[6450-01-P]
 

DEPARTMENT OF ENERGY
 

10 CFR Part 430
 

[Docket Number EERE–2007–BT–STD–0010]
 

RIN: 1904–AA89
 

Energy Conservation Program: Energy Conservation Standards for Residential Clothes 

Dryers and Room Air Conditioners 

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

ACTION: Direct Final rule. 

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

standards for various consumer products and commercial and industrial equipment, including 

residential clothes dryers and room air conditioners. EPCA also requires the U.S. Department of 

Energy (DOE) to determine if amended standards for these products are technologically feasible 

and economically justified, and would save a significant amount of energy. In this direct final 

rule, DOE adopts amended energy conservation standards for residential clothes dryers and room 

air conditioners. A notice of proposed rulemaking that proposes identical energy efficiency 

standards is published elsewhere in today’s Federal Register. If DOE receives adverse comment 

and determines that such comment may provide a reasonable basis for withdrawing the direct 

final rule, this final rule will be withdrawn and DOE will proceed with the proposed rule. 

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DATES: The final rule is effective on [INSERT DATE 120 DAYS FROM DATE OF 

PUBLICATION IN THE FEDERAL REGISTER] unless adverse comment is received by 

[INSERT DATE THAT IS 110 DAYS FROM PUBLICATION IN THE FEDERAL 

REGISTER]. If adverse comments are received that DOE determines may provide a reasonable 

basis for withdrawal of the final rule, a timely withdrawal of this rule will be published in the 

Federal Register. If no such adverse comments are received, compliance with the standards in 

this final rule will be required on [INSERT DATE THAT IS 3 YEARS FROM 

PUBLICATION IN THE FEDERAL REGISTER]. 

ADDRESSES: Any comments submitted must identify the direct final rule for Energy 

Conservation Standards for Residential Clothes Dryers and Room Air Conditioners, and provide 

docket number EERE-2007–BT–STD–0010 and/or regulatory information number (RIN) 

number 1904-AA89. Comments may be submitted using any of the following methods: 

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

for submitting comments. 

2. E-mail: home_appliance2.rulemaking@ee.doe.gov. Include the docket number and/or 

RIN in the subject line of the message. 

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

Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC, 20585-0121. If possible, 

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

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

Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, Washington, DC, 20024. 

Telephone: (202) 586-2945. If possible, please submit all items on a CD. It is not necessary to 

include printed copies. 

For detailed instructions on submitting comments and additional information on the rulemaking 

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

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

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

other supporting documents/materials. All documents in the docket are listed in the 

regulations.gov index. Not all documents listed in the index may be publicly available, such as 

information that is exempt from public disclosure. A link to the docket web page can be found at 

www.regulations.gov. 

For further information on how to submit or review public comments or view hard copies 

of the docket in the Resource Room, contact Ms. Brenda Edwards at (202) 586-2945 or email: 

Brenda.Edwards@ee.doe.gov. 

FOR FURTHER INFORMATION CONTACT: 

Stephen L.Witkowski, U.S. Department of Energy, Office of Energy Efficiency and 

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

Washington, DC, 20585-0121, (202) 586-7463, e-mail: stephen.witkowski @ee.doe.gov. 

3 
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of General Counsel, GC-71, 

1000 Independence Avenue, SW., Washington, DC, 20585-0121, (202) 586-7796, e-mail: 

mailto:Elizabeth.Kohl@hq.doe.gov. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. SUMMARY OF THE DIRECT FINAL RULE 9
 

A. The Energy Conservation Standard Levels 9
 

B. Benefits and Costs to Consumerss 11
 

C. Impact on Manufacturers 11
 

D. National Benefits 12
 

E. Conclusion 19
 

II. INTRODUCTION 19
 

A. Authority 19
 

B. Background 26
 

1. Current Standards 26
 

2. History of Standards Rulemaking for Residential Clothes Dryers and Room Air 

Conditioners 28
 

3. Consensus Agreement for Residential Clothes Dryers and Room Air Conditioners 33
 

III. GENERAL DISCUSSION 36
 

A. Test Procedures 36
 

1. Clothes Dryer Test Procedure 40
 

a. Standby Mode and Off Mode 41
 

b. Automatic Cycle Termination 45
 

c. Ventless Clothes Dryers 59
 

d. Consumer Usage Habits 64
 

e. Drum Capacity Measurement 77
 

f. HVAC Effects 77
 

g. Efficiency Metric 78
 

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2. Room Air Conditioner Test Procedure 79
 

a. Standby Mode and Off Mode 79
 

b. Active Mode Referenced Standards 81
 

c. Annual Active Mode Hours 82
 

d. Part-Load Operation 83
 

e. Distribution of Air 85
 

3. Effects of Test Procedure Revisions on the Measured Efficiency 86
 

a. Clothes Dryers 87
 

b. Room Air Conditioners 90
 

B. Technological Feasibility 91
 

1. General 91
 

2. Maximum Technologically Feasible Levels 92
 

a. Clothes Dryers 94
 

b. Room Air Conditioners 94
 

c. Available Max-Tech Products with Higher EER Ratings 97
 

d. Consideration of Conversion to R-410A Refrigerant in Max-Tech Selections 100
 

C. Energy Savings 102
 

1. Determination of Savings 102
 

2. Significance of Savings 103
 

D. Economic Justification 103
 

1. Specific Criteria 103
 

a. Economic Impact on Manufacturers and Consumers 104
 

b. Life-Cycle Costs 105
 

c. Energy Savings 105
 

d. Lessening of Utility or Performance of Products 106
 

e. Impact of Any Lessening of Competition 107
 

f. Need for National Energy Conservation 107
 

g. Other Factors 108
 

2. Rebuttable Presumption 109
 

IV. METHODOLOGY AND DISCUSSION 109
 

A. Market and Technology Assessment 110
 

1. General 110
 

2. Products Included in this Rulemaking 111
 

a. Clothes Dryers 111
 

b. Room Air Conditioners 114
 

3. Product Classes 115
 

a. Clothes Dryers 116
 

b. Room Air Conditioners 117
 

4. Non-Regulatory Programs 124
 

5. Technology Options 125
 

a. Clothes Dryers 126
 

b. Room Air Conditioners 135
 

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B. Screening Analysis 142
 

1. Clothes Dryers 143
 

2. Room Air Conditioners 147
 

C. Engineering Analysis 149
 

1. Technologies Not Analyzed 149
 

a. Clothes Dryers 150
 

b. Room Air Conditioners 151
 

2. Efficiency Levels and Cost-Efficiency Results 152
 

a. Clothes Dryers 152
 

b. Room Air Conditioners 175
 

D. Markups Analysis 188
 

E. Energy Use Analysis 193
 

1. Clothes Dryers 195
 

2. Room Air Conditioners 201
 

F. Life-Cycle Cost and Payback Period Analyses 208
 

1. Product Cost 212
 

2. Installation Cost 214
 

3. Annual Energy Consumption 215
 

4. Energy Prices 215
 

5. Energy Price Projections 217
 

6. Maintenance and Repair Costs 217
 

7. Product Lifetime 219
 

8. Discount Rates 220
 

a. Residential Discount Rates 221
 

b. Commercial Discount Rates 221
 

9. Compliance Date of Amended Standards 222
 

10. Base Case Efficiency Distribution 222
 

11. Inputs to Payback Period Analysis 223
 

12. Rebuttable-Presumption Payback Period 224
 

G. National Impact Analysis–National Energy Savings and Net Present Value Analysis
 

224
 

1. Shipments 228
 

2. Forecasted Efficiency in the Base Case and Standards Cases 229
 

3. National Energy Savings 231
 

4. Net Present Value of Consumer Benefit 234
 

5. Benefits from Effects of Standards on Energy Prices 235
 

H. Consumer Subgroup Analysis 236
 

I. Manufacturer Impact Analysis 237
 

1. Overview 237
 

a. Phase 1, Industry Profile 238
 

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b. Phase 2, Industry Cash Flow Analysis 239
 

c. Phase 3, Sub-Group Impact Analysis 239
 

2. GRIM Analysis 240
 

a. GRIM Key Inputs 241
 

b. GRIM Scenarios 245
 

3. Discussion of Comments 249
 

a. Small Businesses 249
 

b. Cumulative Regulatory Burden 251
 

c. Employment Impacts 254
 

4. Manufacturer Interviews 255
 

a. Clothes Dryer Key Issues 255
 

b. Room Air Conditioner Key Issues 258
 

J. Employment Impact Analysis 263
 

K. Utility Impact Analysis 265
 

L. Environmental Assessment 266
 

M. Monetizing Carbon Dioxide and Other Emissions Impacts 270
 

1. Social Cost of Carbon 271
 

a. Monetizing Carbon Dioxide Emissions 272
 

b. Social Cost of Carbon Values Used in Past Regulatory Analyses 274
 

c. Current Approach and Key Assumptions 276
 

2. Valuation of Other Emissions Reductions 279
 

V. ANALYTICAL RESULTS 281
 

A. Trial Standard Levels 281
 

B. Economic Justification and Energy Savings 284
 

1. Economic Impacts on Individual Consumers 284
 

a. Life-Cycle Cost and Payback Period 284
 

b. Consumer Sub-Group Analysis 288
 

c. Rebuttable Presumption Payback 289
 

2. Economic Impacts on Manufacturers 291
 

a. Industry Cash Flow Analysis Results 291
 

b. Impacts on Employment 307
 

c. Impacts on Manufacturing Capacity 311
 

d. Impacts on Sub-Groups of Manufacturers 313
 

e. Cumulative Regulatory Burden 313
 

3. National Impact Analysis 314
 

a. Significance of Energy Savings 314
 

b. Net Present Value of Consumer Costs and Benefits 316
 

c. Impacts on Employment 321
 

4. Impact on Utility or Performance of Products 322
 

5. Impact of Any Lessening of Competition 323
 

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6. Need of the Nation to Conserve Energy 323 

7. Other Factors 334 

C. Proposed Standards 334 

1. Benefits and Burdens of TSLs Considered for Clothes Dryers 337 

2. Benefits and Burdens of TSLs Considered for Room Air Conditioners 346 

3. Summary of Benefits and Costs (Annualized) of the Standards 356
 

VI. PROCEDURAL ISSUES AND REGULATORY REVIEW 362
 

A. Review Under Executive Orders 12866 and 13563 362
 

B. Review Under the Regulatory Flexibility Act 364
 

1. Residential Clothes Dryer Industry 366
 

2. Room Air Conditioner Industry 367
 

C. Review Under the Paperwork Reduction Act 368
 

D. Review Under the National Environmental Policy Act 369
 

E. Review under Executive Order 13132 370
 

F. Review Under Executive Order 12988 370
 

G. Review Under the Unfunded Mandates Reform Act of 1995 371
 

H. Review Under the Treasury and General Government Appropriations Act, 1999373 

I. Review Under Executive Order 12630 373
 

J. Review Under the Treasury and General Government Appropriations Act, 2001374 

K. Review Under Executive Order 13211 374
 

L. Review Under the Information Quality Bulletin for Peer Review 375
 

M. Congressional Notification 376
 

VII. PUBLIC PARTICIPATION 376
 

A. Submission of Comments 376
 

VIII. APPROVAL OF THE OFFICE OF THE SECRETARY 381 

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I. Summary of the Direct Final Rule 

A. The Energy Conservation Standard Levels 

The Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA or the Act), as 

amended, provides that any amended energy conservation standard DOE prescribes for covered 

products, such as residential clothes dryers (clothes dryers) and room air conditioners, must be 

designed to achieve the maximum improvement in energy efficiency that is technologically 

feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the amended 

standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In 

accordance with these and other statutory provisions discussed in this notice, DOE adopts 

amended energy conservation standards for clothes dryers and room air conditioners as shown in 

Table I-1. The standards apply to all products listed in Table I-1 and manufactured in, or 

imported into, the United States on or after [INSERT DATE 3 years after date of publication in 

the FEDERAL REGISTER]. 

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Table I-1 Amended Energy Conservation Standards for Residential Clothes Dryers and 

Room Air Conditioners 

Residential Clothes Dryers 

Product Class 

Minimum 

CEF 

Levels * 

lb/kWh 

1. Vented Electric, Standard (4.4 ft3 or greater capacity) 3.73 

2. Vented Electric, Compact (120 V) (less than 4.4 ft3 capacity) 3.61 

3. Vented Electric, Compact (240 V) (less than 4.4 ft3 capacity) 3.27 

4. Vented Gas 3.30 

5. Ventless Electric, Compact (240 V) (less than 4.4 ft3 capacity) 2.55 

6. Ventless Electric Combination Washer/Dryer 2.08 

Room Air Conditioners 

Product Class 

Minimum 

CEER 

Levels ** 

Btu/Wh 

1. Without reverse cycle, with louvered sides, and less than 6,000 Btu/h 11.0 

2. Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h 11.0 

3. Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h 10.9 

4. Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h 10.7 

5a. Without reverse cycle, with louvered sides, and 20,000 to 24,999 Btu/h 9.4 

5b. Without reverse cycle, with louvered sides, and 25,000 Btu/h or more 9.0 

6. Without reverse cycle, without louvered sides, and less than 6,000 Btu/h 10.0 

7. Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h 10.0 

8a. Without reverse cycle, without louvered sides, and 8,000 to 10,999 

Btu/h 

9.6 

8b. Without reverse cycle, without louvered sides, and 11,000 to 13,999 

Btu/h 

9.5 

9. Without reverse cycle, without louvered sides, and 14,000 to 19,999 

Btu/h 

9.3 

10. Without reverse cycle, without louvered sides, and 20,000 Btu/h or 

more 

9.4 

11. With reverse cycle, with louvered sides, and less than 20,000 Btu/h 9.8 

12. With reverse cycle, without louvered sides, and less than 14,000 Btu/h 9.3 

13. With reverse cycle, with louvered sides, and 20,000 Btu/h or more 9.3 

14. With reverse cycle, without louvered sides, and 14,000 Btu/h or more 8.7 

15. Casement-only 9.5 

16. Casement-slider 10.4 * CEF (Combined Energy Factor) is calculated as the clothes dryer test load weight in pounds divided by the sum of 

“active mode” per-cycle energy use and “inactive mode” per-cycle energy use in kWh. ** CEER (Combined Energy Efficiency Ratio) is calculated as capacity times active mode hours (equal to 750) 

divided by the sum of active mode annual energy use and inactive mode. 

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B. Benefits and Costs to Consumerss 

Table I-2 presents DOE’s evaluation of the economic impacts of today’s standards on 

consumers of clothes dryers and room air conditioners, as measured by the average life-cycle 

cost (LCC) savings and the median payback period. The average LCC savings are positive for all 

product classes of clothes dryers and room air conditioners for which consumers would be 

impacted by the standards. 

Table I-2 Impacts of Today’s Standards on Consumers of Clothes Dryers and Room Air

Conditioners 

Product Class Average LCC Savings 

(2009$) 

Median Payback Period 

(years) 

Clothes Dryers 

Electric Standard $14 5.3 

Compact 120V $14 0.9 

Compact 240V $8 0.9 

Gas $2 11.7 

Ventless 240V $0 * n/a * 

Ventless Combination 

Washer/Dryer $0 * n/a * 

Room Air Conditioners 

<6,000 Btu/h, with Louvers $7 8.6 

8,000-13,999 Btu/h, with 

Louvers $22 2.8 

20,000-24,999 Btu/h, with 

Louvers $6 4.3 

>25,000 Btu/h, with Louvers $1 10.1 

8,000-10,999 Btu/h, without 

Louvers $13 2.1 

>11,000 Btu/h, without 

Louvers $11 3.7 

* Because the standard level is the same as the baseline efficiency level, no consumers are impacted and therefore 

calculation of a payback period is not applicable. 

C. Impact on Manufacturers 

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

industry from the base year through the end of the analysis period (2011 to 2043). Using a real 

discount rate of 7.2 percent, DOE estimates that the industry net present value (INPV) for 

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manufacturers of clothes dryers is $1,003.6 million in 2009$. Under today’s standards, DOE 

expects that manufacturers may lose 6.4 to 8.0 percent of their INPV, which is $64.5 to -$80.6 

million. Additionally, based on DOE’s interviews with the manufacturers of clothes dryers, DOE 

does not expect any plant closings or significant loss of employment. 

For room air conditioners, DOE estimates that the INPV for manufacturers of room air 

conditioners is $956 million in 2009$ using a real discount rate of 7.2 percent. Under today’s 

standards, DOE expects that manufacturers may lose 11.6 to 18.6 percent of their INPV, which is 

$111.3 to $177.6 million. Additionally, based on DOE’s interviews with the manufacturers of 

room air conditioners, DOE does not expect any plant closings or significant loss of 

employment. 

D. National Benefits 

DOE’s analyses indicate that today’s standards would save a significant amount of 

energy over 30 years (2014–2043)―an estimated 0.39 quads of cumulative energy for clothes 

dryers and 0.31 quads of cumulative energy for room air conditioners. The combined total, 0.70 

quads, is equivalent to three-fourths of the estimated amount of energy used in 2008 to dry 

clothes in all U.S. homes. In addition, DOE expects the energy savings from today’s standards to 

eliminate the need for approximately 0.98 gigawatts (GW) of generating capacity by 2043. 

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

today’s standards in 2009$ ranges from $1.08 billion (at a 7-percent discount rate) to $3.01 

billion (at a 3-percent discount rate) for clothes dryers, and from $0.57 billion (at a 7-percent 

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discount rate) to $1.47 billion (at a 3-percent discount rate) for room air conditioners. This NPV 

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

increased product costs for products purchased in 2014–2043, discounted to 2011. 

In addition, today’s standards would have significant environmental benefits. The energy 

savings would result in cumulative greenhouse gas emission reductions of approximately 36.1 

million metric tons (Mt) of carbon dioxide (CO2) from 2014 to 2043. During this period, the 

1 standards would also result in emissions reductions of approximately 29.3 thousand tons of 

2 nitrogen oxides (NOX) and 0.073 ton of mercury (Hg). DOE estimates that the net present 

monetary value of the CO2 emissions reductions is between $170 and $2,654 million, expressed 

in 2009$ and discounted to 2011. DOE also estimates that the net present monetary value of the 

NOX emissions reductions, expressed in 2009$ and discounted to 2011, is $4.3 to $43.8 million 

3 at a 7-percent discount rate, and $8.9 to $91.7 million at a 3-percent discount rate.

The benefits and costs of today’s standards can also be expressed in terms of annualized 

values. The annualized monetary values are the sum of (1) the annualized national economic 

value, expressed in 2009$, of the benefits from operating the product (consisting primarily of 

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

1 DOE calculates emissions reductions relative to the most recent version of the Annual Energy Outlook (AEO) 

Reference case forecast. As noted in section 15.2.4 of TSD chapter 15, this forecast accounts for regulatory 

emissions reductions through 2008, including the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), 

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

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

appear in the forecast. 

2 Results for NOX and Hg are presented in short tons. One short ton equals 2000 lbs. 3 DOE is aware of multiple agency efforts to determine the appropriate range of values used in evaluating the 

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

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

rulemakings. 

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which is another way of representing consumer NPV, plus (2) the monetary value of the benefits 

4 of emission reductions, including CO2 emission reductions. The value of the CO2 reductions is 

otherwise known as the Social Cost of Carbon (SCC), and is calculated using a range of values 

per metric ton of CO2 developed by a recent interagency process. The monetary benefits of 

emissions reductions are reported in 2009$ so that they can be compared with the other costs and 

benefits in the same dollar units. The derivation of the SCC values is discussed in section IV.M. 

Although adding the value of consumer savings to the values of emission reductions 

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

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

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

assessments of operating cost savings and the SCC are performed with different methods that use 

quite different timeframes for analysis. The national operating cost savings is measured for the 

lifetime of products shipped in 2014–2043. The SCC values, on the other hand, reflect the 

present value of future climate-related impacts resulting from the emission of one metric ton of 

carbon dioxide in each year. These impacts continue well beyond 2100. 

Table I-3 shows the annualized values for the clothes dryer standards. Using a 7-percent 

discount rate and the SCC value of $22.1/ton in 2010 (in 2009$), the cost of the standards for 

clothes dryers in today’s rule is $52.3 million per year in increased equipment costs, while the 

4 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. 

First, DOE calculated a present value in 2011, the year used for discounting the NPV of total consumer costs and 

savings, for the time-series of costs and benefits using discount rates of three and seven percent for all costs and 

benefits except for the value of CO2 reductions. For the latter, DOE used a range of discount rates, as shown in 

Table I.3. From the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in 

2011, that yields the same present value. The fixed annual payment is the annualized value. Although DOE 

calculated annualized values, this does not imply that the time-series of cost and benefits from which the annualized 

values were determined would be a steady stream of payments. 

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annualized benefits are $139.1 million per year in reduced equipment operating costs, $25.0 

million in CO2 reductions, and $0.9 million in reduced NOX emissions. In this case, the net 

benefit amounts to $112.7 million per year. DOE has calculated that the annualized increased 

equipment cost can range from $50.5 to $66.6 million per year depending on assumptions and 

modeling of equipment price trends. The high end of this range corresponds to a constant real 

equipment price trend. Using the central estimate of energy-related benefits, DOE estimates that 

calculated net benefits can range from $98.4 to $114.5 million per year. 

Using a 3-percent discount rate and the SCC value of $22.1/ton in 2010 (in 2009$), the 

cost of the standards for clothes dryers in today’s rule is $55.4 million per year in increased 

equipment costs, while the benefits are $209.1 million per year in reduced operating costs, $25.0 

million in CO2 reductions, and $1.4 million in reduced NOX emissions. In this case, the net 

benefit amounts to $180.1 million per year. DOE has calculated that the annualized increased 

equipment cost can range from $53.1 to $73.5 million per year depending on assumptions and 

modeling of equipment price trends. The high end of this range corresponds to a constant real 

equipment price trend. Using the central estimate of energy-related benefits, DOE estimates that 

calculated net benefits can range from $162.0 to $182.4 million per year. 

Table I-4 shows the annualized values for the room air conditioner standards. Using a 7­

percent discount rate and the SCC value of $22.1/ton in 2010 (in 2009$), the cost of the 

standards for room air conditioners in today’s rule is $107.7 million per year in increased 

equipment costs, while the annualized benefits are $153.7 million per year in reduced equipment 

15 

Comment [A1]: Change recommended by OIRA. 

Comment [A2]: Change recommended by OIRA. 
 

 

 

 

 

 

 

 

 

 

operating costs, $19.5 million in CO2 reductions, and $0.999 million in reduced NOX emissions. 

In this case, the net benefit amounts to $66.4 million per year. 

DOE has calculated that the annualized increased equipment cost can range from $105.7 to 

$136.6 million per year depending on assumptions and modeling of equipment price trends. The 

high end of this range corresponds to a constant real equipment price trend. Using the central 

estimate of energy-related benefits, DOE estimates that calculated net benefits can range from 

$37.5 to $68.4 million per year. 

Using a 3-percent discount rate and the SCC value of $22.1/ton in 2010 (in 2009$), the 

cost of the standards for room air conditioners in today’s rule is $111.0 million per year in 

increased equipment costs, while the benefits are $186.2 million per year in reduced operating 

costs, $19.5 million in CO2 reductions, and $1.20 million in reduced NOX emissions. In this case, 

Comment [A3]: Change recommended by OIRA. 

the net benefit amounts to $95.9 million per yearDOE has calculated that the range in the Deleted: year 

annualized increased equipment cost can range from $108.0 to $146.0 million per year 

depending on assumptions and modeling of equipment price trends. The high end of this range 

corresponds to a constant real equipment price trend. Using the central estimate of energyrelated benefits, DOE estimates that calculated net benefits can range from $60.9 to $98.9 

million per year. . Comment [A4]: Change recommended by OIRA. 

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Table I-3 Annualized Benefits and Costs of Amended Standards (TSL 4) for Clothes 

Dryers Sold in 2014–2043 

Discount Rate 

Primary 

Estimate * Low Estimate * High Estimate * 

Monetized (million 2009$/year) 

Benefits 

Operating Cost Savings 

7% 139.1 120.6 158.3 

3% 209.1 177.4 241.3 

CO2 Reduction at $4.9/t ** 5% 6.0 6.0 6.0 

CO2 Reduction at $22.1/t ** 3% 25.0 25.0 25.0 

CO2 Reduction at $36.3/t ** 2.5% 39.8 39.8 39.8 

CO2 Reduction at $67.1/t ** 3% 76.0 76.0 76.0 

NOX Reduction at 

$2,519/ton ** 

7% 0.9 0.9 0.9 

3% 1.4 1.4 1.4 

Total† 

7% plus CO2 range 146.1 to 216.1 127.6 to 197.6 165.3 to 235.3 

7% 165.0 146.5 184.3 

3% 235.4 203.7 267.6 

3% plus CO2 range 216.5 to 286.5 184.8 to 254.8 248.7 to 318.7 

Costs 

Incremental Product Costs# 7% 52.3 66.6 50.5 

3% 55.4 73.5 53.1 

Net Benefits 

Total† 

7% plus CO2 range 93.7 to 163.7 61.0 to 131.0 114.8 to 184.8 

7% 112.7 79.9 133.8 

3% 180.1 130.2 214.5 

3% plus CO2 range 161.1 to 231.1 111.3 to 181.3 195.6 to 265.6 

* The primary, low, and high estimates utilize forecasts of energy prices and housing starts from the AEO2010 

Reference case, Low Economic Growth case, and High Economic Growth case, respectively. Low estimate 

corresponds to the low net benefit estimate and uses the zero real price trend sensitivity for equipment prices, and 

the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate 

sensitivity for the equipment price trend. 

** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.9, $22.1, and $36.3per metric ton are the averages of SCC distributions calculated using 

5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th 

percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2009$) is the 

average of the low and high values used in DOE’s analysis. 

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

discount rate, which is $22.1/ton in 2010 (in 2007$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

Deleted: 48.8 

Deleted: 55.9 

Deleted: 51.2 

Deleted: 59.6 

Deleted: 78.7 

Deleted: 148.7 

Deleted: 109.4 

Deleted: 179.4 

Deleted: 97.7 

Deleted: 128.3 

Deleted: 152.5 

Deleted: 208.1 

Deleted: 133.6 

Deleted: 203.6 

Deleted: 189.1 

Deleted: 259.1 

Comment [A5]: Change recommended by OIRA. 

