Cost and Payback Period Analysis
82

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
83

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
84

• Purpose

‒ Quantify changes over time in product shipments due to po

new energy efficiency standards.

‒ Estimate the disaggregation of shipments into product clas

how the shipments by product class change over time.

• Method

‒ The shipments model relies on a range of data sources.

‒ The model accounts for replacements and first time owner

Shipments Analysis
85

Historical Shipments &

Market Share by

Product Class

Appliance Lifetime

To

Replacement

Shipments

Shipments by

Product Class

First‐Time

Owners

Shipments Analysis: Modeling Approach
86

Shipments Analysis: Model Inputs

Input Data Source / Description

Historical Shipments (1972 –

2011)

Total dehumidifier shipments data:

‐ AHAM data submittal (1999–2011, 1995–1998

‐ AHAM Factbook 2000 (1989–1994),‐ Appliance Magazine 1982, 1990 and 1993 (197

Shipments by Product Class Market share by product class developed based on 

preliminary analysis phase of the standards rulema

Replacement Portable and whole‐home dehumidifiers lifetime r

function developed from Life‐Cycle Cost Analysis

‐ Average lifetime for portable dehumidifiers = 1

‐ Average lifetime for whole‐home dehumidifier

First‐Time Owners First‐time owners estimated using AEO 2015 hous

projection
87

Shipments Analysis: Base Case vs. Standards C

• Base Case Shipments Projection

– Capture base‐case shipments projection when new standard

adopted.

– Project shipments to account for replacements and new inst– Develop base‐case projections for product classes.

• Standards Case Shipments Projection

– Project shipments for the base case using historical shipmen– Develop standards case projections accounting for purchase 

increases and operating cost savings.

• Shipments average 2.5 million per year over the proje
88

Shipments Analysis

Item 7: DOE requests comments and information relating to inputs to the shipments model, particularly historical shipme

portable and whole‐home dehumidifiers and market share oproduct class.DOE also welcomes stakeholder inputs and estimates on the 

amended standards on future residential dehumidifier shipm

Request for Comment
89

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
90

National Impact Analysis• Purpose

– Determine the projected national energy savings and consu

net present value.

• Method

– Develop annual series of national energy and economic im

– Use the shipments model to estimate the total stock of res

dehumidifiers in service each year.

– Aggregate the costs and energy use per unit in any given ye

– Report estimates for economic impact as change in consum

Net Present Value (NPV) (in constant year dollars).

– Account for the time‐value of money through defined disco
91

National Impact Analysis Process

Shipments Model

National Energy Savings

NationalEconomicImpacts

LCC Analysis Results and Other Inputs

N

Ener

(

N

Net P

(2013 

• National energy savings calculated for period from 2019 ‐ 2048 

• NPV calculated for products shipped over the period from 2019 

years of shipments).

National Impact Analysis
92

National Impact Analysis: National Energy Sav

Base Case

Annual Energy

Consumption

2048

Base Case

Annual Energy

Consumption

2021

Base Case

Annual Energy

Consumption

2020

Base Case

Annual Energy

Consumption

2019

Shipments

Analysis Stand

Case 

Base-Case Projection

Base Case

Annual Energ

Consumption

Base Case

Annual Energy

Consumption

2021

Base Case

Annual Energy

Consumption

2020

Standards Case

Annual Energy

Consumption

2019

Base-Case

Cumulative

Energy Use

Standards-Case 

Cumulative

Energy Use

Site to FFC

Energy

Conversion

National Energy

Savings
93

National Impact Analysis: Net Present Value
94

National Impact Analysis: Shipment‐Weighted Eff

Base Case ≤30.00 Pints/Day 30.01–45.00 Pints/Day >45.00 Pints/Day

Whole‐Home

Dehumidifiers

≤8.0 ft3 Case

Volume

SWIEF

(L/kWh) 1.20 1.42 2.30 1.85 

SWAEU

(kWh/yr) 477 685 826 916 

• Derived base case efficiency distribution in 2019 from the LCC an

• Incorporate future improvements in efficiency and assumed an a

increase in efficiency of 0.25% between 2019 and 2048.