17 
 

 

 

 

 

 

 

 

 

 

 

 

 

Table I-4 Annualized Benefits and Costs of Amended Standards (TSL 4) for Room Air 

Conditioners Sold in 2014–2043 

Discount Rate 

Primary 

Estimate * Low Estimate * High Estimate * 

Monetized (million 2009$/year) 

Benefits 

Operating Cost Savings 

7% 153.7 145.1 161.9 

3% 186.2 174.2 197.3 

CO2 Reduction at $4.9/t ** 5% 5.0 5.0 5.0 

CO2 Reduction at $22.1/t ** 3% 19.5 19.5 19.5 

CO2 Reduction at $36.3/t ** 2.5% 30.7 30.7 30.7 

CO2 Reduction at $67.1/t ** 3% 59.4 59.4 59.4 

NOX Reduction at 

$2,519/ton ** 

7% 0.999 0.999 0.999 

3% 1.197 1.197 1.197 

Total† 

7% plus CO2 range 159.6 to 214.0 151.1 to 205.5 167.9 to 222.3 

7% 174.1 165.5 182.4 

3% 206.8 194.9 218.0 

3% plus CO2 range 192.3 to 246.7 180.4 to 234.8 203.5 to 257.9 

Costs 

Incremental Product Costs 

7% 107.7 136.6 105.7 

3% 111.0 146.0 108.0 

Net Benefits 

Total† 

7% plus CO2 range 51.9 to 106.3 43.4 to 97.8 62.2 to 116.6 

7% 66.4 28.9 76.7 

3% 95.9 48.9 110.0 

3% plus CO2 range 81.4 to 135.8 34.4 to 88.8 95.5 to 149.9 

* The primary, low, and high estimates utilize forecasts of energy prices and housing starts from the AEO2010 

Reference case, Low Economic Growth case, and High Economic Growth case, respectively. Low estimate 

corresponds to the low net benefit estimate and uses the zero real price trend sensitivity for equipment prices, while 

the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate 

sensitivity for the equipment price trend. 

** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.9, $22.1, and $36.3 per metric ton are the averages of SCC distributions calculated using 

5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th 

Deleted: 107.7 

Deleted: 107 

Deleted: 111 

Deleted: 111 

Deleted: 60 

Deleted: 114 

Deleted: 57.8 

Deleted: 74 

Deleted: 83 

Deleted: 107 

Deleted: 69 

Deleted: 123 

Deleted: 92 

Deleted: 146 

Comment [A6]: Change recommended by OIRA. 

percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2009$) is the 

average of the low and high values used in DOE’s analysis. 

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

discount rate, which is $22.1/ton in 2010 (in 2009$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

18 
 

 

 

 

 

 

 

 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

E. Conclusion 

Based on the analyses culminating in this final rule, DOE found the benefits to the nation 

of the standards (energy savings, consumer LCC savings, national NPV increase, and emission 

reductions) outweigh the burdens (loss of INPV and LCC increases for some users of these 

products). DOE has concluded that the standards represent the maximum improvement in energy 

efficiency that is technologically feasible and economically justified, and would result in 

significant conservation of energy. DOE further notes that clothes dryers and room air 

conditioners achieving these standard levels are already commercially available. 

II. Introduction 

A. Authority 

Title III of EPCA sets forth a variety of provisions designed to improve energy 

efficiency. Part B of title III (42 U.S.C. 6291–6309) provides for the Energy Conservation 

5 Program for Consumer Products other than Automobiles. The program covers consumer 

products and certain commercial equipment (referred to hereafter as “covered products”), 

including clothes dryers and room air conditioners (42 U.S.C. 6292(a)(2) and (8)), and the Act 

prescribes energy conservation standards for certain clothes dryers (42 U.S.C. 6295(g)(3)) and 

for room air conditioners (42 U.S.C. 6295(c)(1)). EPCA further directs DOE to conduct two 

cycles of rulemakings to determine whether to amend these standards. (42 U.S.C. 6295(c)(2) and 

(g)(4)) As explained in further detail in section II.C, “Background,” this rulemaking represents 

the second round of amendments to both the clothes dryer and room air conditioner standards. 

5 For editorial reasons, upon codification in the U.S. Code, Part B was re-designated Part A. 

19 
 

 

 

 

 

DOE notes that this rulemaking is one of the required agency actions in the consolidated 

Consent Decree in State of New York, et al. v. Bodman et al., 05 Civ. 7807 (LAP), and Natural 

Resources Defense Council, et al. v. Bodman, et al., 05 Civ. 7808 (LAP), DOE is required to 

complete a final rule for amended energy conservation standards for room air conditioners and 

clothes dryers that must be sent to the Federal Register by June 30, 2011. 

Under the Act, DOE’s energy conservation program for covered products consists 

essentially of four parts: (1) testing, (2) labeling, (3) Federal energy conservation standards, and 

(4) certification and enforcement procedures. The Federal Trade Commission (FTC) is 

responsible for labeling, and DOE implements the remainder of the program. The Act authorizes 

DOE, subject to certain criteria and conditions, to develop test procedures to measure the energy 

efficiency, energy use, or estimated annual operating cost of each covered product. (42 U.S.C. 

6293) Manufacturers of covered products must use the DOE test procedure as the basis for 

certifying to DOE that their products comply with applicable energy conservation standards 

adopted under EPCA and for representing the efficiency of those products. (42 U.S.C. 6293(c) 

and 6295(s)) Similarly, DOE must use these test procedures to determine whether the products 

comply with standards adopted under EPCA. Id. The test procedures for clothes dryers and room 

air conditioners appear at title 10 Code of Federal Regulations (CFR) part 430, subpart B, 

appendices D and F, respectively. 

EPCA provides criteria for prescribing amended standards for covered products. As 

indicated above, any amended standard for a covered product must be designed to achieve the 

20 
 

 

 

 

 

 

 

 

 

 

maximum improvement in energy efficiency that is technologically feasible and economically 

justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, EPCA precludes DOE from adopting any 

standard that would not result in significant conservation of energy. (42 U.S.C. 6295(o)(3)) 

EPCA also provides that, in determining whether a standard is economically justified, DOE must 

determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) 

DOE must do so after receiving comments on the proposed standard and by considering, to the 

greatest extent practicable, the following seven factors: 

1. The economic impact of the standard on manufacturers and consumers of the products 

subject to the standard; 

2. The savings in operating costs throughout the estimated average life of the covered 

products in the type (or class) compared to any increase in the price, initial charges, or 

maintenance expenses for the covered products that are likely to result from the imposition of the 

standard; 

3. The total projected amount of energy savings likely to result directly from the 

imposition of the standard; 

4. Any lessening of the utility or the performance of the covered products likely to result 

from the imposition of the standard; 

5. The impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard; 

6. The need for national energy conservation; and 

7. Other factors the Secretary considers relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII)) 

21 
 

 

 

 

 

 

 

 

 

 

 

 

The Energy Independence and Security Act of 2007 (EISA 2007; Pub. L. 110-140) Deleted: EPCA allows DOE 

amended EPCA, in relevant part, to grant DOE authority to issue a final rule (hereinafter referred 

to as a “direct final rule”) establishing an energy conservation standard on receipt of a statement 

submitted jointly by interested persons that are fairly representative of relevant points of view 

(including representatives of manufacturers of covered products, States, and efficiency 

advocates) as determined by the Secretary, that contains recommendations with respect to an 

energy conservation standard that are in accordance with the provisions of 42 U.S.C. 6295(o). A 

notice of proposed rulemaking (NOPR) that proposes an identical energy efficiency standard 

must be published simultaneously with the final rule, and DOE must provide a public comment 

period of at least 110 days on this proposal. 42 U.S.C. 6295(p)(4). Not later than 120 days after 

issuance of the direct final rule, if one or more adverse comments or an alternative joint 

recommendation are received relating to the direct final rule, the Secretary must determine 

whether the comments or alternative recommendation may provide a reasonable basis for 

withdrawal under 42 U.S.C. 6295(o) or other applicable law. If the Secretary makes such a 

determination, DOE must withdraw the direct final rule and proceed with the simultaneously 

published notice of proposed rulemaking. DOE must publish in the Federal Register the reason 

why the direct final rule was withdrawn. Id. 

The Consent Decree in State of New York, et al. v. Bodman et al., described above, 

defines a “final rule” to have the same meaning as in 42 U.S.C. 6295(p)(4) and defines “final 

action” as a final decision by DOE. As this direct final rule is issued under authority at 42 

U.S.C. 6295(p)(4) and constitutes a final decision by DOE which becomes legally effective 120 

days after issuance, absent an adverse comment that leads the Secretary to withdraw the direct 

Deleted: . 42 U.S.C. 6295(p)(4). 

Deleted: DOE 

Deleted: DOE 

22 
 

 

 

 

 

 

 

final rule, DOE asserts that issuance of this direct final rule on or before the date required by the 

court constitutes compliance with the Consent Decree in State of New York, et al. v. Bodman et 

al. 

Furthermore, EPCA contains what is commonly known as an “anti-backsliding” 

provision, which mandates that the Secretary not prescribe any amended standard that either 

increases the maximum allowable energy use or decreases the minimum required energy 

efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe a 

new standard if interested persons have established by a preponderance of the evidence that the 

standard is likely to result in the unavailability in the United States of any covered product type 

(or class) with performance characteristics, features, sizes, capacities, and volumes that are 

substantially the same as those generally available in the United States. (42 U.S.C. 6295(o)(4)) 

EPCA also establishes a rebuttable presumption that a standard is economically justified 

if the Secretary finds that the additional cost to the consumer of purchasing a product complying 

with an energy conservation standard level will be less than three times the value of the energy 

savings during the first year that the consumer will receive as a result of the standard, as 

calculated under the applicable test procedure. 42 U.S.C. 6295(o)(2)(B)(iii). 

EPCA requires DOE to specify a different standard level than that which applies 

generally to a type or class of products for any group of covered products that have the same 

function or intended use if DOE determines that products within such group (A) consume a 

different kind of energy from that consumed by other covered products within such type (or 

23 
 

 

 

 

 

 

class); or (B) have a capacity or other performance-related feature which other products within 

such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 

6295(q)(1)) In determining whether a performance-related feature justifies such a different 

standard for a group of products, DOE must consider such factors as the utility to the consumer 

of the feature and other factors DOE deems appropriate. Id. Any rule prescribing such a standard 

must include an explanation of the basis on which such higher or lower level was established. 

(42 U.S.C. 6295(q)(2)) 

Federal energy conservation requirements for covered products generally supersede state 

laws or regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 

6297 (a)–(c)) DOE can, however, grant waivers of Federal preemption for particular state laws or 

regulations, in accordance with the procedures and other provisions of section 327(d) of the Act. 

(42 U.S.C. 6297(d)) 

EPCA also requires that energy conservation standards address standby mode and off 

mode energy use. Specifically, when DOE adopts a standard for a covered product after July 1, 

2010 it must, if justified by the criteria for adoption of standards in section 325(o) of EPCA, 

incorporate standby mode and off mode energy use into the standard, if feasible, or adopt a 

separate standard for such energy use for that product. (42 U.S.C. 6295(gg)) As set forth below, 

the standards for clothes dryers and room air conditioners at 10 CFR 430.32 (h) and (b) are 

minimum energy factors (EF) and minimum energy efficiency ratios (EER), respectively. 

Neither of these metrics incorporates standby or off mode energy use, with the limited exception 

that the EF in appendix D addresses the energy use of pilot lights in gas clothes dryers. (DOE 

24 
 

 

 

 

 

 

 

 

 

 

 

 

notes that standing pilot lights were prohibited by EPCA for products manufactured after January 

1, 1988. As a result, the final amended test procedure, published on January 6, 2011, eliminates 

measurement of the energy use of such pilot lights. Similarly, DOE does not incorporate the 

energy use of pilot lights in the metric for gas clothes dryers established in this final rule.) By 

contrast, the standard levels DOE considered in this direct final rule are expressed in terms of the 

“combined energy factor” (CEF) for clothes dryers and the “combined energy efficiency ratio” 

(CEER) for room air conditioners, and each of these metrics incorporates energy use in all 

modes, including the standby and off modes. DOE uses these metrics in the standards it adopts in 

this direct final rule. 

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued on 

January 18, 2011 (76 FR 3281, Jan. 21, 2011). EO 13563 is supplemental to and explicitly 

reaffirms the principles, structures, and definitions governing regulatory review established in 

Executive Order 12866. To the extent permitted by law, agencies are required by Executive 

Order 13563 to: (1) propose or adopt a regulation only upon a reasoned determination that its 

benefits justify its costs (recognizing that some benefits and costs are difficult to quantify); (2) 

tailor regulations to impose the least burden on society, consistent with obtaining regulatory 

objectives, taking into account, among other things, and to the extent practicable, the costs of 

cumulative regulations; (3) select, in choosing among alternative regulatory approaches, those 

approaches that maximize net benefits (including potential economic, environmental, public 

health and safety, and other advantages; distributive impacts; and equity); (4) to the extent 

feasible, specify performance objectives, rather than specifying the behavior or manner of 

25 
 

 

 

 

 

 

 

 

 

 

 

 

 

compliance that regulated entities must adopt; and (5) identify and assess available alternatives 

to direct regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can be 

made by the public. 

We emphasize as well that Executive Order 13563 requires agencies “to use the best 

available techniques to quantify anticipated present and future benefits and costs as accurately as 

possible.” In its guidance, the Office of Information and Regulatory Affairs has emphasized that 

such techniques may include “identifying changing future compliance costs that might result 

from technological innovation or anticipated behavioral changes.” For the reasons stated in the 

preamble, DOE believes that today’s direct final rule is consistent with these principles, 

including that, to the extent permitted by law, agencies adopt a regulation only upon a reasoned 

determination that its benefits justify its costs and select, in choosing among alternative 

regulatory approaches, those approaches that maximize net benefits. 

Consistent with EO 13563, and the range of impacts analyzed in this rulemaking, the 

energy efficiency standard adopted herein by DOE achieves maximum net benefits. 

B. Background 

1. Current Standards 

In a final rule published on May 14, 1991, DOE prescribed the current Federal energy 

conservation standards for clothes dryers manufactured on or after May 14, 1994. 56 FR 22250. 

This rule completed the first of the two rulemakings required under 42 U.S.C. 6295(g)(4) to 

consider amending the standards for clothes dryers. The current standards consist of four 

Comment [A7]: Change recommended by OIRA. 

26 
 

 

 

 

 

 

 

 

 

minimum EFs, expressed in pounds of clothing load (lb) per kilowatt-hour (kWh), one for gas 

dryers and one each for three different types of electric dryers. 10 CFR 430.32(h). These 

standards are set forth in Table II.1 below. 

Table II.1 Residential Clothes Dryer Current Energy Conservation Standards 

Product Class EF lb/kWh 

Electric, Standard (4.4 cubic feet (ft3) or greater capacity) 3.01 

Electric, Compact (120 V) (less than 4.4 ft3 capacity) 3.13 

Electric, Compact (240 V) (less than 4.4 ft3 capacity) 2.90 

Gas 2.67 

In a final rule published on September 24, 1997, DOE prescribed the current Federal 

energy conservation standards for room air conditioners manufactured on or after October 1, 

2000. 62 FR 50122. This rule completed the first of the two rulemakings required under 42 

U.S.C. 6295(c)(2) to consider amending the standards for room air conditioners. The current 

standards consist of minimum EERs, expressed as cooling capacity in British thermal units (Btu) 

per hour (h) divided by electrical input power in watts (W), that vary depending on the size of 

the room air conditioner, whether it has louvered sides and a heating cycle, and whether it is for 

casement installations. 10 CFR 430.32(b). These standards are set forth in Table II.2 below. 

27 
 

 

 

 

 

 

 

 

 

 

 

 

 

Table II.2 Room Air Conditioner Current Energy Conservation Standards 

Product Class 

EER 

Btu/Wh 

Without reverse cycle, with louvered sides, and less than 6,000 Btu/h 9.7 

Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h 9.7 

Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h 9.8 

Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h 9.7 

Without reverse cycle, with louvered sides, and 20,000 Btu/h or more 8.5 

Without reverse cycle, without louvered sides, and less than 6,000 Btu/h 9.0 

Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h 9.0 

Without reverse cycle, without louvered sides, and 8,000 to 13,999 Btu/h 8.5 

Without reverse cycle, without louvered sides, and 14,000 to 19,999 Btu/h 8.5 

Without reverse cycle, without louvered sides, and 20,000 Btu/h or more 8.5 

With reverse cycle, with louvered sides, and less than 20,000 Btu/h 9.0 

With reverse cycle, without louvered sides, and less than 14,000 Btu/h 8.5 

With reverse cycle, with louvered sides, and 20,000 Btu/h or more 8.5 

With reverse cycle, without louvered sides, and 14,000 Btu/h or more 8.0 

Casement-Only 8.7 

Casement-Slider 9.5 

2. History of Standards Rulemaking for Residential Clothes Dryers and Room Air Conditioners 

EPCA prescribes energy conservation standards for clothes dryers and for room air 

conditioners, consisting of a requirement that gas clothes dryers manufactured after January 1, 

1988 not be equipped with constant burning pilots and performance standards (minimum EER 

levels) for room air conditioners. (42 U.S.C. 6295(c)(1) and (g)(3)) These amendments also 

required, for both products, that DOE conduct two cycles of rulemakings to determine whether to 

amend these standards. (42 U.S.C. 6295(c)(2) and (g)(4)) As indicated above, DOE completed 

the first of these rulemaking cycles for clothes dryers in 1991, by adopting performance 

standards for gas and electric products. DOE completed the first of these rulemaking cycles for 

room air conditioners in 1997 by adopting amended minimum EER levels. 

DOE initiated this rulemaking on October 9, 2007 by publishing a notice announcing the 

availability of the framework document, the “Energy Conservation Standards Rulemaking 

28 
 

 

 

 

 

 

Framework Document for Residential Clothes Dryers and Room Air Conditioners.” In this 

notice, DOE also announced a public meeting and requested public comment on the matters 

raised in the framework document. 72 FR 57254 (October 9, 2007). The framework document 

describes the procedural and analytical approaches that DOE anticipated using to evaluate energy 

conservation standards for clothes dryers and room air conditioners, and identified various issues 

to be resolved in conducting this rulemaking. The framework document is available at 

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

DOE held the public meeting on October 24, 2007 to present the contents of the 

framework document, describe the analyses it planned to conduct during the rulemaking, seek 

comments from interested parties on these subjects, and, in general, inform interested parties 

about, and facilitate their involvement in, the rulemaking. Interested parties discussed the 

following major issues at the public meeting: test procedure revisions; product classes; 

technology options; approaches to the engineering, life-cycle cost, payback period and national 

impact analyses; efficiency levels analyzed in the engineering analysis; and the approach for 

estimating typical energy consumption. At the meeting and during the period for commenting on 

the framework document, DOE received many comments that helped it identify and resolve 

issues involved in this rulemaking. 

DOE then gathered additional information and performed preliminary analyses to help 

develop potential energy conservation standards for clothes dryers and room air conditioners. 

This process culminated in DOE’s announcement of the availability of its preliminary technical 

support document (preliminary TSD) and another public meeting to discuss and receive 

29 
 

 

 

 

 

 

comments on the following matters: the product classes DOE planned to analyze; the analytical 

framework, models, and tools that DOE was using to evaluate standards; the results of the 

preliminary analyses performed by DOE; and potential standard levels that DOE could consider. 

75 FR 7987 (Feb. 23, 2010) (the February 2010 notice). DOE also invited written comments on 

the preliminary analysis. Id. (The preliminary TSD is available at 

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

.html.) DOE also stated its interest in receiving views concerning other relevant issues that 

participants believe would affect energy conservation standards for clothes dryers or room air 

conditioners. Id. at 7990. 

The preliminary TSD provided an overview of the activities DOE undertook in 

developing standards for clothes dryers and room air conditioners, and discussed the comments 

DOE received in response to the framework document. It also described the analytical 

framework that DOE uses in this rulemaking, including a description of the methodology, the 

analytical tools, and the relationships among the various analyses that are part of the rulemaking. 

The preliminary TSD presented and described in detail each analysis DOE performed, including 

descriptions of inputs, sources, methodologies, and results. These analyses were as follows: 

• A market and technology assessment addressed the scope of this rulemaking, identified 

the potential classes for clothes dryers and room air conditioners, characterized the markets for 

these products, and reviewed techniques and approaches for improving their efficiency. 

30 
 

 

• A screening analysis reviewed technology options to improve the efficiency of clothes 

dryers and room air conditioners, and weighed these options against DOE’s four prescribed 

screening criteria. 

• An engineering analysis estimated the manufacturer selling prices (MSPs) associated 

with more energy-efficient clothes dryers and room air conditioners. 

• An energy use analysis estimated the annual energy use of clothes dryers and room air 

conditioners. 

• A markups analysis converted estimated MSPs derived from the engineering analysis to 

consumer prices. 

• A life-cycle cost analysis calculated, for individual consumers, the discounted savings 

in operating costs throughout the estimated average life of each product, compared to any 

increase in installed costs likely to result directly from the imposition of a given standard. 

• A payback period (PBP) analysis estimated the amount of time it takes individual 

consumers to recover the higher purchase expense of more energy efficient products through 

lower operating costs. 

31 
 

 

 

 

 

 

 

 

• A shipments analysis estimated shipments of clothes dryers and room air conditioners 

over the time period examined in the analysis, and was used in performing the national impact 

analysis (NIA). 

• A national impact analysis assessed the national energy savings (NES), and the national 

net present value of total consumer costs and savings, expected to result from specific, potential 

energy conservation standards for clothes dryers and room air conditioners. and 

• A preliminary manufacturer impact analysis (MIA) took the initial steps in evaluating 

the effects on manufacturers of new amended energy conservation standards. 

The public meeting announced in the February 2010 notice took place on March 16, 

2010. At this meeting, DOE presented the methodologies and results of the analyses set forth in 

the preliminary TSD. Major topics discussed at the meeting included test procedure revisions; 

product classes (including ventless clothes dryers) ; integrated efficiency levels; the use of 

alternate refrigerants in room air conditioners; engineering analysis tools; mark-ups; field energy 

consumption; life-cycle cost inputs; efficiency distribution forecasts; national impact analysis 

inputs; and trial standard level selection criteria. DOE also discussed plans for conducting the 

NOPR analyses. The comments received since publication of the February 2010 notice, 

including those received at the March 2010 public meeting, have contributed to DOE’s proposed 

resolution of the issues in this rulemaking. This direct final rule responds to the issues raised in 

the comments received. 

32 
 

 

 

 

 

 

 

3. Consensus Agreement for Residential Clothes Dryers and Room Air Conditioners 

In response to the preliminary analysis, DOE received the “Agreement on Minimum Deleted: also 

Federal Efficiency Standards, Smart Appliances, Federal Incentives and Related Matters for 

Specified Appliances” (the “Joint Petition”), a comment submitted by groups representing 

manufacturers (the Association of Home Appliance Manufacturers (AHAM), Whirlpool 

Corporation (Whirlpool), General Electric Company (GE), Electrolux, LG Electronics, Inc. 

(LG), BSH Home Appliances (BSH), Alliance Laundry Systems (ALS), Viking Range, SubZero Wolf, Friedrich A/C, U-Line, Samsung, Sharp Electronics, Miele, Heat Controller, AGA 

Marvel, Brown Stove, Haier, Fagor America, Airwell Group, Arcelik, Fisher & Paykel, 

Scotsman Ice, Indesit, Kuppersbusch, Kelon, and DeLonghi); energy and environmental 

advocates (American Council for an Energy Efficient Economy (ACEEE), Appliance Standards 

Awareness Project (ASAP), Natural Resources Defense Council (NRDC), Alliance to Save 

Energy (ASE), Alliance for Water Efficiency (AWE), Northwest Power and Conservation 

Council (NPCC), and Northeast Energy Efficiency Partnerships (NEEP)); and consumer groups 

(Consumer Federation of America (CFA) and the National Consumer Law Center (NCLC)) 

(collectively, the “Joint Petitioners”). This collective set of comments, which DOE refers to in 

6 this notice as the “Joint Petition” or “Consensus Agreement” recommends specific energy 

conservation standards for residential clothes dryers and room air conditioners that, in the 

commenters’ view, would satisfy the EPCA requirements in 42 U.S.C. 6295(o). DOE has 

considered the recommended energy conservation standards in today’s final rule. 

6 DOE Docket No. EERE–2007–BT–STD–0010, Comment 35. DOE considered the Joint Petitioners comments to 

supersede earlier comments by the listed parties regarding issues subsequently discussed in the Joint Petition. 

33 
 

 

 

 

 

 

 

 

After careful consideration of the joint comment containing a consensus recommendation 

for amended energy conservation standards for clothes dryers and room air conditioners, the 

Secretary has determined that this “Consensus Agreement” has been submitted by interested 

persons who are fairly representative of relevant points of view on this matter. Congress 

provided some guidance within the statute itself by specifying that representatives of 

manufacturers of covered products, States, and efficiency advocates are relevant parties to any 

consensus recommendation. (42 U.S.C. 6295(p)(4)(A)) As delineated above, the Consensus 

Agreement was signed and submitted by a broad cross-section of the manufacturers who produce 

the subject products, their trade associations, and environmental, energy-efficiency and 

consumer advocacy organizations. Although States were not signatories to the Consensus 

Agreement, they did not express any opposition to it. Moreover, DOE does not read the statute 

as requiring absolute agreement among all interested parties before the Department may proceed 

with issuance of a direct final rule. By explicit language of the statute, the Secretary has 

discretion to determine when a joint recommendation for an energy or water conservation 

standard has met the requirement for representativeness (i.e., “as determined by the Secretary”). 

Accordingly, DOE will consider each consensus recommendation on a case-by-case basis to 

determine whether the submission has been made by interested persons fairly representative of 

relevant points of view. 

Pursuant to 42 U.S.C. 6295(p)(4), the Secretary must also determine whether a jointlysubmitted recommendation for an energy or water conservation standard is in accordance with 

42 U.S.C. 6295(o) or 42 U.S.C. 6313(a)(6)(B), as applicable. This determination is exactly the 

type of analysis which DOE conducts whenever it considers potential energy conservation 

34 
 

 

 

 

 

 

 

 

 

standards pursuant to EPCA. DOE applies the same principles to any consensus 

recommendations it may receive to satisfy its statutory obligation to ensure that any energy 

conservation standard that it adopts achieves the maximum improvement in energy efficiency 

that is technologically feasible and economically justified and will result in significant 

conservation of energy, Upon review, the Secretary determined that the Consensus Agreement 

submitted in the instant rulemaking comports with the standard-setting criteria set forth under 42 

U.S.C. 6295(o). Accordingly, the consensus agreement levels were included as TSL 4 in today’s 

rule for both clothes dryers and room air conditioners, the details of which are discussed at 

relevant places throughout this document. 