• “Roll up” inefficient equipment but do not affect efficient equipm
95

Input Description

Shipments Annual base case and standards case shipments from the Shipment analys

Total Installed Cost Annual weighted‐average per unit values as a function of efficiency level t

analysis.

Annual Energy Use Annual weighted‐average per unit values as a function of efficiency level t

analysis.

Base‐Case Efficiencies

Shipments‐weighted efficiencies determined for the effective year. Based 

efficiency distribution from LCC analysis. Assumes 0.25% efficiency improv

standards.

Standards‐Case

Forecasted Efficiencies

Roll‐up scenario assumed for determining shipment‐weighted efficiency fo

case.

Energy Prices Average prices and forecasted energy prices from EIA AEO 2015 forecasts 

extrapolation to 2048.

Full Fuel Cycle Multiplier for the primary fuel (electricity) used by dehumidifiers.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Guideline A‐

Present Year Future expenses are discounted to the year 2014.

National Impact Analysis: Inputs
96

National Impact Analysis: Trial Standard Levels

TSL

Portable Whole‐H

≤30.00

pints/day

30.01‐45.00

pints/day

>45.00

pints/day

≤8.0 ft3 Case

Volume

1 1.10 1.20 2.40 2.09 2 1.20 1.40 2.80 2.09 3 1.30 1.60 2.80 2.09 4 1.57 1.80 3.66 2.53 
97

National Impact Analysis: Energy Saving Results

TSL Primary Energy Savings (quads) Full‐Fuel‐Cycle 

Savings (quads)

1 0.07 0.07

2 0.11 0.113 0.31 0.32

4 0.75 0.79
98

National Impact Analysis: Consumer NPV Result

TSL 7% Discount Rate (billion 2013$) 3% Discount Ra

(billion 2013$)

1 0.24 0.50

2 0.37 0.783 1.04 2.27

4 2.13 4.96
99

National Impact Analysis

Item 8: DOE requests comments, information and data on thcase efficiency distribution of dehumidifiers.

DOE also requests comments on the assumption that annual

efficiency improvements of 0.25% per year are appropriate f

base‐case analysis.

Request for Comment
100

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
101

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
102

Purpose:• Assess the impacts of potential energy conservation standards o

manufacturers, including subgroups such as small manufacturers

• Examine the direct employment, manufacturing capacity, and cu

regulatory impacts on the industry

Methodology:• Use Government Regulatory Impact Model (GRIM), a industry di

flow model

– The primary output is Industry Net Present Value (INPV)

– By comparing the no‐standards case INVP to the standards case INPV, DOE i

impacts to manufacturers

• Interview manufacturers to refine inputs to the GRIM, develop s

analyses, and address qualitative issues.

Manufacturer Impact Analysis
103

GRIM Overview
104

• Consumer Confusion

– Concerns over the impact of new test conditions in the DOE d

test procedure on rated capacity.

• Manufacturers expressed that the only way to avoid conf

a potentially large investment to redesign products in ord

maintain the same rated capacities.

• Impacts on Consumer Utility

– Increased product efficiency will increase price to consumers 

come at a cost to other product features, such as size, noise l

performance at low temperatures.

Key Issues
105

• Impacts on Profitability

– Conversion costs could be significant if amended standards re

product platforms.

– Customers are price‐sensitive, so an increase in product cost/

lead to a decrease in profitability either due to a decrease in 

a decrease in per‐unit margins (if manufacturers choose to ab

order to maintain volumes).

• Small Business Impacts

– Amended standards could place a disproportionate burden o

whole‐home dehumidifier manufacturers.

• Fewer human and capital resources than larger, more div

portable unit manufacturers.

• Small business manufacturers of whole‐home products a

disadvantaged in achieving the scale needed to exert pur

power in sourcing components from vendors.