In sum, as the relevant criteria under 42 U.S.C. 6295(p)(4) have been satisfied, the 

Secretary has determined that it is appropriate to adopt amended energy conservation standards 

for clothes dryers and room air conditioners through this direct final rule 

As required by the same statutory provision, DOE is also simultaneously publishing a 

NOPR which proposes the identical standard levels contained in this direct final rule with a 110­

day public comment period. DOE will consider whether any comment received during this 

comment period is sufficiently “adverse” as to provide a reasonable basis for withdrawal of the 

direct final rule and continuation of this rulemaking under the NOPR.. Typical of other 

rulemakings, it is the substance, rather than the quantity, of comments that will ultimately 

determine whether a direct final rule will be withdrawn. To this end, the substance of any 

adverse comment(s) received will be weighed against the anticipated benefits of the Consensus 

Agreement and the likelihood that further consideration of the comment(s) would change the 

35 
 

 

 

 

 

 

 

 

 

 

results of the rulemaking. DOE notes that to the extent an adverse comment had been previously 

raised and addressed in the rulemaking proceeding, such a submission will not typically provide 

a basis for withdrawal of a direct final rule. 

III. General Discussion 

A. Test Procedures 

As noted above, DOE’s test procedures for clothes dryers and room air conditioners 

appear at 10 CFR part 430, subpart B, appendices D and F, respectively. Moreover, EPCA 

requires DOE to amend its test procedures for all covered products, including those for clothes 

dryers and room air conditioners, to include measurement of standby mode and off mode energy 

consumption, except where current test procedures fully address such energy consumption or 

such a procedure is technically infeasible. (42 U.S.C. 6295(gg)(2)) Because the clothes dryer and 

room air conditioner test procedures previously covered such energy use only as to pilot lights in 

gas dryers (as noted above, the final test procedure rule eliminates the measurement of this 

energy use given the statutory prohibition), on December 1, 2008 DOE issued a NOPR in which 

it proposed revisions of these test procedures to fully address standby and off mode energy use 

and sought comment on those revisions. 73 FR 74639 (Dec. 9, 2008) (TP NOPR). DOE also held 

a public meeting on December 17, 2008 to receive oral comments. 

DOE subsequently issued a supplemental NOPR (SNOPR) in that rulemaking, in which it 

(1) addressed comments received in response to the TP NOPR; (2) proposed adoption of certain 

definitions and calculation methods for standby and off mode energy use; and (3) proposed 

several amendments to the clothes dryer and room air conditioner test procedures concerning the 

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active modes of these products. 75 FR 37594 (June 29, 2010) (TP SNOPR). For air conditioners, 

these proposed amendments would update references to industry test standards. Id. at 37598. For 

clothes dryers, DOE proposed to amend its test procedures for the active mode by adopting 

methods that would allow the testing of ventless products and would more accurately account for 

automatic cycle termination. Id. at 35798, 35799. DOE also proposed amendments to reflect the 

current usage and capabilities of products (for example, clothes dryer use cycles per year, 

remaining moisture content (RMC) of clothes dryer loads, and load sizes), and to update test 

cloth preconditioning provisions, eliminate reference to an obsolete industry test standard, and 

clarify the required gas supply pressure for testing gas clothes dryers. Id. DOE sought and 

received written comments on the TP SNOPR and also held a public meeting on July 14, 2010 to 

receive oral comments. 

On January 6, 2011, DOE published in the Federal Register a final rule for the test 

procedure rulemaking (76 FR 972) (TP Final Rule), in which it (1) adopted the provisions for the 

measurement of standby mode and off mode power use for both products proposed in the TP 

NOPR, as modified by the TP SNOPR, but required that products be installed and set up for 

standby and off mode testing in accordance with manufacturers’ instructions (and if no 

instructions are given, then the appliance shall be tested at the factory or “default” settings); and 

(2) adopted several amendments to the clothes dryer and room air conditioner test procedures 

concerning the active mode for these products, as proposed in and informed by public comment 

on the TP SNOPR. 76 FR 972 (January 6, 2011). Specifically for room air conditioners, the 

amendments adopted in the TP Final Rule updated the references to industry test standards. 

Specifically for clothes dryers, DOE adopted the amendments to include provisions for the 

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testing of ventless products proposed in the TP SNOPR, along with additional clarifications 

regarding the testing conditions for ventless clothes dryers. 76 FR 976-7. The amendments also 

include the following changes to reflect the current usage and capabilities of products: (1) 

changing the annual clothes dryer use cycles from 416 to 283 cycle per year, (2) changing the 

initial RMC of clothes dryer loads from 70 percent ± 3.5 percent to 57.5 percent ± 3.5 percent, 

and (3) changing the clothes dryer test load size from 7.00 pounds (lbs) ± .07 lbs to 8.45 ± .085 

lbs for standard-size clothes dryers. 76 FR 977. The TP Final Rule also amends the DOE clothes 

dryer test procedure by updating test cloth preconditioning provisions; revising the water 

temperature for test load preparation from 100 degrees Fahrenheit (°F) ± 5 °F to 60 °F ± 5 °F; 

updating references to industry test standards; eliminating reference to an obsolete industry test 

standard; clarifying the required gas supply conditions for testing gas clothes dryers; clarifying 

the provisions for measuring the drum capacity; clarifying the definition of “automatic 

termination control” for clothes dryers; and adding the calculations of EF and CEF to 10 CFR 

part 430, subpart B, appendix D1. 76 FR 978. 

DOE did not adopt the amendments to more accurately measure automatic cycle 

termination proposed in the TP SNOPR. As discussed in the TP Final Rule, DOE conducted 

testing of representative clothes dryers using the automatic cycle termination test procedure 

proposed in the TP SNOPR. The results showed that all of the clothes dryers tested significantly 

over-dried the DOE test load to near bone dry and, as a result, the measured EF values were 

significantly lower than EF values obtained using the existing DOE test procedure. The test data 

also indicated that dryers equipped with automatic termination controls were less efficient than 

timer dryers. 76 FR 977. 

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As noted in the TP Final Rule, DOE believes the test procedure amendments for 

automatic cycle termination proposed in the TP SNOPR do not adequately measure the energy 

consumption of clothes dryers equipped with such systems using the test load specified in the 

DOE test procedure. DOE believes that clothes dryers with automatic termination sensing 

control systems, which infer the RMC of the load from the properties of the exhaust air such as 

temperature and humidity, may be designed to stop the cycle when the consumer load has a 

higher RMC than the RMC obtained using the proposed 

7 automatic cycle termination test procedure in conjunction with the existing test load.

Manufacturers have indicated, however, that test load types and test cloth materials different than 

those specified in the DOE test procedure do not produce results as repeatable as those obtained 

using the test load as currenty specified. Id. 

In addition, DOE presented data in the test procedure final rule published on May 19, 

1981 from a field use survey conducted by AHAM as well as an analysis of field test data on 

automatic termination control dryers conducted by the National Bureau of Standards (now 

known as the National Institute of Standards and Technology (NIST)). Analysis of this data 

showed that clothes dryers equipped with an automatic cycle termination feature consume less 

energy than timer dryers by reducing over-drying. 46 FR 27324 (May 19, 1981). 

7 To investigate this, DOE conducted additional testing using a test load similar to that specified in AHAM Standard 

HLD-1-2009, which consists of cotton bed sheets, towels, and pillow cases. For tests using the same automatic cycle 

termination settings as were used in the testing described earlier (that is, normal cycle setting and highest 

temperature setting), the alternate test load was dried to 1.7 to 2.2 percent final RMC, with an average RMC of 2.0 

percent. In comparison, the same clothes dryer under the same cycle settings dried the DOE test load to 0.3 to 1.2 

percent RMC, with an average RMC of 0.7 percent. Thus, DOE concluded that the proposed automatic cycle 

termination control test procedures may not stop at an appropriate RMC when used with the current test load. 

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For these reasons, DOE stated in the TP Final Rule that the test procedure amendments 

for automatic cycle termination proposed in the TP SNOPR do not adequately measure the 

energy consumption of clothes dryers equipped with such systems. As a result, DOE did not 

adopt the amendments for automatic cycle termination proposed in the TP SNOPR. 76 FR 972, 

977 (January 6, 2011). 

The following sections discuss the comments received in response to the preliminary 

analyses regarding the test procedures for clothes dryers and room air conditioners. 

1. Clothes Dryer Test Procedure 

ACEEE and Earthjustice (EJ) both commented that the DOE test procedure inadequately 

represents field energy use, seriously hindering efforts to develop effective regulations and sound 

public policy, and produces misleading information for consumers and other interested parties. 

8 (ACEEE, No. 24 at p. 2; EJ, No. 28 at p. 1) ACEEE provided suggested test procedure changes, 

which are outlined in its comments and discussed in the sections below. ACEEE stated these 

suggested test procedure changes would improve the understanding of the overall contribution of 

clothes dryers to national energy consumption, the relative performance of products currently on 

the market, and opportunities to improve clothes dryer energy performance (including the 

potential of the design options defined in DOE’s analysis). ACEEE stated that its suggested test 

procedure changes would provide DOE better data for determining the appropriate level for 

standards that yield the maximum cost-effective energy savings for consumers. (ACEEE, No. 24 

at p. 2) Earthjustice commented that DOE should correct errors in the existing test procedure 

8 A notation in the form “ACEEE, No. 24 at p.2” identifies a written comment (1) made by the American Council 

for an Energy Efficient Economy (ACEEE), (2) recorded in document number 24 that is filed in the docket of this 

rulemaking, and (3) which appears on page 2 of document number 24. 

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that, according to Earthjustice, misstate the actual clothes dryer energy consumption, as 

9 identified in the report by ECOS Consulting (ECOS) (prepared for the NRDC), and recalculate 

the estimates of clothes dryer energy use. (EJ, No. 28 at p. 1) As discussed above, DOE recently 

published the TP Final Rule amending its clothes dryer test procedure to address many of the test 

procedure issues identified by ACEEE and Earthjustice. DOE addresses each of these issues 

individually in the sections below. 

a. Standby Mode and Off Mode 

Referenced Standards 

EPCA directs DOE to amend its test procedures to include measures of standby mode and 

off mode energy consumption. EPCA further directs DOE to amend the test procedures to 

integrate such energy consumption into a single energy descriptor for that product. If that is 

technically infeasible, DOE must prescribe a separate standby mode and off mode energy-use 

test procedure, if technically feasible. (42 U.S.C. 6295(gg)(2)(A)) Any such amendment must 

consider the most current versions of the International Electrotechnical Commission (IEC) 

Standard 62301 [“Household electrical appliances – Measurement of standby power,” First 

Edition 2005-06] and IEC Standard 62087 [“Methods of measurement for the power 

10 consumption of audio, video, and related equipment,” Second Edition 2008-09]. Id. 

AHAM supported DOE’s evaluation of the most current draft version of IEC Standard 

62301 Second Edition, which at the time of the preliminary analysis for the standards rulemaking 

9 NRDC, No. 30 at pp. 1-40.
 10 DOE considered IEC Standard 62087 and determined that this standard addresses the methods of measuring the
 

power consumption of audio, video, and related equipment and is therefore inapplicable to the products covered in
 

this rulemaking.
 

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was designated as the Committee Draft for Vote (IEC Standard 62301 CDV), for potential 

revisions to address standby mode and off mode power in DOE’s clothes dryer test procedure. 

AHAM commented that DOE would thus harmonize with international standards, including 

11 those used in Canada and Europe. (AHAM, Public Meeting Transcript, No. 21.4 at p. 30)

In the TP NOPR, DOE discussed that IEC Standard 62301 Second Edition was expected 

at that time to be published in July 2009. For this reason, DOE stated in the TP NOPR that IEC 

Standard 62301 First Edition would be the “current version” at the time of publication of the 

final rule, so consideration thereof would comply with EPCA. DOE incorporated sections from 

IEC Standard 62301 First Edition in the proposed amendments to the clothes dryer test procedure 

in the TP NOPR. 73 FR 74639, 74644 (Dec. 9, 2008). DOE did not receive any comments in 

response to the TP NOPR objecting to the proposed testing methods and procedures referenced 

in IEC Standard 62301 First Edition. Therefore, the TP SNOPR did not affect DOE’s proposal in 

the TP NOPR to incorporate by reference clauses from IEC Standard 62301 First Edition. 75 FR 

37594, 37602 (June 29, 2010). In the TP Final Rule, DOE noted that the most recent draft of IEC 

Standard 62301 Second Edition, designated as the Final Draft International Standard (IEC 

Standard 62301 FDIS) had yet to be made available on IEC’s public website and that IEC 

Standard 62301 Second Edition is now projected to be issued in April 2011. For the reasons 

stated in the TP Final Rule, DOE amended its test procedures for clothes dryers in the final rule 

to incorporate by reference the clauses from IEC Standard 62301 First Edition proposed in the 

11 A notation in the form “AHAM, Public Meeting Transcript, No. 21.4 at p. 30” identifies an oral comment that 

DOE received during the March 16, 2010 public meeting and which was recorded in the public meeting transcript in 

the docket for this rulemaking (Docket No. EE–2007–BT–STD–0010), maintained in the Resource Room of the 

Building Technologies Program. This particular notation refers to a comment (1) made by the Association of Home 

Appliance Manufacturers (AHAM) during the public meeting, (2) recorded in document number 21.4, which is the 

public meeting transcript that is filed in the docket of this rulemaking, and (3) which appears on page 30 of 

document number 21.4. 

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TP SNOPR. DOE also adopted the definitions of “active mode,” “standby mode,” and “off 

mode” based on the language presented in IEC Standard 62301 CDV. 76 FR 972, 976-977 

(January 6, 2011). DOE may consider incorporating by reference clauses from IEC Standard 

62301 Second Edition when that version has been published. 

Testing Procedures 

As discussed in the Referenced Standards section, EPCA directs DOE to amend the test 

procedures to integrate such energy consumption into a single energy descriptor for that product. 

If that is technically infeasible, DOE must prescribe a separate standby mode and off mode 

energy-use test procedure, if technically feasible. (42 U.S.C. 6295(gg)(2)(A)) In the TP NOPR, 

DOE determined that it is technically feasible to incorporate measures of standby mode and off 

mode energy use into the overall energy use metric. 73 FR 74639, 74650 (Dec. 9, 2008). In the 

TP NOPR, DOE proposed to adopt the 140 hours associated with drying as the active mode 

hours and to associate the remaining 8,620 hours of the year with standby mode and off mode. 

73 FR 74639, 74647 (Dec. 9, 2008). In the TP NOPR, DOE also proposed definitions and testing 

methods for multiple standby modes, including “inactive mode,” “delay start mode,” and “cycle 

12 finished mode.” 73 FR 74639, 74647–48 (Dec. 9, 2008). DOE proposed to calculate clothes 

dryer energy use per cycle associated with standby mode and off mode by (1) calculating the 

product of wattage and allocated hours for all possible standby modes and off modes; (2) 

summing the results; (3) dividing the sum by 1,000 to convert from watt-hours (Wh) to kWh; 

and (4) dividing by the number of cycles per year. 73 FR 74639, 74648 (Dec. 9, 2008). In the TP 

12 “Inactive mode” is defined as “a standby mode other than delay start mode or cycle finished mode that facilitates 

the activation of active mode by remote switch (including remote control), internal sensor, or provides continuous 

status display.” “Delay start mode” is defined as “a standby mode that facilitates the activation of active mode by 

timer.” “Cycle finished mode” is defined as “a standby mode that provides continuous status display following 

operation in active mode.” 

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NOPR, DOE reported that the comparison of annual energy use of different clothes dryer modes 

showed that delay start and cycle finished modes represent a negligible percentage of total 

annual energy consumption. The comparison also showed that the power levels in these modes 

are similar to those for inactive mode and off mode. For these two reasons, DOE presented an 

alternate approach that would be limited to specifying the hours for only inactive mode and off 

mode when calculating energy use associated with standby mode and off mode. Under this 

alternate approach, all of the non-active mode hours (8,620) would be allocated to inactive mode 

and off mode. 73 FR 74639, 74648 (Dec. 9, 2008). 

13 In the TP NOPR, DOE proposed to establish the CEF for clothes dryer to integrate 

energy use in the standby mode and off mode with the energy use of the main functions of the 

product. The CEF would be defined as the clothes dryer test load weight in pounds divided by 

the sum of the per-cycle standby and off mode energy consumption and either the total per-cycle 

electric dryer energy consumption or the total per-cycle gas dryer energy consumption expressed 

in kWh. 73 FR 74639, 74650 (December 9, 2008). 

As discussed in chapter 5 of the preliminary TSD, for the preliminary analyses, DOE 

analyzed the cost-efficiency relationship for CEF using the alternative approach for this metric in 

the TP NOPR. That approach allocates all of the non-active mode hours into inactive mode and 

off mode energy use, and then integrates inactive mode and off mode energy use with active 

mode energy use. 

13 DOE proposed to use the term “Integrated Energy Factor” (IEF) in the TP NOPR. 73 FR 74639, 74650 (Dec. 9, 

2008). However, in the TP SNOPR, DOE proposed to revise the name of the metric to “Combined Energy Factor” 

(CEF) to avoid confusion with an existing industry standard. 75 FR 37594, 37612 (June 29, 2010). DOE adopted 

CEF as the measure of clothes dryer energy efficiency in the TP Final Rule. 76 FR 972, 992 (January 6, 2011). 

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BSH commented that, in the formula to calculate the CEF in the clothes dryer test 

procedure, "8620" inactive/off mode hours should be replaced by (8720 - per cycle duration 

(hours) × 416 clothes dryer annual cycles), where 8720 = 365 days × 24 hours per day. 

According to BSH, the standby mode is not valid during the active mode and, therefore, the 

duration of the active mode should be subtracted from the hours per year when calculating the 

standby energy consumption. (BSH, No. 23 at p. 5) DOE notes that the estimate for active mode 

hours presented in the TP NOPR was fixed based on the number of such hours specified in the 

existing test procedure (140 hours). 73 FR 74646–7 (Dec. 9, 2008). DOE acknowledges that its 

estimate of the number of cycles per year has decreased. As discussed in the TP Final Rule, DOE 

notes that changes to the initial RMC, test load size, and specified water temperature for test load 

preparation may also affect cycle time and the number of active mode hours per year. DOE is not 

aware, however, of any data indicating that the number of active mode hours has changed and, if 

so, what a more accurate number might be. Therefore, DOE did not adopt amendments to the 

number of active mode hours in the TP Final Rule. 76 FR 972, 988 (January 6, 2011). For these 

reasons, DOE believes that using the 140 annual active mode hours, as specified in the existing 

test procedure, to determine the number of annual inactive mode and off mode hour of 8,620, as 

adopted in the TP Final Rule (76 FR 990), provides a more representative estimate of consumer 

use than the method suggested by BSH. 

b. Automatic Cycle Termination 

In the framework document, DOE stated the clothes dryer test procedure may not 

adequately measure the benefits of automatic cycle termination, in which a sensor monitors 

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either the exhaust air temperature or moisture in the drum to determine the length of the drying 

cycle. Currently, the test procedure provides a single field use factor for the enhanced 

performance of clothes dryers equipped with automatic termination. This single field use factor 

does not distinguish between the type of sensing control system (for example, temperaturesensing or moisture-sensing controls) and the accuracy of the control system. In chapter 2 of the 

preliminary TSD, DOE stated that it agrees that the effects of automatic cycle termination should 

be more accurately measured in its clothes dryer test procedure, and that this effect should 

properly account for any over- or under-drying. Thus, DOE noted it was considering clothes 

dryer test procedure amendments to address automatic cycle termination in the active mode test 

procedure rulemaking. In response, interested parties commented on the following topics relating 

to automatic cycle termination. 

Definition of Automatic Termination Control 

The Joint Petitioners commented that DOE should revise section 1.11 of 10 CFR 430 

subpart B, appendix D to more clearly account for electronic controls by specifying that a 

preferred automatic termination control setting can also be indicated by a visual indicator (in 

addition to the mark or detent). The clarification would read ". . .mark, visual indicator or detent 

which indicates a preferred. . ." (Joint Petitioners, No. 33 at p. 25) As discussed in the TP Final 

Rule, DOE agreed that a clarification should be added to the definition of “automatic termination 

control.” The clarification would be that a mark, detent, or other visual indicator which indicates 

a preferred automatic termination control setting must be present if the dryer is to be classified as 

having an automatic termination control. DOE so revised the definition in the TP Final Rule. 76 

FR 972, 978 (January 6, 2011). 

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Testing Procedures 

AHAM commented in response to the preliminary analyses that it continues to support 

the use of the automatic termination field use factor as currently specified by the DOE clothes 

dryer test procedure. AHAM stated that clothes dryers utilize different algorithms to determine 

when the drying cycle should end, and any evaluation of a different approach will need to be 

thoroughly investigated and should not be based on DOE test results from four sample units. 

AHAM proposed that DOE conduct a study that evaluates: (1) the accuracy of the DOE field use 

factor for today’s products; and (2) the repeatability and reproducibility of a procedure where 

cycle end is determined by a moisture or temperature sensor. (AHAM, No. 25 at p. 13) 

Whirlpool commented that its testing showed significant improvement in the 

performance of sensors and automatic termination cycles when using systems that incorporate 

sensors that directly measure the moisture level of the clothes. Based on these test results, 

Whirlpool recommended that an additional automatic termination factor be included that would 

be equal to 1.01 to provide an appropriate field use factor for clothes dryers that utilize improved 

moisture sensor systems. (Whirlpool, No. 22 at p. 5) 

After the publication of the preliminary analyses, the Joint Petitioners submitted the Joint 

Petition, in which they commented that DOE should modify the clothes dryer test procedure to 

address the effectiveness of automatic termination controls (for example, moisture sensor and 

temperature sensor controls). (Joint Petitioners, No. 33 at p. 25) Pacific Gas & Electric (PG&E), 

Southern California Gas Company (SCGC), San Diego Gas and Electric Company (SDGE), and 

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Southern California Edison (SCE) jointly (hereafter the “California Utilities”). NRDC, and 

NEEP commented that the current DOE test procedure does not test the effectiveness of control 

sensors, which was found to vary significantly. (California Utilities, No. 31 at p. 3; NRDC, No. 

26 at pp. 1, 2; NRDC, No. 30 at p. 29; NEEP, No. 27 at p. 3) NRDC, NEEP, and the California 

Utilities stated that the DOE test procedure is unrealistic and tests only the bulk-drying stage. In 

addition, by not testing the high-heat stage (which contributes very little to drying clothes) and 

instead applying a field use factor, the current test methods overestimate the efficiency of the 

clothes dryer. The current test methods also do not appropriately measure the energy use of 

clothes dryers that use more effective controls to limit the energy consumption of the high-heat 

stage. (NRDC, No. 26 at pp. 1, 2; NRDC, No. 30 at p. 29; NEEP, No. 27 at p. 3; California 

Utilities, No. 31 at p. 3) NRDC added that the ECOS report stated that there is not much 

variation in efficiency of the bulk drying stage among different clothes dryers. However, there 

are considerable differences in the energy consumption of the high-heat stage, which is not 

measured by the DOE test procedure. (NRDC, No. 30 at p. 23) The ECOS report found that the 

difference between a standard clothes dryer and one that is effective at turning itself off when 

clothes are actually dry is about 0.76 kWh per load (5,000 kWh over typical lifetime). (NRDC, 

No. 26 at pp. 1, 2) The California Utilities also added that according to the ECOS report, clothes 

dryers, even with the same sensors, can use very different control algorithms that result in 

substantial variations between clothes dryers in the length of, and the amount of energy 

consumed during, the high-heat stage. (California Utilities, No. 31 at p. 3) 

NRDC commented that DOE should change its test procedure to measure at dryness 

levels less than 5-percent RMC with logging equipment that provides data enabling the lab to 

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calculate when 5-percent RMC is reached and how long the clothes dryer continues to run 

thereafter. (NRDC, No. 26 at pp. 1, 2; NRDC, No. 30 at pp. 29–30) The California Utilities, 

ACEEE, and NPCC also commented that the test procedure should let the clothes dryer run until 

automatic shutoff, allowing the clothes dryer's sensors and termination controls to operate as 

intended, which would: (1) be more representative of actual consumer behavior and give a better 

measure of expected energy use for consumers; (2) avoid the need for an field use factor to 

account for high-heat stage energy use and instead measure energy use directly; (3) appropriately 

measure the energy use of clothes dryers with better termination controls and encourage 

innovation in these controls; and (4) make the test procedure easier because the technician does 

not need to keep weighing the clothes. (California Utilities, No. 31 at pp. 3–4, 12; ACEEE, No. 

24 at pp. 1–2; NPCC, No. 32 at pp. 1–2) 

The California Utilities recommended the following amendments to section 3.3, “Test 

cycle” of the clothes dryer test procedure: 

Set the clothes dryer for its “Normal” or “Cotton” cycle. If this in turn sets a 

temperature or dryness control, leave those controls at the default setting. If a 

temperature control must also be set, set it for “High heat” or “Cotton.” If a 

dryness control must also be set, set it for “Normal dry” or midway between 

“More dry” and “Less dry.” 

Allow the clothes dryer to run until its cycle is complete. Promptly remove and 

weigh the test load. If it contains 5-percent or less RMC, the test cycle is 

complete. 

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If the test load contains more than 5-percent RMC, return the load to the clothes 

dryer and reset the controls. In this case, the dryness control would then be set for 

“Maximum dry” and the cycle would be run to completion again and the test load 

weighed. Repeat if necessary until the RMC is 5 percent or less. 

Total the amount of electricity (and gas if applicable) used during the initial 

default cycle and any subsequent cycles. (California Utilities, No. 31 at p. 4) 

The California Utilities also stated that section 4 of the DOE test procedure would be 

modified to remove all references to the field use factor. That factor is no longer needed because 

the test cycle now represents a typical consumer use cycle (including both the bulk-drying and 

high-heat stages), and would be omitted from all calculations. (California Utilities, No. 31 at p.4) 

The California Utilities stated that the clothes dryers tested for the ECOS report using the default 

settings of the “Normal” or “Cotton” cycles all resulted in RMCs between 0 and 3 percent at the 

completion of the clothes dryer cycle. Therefore, it may be reasonable to assume that the 

additional cycles will rarely be used. The California Utilities stated that the additional cycles are 

included in their proposal to prevent a manufacturer from creating a default cycle that saves 

energy by not actually getting the clothes adequately dry. The California Utilities also stated that 

their proposed procedure represents the most likely consumer response to clothes that did not get 

dry the first time. (California Utilities, No. 31 at p. 4) 

The California Utilities also commented that, under their recommended test procedure 

changes for automatic cycle termination, there is a noticeable difference in energy consumption 

between the best and worst clothes dryers. For clothes dryers that respond effectively when the 

50 
 

 

 

 

 

 

 

clothes have reached 5-percent RMC by discontinuing the application of heat and allowing the 

residual heat in the clothes to evaporate the remaining moisture, the energy measured under the 

new test cycle will be very similar to the energy measured under the current DOE test procedure, 

as the shutoff point will occur near 5-percent RMC under either test. The California Utilities 

stated that its proposed test procedure would more accurately measure the real contribution of 

automatic termination controls and mimic consumer behavior. As a result there would be no 

need to use a field use factor for clothes dryers with automatic termination controls. (California 

Utilities, No. 31 at p. 4) 

BSH commented that DOE should test clothes dryers using the automatically controlled 

programs including the cool-down phase. According to BSH, timer dryers waste energy because 

consumers will set a longer drying time than required to ensure the desired drying results, 

resulting in over-drying. BSH commented that a change in the test procedure to measure the real 

final moisture content for automatically controlled dryers will show the differences between 

competitive clothes dryers. BSH also commented that the cool-down phase is, in automatically 

controlled dryers, an essential part of the process to use the energy in the most efficient way, and 

that the heat accumulated in the appliance and the laundry may be used to finish drying the 

laundry and increase the efficiency of the clothes dryer. (BSH, No. 23 at pp. 4–5) 

NRDC commented that the ECOS report states that newer clothes dryers are capable of 

moisture-sensing drying, but that feature can be (and likely routinely is being) overridden by 

consumers who continue to operate clothes dryers on a time basis as they always have. NRDC 

added that the ECOS report states that DOE should require manufacturers to incorporate 

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moisture sensing into the timed cycle to ensure that the heating element shuts off and that airflow 

is greatly reduced once the clothes are dry. (NRDC, No. 30 at p. 29) 

As discussed above in this section, DOE proposed amendments to its clothes dryer test 

procedure in the TP SNOPR to more accurately account for automatic cycle termination. 

However, as discussed in the TP Final Rule, DOE conducted testing on a sample of 

representative clothes dryers according to the amendments to the test procedure for automatic 

cycle termination proposed in the TP SNOPR. The tests consisted of running the clothes dryer on 

a “normal” automatic termination setting and stopping the clothes dryer when the heater switches 

off for the final time (immediately before the cool-down period begins). Three identical tests 

were conducted for each clothes dryer unit, and the results were averaged. DOE first noted that 

not all of the clothes dryers offered a “normal” cycle setting. For those clothes dryers, DOE 

chose the cycle that would most closely match a “normal” cycle. The results of this testing, 

presented below in Table III.1, showed that the tested clothes dryers had a measured EF of 

between 12.4 percent and 38.8 percent lower than the EF measured according to the current DOE 

clothes dryer test procedure. DOE also noted that all of tested units dried the test load to final 

RMCs well below the target RMC of 5 percent, ranging from 0.4 percent to 1.4 percent RMC, 

with an average of 0.8 percent. DOE also noted that even if the field use factor for a timer dryer 

is applied to the measured EF for a clothes dryer equipped with automatic cycle termination, 

using the current DOE clothes dryer test procedure (to add the fixed estimate of over-drying 

energy consumption associated with time termination control dryers), this EF would still be less 

than the EF measured under the automatic cycle termination test procedure amendments 

proposed in the TP SNOPR. 76 FR 972, 999 (January 6, 2011). 

52 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table III.1 DOE Clothes Dryer Automatic Cycle Termination Tests 

Test Unit 

Current DOE 

Test 

Procedure EF 

lb/kWh 

Current DOE 

Test Procedure 

w/ Modified field 

use Factor * 

EF lb/kWh 

Proposed Automatic Cycle 

Termination Test Procedure 

EF 

lb/kWh 

% 

Change 

Final 

RMC 

% 

Vented Electric 

Standard 

Unit 3 3.20 2.82 2.59 -19.1% 1.0 

Unit 4 3.28 2.89 2.59 -21.2% 0.6 

Vented Gas 

Unit 8 2.83 2.50 2.42 -14.5% 0.4 

Unit 9 2.85 2.51 2.38 -16.3% 0.9 

Unit 11 2.98 2.63 2.40 -19.5% 0.9 

Vented Electric 

Compact 240V 

Unit 12 3.19 2.81 2.64 -17.3% 0.5 

Unit 13 2.93 2.59 2.27 -22.7% 1.4 

Vented Electric 

Compact 120V Unit 14 3.23 2.85 1.98 -38.8% 0.7 

Ventless Electric 

Compact 240V Unit 15 2.37 2.09 2.07 -12.4% 1.1 

* Field use factor changed from 1.04 for clothes dryers with automatic termination to 1.18 for timer dryers. 

In the TP Final Rule, DOE stated that these test results showed significantly higher 

measured energy use for clothes dryers tested under the DOE test procedure with the proposed 

automatic cycle termination amendments. DOE evaluated possible reasons for this difference. 

14 DOE concluded that given the test load specified in the test procedure, the proposed automatic 

cycle termination control procedures may not adequately measure clothes dryer performance. As 

discussed in the previous paragraph, DOE believes that, although automatic termination control 

dryers may be measured as having a lower efficiency than a comparable dryer with only time 

termination control if tested according to the proposed test procedure, automatic termination 

control dryers may in fact be drying the clothing to approximately 5-percent RMC in real world 

use. DOE believes that automatic termination control dryers reduce energy consumption (by 

reducing over-drying) compared to timer dryers based on analysis of the AHAM field use survey 

and analysis of field test data conducted by NIST. 46 FR 27324 (May 19, 1981). 

14 The DOE clothes dryer test load is comprised of 22 in × 34 in pieces of 50/50 cotton/polyester-blend cloth. 

53 
 

 

 

 

 

 

 

 

 

 

For these reasons, DOE stated in the TP Final Rule that it believes that the test procedure 

amendments for automatic cycle termination proposed in the TP SNOPR do not adequately 

measure the energy consumption of clothes dryers equipped with such systems. As a result, DOE 

did not adopt the amendments for automatic cycle termination proposed in the TP SNOPR. 76 

FR 972, 1000 (January 6, 2011). DOE noted that if data is made available to develop a test 

procedure that accurately measures the energy consumption of clothes dryers equipped with 

automatic termination controls, DOE may consider revised amendments in a future rulemaking. 

With regard to NRDC’s comment that DOE should require manufacturers to incorporate 

moisture sensing into the timed cycle, DOE notes that EPCA defines an energy conservation 

standard as either a performance standard or, for certain products including clothes dryers, a 

design requirement. (42 U.S.C. 6291(6)) EPCA also specifies that DOE may set more than one 

energy conservation standard for products that serve more than one major function by setting one 

energy conservation standard for each major function. (42 U.S.C. 6295(o)(5)) DOE notes the 

energy conservation standards for clothes dryers set forth in this final rule are based on drying 

performance and that an additional precriptive standard to require manufacturers to incorporate 

moisture sensing into the timed dry cycle would address the same major function of the drying 

performance. For these reasons, DOE is not adopting an additional prescriptive requirement for 

clothes dryers. 

DOE believes that the alternate test procedure for automatic cycle termination 

recommended by the California Utilities is similar to the test cycle proposed by DOE in the TP 

SNOPR. DOE notes that the California Utilities’ recommendations would clarify the settings to 

54 
 

 

 

 

 

 

 

 

be used in cases where a “Normal” cycle or “High heat” temperature setting was not clearly 

specified. DOE does not believe that this added clarification would resolve the issues with the 

proposed automatic cycle termination test procedure identified in this section because the setting 

used during DOE testing would be the same under the California Utilities’ recommendation. In 

addition, DOE notes that the California Utilties’ recommendation to specify the “Normal dry” 

setting is generally the default setting under the “Normal” cycle. DOE also notes that the 

“Normal dry” setting was used during its testing, and as a result this clarification would not 

resolve the issues associated with the automatic cycle termination test procedure identified 

above. Finally, DOE notes the California Utilities’ recommendation that if the test load contains 

more than 5-percent RMC, the test load would be placed back in the clothes dryer and the cycle 

would be run again using the “Maximum dry” setting is similar to the proposed amendments in 

the TP SNOPR. However, the proposed amendments in the TP SNOPR would require the test be 

re-run from the start using the specified initial RMC and the “Maximum dry” setting. The 

California Utilities’ recommendations would require that the test load with the RMC at the end 

of the first test cycle be re-run on a cycle with the “Maximum dry” setting and the energy would 

then be accumulated. DOE believes that this recommendation would not resolve the issue of the 

significant over-drying observed during testing because it addresses cases only in which the test 

load under-dries. For these reasons, DOE is not adopting the alternate test procedure for 

automatic cycle termination recommended by the California Utilities. If DOE considers adopting 

test procedure amendments for automatic cycle termination in a future rulemaking, it may 

consider these recommendations. 

Cycle Settings 

55 
 

 

 

 

 

 

 

 

NRDC commented that the testing described in the ECOS report showed that automatic 

termination cycles using lower heat settings or lower dryness level reduce energy consumption 

and increase efficiency because less energy is spent heating air, cloth, and metal. NRDC 

commented that the ECOS report summarized testing results for one clothes dryer that showed 

that the difference in energy consumption between the highest and lowest heat settings was 13 

percent and that the drying time increased (from 35 to 49 minutes), but very similar final RMCs 

were achieved. (NRDC, No. 30 at p. 22) NRDC commented that the ECOS report found that a 

“normal dry” setting removed practically all of the water (producing a final RMC of less than 1 

percent), making the “more dry” setting appear to be unnecessary. The ECOS report stated that 

the “normal dry” used about 12 percent less energy than the “more dry” setting, and the “less 

dry” setting saved another 18 percent, but did leave residual moisture in the clothes. NRDC 

commented that the ECOS report added that in all but the highest humidity climates, the “less 

dry” setting may be fully adequate and would give considerable energy savings. Id. NRDC 

commented that DOE should measure the efficiency of different clothes dryer settings, in 

particular the “more dry” setting, which the ECOS report stated may not be warranted because 

the “normal dry” settings remove effectively all of the moisture. (NRDC, No. 26 at pp. 1, 3) 

As discussed in the previous section, DOE did not adopt amendments to more accurately 

account for automatic cycle termination in the TP Final Rule. Therefore DOE did not consider 

amendments to the clothes dryer test procedure to measure the efficiency of different clothes 

dryer automatic cycle termination temperature and dryness level settings. 

Effect of Automatic Cycle Termination Test Procedure on Measured Energy Factor 

56 
 

 

 

 

 

 

 

 

 

 

The California Utilities stated that under their proposed test procedure, the 4 percent field 

use factor would not be necessary; therefore removing it would reduce apparent (reported) 

energy use by 4 percent. Instead of EFs from 3.01 to 3.4, these clothes dryers would be rated at 

EF from 3.13 to 3.54. According to the California Utilities, these higher ratings are appropriate 

because these clothes dryers stop quickly and save the consumer energy under real world 

operating conditions. (California Utilities, No. 31 at pp. 4–5) NRDC commented that the ECOS 

report summarized testing results that showed that some electronically controlled dryers could 

detect the clothes were already dry and shut down after 5 to 15 minutes, while 

electromechanically controlled dryers needed up to 50 minutes before shutting down. (NRDC, 

No. 30 at pp. 29–30) The California Utilities also noted that one clothes dryer tested in the ECOS 

report ran for an additional 30 minutes after reaching 5 percent RMC because of an inefficient 

control algorithm and would test with an EF of about 2.51 under their proposed test procedure. 

According to the California Utilities, this lower rating would be appropriate, because in real 

practice this dryer would significantly increase clothes dryer energy use. (California Utilities, 

No. 31 at p. 5) The California Utilities commented that a real savings opportunity exists simply 

through an improved test procedure (as they proposed), which will better characterize the realworld energy performance of dryers. The California Utilities added that dryers that meet the 

baseline EF under the current test procedure but have poor automatic termination controls will 

not meet the same EF under a revised test. Thus, those dryers will have to improve to meet the 

baseline EF of 3.01. The California Utilities added that, if tested using their proposed test 

procedure, the least efficient clothes dryers in the sample of clothes dryers in the ECOS report 

will need to increase their efficiency by 20 percent or more to meet the current energy 

conservation standard. (California Utilities, No. 31 at p. 5) 

57 
 

 

 

 

 

 

 

 

 

 

As discussed in the Test Procedures section, DOE did not adopt the amendments to the 

clothes dryer test procedure to better account for automatic cycle termination that were proposed 

in the TP SNOPR. As a result, DOE is not considering any revisions to the energy conservation 

standards based on the proposed amendments for automatic cycle termination in the TP SNOPR. 

If DOE considers potential amendments for automatic cycle termination in a future rulemaking, 

it would also consider any necessary revisions to the energy conservation standards. In addition, 

as discussed above, DOE noted that the alternate test procedure for automatic cycle termination 

recommended by the California Utilities is similar to the test cycle proposed by DOE in the TP 

SNOPR. As a result, DOE does not believe the measured EF would be different between the 

proposed amendments in the TP SNOPR and the California Utilities’ recommendations except 

for cases in which the test load is not dried to below 5-percent RMC. In this case the California 

Utilities’ recommendations would require that the measured energy consumption from any 

additional test cycles using the “Maximum dry” setting be added to the energy consumption from 

the first test cycle, whereas the measured efficiency under the proposed amendments in the TP 

SNOPR would be based on only the re-run test cycle using the “Maximum dry” setting. 

However, for the reasons discussed above, DOE believes that the California Utilities’ 

recommendations would not resolve the issue of the significant over-drying observed during 

DOE testing. As a result, DOE is not adopting the alternate test procedure for automatic cycle 

termination recommended by the California Utilities and therefore is not considering any 

revisions to the energy conservation standards based on these recommendations. 

58 
 

 

 

 

c. Ventless Clothes Dryers 

For the reasons discussed in section IV.A.3.a of this direct final rule, DOE defines two 

new product classes in this rulemaking for ventless clothes dryers. The clothes dryer test 

procedure at 10 CFR part 430, subpart B, appendix D is unable to test ventless clothes dryers, 

which include condensing clothes dryers as well as combination washer/dryers. Ventless clothes 

dryers do not vent exhaust air to the outside as a conventional, vented dryer does. Instead, they 

typically use ambient air in a heat exchanger to cool the hot, humid air inside the appliance, 

thereby condensing out the moisture. Alternatively, cold water can be used in the heat exchanger 

to condense the moisture from the air in the drum. In either case, the dry air exiting the drum is 

reheated and recirculated in a closed loop. Thus, rather than venting moisture-laden exhaust air 

outside, ventless clothes dryers produce a wastewater stream that can be either collected in an 

included water container or discharged down the household drain. The process of condensing out 

the moisture in the recirculated air results in higher energy consumption than a conventional 

dryer, and it can significantly increase the ambient room temperature. 

To address the potential limitation of the clothes dryer test procedure for ventless dryers, 

DOE proposed an alternate test procedure for ventless dryers in the TP SNOPR and adopted this 

procedure in the TP Final Rule. [75 FR 37594, 37620 (June 29, 2010); 76 FR 972, 976-977 

(January 6, 2011)] The alternate test procedure consists of adding separate definitions for a 

“conventional clothes dryer” (vented) and a “ventless clothes dryer.” Further, the alternate test 

procedure qualifies the requirement for an exhaust simulator so that it would only apply to 

conventional clothes dryers. DOE also adopted provisions to clarify the testing procedures for 

ventless clothes dryers, including requirements for clothes dryers equipped with a condensation 

59 
 

 

 

 

 

 

 

 

 

box, requirements for the condenser heat exchanger, and specifications for ventless clothes dryer 

preconditioning. DOE also adopted clarifications in the TP Final Rule to provide explicit 

instructions as to the procedure for re-running the test cycle when the condensation box is full. 

DOE also revised the requirement for ventless clothes dryer preconditioning to remove the 

maximum time limit for achieving a steady-state temperature. DOE also included additional 

editorial clarifications to the testing procedures for ventless clothes dryers. 76 FR 972, 976-977 

(January 6, 2011). 

In chapter 2 of the preliminary TSD, prior to adoption of the TP Final Rule, DOE stated 

that it was considering amendments to its clothes dryer test procedure to allow for the 

measurement of the energy efficiency of ventless clothes dryers in its active mode test procedure 

rulemaking. 

The Joint Petitioners commented that DOE should create a ventless clothes dryer 

(including ventless combination washer/dryer) test procedure to inform a baseline energy 

consumption level for this new product category. (Joint Petitioners, No. 33 at p. 25) 

AHAM suggested that DOE incorporate language from the alternate test procedure 

presented in the LG’s Petition for Waiver and Denial of the Application for Interim Waiver (71 

FR 49437, 49439 (Aug. 23, 2006)), with the additional changes that the term "condensing 

clothes dryer" be changed to "ventless clothes dryer" and "HLD-1" be changed to "AHAM HLD1." AHAM stated that DOE should validate the proposed test procedure approach and the 

resultant energy consumption values through a viable statistical method. AHAM stated that it is 

60 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

not in a position to provide data on ventless products due to the small number of products in the 

proposed “compact ventless” product class. According to AHAM, ventless clothes dryers, when 

tested using the dryer‐centric approach presented by DOE in the LG Petition for Waiver, will 

appear to have higher energy consumption (kWh per year) than conventional vented clothes 

dryers. (AHAM, No. 25 at p. 4) 

Whirlpool commented that its proposal, which provides amendments to the DOE test 

procedure to include methods for testing of ventless clothes dryers, improves upon the DOE 

proposal for the ventless clothes dryer test procedure because it takes into account technical 

15 differences between vented and ventless clothes dryers. (Whirlpool, No. 13 at pp. 1–22) 

Whirlpool indicated that their proposal was a draft only and they would be willing to work with 

DOE to make revisions or enhancements to this proposal. (Whirlpool, No. 22 at p. 1) 

In the TP Final Rule, DOE adopted testing methods for the testing of ventless clothes 

dryers based on the alternate test procedure proposed in the TP SNOPR; the amendments 

suggested by Whirlpool; and additional language from the internationally accepted test standards 

Australia/New Zealand (AS/NZS) Standard 2442, “Performance of household electrical 

appliances – Rotary clothes dryers” and European Standard EN 61121, “Tumble dryers for 

household use – Methods for measuring the performance,” Edition 3 2005 (EN Standard 61121). 

76 FR 972, 976 (January 6, 2011). Also noted in the TP Final Rule, DOE used the term 

“ventless” instead of “condensing,” as suggested by AHAM, to reflect the actual consumer 

utility (that is, no external vent required) because it is possible that vented dryers that also 

15 Whirlpool’s proposed amendments for ventless clothes dryers included: (1) definitions of “conventional” and 

“condensing” clothes dryers; (2) installation conditions; (3) requirements for clothes dryer preconditioning; (4) 

requirements for condensation boxes and condenser units; and (5) requirements for test cycle measurements. 

61 
 

 

 

 

 

 

 

 

 

 

condense may become available on the market. Id. DOE also conducted testing for the TP Final 

Rule to evaluate the repeatability of the amended test procedure for ventless dryers. As detailed 

in the TP Final Rule, ventless electric compact 240V dryers and ventless electric combination 

washer/dryers showed less than 1 percent variation and less than 3.5 percent variation in EF from 

test to test, respectively. DOE stated in the TP Final Rule that it believes that the amendments for 

ventless clothes dryers produce repeatable measurements of EF. 76 FR 972, 1009 (January 6, 

2011). DOE also notes that the measured EF values for ventless electric compact (240V) dryers 

and ventless electric combination washer/dryers tested according to the DOE test procedure at 

appendix D, using only the amendments for ventless clothes dryers (2.37 and 2.02, respectively), 

are in close agreement with the baseline values proposed in the preliminary analyses shown 

below in Table IV.15 and Table IV.16. Therefore, DOE did not revise the baseline EF levels for 

the ventless clothes dryer product classes. 

In response to AHAM’s comment that “HLD-1” should be changed to “AHAM HLD-1,” 

DOE has adopted this editorial change in the TP Final Rule. 76 FR 972, 1032 (January 6, 2011). 

BSH commented that DOE should consider the condensation rate for ventless clothes 

dryers. BSH added that the condensation rate efficiency is an important indicator to measure. 

(BSH, No. 23 at p. 4) DOE notes that EN Standard 61121 provides for a measurement of the 

condensation rate efficiency. However, this measurement is not used in the calculation of energy 

use, which considers only the energy required to dry the load to a specified final RMC. However, 

DOE also notes that the ability of a ventless clothes dryer to condense moisture directly affects 

the energy use per-cycle. For example, if a ventless clothes dryer has a lower condensation 

62 
 

 

 

 

 

 

 

 

 

 

 

efficiency, the air recirculated into the drum would contain more moisture and thus would be 

able to remove less moisture from the test load. As a result, the energy use of such a ventless 

clothes dryer would be greater than a ventless clothes dryer with a higher condensation 

efficiency because it would need to run for a longer time to condense the same amount of 

moisture from the test load. Therefore, DOE believes that the condensation efficiency of a 

ventless clothes dryer is sufficiently accounted for in the measurement of the per-cycle energy 

consumption. For these reasons, DOE is not providing for a measurement of condensation 

efficiency of a clothes dryer. 

NRDC questioned whether ventless electric combination washer/dryers are going to be 

tested in drying mode only or as a unit with washing and drying capability. NRDC stated that, 

according to the ECOS report, there is a potential for energy savings if manufacturers are 

allowed to test units together that work together, because it is more efficient to manually remove 

the water than to dry it. NRDC supported the ECOS report suggestion that DOE consider a 

testing and labeling program based on the total energy use, cost, and CO2 emissions for washing 

and drying a standard load of clothes. According to the ECOS report submitted by NRDC, highly 

efficient clothes washers greatly decrease the amount of work that a clothes dryer needs to do, 

but that a clothes dryer is less efficient when drying loads with lower initial RMCs. (NRDC, 

Public Meeting Transcript, No. 21.4 at p. 22; NRDC, No. 30 at pp. 31–32) Whirlpool 

commented that the development of a test procedure for ventless electric combination 

washer/dryers is not worth the time and resources necessary to develop it and suggested that 

DOE not proceed with such an effort. (Whirlpool, No. 22 at p. 1) DOE is not aware of repeatable 

and representative test methodologies to accurately measure the efficiency of a combined wash63 
 

 

 

 

 

 

 

 

dry cycle. DOE notes that the clothes washer test procedure requires the measurement of 

multiple load sizes (minimum, maximum, and average values) as well as multiple cycle settings 

and water temperatures, but the clothes dryer test procedure requires only a single test load size 

with a single timed dry cycle with the highest temperature setting. DOE is not aware of how the 

test load sizes and cycle settings would be aligned to produce accurate and representative test 

results. DOE also notes that the maximum load size for the washing portion of the cycle (sized 

according to the capacity of the drum), may be larger than the load size recommended by 

manufacturers for the drying portion of the cycle, and thus it is not clear what size test load 

should be specified for a combined cycle. For these reasons, DOE is not adopting a test 

procedure to measure a full combined wash-dry cycle. DOE also notes that the efficiency of the 

washer portion of a combination washer/dryer is covered under the minimum energy 

conservation standards for clothes washers, and that the TP Final Rule amended the clothes dryer 

test procedure to include methods for measuring the energy use of the drying portion of a 

combination washer/dryer. 

d. Consumer Usage Habits 

Annual Cycles 

DOE published a final rule on August 27, 1997, amending the DOE clothes washer test 

procedure to lower the annual clothes washer use cycle value from 416 to 392 cycles per year, a 

value DOE determined to be more representative of current usage patterns. 62 FR 45484. 

Further, the revised DOE clothes washer test procedure assumes that 84 percent of all clothes 

washer loads are dried in clothes dryers. Thus, the annual usage pattern for clothes dryers would 

be 329 cycles per year. In addition, in the recently proposed amendments to the clothes washer 

64 
 

 

 

 

 

 

 

 

 

test procedure, DOE proposed to amend the number of cycles per year to 295. 75 FR 57556, 

57564 (Sept. 21, 2010). In contrast, the current DOE residential clothes dryer test procedure in 

appendix D assumes an average annual clothes dryer use of 416 cycles per year. (10 CFR 

430.23(d)(1)) 

DOE stated in chapter 2 of the preliminary TSD that it was reviewing available data on 

the number of annual clothes dryer cycles, and would consider amendments to its test procedure 

to accurately reflect the number of annual clothes dryer cycles for the clothes dryer tests. 

The Joint Petitioners and ACEEE commented that DOE should update the number of 

clothes dryer cycles per year based on the best available data (ideally based on a nationally 

representative sample). (Joint Petitioners, No. 33 at p. 25; ACEEE, No. 24 at p. 1) The California 

Utilities supported reducing the clothes dryer cycles per year from 416 to 329 to reflect new 

Energy Information Administration (EIA)’s “Residential Energy Consumption Survey” (RECS) 

survey data on household use. (California Utilities, No. 31 at pp. 2–3, 12) According to AHAM, 

a recent Proctor & Gamble (P&G) consumer survey showed that the average consumer dries 

5.35 loads per week, or 278 load per year, which is essentially identical to the value estimated by 

RECS (279 cycles per year), providing good verification for the RECS approach. AHAM 

commented that DOE should ensure that any value used in the economic portion of the 

rulemaking analysis (that is, cycles per year) be used in the engineering analysis, and that the test 

procedure be modified to reflect this value. (AHAM, No. 25 at p. 9) 

65 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

As discussed in the TP Final Rule, DOE amended its clothes dryer test procedure to 

change the number of clothes dryer cycles per year from 416 to 283 based on data from the 2005 

RECS. 76 FR 972, 977 (January 6, 2011). DOE notes that this value is in close agreement with 

the estimates provided in the P&G data (278 cycles per year). DOE also noted in the TP SNOPR 

that data from the 2004 California Statewide Residential Appliance Saturation Study (RASS), 

which surveyed appliance product usage patterns, including clothes dryers, indicated an average 

of 4.69 loads per week, or approximately 244 loads per year, which is in agreement with the 

downward trend of the number of clothes dryer cycles per year. Because the 2004 California 

Statewide RASS provides only a limited dataset, however, DOE stated in the TP SNOPR that it 

did not intend to rely only on this data to determine an appropriate number of annual use cycles 

for the clothes dryer test procedure. 75 FR 37594, 37625 (June 29, 2010). DOE believes that 

these data sources provide sufficient justification for the revised value of 283 cycles per year 

using the RECS-based approach. 