Key Issues
106

• Baseline Manufacturer Markup = 1.45• Manufacturer Markup Scenarios: Change in manufactu

markup reflects the industry’s ability to increase prices investments grow and MPCs increase.

– High Scenario: Preservation of Gross Margin

• Manufacturers maintain the same markup before and afte

standards

– Low Scenario: Preservation of Operating Profit

• Manufacturers reduce markups on minimally compliant p

Markup Scenarios
107

INPV Results

• Preservation of Gross Margin Percentage Markup Scenario (Least Sever

Manufacturers)

• Preservation of Operating Profit Markup Scenario (Most Severe Impact 

Manufacturers)

Units Base Case Trial Standard Level 123 

INPV (2013$ millions) 186.5 184.0 183.4 155.2 

Change in INPV (2013$ millions) ‐ ‐2.5 ‐3.1 ‐31.3 

(%) ‐ ‐1.4% ‐1.6% ‐16.8% 

Product Conversion Costs (2013$ millions) ‐ 3.9 5.1 30.2 

Capital Conversion Costs (2013$ millions) ‐ 1.3 1.7 20.5 Total Conversion Costs (2013$ millions) ‐ 5.2 6.7 50.7 

Units Base Case Trial Standard Level 123 

INPV (2013$ millions) 186.5 183.5 182.1 151.6 

Change in INPV (2013$ millions) ‐ ‐3.0 ‐4.4 ‐34.9 

(%) ‐ ‐1.6% ‐2.4% ‐18.7% 

Product Conversion Costs (2013$ millions) ‐ 3.9 5.1 30.2 

Capital Conversion Costs (2013$ millions) ‐ 1.3 1.7 20.5 Total Conversion Costs (2013$ millions) ‐ 5.2 6.7 50.7 
108

Manufacturer Impact Analysis

Item 9: As part of the MIA, DOE estimates the product and caconversion costs that all manufacturers must make to comply 

potential standards. DOE requests comment on the industry 

conversion costs and industry capital conversion costs necess

dehumidifier manufacturers to comply with the proposed sta

Details of the Manufacturer Impact Analysis can be found in 

12 of the TSD.

Request for Comment
109

Manufacturer Impact Analysis

Item 10: DOE quantitatively assessed the impacts of standarddirect employment. DOE seeks comment on the potential do

employment impacts to dehumidifier manufacturers at the p

efficiency levels.Item 11: DOE considers the impacts on certain manufacturer

subgroups, including small business manufacturers, that hav

different cost structures or operate within different regulato

frameworks in the NOPR stage. DOE requests feedback on su

to analyze and/or characteristics appropriate for subgroup a

Request for Comment
110

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview2 Proposed Standards3 Market and Technology Assessment and Screening4 Engineering Analysis5 Markups and Energy Use Analysis6 Life‐Cycle Cost and Payback Period Analysis7 Shipments and National Impact Analysis8 Manufacturer Impact Analysis9 Additional NOPR Analyses and Closing Remarks
111

NOPR Rulemaking Stage

Market & Technology

ScreeningAnalysis

EngineeringAnalysis

MarkupsAnalysisEnergy Use Analysis

Manufacturer Impact Analysis

NationalImpactAnalysis

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Framework

Document

Final

Rule

Preliminary

Analysis

NOPR
112

Consumer Subgroup Analysis• Purpose

– Evaluate the economic impacts of standards on consumer s

who may be disproportionately impacted compared with t

user population.

• Method

– Identify senior‐only and low‐income households.

• Results

– LCC and PBP results were not appreciably different than fo

population.
113

• Purpose

– Estimate the emissions reductions resulting from amended 

conservation standards.

– Includes estimating considers full‐fuel‐cycle emissions; bot

emissions and “upstream” emissions.

– Includes fugitive methane emissions.

• Method

– Provide from National Impact Analysis an annual time‐serie

savings over the analysis period.