Cycle Time 

Edison Electric Institute (EEI) commented that DOE’s assumption of 8,620 standby 

hours leaves 140 active mode hours which would correspond to 20 minutes per drying cycle (if 

the assumption is that there are 416 dryer cycles per year). EEI questioned whether this was 

accurate and stated that DOE should review those numbers. (EEI, Public Meeting Transcript, No. 

21.4, at p. 49) DOE notes that the TP Final Rule amends the DOE clothes dryer test procedure to 

lower the initial RMC of the clothes load from 70 percent to 57.5 percent which will result in a 

decreased cycle time. DOE also notes that the amendments in the TP Final Rule to increase the 

test load size for standard size dryers from 7 lb. to 8.45 lb. as well as changing the water 

66 
 

 

 

 

 

 

 

 

 

 

temperature for test load preparation from 100 °F to 60 °F will result in an increased cycle time. 

76 FR 972, 988 (January 6, 2011). The TP Final Rule also amended the clothes dryer test 

procedure to change the number of cycles per year from 416 to 283. 76 FR 977. Based on the 

amendment to the number of annual use cycles, DOE notes that the cycle length would be 

approximately 30 minutes (140 annual active mode hours / 283 active mode cycles per year). 

DOE is unaware, however, of consumer usage data indicating that the number of active mode 

hours per year has changed. For these reasons, DOE did not change the number of clothes dryer 

active mode hours in the TP Final Rule. 

Initial RMC 

The DOE clothes dryer test procedure in appendix D specifies that the clothes load have 

an initial RMC of 70 ± 3.5 percent. DOE stated in the preliminary TSD that a review of 

residential clothes washer models in the California Energy Commission (CEC) product database 

suggests that the average RMC is less than the nominal 70 percent that is currently provided for 

in the DOE clothes dryer test procedure. Therefore, DOE stated it was considering amendments 

to the clothes dryer test procedure to address RMC. 

The Joint Petitioners and ACEEE commented that DOE should update the initial RMC 

based on the best available data (ideally based on a nationally representative sample). (Joint 

Petitioners, No. 33 at p. 25; ACEEE, No. 24 at p. 1) NRDC commented that DOE’s initial RMC 

assumptions do not reflect today’s washing machines and should be revised to better reflect 

current washer technology. (NRDC, No. 26 at pp. 2, 4) NRDC commented that the ECOS report 

summarized test results for a single clothes washer which showed that the RMCs after the wash 

67 
 

 

 

 

 

 

 

 

 

 

cycle is finished are 70-percent RMC for cotton bath towels and 40-percent RMC for the DOE 

50/50 cotton/polyester test cloths. (NRDC, No. 30 at pp. 30–31) NRDC also stated that the 

energy consumption of a clothes dryer decreases when the initial RMC is lower, but not in direct 

proportion to the lowered water content because energy is still used to heat and move the air, 

cloth and metal. (NRDC, No. 26 at pp. 2, 4) The California Utilities and the NPCC both 

supported reducing the initial RMC from the current 70 percent to a value nearer to 56 percent, 

based on data submitted by AHAM, recognizing that today's washers have faster spin speeds and 

typically leave less water in the clothes. (California Utilities, No. 31 at pp. 2, 12; NPCC, No. 32 

at p. 2) However, NPCC also commented that even an initial RMC of 56 percent may not reflect 

the RMC produced by higher efficiency clothes washers that may be required as a result of the 

current DOE rulemaking for those products. NPCC commented that that the average RMC for 

clothes washers in the July 2008 CEC appliance product directory was only 46 percent (as 

presented by DOE), which is well below its proposed revised value. (NPCC, No. 32 at p. 2) 

AHAM and Whirlpool supported using the industry shipment-weighted average 

residential clothes washer RMC of 47 percent derived from data provided by AHAM. They 

commented that DOE should use the 47-percent RMC in both the engineering and economic 

analyses; modify the test procedure by changing the RMC from 70 percent to 47 percent; and 

modify the baseline energy factor to reflect the change in the test procedure. Whirlpool added 

that failure to do so will result in overstating clothes dryer energy use, thus rendering all payback 

and LCC calculations erroneous. (AHAM, No. 25 at p. 10; Whirlpool, No. 22 at pp. 2–3) AHAM 

also stated that data collected by industry showed a 22-percent increase in EF when the initial 

RMC is changed to 56 percent. AHAM commented that they expect EF will increase further as 

68 
 

 

 

 

 

 

 

 

 

 

 

RMC is reduced to 47 percent, but that the relationship is not expected to be linear. (AHAM No. 

25 at p. 10) 

BSH also commented that it supports reducing the initial RMC for testing purposes, and 

added that the DOE test procedure should be defined before any energy conservation standard 

levels are established. (BSH, No. 23 at p. 6) BSH also commented that it should be clarified 

which energy consumption results from each change in the test procedure before a suitable 

classification can be done and added that a round robin test may be helpful to estimate the energy 

levels. (BSH, No. 23 at p. 6) 

In the TP SNOPR, DOE proposed to change the initial RMC from 70 percent to 47 

percent based on shipment-weighted clothes washer RMC data provided by AHAM. 75 FR 

37594, 37626–31 (June 29, 2010). As discussed in the TP Final Rule, DOE received comments 

in response to the TP SNOPR that the shipment-weighted average RMC value in the AHAM 

data was based on the clothes washer RMC, which uses an RMC correction factor to normalize 

testing results from different lots of test cloth, but the DOE clothes dryer test procedure should 

instead use the uncorrected RMC value. DOE determined that an initial clothes dryer RMC of 

57.5 percent more accurately represents the moisture content of current laundry loads after a 

wash cycle for the purposes of clothes dryer testing, derived from the 47-percent shipmentweighted RMC for clothes washers (that was based on analysis of data provided by AHAM) 

without the application of the RMC correction factor specified in the DOE clothes washer test 

procedure, as discussed above in this paragraph. DOE validated this estimate using clothes 

washer uncorrected RMC data from testing of a limited sample of representative clothes washers 

69 
 

 

 

 

 

 

 

 

for the DOE clothes washer energy conservation standards rulemaking. As a result, the TP Final 

Rule amended the DOE clothes dryer test procedure to adopt this value for the initial RMC. 76 

FR 972, 977 (January 6, 2011). As discussed in section IV.C.2.a, DOE conducted testing for the 

TP Final Rule in order to analyze how the amendments to the test procedure, including the 

change to the initial RMC, would affect the measured efficiency of clothes dryers. 

Load Size 

Currently the DOE test procedure for clothes dryers requires a 7.00 lb ± .07 lb test load 

for standard-size dryers and a 3.00 lb ± .03 lb test load for compact-size dryers. (10 CFR part 

430, subpart B, appendix D, section 2.7) DOE stated in chapter 2 of the preliminary TSD that it 

was reviewing available data to determine the current representative clothes dryer load size, and 

would consider amendments to its test procedure to accurately reflect the current clothes dryer 

test load size for the clothes dryer tests. 

The Joint Petitioners and ACEEE commented that DOE should update the size of the 

clothes dryer test load based on the best available data (ideally based on a nationally 

representative sample). (Joint Petitioners, No. 33 at p. 25; ACEEE, No. 24 at p. 1) The California 

Utilities and NPCC both supported increasing the test load size from 7 lb. to 8.3 lb., or another 

appropriate value, commenting that 8.3 lb. is more typical of the size of loads in today's larger 

clothes dryers, as based on DOE's distribution of tub sizes from models in the CEC database. 

(California Utilities, No. 31 at p. 2; NPCC, No. 32 at p. 2) NRDC also commented that DOE 

should consider modifying the clothes dryer size criteria, stating that test load sizes for clothes 

dryers do not correlate to the test load sizes for washers and likely do not reflect real life load 

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size. According to NRDC, current clothes dryer size classes are likely inaccurate given that 

today’s clothes dryers can comfortably hold loads of 10 to 17 lb., with more 7 to 8 cubic foot 

3 3 (ft ) models now on the market than models smaller than 7 ft . NRDC commented that DOE 

should reevaluate its clothes dryer size criteria and test load size to better reflect the clothes 

dryers available on the market today. (NRDC, No. 26 at pp. 2, 4; NRDC, No. 30 at p. 30) 

AHAM commented that it prefers that DOE utilize industry values for data such as 

clothes dryer load size. AHAM stated that the shipment-weighted residential clothes washer 

3 drum volume for standard‐size products in 2008 was 3.24 ft , which corresponds to an average 

clothes washer load size of 8.15 lb. AHAM also stated that for compact clothes washers, the 

3 shipment‐weighted average drum volume was 1.5 ft , which corresponds to an average load size 

of 4.70 lb. AHAM added that because compact products are a separate product class, they should 

be treated as such in the analysis. AHAM commented that it supports the use of two separate 

load sizes (8.15 lb. for standard-size and 4.70 lb. for compact-size products), if the modified load 

size is used in both the engineering and economic analyses, and if the test procedure is modified 

to be consistent with this analysis and the baseline EF is modified to reflect the change in load 

size. (AHAM, No. 25 at pp. 10–11) 

In the TP Final Rule, DOE amended the clothes dryer test procedure to change the load 

size from 7.00 lb ± .07 lb to 8.45 lb ± .085 lb based on the historical trends of the shipmentweighted average tub volume for residential clothes washers from 1981 to 2008 and the 

corresponding percentage increase in clothes washer load sizes (as specified in the load size table 

5.1 in the DOE clothes washer test procedure at 10 CFR part 430, subpart B, appendix J1), which 

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is assumed to proportionally impact clothes dryer load size. 76 FR 972, 977 (January 6, 2011). 

DOE believes that this estimate using the percentage increase in load size based on trends in 

clothes washer tub volumes would produce a more representative value than simply using the 

nominal load size value in the clothes washer test procedure, as suggested by AHAM. DOE does 

not have any consumer usage data indicating that consumers always machine dry the same size 

load from the wash cycle such that the average clothes washer load size can be directly applied 

to the clothes dryer test procedure, as suggested by AHAM. As discussed in section IV.C.2.a, 

DOE conducted testing for the TP Final Rule in order to analyze how the amendments to the test 

procedure, including the change to the load size, would affect the measured efficiency. 

DOE stated in the TP Final Rule that it believes that most compact clothes dryers are 

used in conjunction with compact-size clothes washers, and DOE is not aware of data on the 

trends of compact clothes washer tub volumes that would suggest that the tub volume for such 

clothes washers has changed significantly. 76 FR 972, 1014 (January 6, 2011). DOE did not 

receive any such data in response to its requests in the TP SNOPR. In addition, as discussed 

above, DOE does not have any consumer usage data indicating that consumers always machine 

dry the same size load from the wash cycle such that the average clothes washer load size can be 

directly applied to the clothes dryer test procedure, as suggested by AHAM. For these reasons, 

DOE did not revise the test load size for compact clothes dryers in the TP Final Rule. Id. 

NRDC also commented that the ECOS report states that if DOE were to test each model 

across a wide range of load sizes and report multiple values, it would help consumers choose the 

appropriate sized clothes dryer and to fill it with the recommended amount of clothing to dry as 

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efficiently as possible. (NRDC, No. 30 at p. 30) DOE is not aware of any data indicating what 

load sizes typical consumers use or data on the percentage of clothes dryer cycles at different 

load sizes to determine how such results would be used to calculate an energy use or energy 

efficiency metric. DOE is also unaware of data showing how such a change would affect the 

measured EF compared to the existing test procedure, as required by EPCA. (42 U.S.C. 

6293(e)(1)) DOE notes that requiring additional test cycles for different size loads would add 

significant testing burden on manufacturers. For these reasons, DOE did not amend the clothes 

dryer test procedure to require the testing of multiple test load sizes in the TP Final Rule. 

BSH proposed that tumble clothes dryers be tested with a load size relative to the drum 

volume, and that this relationship be linear. BSH commented that the load size that the consumer 

uses generally matches the drum size of the clothes dryer (the larger the drum the higher the 

average load size dried). According to BSH, using only two load sizes for a wide range of drum 

volumes will cause unfairness in comparison of different clothes dryers. For example, a standard 

clothes dryer with a 125-liter drum volume but 60 centimeter (cm) housing (which is right above 

the limit to be “compact”) has an unfair advantage when its energy efficiency is measured due to 

the fact that the load fills the drum much better than in a larger appliance. (BSH, No. 23 at p. 4) 

DOE is not aware of any consumer usage data indicating how load size varies with clothes dryer 

drum capacity. In addition, DOE is not aware of any data indicating how such a change would 

affect the measured efficiency. For these reasons, DOE did not amend the clothes dryer test 

procedure to require that the load size vary with drum capacity. 

Water Temperature for Test Load Preparation 

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The current clothes dryer test procedure specifies a water temperature of 100 °F ± 5 °F 

for the test load preparation. (10 CFR part 430, subpart B, appendix D, section 2.7) The 

California Utilities, ACEEE, and NPCC stated that this initial clothes load temperature may have 

been common when most clothes washers used a hot water rinse. However, today almost all 

clothes washers now default to a cold water final rinse to save water heating energy. (California 

Utilities, No. 31 at pp. 3, 12; ACEEE, No. 24 at p. 2; NPCC, No. 32 at p. 2) According to 

ACEEE, today's clothes washers typically have a cold rinse default and consumers increasingly 

select cold water wash and rinse in response to public information campaigns and the 

introduction of special “cold water wash” detergents. (ACEEE, No. 24 at p. 2) The California 

Utilities, ACEEE, and NPCC recommended that DOE align the clothes dryer test method with 

the clothes washer test method by reducing the water temperature for clothes dryer test load 

preparation to 60 °F ± 5 °F. (ACEEE, No. 24 at p. 2) 

As discussed in the TP Final Rule, DOE analyzed 2005 RECS data on the rinse water 

temperatures selected by consumers for clothes washer cycles, which indicates that for 

consumers that use a clothes washer in the home, approximately 80 percent of wash cycles per 

year use a cold rinse. 76 FR 972, 996 (January 6, 2011). In addition, DOE also noted that the 

clothes washer test procedure specifies a warm rinse temperature use factor of 27 percent, 

suggesting that for the majority of clothes washer cycles, consumers use the cold rinse. (10 CFR 

part 430, subpart B, appendix J1) DOE also sought comment on the warm rinse temperature use 

factor in the recent proposal to amend the test procedure for residential clothes washers because 

it received consumer usage survey data from a manufacturer indicating that, for one clothes 

washer model with no cold rinse option on the cycle recommended for cotton clothes and a 

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default cold rinse on all other cycles, users participating in the survey reported using warm rinse 

for 1.6 percent of all cycles. 75 FR 57556, 57571 (Sept. 21, 2010) For these reasons, DOE 

amended the clothes dryer test procedure to change the water temperature for clothes dryer test 

load preparation from 100 °F ± 5 °F to 60 °F ± 5 °F to be more representative of the clothes load 

after a cold rinse cycle at the end of the wash cycle. 76 FR 972, 996 (January 6, 2011). 

Test Cloth 

The current clothes dryer test procedure specifies the use of energy test cloth consisting 

of a pure finished bleach cloth, made with a momie or granite weave, which is a blended fabric 

of 50-percent cotton and 50-percent polyester. Each energy test cloth measures 24 inches by 36 

inches. Additional specifications are provided in the test procedure for the weight, thread count, 

and allowable shrinkage. (10 CFR part 430, subpart B, appendix D, section 2.7) 

The ECOS report stated that DOE should test a mix of cotton and synthetics of various 

sizes, including large sheets, towels, and jeans, rather than only testing small, uniform 

synthetic‐blend test cloths to more closely approximate real-world performance. The ECOS 

report also stated that this would deal more fairly with the real-world situation in which some 

fabrics have finished drying before others, causing the load to either finish before everything is 

dry or after some of the fabrics have been over‐dried. NRDC also commented that the ECOS 

report presented test results using different mixes of test loads which showed that clothes dryers 

often stopped with the synthetic quite dry (less than 2-percent final RMC) but the cotton still 

damp (greater than 6-percent RMC). According to NRDC, if DOE were to test each model 

across a wide range of load types and report multiple values, it would help consumers choose an 

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appropriately sized clothes dryer and to fill it with the recommended amount of clothing so that it 

would dry as efficiently as possible. (NRDC, No. 30 at pp. 22, 30) NRDC added that in this realworld scenario, clothes dryers may be less effective due to clothing balling up or the clothes 

dryer shutting off early due to a variety in cloth blends. NRDC added that certain techniques 

such as agitating the drum or reversing the cycle may help mitigate these problems and 

potentially increase efficiency in a real world scenario. NRDC also added that the standard DOE 

test cloths do not constitute a typical load and therefore do not accurately test clothes dryers’ 

effectiveness at drying loads that have a variety of fabric types or are more likely to clump. 

NRDC suggested a mix of 100-percent cotton and 50:50 cotton/polyester as an alternative test 

load. (NRDC, No. 26 at pp. 1, 3; NRDC, Public Meeting Transcript, No. 21.4 at p. 43) 

DOE is unaware of data to determine the composition of clothing types and materials that 

would be more representative of typical consumer clothing loads than the existing DOE test cloth 

and still produce accurate and repeatable results. Similarly, DOE is unaware of data showing the 

test-to-test repeatability of different test loads. Based on discussions with manufacturers, DOE 

understands the test material specified in the existing DOE clothes dryer test procedure produces 

the most repeatable results, and other tests loads are less repeatable. In addition, DOE also notes 

that requiring additional test cycles for loads with different clothes types and materials would 

add significant testing burden on manufacturers. For these reasons, DOE did not amend the 

clothes dryer test procedure in the TP Final Rule to change the DOE test load or to require the 

testing of multiple test loads composed of different clothes types and materials. 

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e. Drum Capacity Measurement 

The Joint Petitioners commented that DOE should clarify section 3.1 of the clothes dryer 

test procedure regarding the measurement of drum capacity to specify that the clothes dryer’s 

rear drum surface be supported on a platform scale to “prevent deflection of the drum surface...” 

instead of “prevent deflection of the dryer.” (Joint Petitioners, No. 33 at p. 25) As discussed in 

the TP Final Rule, DOE agrees with the comments that the reference to deflection of the “dryer” 

is unclear and should be clarified to specify that the clothes dryer’s rear drum surface should be 

supported on a platform scale to prevent deflection of the drum surface. For this reason, DOE 

amended the clothes dryer test procedure in TP Final Rule to reflect this change. 76 FR 972, 

1019 (January 6, 2011). 

f. HVAC Effects 

According to EPCA, any prescribed or amended test procedures shall be reasonably 

designed to produce test results which measure energy efficiency, energy use, water use, or 

estimated annual operating cost of a covered product during a representative average use cycle or 

period of use. (42 U.S.C. 6293(b)(3)) 

NRDC and NPCC commented that DOE should analyze the effects of clothes dryers on a 

home’s heating and cooling energy use. (NRDC, No. 26 at pp. 1, 4; NPCC, No. 32 at p. 2) 

NRDC also commented that the current test procedure does not analyze the clothes dryer's effect 

on the heating and cooling of the surrounding room, in particular, whether the clothes dryer 

warms the room, cools it, or leaves it unchanged. NRDC stated that the test procedure does not 

distinguish between clothes dryers that vent their exhaust air outside (and require makeup air to 

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be conditioned), and those that are unvented. (NRDC, No. 26 at pp. 1, 4; NRDC, No. 30 at p. 31) 

NPCC also commented that DOE's analysis of the economics of heat recovery clothes dryers 

should incorporate the reduced impact on space conditioning of this technology option. (NPCC, 

No. 32 at p. 2) The California Utilities recommended that the DOE clothes dryer test procedure 

be amended to measure the total airflow volume during the test cycle in order to gather data on 

heating, ventilation, and air conditioning (HVAC) loading. (California Utilities, No. 31 at pp. 9, 

12) 

As discussed above, EPCA requires that any prescribed or amended test procedures be 

reasonably designed to produce test results which measure energy efficiency, energy use, water 

use, or estimated annual operating cost of a covered product during a representative average use 

cycle or period of use. (42 U.S.C. 6293(b)(3)) DOE believes that accounting for the effects of 

clothes dryers on HVAC energy use is inconsistent with the EPCA requirement that a test 

procedure measure the energy efficiency, energy use, or estimated annual operating cost of a 

covered product. As a result, DOE did not revise the clothes dryer test procedure to account for 

HVAC energy use in the TP Final Rule and does not account for HVAC energy use in these 

standards. 

g. Efficiency Metric 

The energy efficiency metric currently used for clothes dryer energy conservation 

standards, EF, is defined on the basis of a per-cycle measure of the lb. of clothes dried per kWh. 

(10 CFR 430.23) 

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BSH commented that DOE should calculate yearly energy consumption for clothes 

dryers by considering a defined amount of laundry dried within a year. BSH stated that the 

energy consumption for the yearly load dried in small clothes dryer should be correlated to the 

energy consumption when the same yearly load is dried in a larger clothes dryer. BSH added that 

if only the number of loads is used then for a larger clothes dryer, the energy labeled would refer 

to a much larger amount of clothing than for a smaller clothes dryer. According to BSH, the 

values would not be comparable and it would appear to the consumer that the larger clothes dryer 

uses more energy per cycle than the smaller. In reality, when using a compact size clothes dryer 

consumers would run more cycles per year to dry their yearly amount of laundry. (BSH, No. 23 

at p. 5) DOE is not aware of consumer usage data showing the relationship between clothes dryer 

drum capacity and the amount of laundry dried by the consumer per year that would suggest that 

consumers typically dry the same amount of clothing per year, regardless of the drum capacity. 

For these reasons, DOE did not amend the clothes dryer test procedure in the TP Final Rule to 

specify a single value for the amount of laundry dried per year. 

2. Room Air Conditioner Test Procedure 

a. Standby Mode and Off Mode 

Referenced Standards 

As noted above, EPCA directs DOE to amend its test procedures to include measures of 

standby mode and off mode energy consumption, taking into consideration the most current 

versions of IEC Standard 62301 and IEC Standard 62087. (42 U.S.C. 6295(gg)(2)(A)) For the 

reasons discussed for the clothes dryer test procedure, DOE determined that only IEC Standard 

62301 is relevant to the room air conditioner test procedure. 

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AHAM supported DOE’s evaluation of IEC Standard 62301 CDV for potential revisions 

to address standby mode and off mode power in the room air conditioner test procedure. AHAM 

commented that DOE would thus harmonize with international standards, including those 

developed in Canada and Europe. (AHAM, Public Meeting Transcript, No. 21.4 at p. 30) As 

discussed for clothes dryers in section III.A.1.a, DOE considered the current version, IEC 

Standard 62301 First Edition, as required by EPCA. For the reasons stated in the TP Final Rule, 

DOE amended its test procedures for room air conditioners in the final rule to incorporate by 

reference the clauses from IEC Standard 62301 First Edition proposed in the TP SNOPR, as well 

as the provisions of IEC Standard 62301 CDV for the mode definitions. 76 FR 972, 975-6 

(January 6, 2011). DOE may consider incorporating by reference clauses from IEC Standard 

62301 Second Edition when that version has been published. 

Testing Procedures 

EEI commented that the total number of standby hours would be 8,010 if a product is 

plugged in all year (8,760 total hours in a year less the 750 cooling mode operating hours), and 

closer to 2,000 if unplugged. EEI requested clarification on the source of the 5,115 standby 

hours. (EEI, Public Meeting Transcript, No. 21.4 at p. 37) DOE notes that the estimate of 5,115 

total standby and off mode hours, explained in greater detail in the TP SNOPR (75 FR 37594, 

37610 (June 29, 2010), assumes (1) the cooling season length is 90 days or 2,160 hours; (2) half 

of the products in the field would be unplugged outside of the cooling season, while the others 

would be in standby and/or off mode; and (3) that the cooling season hours not associated with 

active mode cooling are evenly split between off-cycle mode and standby mode or off mode. 

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Off-cycle mode involves operation of the fan but not the compressor. DOE noted in the TP 

NOPR that it is not aware of any reliable data for hours spent in different standby and off modes 

for room air conditioners. 73 FR 7439, 74648–49 (Dec. 9, 2008). In the absence of data 

suggesting a different allocation of annual hours, DOE adopted the estimate of 5,115 annual 

hours standby and off mode hours in the TP Final Rule. 76 FR 972, 991 (January 6, 2011). 

b. Active Mode Referenced Standards 

The current DOE room air conditioner test procedure incorporates by reference two 

industry test standards: (1) American National Standard (ANS) (since renamed American 

16 National Standards Institute (ANSI)) Z234.1-1972, “Room Air Conditioners;” and (2) 

American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) 

17 Standard 16-69, “Method of Testing for Rating Room Air Conditioners.” (10 CFR part 430, 

subpart B, appendix F, section 1) 

AHAM commented that its current room air conditioner standard is American National 

Standards Institute (ANSI)/AHAM RAC-1-2008. (AHAM, Public Meeting Transcript, No. 21.4 

at p. 35; AHAM, No. 25 at p. 13) As discussed in the TP Final Rule, DOE adopted the 

amendments to reference the relevant sections of the current industry test standards for room air 

conditioners, which are designated as: (1) ANSI/AHAM RAC-1-R2008, “Room Air 

Conditioners;” and (2) ANSI/ American Society of Heating, Refrigerating, and Air-Conditioning 

Engineers (ASHRAE) Standard 16-1983 (RA 2009), “Method of Testing for Rating Room Air 

16 ANSI standards are available at www.ansi.org. 17 ASHRAE standards are available at www.ashrae.org. 

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Conditioners and Packaged Terminal Air Conditioners” (ANSI/ASHRAE Standard 16-1983 (RA 

2009)). 76 FR 972, 978 (January 6, 2011) 

c. Annual Active Mode Hours 

The current DOE room air conditioner test procedure assumes that room air conditioners 

have an average annual use of 750 hours. (10 CFR part 430.23(f)) DOE noted in chapter 3 of the 

preliminary TSD that DOE’s TSD from September 1997, issued in support of the 1997 room air 

18 conditioner rulemaking, provides estimates for average annual operating hours closer to 500. 

DOE noted in the preliminary TSD developed in support of today’s final rule, however, that a 

similar assessment of room air conditioner hours of operation developed in support of the June 

2010 TP SNOPR suggests that the annual hours of operation have since increased and are now in 

fact close to 750. 75 FR 37594, 37633 (June 29, 2010). 

EEI commented that the active mode hours for room air conditioners may be more than 

the 750 hours currently specified in the DOE room air conditioner test procedure and questioned 

whether the 750 hours reflect both residential and commercial applications. (EEI, Public Meeting 

Transcript, No. 21.4 at p. 36) As discussed in the TP Final Rule, DOE noted that estimates using 

19 data from the EIA’s 2005 RECS support maintaining the 750 annual operating hours 

specification. As a result, DOE did not amend the room air conditioner test procedure to change 

the number of annual operating hours. 76 FR 972, 978 (January 6, 2011). 

18 U.S. Department of Energy—Office of Energy Efficiency and Renewable Energy, Technical Support Document 

for Energy Conservation Standards for Room Air Conditioners. September 1997. Chapter 1, section 1.5. 

Washington, DC, available at www.eere.energy.gov/buildings/appliance_standards/residential/room_ac.html 19 U.S. Department of Energy-Energy Information Administration. “Residential Energy Consumption Survey,” 

2005 Public Use Data Files, 2005. Washington, DC. Available online at: www.eia.doe.gov/emeu/recs/ 

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d. Part-Load Operation 

DOE noted in the preliminary TSD (chapter 5, “Engineering Analysis”) that the DOE 

room air conditioner test procedure at appendix F measures full-load performance but is not able 

to assess energy savings associated with technologies which improve part-load performance. 

DOE considered amendments to its room air conditioner test procedure to measure partload performance, but did not propose such changes, as explained in the June 2010 TP SNOPR 

and the TP final rule. 75 FR 37594, 37634 (June 29, 2010); 76 FR 972, 1016 (January 6, 2011). 

DOE concluded that developing an additional test for part load, or switching to a seasonal metric 

to integrate part-load performance is not warranted. DOE noted that 1) sufficient information is 

not available at this time regarding use of room air conditioner features that prevent overcooling; 2) widespread use of part-load technology in room air conditioners is not likely to be 

stimulated by the development of a part-load or seasonal metric at this time, and therefore, the 

significant effort required to develop an accurate part-load metric is not likely to be justified by 

the expected minimal energy savings; and 3) key design changes that improve full-load 

efficiency also improve part-load efficiency, so the existing EER metric is already a strong 

indication of product efficiency over a wide range of conditions. 

DOE stated in the preliminary TSD that it did not consider technologies such as variable 

speed compressors and thermostatic expansion valves as design options during the engineering 

analysis because these design options save energy only during part-load operation. DOE expects, 

based on available data and the considerations discussed in the test procedure SNOPR and 

reiterated above, that such technologies will not save enough energy to be cost effective. 

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DOE requested comments regarding additional design options that it should consider in 

the engineering analysis. (See the preliminary TSD Executive Summary, section ES.4) 

NRDC commented that DOE should further analyze the efficiency of part-load operation. 

NRDC stated that DOE assumed that room air conditioners are generally undersized and run at 

full capacity and, therefore, did not take into consideration the potential to improve part-load 

efficiency. NRDC recommended that DOE further investigate the underlying assumption that 

room air conditioners are almost always run at full capacity and analyze the potential to improve 

part-load operation efficiency. (NRDC, No. 26 at p. 5) The comment does not provide any new 

information regarding room air conditioner operation that would allow development of an 

appropriate seasonal efficiency metric. As discussed in the TP Final Rule, development of such a 

metric that would take part load operation into account would require knowledge of the 

distribution of hours spent by room air conditioners at different load levels and at different 

outdoor and indoor temperature and humidity conditions. 76 FR 972, 1016 (January 6, 2011). 

Because such data is not available, DOE cannot establish an appropriate efficiency metric and 

cannot properly evaluate part-load technologies. DOE may amend the test procedure to account 

for part-load performance in a future rulemaking if sufficient information becomes available. 

DOE also notes that the existing EER metric, which represents most of the CEER metric 

that is the basis of the energy standard prescribed in today’s rule, is already a strong indicator of 

product efficiency over a wide range of conditions. Most of the design options that improve 

efficiency measured using EER would also improve efficiency measured using a part-load 

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metric. For these reasons, DOE did not amend its room air conditioner test procedure to measure 

part-load performance. 76 FR 972, 1016 (January 6, 2011). 

e. Distribution of Air 

NRDC commented that DOE should consider how effectively room air conditioners 

distribute air throughout the room, adding that if all the cooling is provided by convection into 

the space, the effectiveness of delivering that cooling by the fan and integral diffuser may have a 

significant impact on energy use. NRDC stated that the DOE test procedure should take into 

account how far into the room the airflow travels and whether the unit allows for adjustments to 

the airflow pattern. NRDC also commented that many units will be placed at sill height, but 

buildings with wall sleeves will likely have units that are installed below the sill, which could 

pose different concerns with room air distribution to provide adequate mixing to avoid drafts. 

(NRDC, No. 26 at p. 6) 

DOE notes that the DOE test procedure measures the cooling delivered by the room air 

conditioner regardless of the distribution of the cooling air within the test chamber. Thus, design 

options that optimize distribution of the cooling air would not improve the measurement. 

DOE agrees with the comment’s premise that the energy use of a room air conditioner 

used by a consumer may be affected by the air circulation patterns it establishes in a room. For 

example, a consumer located in a room far from the unit and not in line with the product’s 

discharge air outlet may keep the unit operating longer to achieve comfortable local room 

conditions. This influence has as much to do with installation and use as it does with product 

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characteristics. The relationship between room air circulation and room air conditioner energy 

use is not sufficiently well understood to allow any consideration of integration of such factors 

into the energy use metric. DOE is not aware of data evaluating the impact a product’s air 

distribution patterns have on product energy use by consumers. As a result, this issue is not 

addressed by today’s rule. 

3. Effects of Test Procedure Revisions on the Measured Efficiency 

In any rulemaking to amend a test procedure, DOE must determine to what extent, if any, 

the proposed test procedure would alter the measured energy efficiency of any covered product 

as determined under the existing test procedure. (42 U.S.C. 6293(e)(1)) If DOE determines that 

the amended test procedure would alter the measured efficiency of a covered product, DOE must 

amend the applicable energy conservation standard accordingly. In determining the amended 

energy conservation standard, the DOE must measure, pursuant to the amended test procedure, 

the energy efficiency, energy use, or water use of a representative sample of covered products 

that minimally comply with the existing standard. The average of such energy efficiency, energy 

use, or water use levels determined under the amended test procedure shall constitute the 

amended energy conservation standard for the applicable covered products. (42 U.S.C. 

6293(e)(2)) EPCA also states that models of covered products in use before the date on which 

the amended energy conservation standard becomes effective (or revisions of such models that 

come into use after such date and have the same energy efficiency, energy use, or water use 

characteristics) that comply with the energy conservation standard applicable to such covered 

products on the day before such date shall be deemed to comply with the amended energy 

conservation standard. (42 U.S.C. 6293(e)(3)) 

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EPCA also provides that amendments to the test procedures to include standby mode and 

off mode energy consumption will not determine compliance with previously established 

standards. (U.S.C. 6295(gg)(2)(C)) Because the amended test procedures for standby mode and 

off mode energy consumption would not alter existing measures of energy consumption or 

efficiency, these amendments would not affect a manufacturer’s ability to demonstrate 

compliance with previously established standards. 

For the TP Final Rule, DOE investigated how the amended test procedures would affect 

the measured efficiency as compared to the existing DOE test procedures. The following sections 

discuss these effects for each product. 

a. Clothes Dryers 

The Joint Petitioners proposed that the final rule amending the clothes dryer test 

procedure also amend the standards in the Joint Petition according to the procedures in section 

323(e)(2) of EPCA, except that for the purposes of establishing a representative sample of 

products, DOE should choose a sample of minimally compliant dryers which automatically 

terminate the drying cycle at no less than 4-percent RMC. (Joint Petitioners, No. 33 at p. 17) 

As discussed above, DOE did not adopt amendments to the clothes dryer test procedure 

to better account for automatic cycle termination. As a result, DOE did not consider any 

revisions to the energy conservation standards based on amendments for automatic cycle 

termination. However, DOE notes that EPCA does not include any exceptions that would allow 

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for the measurement of only dryers that automatically terminate the drying cycle at no less than 

4-percent RMC. (42 U.S.C. 6293(b)(1)-(3)) 

As part of the TP Final Rule, DOE conducted testing on a sample of 17 representative 

clothes dryers to evaluate the effects of the amendments to the clothes dryer test procedure on the 

measured EF. 76 FR 972, 1026-27 (January 6, 2011). DOE tested these units according to the 

amended clothes dryer test procedure in the TP Final Rule, conducting up to three tests for each 

test unit and averaging the results. The results from this testing are shown below in Table III.2. 

DOE noted in its testing that the amendments to the initial RMC, water temperature for test load 

preparation, and load size had an effect on the measured EF as compared to the existing test 

procedure. For vented electric-standard size clothes dryers tested using the amended test 

procedure, the measured EF increases by an average of about 20.1 percent. For vented gas 

clothes dryers, the measured EF increased by an average of about 19.8 percent. For vented 

electric compact 120V and 240V clothes dryers, the measured EF increased by an average of 

about 15.6 and 12.8 percent, respectively. For ventless electric compact 240V clothes dryers and 

ventless electric combination washer/dryers, the measured EF increased by an average of about 

13.6 and 11.4 percent, respectively, as compared to the measured EF using the existing test 

procedure with only the amendments for ventless clothes dryers. (That is, without the changes to 

the initial RMC, water temperature for test load preparation, or other changes) DOE noted that 

the increase in measured EF is greater for the standard-size products (that is, vented electric 

standard and vented gas clothes dryers) than for compact-size products due to the additional 

amendments to increase the test load size for standard-size products. 76 FR 972, 1027 (January 

6, 2011). As discussed in section IV.C.2.a, DOE applied these percentage increases in the 

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measured EF based on the test procedure amendments for each product class to the efficiency 

levels proposed in the preliminary analysis. 

Table III.2 DOE Test Results to Evaluate the Effects of the Clothes Dryer Test Procedure 

Amendments on Measured EF 

Test Unit 

Average EF lb/kWh 

Change 

Current Test 

Procedure 

Amended Test 

Procedure 

Vented Electric 

Standard 

Unit 1 3.07 3.69 20.4% 

Unit 2 3.14 3.77 19.5% 

Unit 3 3.20 3.83 19.6% 

Unit 4 3.28 3.92 19.4% 

Unit 5 3.24 3.96 22.5% 

Unit 6 3.12 3.72 19.1% 

Vented Gas 

Unit 7 2.78 3.36 20.6% 

Unit 8 2.83 3.40 19.9% 

Unit 9 2.85 3.42 20.2% 

Unit 10 2.80 3.37 20.5% 

Unit 11 2.98 3.50 17.6% 

Vented Electric 

Compact (240V) 

Unit 12 3.19 3.56 11.4% 

Unit 13 2.93 3.35 14.2% 

Vented Electric 

Compact (120V) Unit 14 3.23 3.74 15.6% 

Ventless Electric 

Compact (240V) Unit 15 2.37 2.69 13.6% 

Ventless Electric 

Combo Washer/Dryer 

Unit 16 2.01 2.27 12.5% 

Unit 17 2.50 2.76 10.3% 

Table III.3 shows how the current energy conservation standards are affected by the 

amendments to the DOE clothes dryer test procedure. 

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Table III.3 Energy Factor of a Minimally Compliant Clothes Dryer with the Current and 

Amended Test Procedure 

Product Class 

EF lb/kWh 

Existing 

Test 

Procedure 

Amended 

Test 

Procedure 

1. Electric, Standard (4.4 ft3 or greater capacity) 3.01 3.62 

2. Electric, Compact (120 v) (less than 4.4 ft3 capacity) 3.13 3.62 

3. Electric, Compact (240 v) (less than 4.4 ft3 capacity) 2.90 3.27 

4. Gas 2.67 3.20 

b. Room Air Conditioners 

The Joint Petitioners proposed that the final rule amending the room air conditioner test 

procedure amend the standards in the consensus agreement according to the procedures in 

section 323(e)(2) of EPCA. (Joint Petitioners, No. 33 at p. 18) These are the provisions that 

require DOE to adjust the efficiency standard if DOE determines that changes in the energy test 

procedure alter the measured energy use of covered products. While the measured efficiency of 

room air conditioners is altered by the incorporation of standby and off mode energy use in the 

new efficiency metric. However, DOE determined in the TP Final Rule that the amendments to 

the room air conditioner test procedure do not impact the measurement of EER while providing 

more accurate and repeatable measurements of capacity and greater flexibility to manufacturers 

in selecting equipment and facilities. 76 FR 972, 1028 (January 6, 2011). For this reason, DOE 

believes that revisions to the energy conservation standards for room air conditioners because of 

the amendments to the test procedure would not be warranted. 

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B. Technological Feasibility 

1. General 

In each standards rulemaking, DOE conducts a screening analysis based on information it 

has gathered on all current technology options and prototype designs that could improve the 

efficiency of the products or equipment that are the subject of the rulemaking. As the first step in 

such analysis, DOE develops a list of technology options for consideration in consultation with 

manufacturers, design engineers, and other interested parties. DOE then determines which of 

these means for improving efficiency are technologically feasible. DOE considers a technology 

option to be technologically feasible if it is incorporated into commercially available products or 

working prototypes. 10 CFR 430, subpart C, appendix A, section 4(a)(4)(i). 

Once DOE has determined that particular technology options are technologically feasible, 

it further evaluates each of these technology options in light of the following additional screening 

criteria: (1) practicability to manufacture, install, or service; (2) adverse impacts on product 

utility or availability; and (3) adverse impacts on health or safety. Section IV.B of this notice 

discusses the results of the screening analysis for clothes dryers and room air conditioners, 

particularly the designs DOE considered, those it screened out, and those that are the basis for 

the trial standard levels (TSLs) in this rulemaking. For further details on the screening analysis 

for this rulemaking, see chapter 4 of the technical support document accompanying today’s 

direct final rule (direct final rule TSD). 

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2. Maximum Technologically Feasible Levels 

When DOE proposes to adopt an amended standard for a type or class of covered 

product, it must “determine the maximum improvement in energy efficiency or maximum 

reduction in energy use that is technologically feasible” for such product. (42 U.S.C. 6295(p)(1)) 

Accordingly, DOE determined the maximum technologically feasible (“max-tech”) 

improvements in energy efficiency for clothes dryers and room air conditioners in the 

engineering analysis, using the design options used in the most efficient products available on 

the market or in working prototypes. (See chapter 5 of the direct final rule TSD.) Table III.4 lists 

the max-tech levels that DOE determined for this rulemaking. 

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Table III.4 Maximum Technologically Feasible Efficiency Levels for Residential Clothes 

Dryers and Room Air Conditioners 

Residential Clothes Dryers 

Product Class 

MaxTech 

CEF 

lb/kWh 

1. Vented Electric, Standard (4.4 ft3 or greater capacity) 5.42 

2. Vented Electric, Compact (120 V) (less than 4.4 ft3 capacity) 5.41 

3. Vented Electric, Compact (240 V) (less than 4.4 ft3 capacity) 4.89 

4. Vented Gas 3.61 

5. Ventless Electric, Compact (240 V) (less than 4.4 ft3 capacity) 4.03 

6. Ventless Electric Combination Washer/Dryer 3.69 

Room Air Conditioners 

Product Class 

MaxTech 

CEER 

Btu/Wh 

1. Without reverse cycle, with louvered sides, and less than 6,000 Btu/h 11.67 

2. Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h 11.96 

3. Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h 11.96 

4. Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h 11.96 

5A. Without reverse cycle, with louvered sides, and 20,000 to 27,999 Btu/h 10.15 

5B. Without reverse cycle, with louvered sides, and 28,000 Btu/h or more 9.80 

6. Without reverse cycle, without louvered sides, and less than 6,000 Btu/h 10.35 

7. Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h 10.35 

8A. Without reverse cycle, without louvered sides, and 8,000 to 10,999 

Btu/h 

10.35 

8B. Without reverse cycle, without louvered sides, and 11,000 to 13,999 

Btu/h 

10.02 

9. Without reverse cycle, without louvered sides, and 14,000 to 19,999 

Btu/h 

10.02 

10. Without reverse cycle, without louvered sides, and 20,000 Btu/h or 

more 

9.80 

11. With reverse cycle, with louvered sides, and less than 20,000 Btu/h 11.96 

12. With reverse cycle, without louvered sides, and less than 14,000 Btu/h 10.15 

13. With reverse cycle, with louvered sides, and 20,000 Btu/h or more 10.35 

14. With reverse cycle, without louvered sides, and 14,000 Btu/h or more 10.02 

15. Casement-Only 10.35 

16. Casement-Slider 10.35 

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a. Clothes Dryers 

For electric vented and vent-less clothes dryers, the max-tech level corresponds to the 

efficiency improvement associated with incorporating heat pump technology, according to 

information from manufacturer interviews and available research on heat pump dryers. For 

vented gas clothes dryers, the max-tech level is the value proposed in the framework document 

was based on data contained in the CEC product database. AHAM submitted aggregated 

incremental manufacturing cost data in support of this max-tech efficiency level for vented gas 

clothes dryers. As discussed in chapter 5 of the preliminary TSD, multiple manufacturers stated 

during interviews that the current maximum efficiency listed for vented gas clothes dryers in a 

more recent version of the CEC product database is not achievable. Also, as discussed in chapter 

5 of the preliminary TSD, DOE testing of the “maximum-available” vented gas clothes dryer in 

this more recent version of the CEC product database determined that this unit did not achieve 

the rated efficiency. For these reasons, DOE considered the vented gas clothes dryer max-tech 

value for which AHAM submitted aggregated incremental manufacturing costs. This max-tech 

level was supported by multiple manufacturers during interviews. 

b. Room Air Conditioners 

As described in the direct final rule TSD (chapter 5, “Engineering Analysis”), DOE 

conducted a full engineering analysis for seven room air conditioner product classes, which 

comprise a large percentage of identified products on the market. DOE’s approach for extending 

the analysis of the proposed standard levels to the non-analyzed product classes is described in 

chapter 5, “Engineering Analysis”, of the direct final rule TSD. This section of this notice reports 

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specifically on the max-tech efficiency levels for the product classes directly analyzed in the 

engineering analysis. 

DOE used the full set of design options considered applicable to these product classes to 

determine the max-tech efficiency levels. (See chapter 5 of the direct final rule TSD.) Table 

III.5, below, lists the max-tech levels that DOE determined for this rulemaking—the table shows 

the levels for the directly analyzed product classes (see section IV.C regarding discussion of the 

product classes that were directly analyzed). The max-tech levels that DOE determined for this 

rulemaking are based on design options that are used in commercially-available products. 

Table III.5. Max-Tech EERs for the Room Air Conditioner Products Rulemaking 

Analyzed 

Product 

Class 

Description 

Combined 

Energy 

Efficiency Ratio 

(EER) Level 

DOE Final Rule 

Max-Tech. 

1 Less than 6,000 Btu/h, without reverse cycle 

and with louvered sides 11.7 

2 6,000 to 7,999 Btu/h, without reverse cycle and 

with louvered sides N/A * 

3 8,000 to 13,999 Btu/h, without reverse cycle 

and with louvered sides 12.0 

4 14,000 to 19,999 Btu/h, without reverse cycle 

and with louvered sides N/A * 

5A 20,000 Btu/h to 27,999 Btu/h, without reverse 

cycle and with louvered sides 10.2 

5B 28,000 Btu/h or more, without reverse cycle 

and with louvered sides 9.8 

8A 8,000 to 10,999 Btu/h, without reverse cycle 

and without louvered sides 10.4 

8B 11,000 to 13,999 Btu/h, without reverse cycle 

and without louvered sides 10.0 

The DOE max-tech levels differ from those presented in the preliminary TSD. They are 

higher for three of the analyzed product classes, and lower for three (one product class was not 

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analyzed during the preliminary analysis). The engineering analysis revisions are discussed in 

Section IV.C.2.b below. 

DOE determined that max-tech levels for most room air conditioner product classes 

higher than the commercially available max tech were technologically feasible. Although the 

commercially available products generally do not use all the energy efficient design options 

considered in the DOE max-tech analyses, the design options are all used in commercially 

available products, some of which combine nearly all of the design options used in the DOE max 

tech configurations. 

DOE determined the max-tech levels of each analyzed product class as part of its 

engineering analysis. The max-tech levels represent the most efficient design option 

combinations applicable for the analyzed products. Details of this analysis are described in the 

direct final rule TSD in chapter 5. DOE used different design option groups for each analyzed 

product class’s max-tech design, as indicated in Table III.6. 

Table III.6. Options Considered for Room Air Conditioner Max-Tech Levels 

Product 

Class 

Design Option 

BLDC* FanMotorsHighEfficiencyPSC MotorsHeat Exchanger ImprovementSubcoolers10 EER Cmpressor10.3 EER CmpressorChassisGrowths 

1      

3      

5A      

5B      

8A     

8B     

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Stakeholder comments and questions regarding the preliminary analysis max-tech levels 

primarily addressed the max-tech levels that DOE selected for the analyses. Some stakeholders 

argued that max available products exist at higher levels, while others argued that the conversion 

to R-410A refrigerant requires a re-examination of max-tech levels. 

c. Available Max-Tech Products with Higher EER Ratings 

Numerous stakeholders commented that DOE should update its analysis to include all 

® current ENERGY STAR and max-tech units on the market. The California Utilities suggested 

that DOE consider the current best R-410A products on the ENERGY STAR list (California 

Utilities, No. 31 at pp. 16–17). The California Utilities also pointed out that the ENERGY STAR 

Database listed products with a 13.5 EER, and that the CEC Database listed four products with a 

13.8 EER (California Utilities, No. 31 at p. 13). The Northwest Power and Conservation Council 

(NPCC) and ACEEE also commented that there were higher efficiency products available than 

had been assumed by DOE (NPCC, No. 32 at p. 4; ACEEE, No. 24 at p. 4). 

DOE is aware that the ENERGY-STAR and CEC databases list products that exceed the 

max-tech EER of 12.0 that DOE identified in the preliminary analysis. Table III.7 lists products 

listed at 12.0 EER or higher in one or both of these databases. 

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Table III.7. Room Air Conditioner Models of Interest for Max-Tech Analysis, as Listed in 

the ENERGY STAR and CEC Databases 

Brand Model Listed EER Source 

CEC ENERGY STAR 

Climette CH1826A 13.8 

Comfort-Aire REC-183 13.8 

Fedders AED18E7DG 13.8 

Maytag MED18E7A 13.8 

Fedders A7Q06F2A 13.4 

Turbo Air TAS-09EH 13.5 

Turbo Air TAS-12EH 13.0 

Turbo Air TAS-18EH 13.0 

Friedrich SS10M10 12.0  

Friedrich YS09L10 12.0  

Friedrich SS10L10 12.0  

Friedrich XQ06M10 12.0  

Friedrich SS12M10 12.0 

Haier ESAD4066 12.0 

DOE searched product databases and manufacturer websites to gather information about 

these products and to determine whether these products represented valid room air conditioner 

ratings. DOE’s investigation indicates that none of the products listed with EER higher than 12.0 

represent valid room air conditioner ratings, and that some of the products rated at an EER of 

12.0 are also invalid representations. The first five products in the table are listed with much 

20 lower EER ratings in Natural Resources Canada (NRCan) database. The three Turbo-Air 

21 products are ductless mini-split products (as identified by the manufacturer’s website ), not 

room air conditioners. The Friedrich SS12M10 has been re-rated at lower than 12.0 EER22, and 

the validity of the 12.0 rating of the Haier ESAD4066 is likely also incorrect, as discussed in 

20 (1) Natural Resources Canada, Office of Energy Efficiency. EnerGuide for Equipment – EnerGuide Room Air
 

Conditioner Directory 2002. 2002; (2) Room Air Conditioner Model Listing. “EnerGuide Room Air Conditioner
	

Directory 2004” http://oee.nrcan.gc.ca/. 21 Product Specifications and Descriptions for Turbo Air Products TAS-09EH, TAS-12EH, TAS-18EH. 

http://www.turboairinc.net/productspecs/productspecs.html
 22 Friedrich product specifications. Specifications for SS12M10. http://kuhl.friedrich.com/model-specifications/
 

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greater detail below. Consequently, DOE concludes that its identification of a max-tech available 

level no higher than 12.0 EER is valid. 

The California Utilities stated that the analysis for room air conditioners was quite 

favorable in terms of cost-effectiveness, and that many of the analyzed efficiency levels had 

LCC savings relative to the baseline levels. They indicated that, if DOE’s selected efficiency 

levels are as cost-effective as the analysis suggests, that there may be additional design options 

or higher efficiency levels that also merit DOE's analysis. (California Utilities, No. 31 at p. 13) 

PG&E asked whether DOE would consider higher max-tech levels that might result in more 

stringent standards (Public Meeting Transcript, No. 21.4 at p. 130). 

DOE is required to establish energy conservation standards that achieve the maximum 

improvement in energy efficiency that is technologically feasible and economically justified. (42 

U.S.C. 6295(o)(2)). DOE developed max-tech levels in the preliminary analysis and made 

adjustments in the engineering analysis based on new information, as mentioned above, 

particularly regarding compressors designed for R-410A refrigerant. The engineering analysis 

adjustments are discussed in more detail in section IV.C.2.b below. DOE determined that the 

products cited by the commenters that appeared to have higher efficiencies than the max-tech 

levels either were not room air conditioners or did not have valid ratings. The max-tech levels 

incorporate all applicable design options for each of the product classes, and based on DOE’s 

research and engineering analysis, DOE does not believe that products with higher efficiency 

than DOE’s max-tech are technologically feasible. 

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d. Consideration of Conversion to R-410A Refrigerant in Max-Tech Selections 

As detailed in the direct final rule TSD (chapter 5), the use of HCFC-22 refrigerant in 

room air conditioners was phased out starting January 1, 2010. The industry has switched to R410A refrigerant, which has required significant design modification. Although DOE based its 

preliminary analyses on use of R-410A refrigerant because HCFC-22 can no longer be used, few 

R-410A products were available for reverse engineering when DOE conducted the preliminary 

analyses. Also, there was limited information regarding compressors designed for the new 

refrigerant, or regarding manufacturers’ experiences developing product designs for the new 

refrigerant. 

GE Consumer & Industrial (GE) asked during the March 2010 public meeting whether 

any of the models considered for the engineering analysis (specifically the max-tech levels) were 

R-410A products (GE, Public Meeting Transcript, No. 21.4 at pp. 72–73). DOE responded that it 

based the max-tech analysis of product class 1 on a 12 EER R-410A product that was available 

at the time of the analysis. GE commented that Consumer Reports published an article in 

23 October 2008 in which it reported on test results indicating that this product’s efficiency was 

not 12 EER (Public Meeting Transcript, No. 21.4 at 72-73). GE indicated that DOE should not 

consider this model to be representative of the technologies or costs required to achieve 12 EER. 

GE recommended that DOE instead use an alternative model to represent this efficiency level: 

24 the Friedrich model XQ06M10, which has a 6,000 Btu/h capacity and 12.0 EER, with a retail 

price of over $600 and a weight of 72 lbs. 