– Use Energy Information Administration’s National Energy M

System (NEMS) to represent the impacts of amended stand

Emissions Analysis
114

Emissions Analysis: Results

TSL 1 TSL 2 TSL 3 

CO2 (million metric tons) 4.27 6.75 19.31 

NOx (thousand tons) 6.33 10.03 28.79 SO2 (thousand tons) 3.56 5.61 15.95 Hg (tons) 0.01 0.02 0.05 N2O (thousand tons) 0.06 0.09 0.26 CH4 (thousand tons) 18.70 29.75 85.88 
115

Emission Monetization Analysis• Use the most current Social Cost of Carbon (SCC) values develo

interagency process.

– SCC is intended to be a monetary measure of the incremental dam

from greenhouse gas (GHG) emissions, including, but not limited 

productivity loss, human health effects, property damage from ris

and changes in the ecosystem.

• Use the most recent (2013) U.S. government interagency estim

SCC for emissions in 2015, per metric ton avoided (in 2013$):

– $12.0 (average value from distribution with a 5% discount rate)

– $40.5 (average value from distribution with a 3% discount rate)

– $62.4 (average value from distribution with a 2.5% discount rate)

– $119 (95th‐percentile value from distribution with a 3% discount 

• Report the SCC in constant dollars as increased over time.

• Monetize the NOx emissions reductions resulting from amende
116

Emission Monetization Analysis: Results

TSL 1 TSL 2 TSL 3 T

CO2 31 to 432 49 to 679 137 to 1,931 328 

NOx 3 % discount

rate

23.3 36.5 103.7 

NOx 7 % discount

rate

10.2 15.9 44.0 

Full Fuel Cycle Emissions Reduction Benefits (million 
117

Utility Impact Analysis• Purpose

– Estimate the changes in electric installed capacity and gene

result from amended energy conservation standards.

• Method

– Provide from National Impact Analysis an annual time‐serie

savings over the analysis period.

– Use Energy Information Administration’s National Energy M

System (NEMS) to represent the impacts of amended stand

• Output

– Reductions in total electricity generation.

– Reductions in primary fuel (e.g. coal, natural gas) consump

– Changes to the mix of electricity generation by fuel type.

– Changes to total installed capacity.
118

Employment Impact Analysis• Purpose

– Estimate the national net impact on jobs as a consequence 

energy conservation standards, including indirect employm

• Method

– Use the ImSET (Impact of Sector Energy Technologies) mod

evaluation of indirect employment impacts; direct employm

to the commercial air conditioning industry are developed 

Manufacturer Impact Analysis.

– Input into ImSET the changes in national equipment and en

expenditures from the National Impact Analysis.

• Results

– Net labor market impacts are negligible over time due to th

magnitude of the short‐term effects.
119

Regulatory Impact Analysis• Purpose

– Investigate the national impacts of non‐regulatory alternat

mandatory amended energy conservation standards.

• Method

– Modify the NIA spreadsheet to analyze the following non‐r

alternatives and their impact on purchase price and energy 

– National Energy Savings and Net Present Value for the non

alternatives.

• No new regulatory action • Manufacturer tax credits

• Consumer rebates • Voluntary efficiency targets

• Consumer tax credits • Bulk government procureme
120

How to Submit Written Comments

In all correspondence, please refer to this rulemaking by:

– Standards for Residential Dehumidifiers

– Docket Number EERE‐2012‐BT‐STD‐0027

– Regulation Identification Number (RIN) 1904‐AC81

Email: ResDehumidifier2012STD0027@ee.doe.gov

Postal: CourierMs. Brenda Edwards Ms. Brenda Edwards

U.S. Department of Energy U.S. Department of Energy

Building Technologies Program, Building Technologies Prog

Mailstop EE‐5B 950 L’Enfant Plaza, SW

1000 Independence Avenue, SW Washington, DC 20024

Washington, DC 20585‐0121 Tel: 202 586‐2945

Comment period closes August 3, 2015, 11:59 P