23 “Energy Star has lost some luster.” Consumer Reports. October 2008. Pg. 24 Vol. 73 No. 10. Copyright 2008 

Consumers Union of U.S., Inc.
 24 The GE comment identified Friedrich model AQ06M10, but the listing on the Friedrich website is XQ06M10 for
 

a product matching the GE description (same capacity, EER, weight, and other relevant attributes).
 

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The California Utilities requested clarification on DOE’s decision to not pursue a full 

teardown of the single R-410A unit identified in the preliminary analysis (California Utilities, 

No. 31 at p. 17). In response, DOE notes that it had obtained sufficient information about this 

unit to allow development of both an energy model and manufacturing cost model through close 

examination of heat exchanger details, identification of the compressor and fan motor model 

number, and measurement of fan power input. 

DOE considered the Consumer Reports article regarding the product identified in the 

preliminary analysis, which was initially considered to represent 12.0 EER using R-410A. 

Matching this performance level with the energy model required making some input assumptions 

that DOE considers unlikely, particularly for the condenser air flow rate. Given the information 

available, DOE agrees with GE’s suggestion to instead use the Friedrich 12.0 EER product as a 

representation of this performance level. The revised analysis for product class 1 is based on 

calibration of the energy model to match the performance of the Friedrich product. DOE 

conducted a teardown of this product to verify its design details. 

The analysis shows that the product class 1 max-tech level is 11.8, slightly lower than 12. 

This reflects (1) reduction of the capacity from the 6,000 Btu/h of the Friedrich unit to the 5,000 

Btu/h considered representative for the product class, and (2) adopting a 50 lb. product weight 

limit, as suggested by AHAM (AHAM, No. 25 at p. 6) AHAM commented that OSHA 

recommends that articles heavier than 50 lbs. should be lifted by two rather than one person. Id. 

DOE considers this limit to be an appropriate demarcation for product class 1, since most of 

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these products currently weigh less than 50 lb. Increase in weight beyond 50 lbs., requiring 

additional personnel for installation, represents a distinct reduction in consumer utility 

(specifically, the ability to remove the unit from the window during the off-season, relocate it to 

other windows without calling an installer, or both). Size limits for room air conditioners are 

discussed in greater detail in section IV.C.2.b, below. 

During the final rule analysis, DOE also considered new products of other product classes 

that use R-410A refrigerant and adjusted its analysis accordingly based on new information 

regarding designs and efficiency levels of these products. Adjustments DOE made to the 

engineering analysis during the final rule phase are detailed in section IV.C.2.b below, and in 

chapter 5 of the TSD. 

C. Energy Savings 

1. Determination of Savings 

DOE used its NIA spreadsheet model to estimate energy savings from amended standards 

25 for the products that are the subject of this rulemaking. For each TSL, DOE forecasted energy 

savings beginning in 2014, the year that manufacturers would be required to comply with 

amended standards, and ending in 2043. DOE quantified the energy savings attributable to each 

TSL as the difference in energy consumption between the standards case and the base case. The 

base case represents the forecast of energy consumption in the absence of amended mandatory 

efficiency standards, and considers market demand for more-efficient products. 

25 The NIA spreadsheet model is described in section IV.G of this notice. 

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The NIA spreadsheet model calculates the electricity savings in “site energy” expressed 

in kWh. Site energy is the energy directly consumed by appliances at the locations where they 

are used. DOE reports national energy savings on an annual basis in terms of the aggregated 

source (primary) energy savings, the savings in the energy used to generate and transmit the site 

energy. (See direct final rule TSD chapter 10.) To convert site energy to source energy, DOE 

derived annual conversion factors from the model used to prepare the EIA Annual Energy 

Outlook 2010 (AEO2010). 

2. Significance of Savings 

As noted above, DOE cannot adopt a standard for a covered product if such standard 

would not result in “significant” energy savings. 42 U.S.C. 6295(o)(3)(B) While the term 

“significant” is not defined in the Act, the U.S. Court of Appeals, in Natural Resources Defense 

Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985), indicated that Congress intended 

“significant” energy savings in this context to be savings that were not “genuinely trivial.” The 

energy savings for all of the TSLs considered in this rulemaking are nontrivial, and, therefore, 

DOE considers them “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B). 

D. Economic Justification 

1. Specific Criteria 

As noted in section II.B, EPCA provides seven factors to be evaluated in determining 

whether a potential energy conservation standard is economically justified. (42 U.S.C. 

6295(o)(2)(B)(i)) The following sections discuss how DOE has addressed each of those seven 

factors in this rulemaking. 

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a. Economic Impact on Manufacturers and Consumers 

In determining the impacts of an amended standard on manufacturers, DOE first 

determines the quantitative impacts using an annual cash-flow approach. This step includes both 

a short-term assessment—based on the cost and capital requirements during the period between 

the issuance of a regulation and when entities must comply with the regulation—and a long-term 

assessment over a 30-year analysis period. The industry-wide impacts analyzed include INPV 

(which values the industry on the basis of expected future cash flows), cash flows by year, 

changes in revenue and income, and other measures of impact, as appropriate. Second, DOE 

analyzes and reports the impacts on different types of manufacturers, including analysis of 

impacts on small manufacturers. Third, DOE considers the impact of standards on domestic 

manufacturer employment and manufacturing capacity, as well as the potential for standards to 

result in plant closures and loss of capital investment. Finally, DOE takes into account 

cumulative impacts of different DOE regulations and other regulatory requirements on 

manufacturers. 

For individual consumers, measures of economic impact include the changes in LCC and 

the PBP associated with new or amended standards. The LCC, specified separately in EPCA as 

one of the seven factors to be considered in determining the economic justification for a new or 

amended standard, 42 U.S.C. 6295(o)(2)(B)(i)(II), is discussed in the following section. For 

consumers in the aggregate, DOE also calculates the national net present value of the economic 

impacts on consumers over the forecast period used in a particular rulemaking. 

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b. Life-Cycle Costs 

The LCC is the sum of the purchase price of a product (including its installation) and the 

operating expense (including energy and maintenance and repair expenditures) discounted over 

the lifetime of the product. The LCC savings for the considered efficiency levels are calculated 

relative to a base case that reflects likely trends in the absence of amended standards. The LCC 

analysis requires a variety of inputs, such as product prices, product energy consumption, energy 

prices, maintenance and repair costs, product lifetime, and consumer discount rates. DOE 

assumed in its analysis that consumers will purchase the considered products in 2014. 

To account for uncertainty and variability in specific inputs, such as product lifetime and 

discount rate, DOE uses a distribution of values with probabilities attached to each value. A 

distinct advantage of this approach is that DOE can identify the percentage of consumers 

estimated to receive LCC savings or experience an LCC increase, in addition to the average LCC 

savings associated with a particular standard level. In addition to identifying ranges of impacts, 

DOE evaluates the LCC impacts of potential standards on identifiable subgroups of consumers 

that may be disproportionately affected by a national standard. 

c. Energy Savings 

While significant conservation of energy is a separate statutory requirement for imposing 

an energy conservation standard, EPCA requires DOE, in determining the economic justification 

of a standard, to consider the total projected energy savings expected to result directly from the 

standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) DOE uses the NIA spreadsheet results in its 

consideration of total projected energy savings. 

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d. Lessening of Utility or Performance of Products 

In establishing classes of products, and in evaluating design options and the impact of 

potential standard levels, DOE sought to develop standards for clothes dryers and room air 

conditioners that would not lessen the utility or performance of these products. (42 U.S.C. 

6295(o)(2)(B)(i)(IV)) None of the TSLs considered in this notice would reduce the utility or 

performance of the clothes dryers under consideration in this rulemaking. DOE considered the 

possibility that room air conditioners size increases (and related weight increases) may reduce 

utility. DOE requested comments from stakeholders during the preliminary analysis phase 

addressing this issue. In response, DOE received comments from AHAM recommending limits 

to product weights and from NRDC recommending limits to product dimensions. These 

comments and DOE’s response to them are discussed in section IV.C.2.b. DOE adjusted its 

analysis so that analyzed TSLs are within the weigh and dimension limits suggested by 

stakeholders. These adjustments included: (1) use of a 50 lbs. limit for the product class 1 

analysis, and (2) use of maximum height and width dimensions (for all product classes with 

louvered sides) consistent with max-tech available products. DOE made these adjustments to its 

analysis specifically to avoid the possible reduction in consumer utility that could result from 

increases in size and weight. Further discussion of this analysis can be found in the direct final 

rule TSD in chapter 5. Furthermore, the energy conservation standards are performance 

standards rather than design standards, so they do not specify the design options that 

manufacturers must use to achieve the required efficiency levels. Manufacturers may use design 

options other than those selected by DOE in its analyses to achieve the required levels. 

Consequently, DOE believes that the TSLs considered and the TSLs adopted for the energy 

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conservation standard do not represent any such consumer utility reductions, notwithstanding 

increases in size and weight that DOE considered in the analyses for some of the product classes. 

e. Impact of Any Lessening of Competition 

EPCA directs DOE to consider any lessening of competition that is likely to result from 

standards. It also directs the Attorney General of the United States (Attorney General) to 

determine the impact, if any, of any lessening of competition likely to result from a proposed 

standard and to transmit such determination to the Secretary within 60 days of the publication of 

a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii)) DOE published a NOPR containing energy conservation 

standards identical to those set forth in today’s direct final rule and transmitted a copy of today’s 

direct final rule and the accompanying TSD to the Attorney General, requesting that the 

Department of Justice (DOJ) provide its determination on this issue. DOE will consider DOJ’s 

comments on the rule in determining whether to proceed with the direct final rule. DOE will also 

publish and respond to DOJ’s comments in the Federal Register in a separate notice. 

f. Need for National Energy Conservation 

The energy savings from new or amended standards are likely to improve the security 

and reliability of the nation’s energy system. Reduced demand for electricity may also result in 

reduced costs for maintaining the reliability of the nation’s electricity system. DOE conducts a 

utility impact analysis to estimate how standards may affect the nation’s needed power 

generation capacity. 

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Energy savings from the proposed standards are also likely to result in environmental 

benefits in the form of reduced emissions of air pollutants and greenhouse gases associated with 

energy production. DOE reports the environmental effects from the proposed standards, and 

from each TSL it considered, in the environmental assessment contained in chapter 15 in the 

direct final rule TSD. DOE also reports estimates of the economic value of emissions reductions 

resulting from the considered TSLs. 

g. Other Factors 

EPCA allows the Secretary of Energy, in determining whether a standard is economically 

justified, to consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(VII)) In developing the direct final rule, DOE has also considered the 

submission of the Joint Petition, which DOE believes sets forth a statement by interested persons 

that are fairly representative of relevant points of view (including representatives of 

manufacturers of covered products, States, and efficiency advocates) and contains 

recommendations with respect to an energy conservation standard that are in accordance with 42 

U.S.C. 6295(o). DOE has encouraged the submission of consensus agreements as a way to bring 

diverse stakeholders together, to develop an independent and probative analysis useful in DOE 

standard setting, and to expedite the rulemaking process. DOE also believes that standard levels 

recommended in the consensus agreement may increase the likelihood for regulatory 

compliance, while decreasing the risk of litigation. 

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2. Rebuttable Presumption 

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that 

an energy conservation standard is economically justified if the additional cost to the consumer 

of a product that meets the standard is less than three times the value of the first-year of energy 

savings resulting from the standard, as calculated under the applicable DOE test procedure. 

DOE’s LCC and PBP analyses generate values used to calculate the payback period for 

consumers of potential amended energy conservation standards. These analyses include, but are 

not limited to, the 3-year payback period contemplated under the rebuttable presumption test. 

DOE routinely conducts, however, an economic analysis that considers the full range of impacts 

to the consumer, manufacturer, nation, and environment, as required under 42 U.S.C. 

6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE to definitively evaluate 

the economic justification for a potential standard level (thereby supporting or rebutting the 

results of any preliminary determination of economic justification). The rebuttable presumption 

payback calculation is discussed in section IV.F.12 of this direct final rule and chapter 8 of the 

direct final rule TSD. 

IV. Methodology and Discussion 

DOE used two spreadsheet tools to estimate the impact of today’s proposed standards. 

The first spreadsheet calculates LCCs and payback periods of potential new energy conservation 

standards. The second provides shipments forecasts and then calculates national energy savings 

and net present value impacts of potential energy conservation standards. The two spreadsheets 

are available online at: [INSERT URL] The Department also assessed manufacturer impacts, 

largely through use of the Government Regulatory Impact Model (GRIM). 

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Additionally, DOE estimated the impacts on utilities and the environment of energy 

efficiency standards for clothes dryers and room air conditioners. DOE used a version of EIA’s 

National Energy Modeling System (NEMS) for the utility and environmental analyses. The 

NEMS model simulates the energy sector of the U.S. economy. EIA uses NEMS to prepare its 

Annual Energy Outlook (AEO), a widely known baseline energy forecast for the United States. 

For more information on NEMS, refer to “The National Energy Modeling System: An 

Overview,” DOE/EIA–0581 (98) (Feb.1998), available at: 

http://tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf. 

The version of NEMS used for appliance standards analysis is called NEMS-BT, and is 

26 based on the AEO version with minor modifications. NEMS-BT offers a sophisticated picture 

of the effect of standards, because it accounts for the interactions between the various energy 

supply and demand sectors and the economy as a whole. 

A. Market and Technology Assessment 

1. General 

When beginning an energy conservation standards rulemaking, DOE develops 

information that provides an overall picture of the market for the products concerned, including 

the purpose of the products, the industry structure, and market characteristics. 

26 EIA approves the use of the name “NEMS” to describe only an AEO version of the model without any 

modification to code or data. Because the present analysis entails some minor code modifications and runs the 

model under various policy scenarios that deviate from AEO assumptions, the name “NEMS-BT” refers to the 

model as used here. (BT stands for DOE’s Building Technologies Program.) 

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This activity includes both quantitative and qualitative assessments based on publicly available 

information. The subjects addressed in the market and technology assessment for this rulemaking 

include quantities and types of products sold and offered for sale; retail market trends; products 

covered by the rulemaking; product classes and manufacturers; regulatory and non-regulatory 

programs; and technology options that could improve the energy efficiency of the product(s) 

under examination. See chapter 3 of the direct final rule TSD for further discussion of the market 

and technology assessment. 

2. Products Included in this Rulemaking 

This subsection addresses the scope of coverage for today’s direct final rule, discussing 

whether certain products are subject to the amended standards and whether certain technologies 

provide a viable means of improving energy efficiency. In the sections that follow, DOE 

discusses the comments received on the scope of coverage set forth in the preliminary analysis. 

a. Clothes Dryers 

Hydromatic Technologies Corporation (HTC) suggested that DOE consider “solar” 

clothes dryers in this rulemaking. (HTC, No. FDMS DRAFT 0068 at p. 3) Under EPCA, any 

standard for clothes dryers must establish either a maximum amount of energy use or a minimum 

level of efficiency based on energy use. (42 U.S.C. 6291(5)-(6)) EPCA defines “energy use,” in 

part, as “the quantity of energy” that the product consumes. (42 U.S.C. 6291(4)) EPCA defines 

“energy” as meaning “electricity, or fossil fuels,” or other fuels that DOE adds to the definition, 

by rule, upon determining “that such inclusion is necessary or appropriate to carry out the 

purposes” of EPCA. (42 U.S.C. 6291(3)) DOE has not added solar energy (or any other type of 

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fuel) to EPCA’s definition of “energy.” Thus, DOE currently lacks authority to prescribe 

standards for clothes dryers when they use the sun's energy instead of fossil fuels or electricity. 

DOE also notes that it is unaware of any existing clothes dryers that are solar-powered. 

DOE has also considered in this rulemaking standards based on microwave or heat pump 

technology. EPCA does not define “clothes dryer,” but DOE’s regulations under EPCA provide 

separate definitions for electric and gas products. Because the types of clothes dryers just 

mentioned are or would be electric products, DOE’s definition of “electric clothes dryer” is 

relevant in considering them. DOE defines electric clothes dryer as a cabinet-like appliance 

designed to dry fabrics in a tumble-type drum with forced air circulation. The heat source is 

electricity and the drum and blower(s) are driven by an electric motor(s). 10 CFR 430.2. 

As to microwave technology, in this rulemaking DOE has considered whether microwave 

drying would be a viable option for improving clothes dryer efficiency. DOE determined, 

however, that this technology did not merit further consideration for reasons discussed in section 

IV.B.1. In addition, DOE is unaware of any microwave dryers that are currently commercially 

available for sale in the United States or elsewhere. Therefore, in this rulemaking DOE did not 

consider clothes dryer standards based on microwave technology. 

DOE also identified heat pump technology as a possible option for improving the energy 

efficiency of electric clothes dryers. Unlike microwave technology, DOE did not screen out this 

technology from further consideration in this rulemaking. Furthermore, DOE determined that 

heat pump clothes dryers are commercially available in Europe and Japan. Accordingly, DOE 

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has fully evaluated in this rulemaking whether standards based on heat pump technology are 

warranted for clothes dryers. 

DOE also considered non-tumbling (that is, cabinet) clothes dryers. DOE notes that, 

because they do not use a tumbling-type drum, they are not currently within DOE’s definition of 

“electric clothes dryer.” 10 CFR 430.2. In analyzing non-tumbling dryers, DOE determined that 

although these clothes dryers are currently on the market in the United States, DOE understands 

that they have a very limited market share. Based on a survey of cabinet clothes dryer models 

available on the U.S. market, DOE is aware of only three cabinet clothes dryer models from two 

clothes dryer manufacturers that have very low market share (i.e., less than 1 percent) in the 

conventional tumbling-type clothes dryer market. For these reasons, DOE is not considering 

standards for these clothes dryers in this rulemaking. 

DOE also considered centrifugal spinners. DOE notes that, although centrifugal spinners 

remove a certain quantity of moisture from a clothes load, they are not within DOE’s definition 

of “electric clothes dryer” as a product designed to dry fabrics in a tumble-type drum with forced 

air circulation, where the heat source is electricity and the drum and blower(s) are driven by an 

electric motor(s). 10 CFR 430.2. Such products extract moisture from a clothes load by means of 

centrifugal force at high spin speeds, without the application of additional heat. The ECOS report 

submitted to DOE by NRDC states that centrifugal spinners remove 5–14 lbs. of water per kWh 

of electricity, depending on the size and type of load, making them at least two to seven times as 

efficient as a typical electric dryer. The ECOS report further cites multiple sources suggesting 

that mechanical extraction of water is 19–70 times more efficient than evaporating it in a typical 

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drying process. According to the ECOS report, a centrifugal spinner can reduce initial RMC in a 

clothes load to be dried in a conventional clothes dryer from 60–70 percent down to 45 percent. 

Sources cited in the ECOS report variously ascribe to this decrease in initial RMC a 25-percent 

reduction in clothes dryer electricity use, or 209 kWh annual energy savings for a typical clothes 

dryer. (NRDC, No. 30 at pp. 10–11) Although such centrifugal spinners are currently on the 

market in the United States, DOE understands that they have a very limited market share. DOE 

also notes that it is not aware of any centrifugal spinners that can remove moisture from the test 

load down to 2.5–5 percent RMC, as required by the DOE clothes dryer test procedure. In 

addition, DOE is not aware of any clothes dryers currently available on the market or prototype 

designs that incorporate centrifugal spinning and are capable of drying the test load to 2.5–5 

percent RMC. For these reasons, DOE is not considering standards for these clothes dryers in 

this rulemaking 

b. Room Air Conditioners 

DOE defines “room air conditioner” under EPCA, in part, as a “consumer product . . . 

which is an encased assembly designed as a unit for mounting in a window or through the wall 

for the purpose of providing delivery of conditioned air to an enclosed space. It includes a prime 

source of refrigeration and may include a means for ventilating and heating.” 10 CFR 430.2. A 

product known as a “portable air conditioner” has most of these characteristics. However, it rests 

on the floor, often on wheels, with a short ducted connection to a window or other access to the 

outside to vent warm condenser air and, for some of these products, to provide condenser cooling 

air from the outside. DOE notes that portable air conditioners are not within the current DOE 

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definition of “room air conditioner” because they are not designed “for mounting in a window or 

through the wall.” 10 CFR 430.2 

DOE notes that EPCA authorizes the prescription of standards for room air conditioners 

(42 U.S.C. 6292(2)), and that portable air conditioners do not fall within DOE’s regulatory 

definition of room air conditioner at 10 CFR 430.2, as stated above, or the definitions found in 

the current industry standards ANSI/AHAM RAC-1-2008 and ANSI/ASHRAE Standard 16­

27 1983 (RA 2009). DOE also notes that portable air conditioners cannot be tested in the window 

configuration used in the referenced standard ANSI/ASHRAE Standard 16-1983 (RA 2009), in 

the amended test procedure. 76 FR 972, 978 (January 6, 2011). DOE believes that a separate test 

procedure analysis would need to be considered for these products; as an example, DOE notes 

that the ANSI/ASHRAE test procedure standard for portable air conditioners (ANSI/ASHRAE 

Standard 128-2001, “Method of Rating Unitary Spot Air Conditioners”) references the 

ANSI/ASHRAE Standard 37-2005 “Methods of Testing for Rating Unitary Air-Conditioning 

and Heat Pump Equipment” for testing, and excludes equipment covered by ANSI/AHAM RAC1 2008. Thus, DOE is not considering standards for portable air conditioners in this rulemaking. 

DOE may, however, consider standard for portable air conditioners in a future rulemaking. 

3. Product Classes 

In evaluating and establishing energy conservation standards, DOE divides covered 

products into classes by the type of energy used, or by capacity or other performance-related 

feature that justifies a different standard for products having such feature. (See 42 U.S.C. 

27 EPCA also authorizes the classification of additional consumer products as covered products pursuant to 42 

U.S.C. 6292(b) provided that certain criteria are met. 

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6295(q)) In determining whether a feature justifies a different standard, DOE must consider 

factors such as the utility of the feature to users. Id. DOE is required to establish different energy 

conservation standards for different product classes based on these criteria. 

a. Clothes Dryers 

In the preliminary analysis, DOE proposed to analyze six product classes for residential 

clothes dryers (for details on these product classes, see chapter 3 of the preliminary TSD). In 

particular, DOE considered four product classes for vented clothes dryers and two product 

classes for ventless clothes dryers, ventless electric compact (240 V) and combination 

28 washer/dryers, recognizing the unique utility that ventless clothes dryers offer to consumers.

AHAM, BSH, and Whirlpool suggested that DOE consider an additional product class 

for electric standard-size ventless clothes dryers, even though such products are not currently on 

the market in the United States, to prepare for likely market entry. AHAM stated that a standardsize ventless product class would decrease the request for waivers that DOE may receive in the 

near future. AHAM further commented that the analysis for a standard-size ventless product 

class could be extrapolated from the analysis for compact-size ventless clothes dryers. (AHAM, 

Public Meeting Transcript, No. 21.4 at pp. 19–20; AHAM, No. 25 at pp. 4–5; BSH, No. 23 at p. 

3; Whirlpool, No. 22 at p. 1) 

Because DOE is unaware of any standard-size ventless clothes dryers currently on the 

market, as discussed in section IV.A.2.a, and because DOE does not have information on the 

28 Previously, DOE has described ventless dryers as condensing dryers. The new designation reflects the actual 

consumer utility (that is, no external vent required) and the market availability of vented dryers that also condense. 

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performance of standard-size ventless clothes dryers that would warrant the definition of a 

separate product class, DOE is not establishing a product class for standard-size ventless clothes 

dryers in today’s direct final rule. 

According to BSH, clothes dryers should be classified as vented, ventless, and gas 

product classes, without differentiation by drum size. (BSH, No. 23 at p. 4) EPCA requires DOE 

to specify a level of energy use or efficiency different from that which applies to the type of 

covered product for any group of such products that have a capacity or other performance-related 

feature that justifies a different standard. DOE has previously determined, and has verified in 

recent testing, that compact-size clothes dryers have inherently different energy consumption 

than standard-size clothes dryers. DOE also notes that compact-size clothes dryers provide utility 

to consumers by allowing for installation in space-constrained environments. Therefore, DOE 

has determined that the capacity and utility of compact clothes dryers justifies a different 

standard and establishes separate product classes for compact clothes washers under EPCA. (42 

U.S.C. 6295(q)) 

b. Room Air Conditioners 

The 1997 final rule for room air conditioners established standards for 16 product classes 

based on the following characteristics: capacity, presence or absence of louvered-sides 

(louvered-side products are intended for installation in windows, while products without 

louvered sides are for through-the-wall installation), type of cabinet (casement-only, casementslider, and other), and presence or absence of heat pump mode for heating. 72 FR 50122 (Sept. 

24, 1997). 

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In its preliminary analysis, DOE proposed no changes to the existing product class 

structure. DOE received two comments addressing product classes, as discussed below. 

AHAM recommended that DOE consider splitting the following two product classes: 

product class 5 (room air conditioners without reverse cycle, with louvered sides, and capacity 

20,000 Btu/h or more) and product class 8 (room air conditioners without reverse cycle, without 

louvered sides, and capacity 8,000 to 13,999 Btu/h) (AHAM, No. 25 at p. 6). AHAM 

recommended that product class 5 be split into two product classes, (1) from 20,000 Btu/h to 

24,999 Btu/h, and (2) greater than 25,000 Btu/h. AHAM also recommended that product class 8 

be split into two product classes, (1) 8,000 Btu/h to 10,999 Btu/h, and (2) 11,000 Btu/h to 13,999 

Btu/h. AHAM stated that manufacturers are reaching the limit of achievable efficiency levels for 

higher-capacity room air conditioners. Id. 

The Joint Comment also proposed splitting both product classes 5 and 8, but 

recommended a different capacity at which to split product class 5. The joint comment proposed 

that the new product classes derived from the current product class 5 be (1) from 20,000 Btu/h to 

27,999 Btu/h, and (2) 28,000 Btu/h and greater. The Joint Comment proposed the same two 

separated product classes for product class 8 that AHAM proposed. (Joint Comment, No. 31 at p. 

7–8) 

DOE agrees with the recommendations of AHAM and the Joint Comment that the new 

product classes are needed to ensure establishment of meaningful efficiency levels over the full 

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range of capacities. This is discussed in detail in the following sections which separately address 

each of the product class splits. 

Splitting of Product Class 5 

DOE splits current product class 5 (room air conditioners without reverse cycle, with 

louvered sides, and capacity 20,000 Btu/h or more) into two new product classes: 5A (room air 

conditioners without reverse cycle, with louvered sides, and capacity from 20,000 Btu/h to 

27,999 Btu/h) and 5B (room air conditioners without reverse cycle, with louvered sides, and 

capacity 28,000 Btu/h or more). This step is consistent with the recommendations of AHAM and 

the Joint Comment recommendations to split the product class, but uses the split recommended 

by the Joint Comment. 

DOE made this decision based on the following input: 

Discussions with individual manufacturers of the efficiency options available to large 

room air conditioners. 

Research on available product sizes and available product efficiencies. 

Reverse engineering of two product class 5 units, including a 28,500 Btu/h unit. 

Engineering analysis of R-410A product class 5 baseline products at two capacity levels 

(24,000 Btu/h and 28,000 Btu/h). 

Max-tech available EER for product classes 1 through 5 (room air conditioners without 

reverse cycle, with louvered sides, covering the full capacity range of available products) for 

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products using R-410A refrigerant are shown in Table IV.1 below. The max-tech EER drops 

gradually as capacity increases above 6,000 Btu/h, but drops significantly above 28,000 Btu/h. 

Table IV.1. Max-Tech Louvered R-410A Room Air Conditioners 

Room Air Conditioner R-410A Louvered 

Products (Market Max Available Levels) 

Product 

Class 

Capacity Max 

Available 

EER 

1 5,200 11.0 

1 5,500 11.2 

2 6,000 12.0 

2 7,900 11.7 

3 11,700 11.4 

4 18,000 10.7 

5 20,800 10 

5 27,800 9.7 

5 36,000 8.5 

DOE produced cost-efficiency curves for product class 5 products at both 24,000 Btu/h 

and 28,000 Btu/h capacity levels. Table IV.2 shows the results of these analyses, which clearly 

show (1) much steeper increase in cost as the CEER increases and (2) significantly lower maxtech for the larger capacity products. This analysis demonstrates the much greater potential for 

efficiency improvement for the lower-capacity products. 

Table IV.2. Comparison of 24,000 Btu/h and 28,000 Btu/h Room Air Conditioner 

Incremental Costs 

Efficiency 

Level 

PC5A – 24,000 Btu/h PC5B – 28,000 Btu/h 

CEER Incremental 

Cost 

CEER Incremental Cost 

1 8.47 $0.00 8.48 $0.00 

2 9.0 $8.85 9.0 $23.52 

3 9.4 $19.04 9.4 $50.27 

4 9.8 $50.66 9.8 $229.01 

5 10.15 $204.62 - -

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The cost-efficiency analysis and the market analysis demonstrate that limitations in the 

max-tech levels for product class 5 units occur at the 28,000 Btu/h capacity, rather than the 

24,000 Btu/h capacity. DOE used these analyses to determine that the 28,000 Btu/h capacity split 

was more appropriate than the 24,000 Btu/h split. 

DOE’s decision to establish the new product classes 5A and 5B that take the place of the 

current product class 5, and split the product class at the 28,000 Btu/h capacity level, is based on 

the stakeholder comments and DOE’s analysis. Additional details of the analysis can be found in 

chapter 3 of the direct final rule TSD. 

Splitting of Product Class 8 

DOE splits product class 8 (room air conditioners without reverse cycle, without louvered 

sides, and capacity 8,000 to 13,999 Btu/h) to establish two new product classes: 8A (room air 

conditioners without reverse cycle, without louvered sides, and capacity 8,000 to 10,999 Btu/h) 

and 8B (room air conditioners without reverse cycle, without louvered sides, and capacity 11,000 

to 13,999 Btu/h). 

DOE based this split on information similar to that of the decision to split product class 5, 

as discussed above. DOE focused its reverse engineering and engineering for these product 

classes on capacities of 8,000 Btu/h and 12,000 Btu/h. 

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The max-tech EERs of available room air conditioners without louvered sides using R410A refrigerant are dependent on capacity range. These products are designed to fit in sleeves 

installed in the building wall. Due to the dependence of this market on replacement sales, as 

reported by manufacturers during interviews for the final rule analysis, there is little opportunity 

to adjust the physical size of the product. (This is in contrast to products with louvered sides, 

designed to fit in windows, which allows more flexibility for size increase to improve 

efficiency.) Non-louvered products with capacity greater than 12,600 Btu/h are unable to meet 

the current ENERGY STAR EER level. DOE further notes that non-louvered ENERGY STAR 

products in the capacity range 11,500 to 12,800 Btu/h require oversized sleeves. At a slightly 

higher capacity level, these products cannot be designed to meet the DOE energy standard—the 

available data show that there are currently no available non-louvered products having greater 

than 13,999 Btu/h capacity. 

DOE produced cost-efficiency curves for non-louvered R-410A room air conditioners at 

8,000 Btu/h and 12,000 Btu/h capacities, shown in Table IV.3 below. As for the product class 5 

analyses, the results show the significantly steeper increase in cost as efficiency level is raised 

above the baseline and the reduced max-tech level for the higher-capacity product. 

Table IV.3. Comparison of 8,000 Btu/h and 12,000 Btu/h Room Air Conditioner 

Incremental Costs 

Efficiency 

Level 

PC8A – 8,000 Btu/h PC8B – 12,000 Btu/h 

CEER Incremental 

Cost 

CEER Incremental Cost 

1 8.41 $0.00 8.44 $0.00 

2 9.3 $4.61 9.3 $11.72 

3 9.6 $6.68 9.5 $15.39 

4 10.0 $16.63 9.8 $26.06 

5 10.4 $88.45 10.0 $93.36 

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DOE’s decision to establish the new product classes 8A and 8B that take the place of the 

current product class 8 is based on the stakeholder comments and DOE’s analysis. DOE has 

decided to split the product class at the 11,000 Btu/h capacity level recommended by both 

AHAM and the Joint Comment. Additional details of the analysis can be found in chapter 3 of 

the direct final rule TSD. 

Product Class Summary 

Table IV.4 below presents the product classes established in this rulemaking, including 

both current and classes established in this rulemaking. 

Table IV.4. Proposed Room Air Conditioner Product Classes 

No. Product Class 

Classes Listed in the CFR 

1 Without reverse cycle, with louvered sides, and less than 6,000 Btu/h 

2 Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h 

3 Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h 

4 Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h 

6 Without reverse cycle, without louvered sides, and less than 6,000 Btu/h 

7 Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h 

9 Without reverse cycle, without louvered sides, and 14,000 to 19,999 Btu/h 

10 Without reverse cycle, without louvered sides, and 20,000 Btu/h or more 

11 With reverse cycle, with louvered sides, and less than 20,000 Btu/h 

12 With reverse cycle, without louvered sides, and less than 14,000 Btu/h 

13 With reverse cycle, with louvered sides, and 20,000 Btu/h or more 

14 With reverse cycle, without louvered sides, and 14,000 Btu/h or more 

15 Casement-Only 

16 Casement-Slider 

Product Classes Established in this Rulemaking 

5A Without reverse cycle, with louvered sides, and 20,000 Btu/h to 27,999 Btu/h 

5B Without reverse cycle, with louvered sides, and 28,000 Btu/h or more 

8A Without reverse cycle, without louvered sides, and 8,000 to 10,999 Btu/h 

8B Without reverse cycle, without louvered sides, and 11,000 to 13,999 Btu/h 

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EPCA requires that the establishment of separate product classes be based on either (A) 

consumption of a different kind of energy from that consumed by other covered products within 

such type (or class); or (B) a capacity or other performance-related feature which other products 

within such type (or class) do not have, where such feature justifies a higher or lower standard 

from that which applies to other products within such type (or class). (42 U.S.C. 6295(q)). The 

second of these criteria is applicable to the new product classes proposed in this rulemaking, 

because the new product classes are based on product capacity. The justification of different 

standards for the new product classes of different capacities is discussed above in this section. 

4. Non-Regulatory Programs 

DOE’s market assessment provides a profile of the residential clothes dryer and room air 

conditioner industries in the United States. As part of the market and technology assessment, 

DOE reviews non-regulatory programs promoting energy-efficient residential appliances in the 

United States. Non-regulatory programs that DOE considers in its market and technology 

assessment include ENERGY STAR, a voluntary labeling program jointly administered by the 

U.S. Environmental Protection Agency (EPA) and DOE. ENERGY STAR identifies energy 

29 efficient products through a qualification process. To qualify, a product must exceed Federal 

minimum standards by a specified amount, or if no Federal standard exists, exhibit select energysaving features. ENERGY STAR specifications currently exist for room air conditioners, but not 

for residential clothes dryers. 

BSH commented that it would support ENERGY STAR qualification for clothes dryers, 

as well as an energy label system that would help consumers purchase the most efficient models 

29 For more information, please visit www.energystar.gov. 

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on the market. According to BSH, the European labeling system for clothes dryers has resulted 

in benefits to consumers, manufacturers, and the environment. (BSH, No. 23 at pp. 2, 6) The 

California Utilities commented that a revised test procedure could better differentiate clothes 

dryer models in terms of energy performance, facilitating an ENERGY STAR program. 

According to the California Utilities, there is currently no ENERGY STAR program because 

clothes dryers do not differ in apparent energy use as measured by the existing clothes dryer test 

procedure. (California Utilities, No. 31 at p. 6) 

DOE notes that, according to the joint program between the EPA and DOE, the EPA 

determines whether to add qualification specifications for newly covered products within 

ENERGY STAR. DOE encourages the implementation of ENERGY STAR specifications and 

labeling as a means to achieve national energy savings, and would assist the EPA in applying the 

DOE clothes dryer test procedure to evaluate qualifying products in any future ENERGY STAR 

ratings for clothes dryers. 

Energy labeling for clothes dryers under the EnergyGuide program is regulated by the 

FTC. (10 CFR 305) Although DOE does not have the authority under EPCA to revise the 

regulations for energy labeling to include clothes dryers, DOE would provide technical 

information to the FTC to support any new EnergyGuide labeling requirement for these products. 

5. Technology Options 

As part of the market and technology assessment, DOE develops a list of technologies for 

consideration for improving the efficiency of clothes dryers and room air conditioners. Initially, 

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these technologies encompass all those DOE believes are technologically feasible (the first of the 

four criteria in the screening analysis). Chapter 3 of the preliminary TSD includes the detailed 

list of all technology options identified for clothes dryers and room air conditioners. DOE 

received several comments in response to the technologies proposed in the preliminary analysis 

to be analyzed for clothes dryers and room air conditioners. 

a. Clothes Dryers 

Heat Pump Clothes Dryers 

DOE notes that heat pump clothes dryers function by recirculating the exhaust air back to 

the dryer while moisture is removed by a refrigeration-dehumidification system. The warm and 

damp exhaust air of the dryer enters the evaporation coil of the dehumidifier where it cools down 

below the dew point, and sensible and latent heat are extracted. The heat is transferred to the 

condenser coil by the refrigerant and reabsorbed by the air, which is moving in a closed air cycle. 

DOE notes that there are no heat pump dryers currently available on the U.S. market, but that 

heat pump clothes dryers are available on the market in Europe. 

BSH commented that it foresees the heat pump clothes dryer as an innovative technology 

breakthrough for improved efficiency in the next few years in North America. BSH noted that in 

Europe in the last 2 years the market share for heat pump clothes dryers has increased from 3 to 

11 percent, and that this success is based on four key factors: 1) European energy consumption 

values are comparable for all sizes of clothes dryers because they are independent of drum size; 

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30 2) the percent range between energy classes in Europe (A = best, B, C...) remains constant, so 

one energy classification is not proportionally larger than another; 3) realistic load quantities are 

used for testing; and 4) automatic termination control dryers are standard and are given 

preferential treatment over timer dryers (which tend to over dry and use more energy). (BSH, 

No. 23 at p. 2) 

In the context of the energy conservation standards rulemaking, DOE conducts its 

analysis to determine an economically justified minimum efficiency standard. DOE notes that 

the efficiency levels proposed in the preliminary analyses are not used for product marketing 

classification as they are in the European energy label system. As a result, DOE does not intend 

to create an energy class system as part of the energy conservation standard rulemaking. As 

discussed in section III.A.1.d, DOE also notes that its clothes dryer test procedure specifies a 

single test load size for standard-size clothes dryers and a single test load size for compact-size 

clothes dryers. In response to BSH’s comments regarding realistic load quantities, DOE also 

notes that it amended the clothes dryer test procedure to revise the test load size for standard-size 

clothes dryers to be more representative of current consumer usage habits, as discussed in the TP 

Final Rule. 76 FR 972, 977 (January 6, 2011). Also, as discussed above in section III.A.1.b, 

DOE did not amend the test procedure in the TP Final Rule to better account for automatic cycle 

termination. DOE notes that the clothes dryer test procedure provides a field use factor for 

automatic termination control dryers and a different field use factor for timer dryers. As 

discussed above, DOE notes that heat pump clothes dryers are available on the market in Europe. 

DOE also notes that multiple clothes dryer manufacturers that manufacture heat pump clothes 

30 The European energy label system uses a letter scale from “A” to “G” to rate the efficiency and performance of 

certain appliance products. A rating of “A” denotes the highest efficiency unit, whereas a rating of “G” denotes the 

lowest efficiency unit. 

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dryers for the international markets also manufacture clothes dryers for the United States. For 

these reasons, DOE believes that heat pump technology is technologically feasible and therefore 

considered heat pump clothes dryers for the engineering analysis. 

Heat Recovery 

For this technology option, a heat exchanger is used to recover exhaust heat energy and to 

preheat inlet air. Based on research of this technology and discussions with manufacturers, this 

system is feasible for both gas and electric dryers because none of the exhaust air re-enters the 

dryer. Energy savings are achieved either by using the additional recovered heat to increase the 

temperature of the air entering the drum and thus reduce the drying time or by using the 

additional recovered heat to reduce the required heater input power, depending on how the 

system is implemented. As reported in chapter 3 of the preliminary TSD, estimated energy 

savings from several researchers range from 2 to 6 percent in non-condensing mode. 

The California Utilities and NRDC commented that the energy savings associated with 

heat recovery would be significantly higher. According to the California Utilities, 80-percent 

efficient counter-flow heat exchangers are widely available, while 90-percent efficient heat 

exchangers are technically feasible. The California Utilities estimate energy savings for heat 

recovery to be about 30 percent for electric clothes dryers and 20 percent for gas clothes dryers. 

The California Utilities noted that ventless dryers are available in the United States and are 

common in Europe, suggesting that heat recovery is both technically feasible and practical to 

manufacture (California Utilities, No. 31 at pp. 6–7, 12, 21) The California Utilities stated that 

the technologies behind heat recovery and ventless clothes dryers differ only in where the air 

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from the heat exchanger is routed. In ventless clothes dryers, cooled exhaust air is channeled to 

the heater to be reused and the warmed room air is vented back to the room. For heat recovery, 

these are reversed, such that cooled exhaust air is vented (usually outside) and the warmed room 

air is channeled into the heater. (California Utilities, No. 31 at p. 6) The California Utilities 

provided a specific example of a dryer with an EF of 3.10, or 2.26 kWh per cycle, which is 

stopped at the end of the bulk drying stage. The clothes dryer in this example is assumed to have 

an average exhaust temperature of 110 °F, or 40 °F above ambient temperature. According to the 

California Utilities, a 90-percent efficient counter-flow heat exchanger would preheat the 

incoming air by 36 °F, which would result in 0.684 kWh directly replacing heat that would 

otherwise be supplied by the electric resistance heater. The replaced heat would correspond to 

1.58 kWh per cycle to dry the 7-lb test load and an EF of 4.43. This would result in a 30-percent 

energy savings due to heat recovery. Id. According to NRDC, as stated in the ECOS report, 40­

percent energy savings (1.348 kWh of heater energy savings per cycle) can be achieved for a 

load of cotton towels with a 90-percent efficient air-to-air cross-flow heat exchanger between the 

exhaust and intake of the clothes dryer. (NRDC, No. 30 at p. 27) 

DOE is not aware of any data indicating that a cross-flow heat exchanger may be used in 

a clothes dryer application and achieve 80-percent or 90-percent efficiency. DOE notes that an 

air-to-air heat exchanger used in a clothes dryer must have sufficient fin spacing to prevent lint 

fouling of the heat exchanger. DOE also notes that the ECOS report does not provide details of 

how the potential energy savings associated with heat recovery were calculated (that is, data for 

airflow, temperature, specific heat, and similar items). DOE notes that the California Utilities 

comment stated that, for an exhaust temperature of 110 °F and a 90-percent efficient cross-flow 

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heat exchanger, the energy savings would be approximately 0.684 kWh per cycle. However, the 

ECOS report estimated that the energy savings would be 1.348 kWh for what appear to be the 

same conditions. Because the details of how these estimates were calculated were not provided, 

DOE is unable to verify the energy savings suggested by the commenters would occur. 

DOE also notes that it is unclear whether the estimates provided by the California 

Utilities and the ECOS report for heat recovery considered condensation in the exhaust air 

stream. Manufacturers indicated that such heat recovery systems must be designed to prevent 

condensation in the exhaust ducting, and as a result, there is a limit to the amount of heat that can 

be recovered. 

DOE notes that it has revised the cost-efficiency analysis from the preliminary analyses 

based on its analysis and discussions with manufacturers. As discussed in section IV.C.2, inlet 

air preheating (that is, heat recovery) is considered applicable to the maximum-available 

efficiency levels for vented clothes dryer product classes, and DOE estimates this technology 

option would provide roughly a 6–7 percent improvement in efficiency. Manufacturers 

confirmed during interviews with DOE that this efficiency improvement accurately estimates the 

energy savings potential associated with inlet-air preheating in real-world applications, 

considering such factors as condensation in the exhaust airstream and lint accumulation in the 

heat exchanger. 

Hydronic Heating 

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HTC requested that DOE consider its “hydronically heated” clothes dryer, which uses a 

self-contained hydronic heating system, as a technology option. According to HTC, this 

technology currently exists, but products incorporating such a design are not yet being sold 

pending HTC’s resolution of licensing and private labeling considerations. (HTC, No. FDMS 

DRAFT 0068 at p. 3) DOE is also aware of HTC’s stand-alone hydronic heater that could be 

implemented as a clothes dryer heat source, utilizing water or other heat transfer fluids and an 

immersion element similar to a water heater. The heated fluid would then pass through a heat 

exchanger, where the heat would be transferred to the air entering the drum and then pumped 

back to the hydronic heater. Because DOE has not been able to identify any clothes dryers with 

such hydronic heating systems currently on the market, however, DOE is unable to evaluate the 

energy consumption associated with a clothes dryer equipped with a stand-alone hydronic 

heating device and thus has not included it as a design option in today’s direct final rule. 

Improved Cycle Termination 

According to NRDC, the test results in the ECOS report show that a clothes dryer 

equipped with improved automatic cycle termination saves 0.76 kWh per load compared to a 

clothes dryer with electromechanical controls. (NRDC, Public Meeting Transcript, No. 21.4 at p. 

42) The California Utilities noted that “high performance” automatic cycle termination controls 

are already available in dryers on the market that produce energy savings on the order of 10­

percent or more above current energy use, although DOE’s clothes dryer test procedure must be 

amended to measure this improvement. The California Utilities strongly urged DOE to analyze 

this technology option. 

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For the reasons described in section III.A.1.b, DOE did not adopt in the TP Final Rule the 

amendments for measuring automatic cycle termination proposed in the TP SNOPR. Therefore, 

DOE did not analyze this technology option further. 

Modulating Heat 

The NRDC/ECOS report stated that if a conventional gas clothes dryer is improved with 

modulating burner technology, the performance of the clothes dryer would be roughly equivalent 

to or superior to many heat pump clothes dryers in terms of CO2 emissions, source energy use, 

and energy cost. This performance would be achieved while also offering faster drying times and 

lower initial purchase price. (NRDC, No. 30 at pp. 37–38) DOE notes that heat pump technology 

is applicable only to electric clothes dryers, for which DOE maintains a product class distinction 

from gas clothes dryers. DOE analyzed technologies currently available on the market and 

concluded that two-stage gas burner modulation is necessary to achieve max-tech performance. 

Because DOE is not aware of any gas clothes dryers with fully modulating burner systems 

currently on the market, DOE did not consider this technology further in developing the 

standards set forth in today’s direct final rule. DOE does include this technology as a longer-term 

means to achieve energy efficiency improvements in a sensitivity analysis described in chapter 

16 of the direct final rule TSD. 

Outdoor Intake Air 

The California Utilities and NRDC suggested that DOE consider as a technology option 

those technologies that draw intake air for the clothes dryer from outside the residence, thereby 

reducing space conditioning loads in the home. (California Utilities, No. 31 at p. 8; NRDC, 

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Public Meeting Transcript, No. 21.4 at p. 44) The California Utilities further suggest that such a 

technology option may be necessitated by the trend in residential new construction towards 

tighter building envelopes. Tighter envelopes result in reduced exhaust airflow from the clothes 

dryer and greater depressurization impacts, which can potentially result in indoor air quality 

problems. According to the California Utilities, the HVAC load is proportional to the amount of 

air vented from the clothes dryer, but this load can be reduced or eliminated by reducing the total 

air drawn through the dryer or by having a separate outside air intake and vent. The California 

Utilities estimate energy savings due to reductions in HVAC load on the order of 10 percent or 

more. (California Utilities, No. 31 at pp. 2, 8–9) The NRDC/ECOS report states that outdoor 

intake air could save about 1 kWh per load, but that without heat recovery this technology option 

would only be advantageous in the summer. The NRDC/ECOS report adds that with heat 

recovery outdoor intake air is advantageous year-round. (NRDC, No. 30 at pp. 27–28) 

As discussed in section III.A.1.f, EPCA requires that any test procedures prescribed or 

amended under this section shall be reasonably designed to produce test results which measure 

energy efficiency, energy use, water use, or estimated annual operating cost of a covered product 

during a representative average use cycle or period of use. (42 U.S.C. 6293(b)(3)) DOE believes 

that accounting for the effects of clothes dryers on HVAC energy use is inconsistent with this 

requirement. Therefore, DOE did not revise the clothes dryer test procedure to account for 

HVAC energy use in the TP Final Rule, and does not consider outdoor intake air as an additional 

technology option. 

Reverse Tumble 

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NRDC commented that the use of synthetic mixed fabric in the DOE clothes dryer test 

procedure may be underestimating the efficiency improvement associated with reverse tumble. 

NRDC stated that cotton and other natural fabrics tend to ball up when rotated continuously in 

one direction, and therefore the test procedure is underestimating the potential benefit of reverse 

tumble. (NRDC, Public Meeting Transcript, No. 21.4 at pp. 42–43) As discussed in section 

III.A.1.d, DOE is unaware of data to determine the composition of clothing types and materials 

that would produce results as repeatable as those resulting from use of the current test cloth. 

Therefore, DOE did not amend the clothes dryer test procedure in the TP Final Rule to change 

the test load composition. In the absence of comments providing information on the efficacy of 

reverse tumble for the existing DOE test cloth, DOE continues to believe that no measurable 

energy savings are associated with this technology option. 

Switch Mode Power Supply 

ACEEE stated that the technology to reduce standby power consumption to less than 1 

W, via switch mode power supply controllers, is widely available at low cost. (ACEEE, No. 24 

at p. 2) NRDC stated that the ECOS report found standby power levels in the range of 0.03 to 

0.05 W with switch mode power supply controllers, corresponding to energy consumption of 4–6 

kWh over the lifetime of the clothes dryer. (NRDC, No. 26 at p. 3; NRDC, No. 30 at p. 5) DOE 

has observed that switching power supplies offer the highest conversion efficiencies (up to 75 

percent) and lowest no-load standby losses (0.2 W or less), though at a higher cost, higher part 

count, and greater complexity than conventional linear power supplies. DOE noted, however, 

that switch mode power supplies are incorporated in many clothes dryers currently on the 

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market, and thus has included switch mode power supplies in its analysis for today’s direct final 

rule. 

Vent Selector Switch 

The NRDC/ECOS report suggested as an additional technology option the incorporation 

of a “summer/winter” selector so that the waste heat would be delivered to the building during 

the winter instead of being vented outside. According to the ECOS report, 60 percent of the 

energy used by the clothes dryer evaporates water from the clothes load and the other 40 percent 

is available as waste heat to the room. (NRDC, No. 30 at p. 28) For the reasons discussed in 

section III.A.1.f, DOE did not consider the energy impacts on the space conditioning 

requirements in amending its clothes dryer test procedure, and thus did not evaluate this 

technology further. 

b. Room Air Conditioners 

DOE received comments from several interested parties recommending that DOE also 

consider the following technologies: alternative refrigerants, suction line heat exchangers 

(SLHX), flooded evaporator coils, and automatic timers. 

AHAM commented that it had no additional design option suggestions for room air 

conditioners, and that many of the design options proposed and initially evaluated by DOE are 

already employed by a number of manufacturers to increase the efficiency of today's products 

(AHAM, No. 25 at p. 4). 

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Alternative Refrigerants 

DOE notes that HCFC-22 was traditionally the refrigerant used in room air conditioners. 

On December 15, 2009, the EPA issued a final rule banning the sale and distribution of airconditioning and refrigeration appliances containing HCFC-22, applying to appliances and 

components manufactured on or after January 1, 2010. 74 FR 66412, 66418. 

During individual manufacturer interviews conducted for the preliminary analysis, 

manufacturers revealed that the room air conditioning industry was transitioning to using R410A refrigerant. DOE also discussed the transition with compressor manufacturers, who were 

developing and manufacturing R-410A rotary compressors for use in room air conditioners. 

Because of the phaseout of HCFC-22 and the transition to R-410A, DOE conducted the 

analysis for today’s direct final rule based on use of R-410A refrigerant. DOE’s analysis of R410A room air conditioners is presented in chapter 5 of the direct final rule TSD. 

A number of commenters urged DOE to consider alternative refrigerants as a technology 

option in the screening process. Both ACEEE and the California Utilities suggested that DOE 

consider hydrocarbon refrigerants possible alternatives to R-410A. (ACEEE, No. 24 at p. 4; 

California Utilities, No. 31 at p. 16) The California Utilities also suggested that DOE consider R407C. (California Utilities, No. 31 at p. 16) NPCC supported consideration of alternative 

refrigerants as well. (NPCC, No. 32 at p. 4) 

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DOE notes that no hydrocarbon refrigerants are currently included as acceptable for use 

in air-conditioning applications by the EPA Significant New Alternatives Policy (SNAP) 

Program list. This program was established to identify acceptable alternatives to ozone-depleting 

31 substances used in a variety of applications. The list identifies allowed applications for use of 

the alternative substances. Since there have been no hydrocarbons included on the SNAP list as 

acceptable for use in air conditioning appliances, DOE did not consider these alternative 

refrigerants in its analysis. 

R-407C, on the other hand, is approved as an acceptable substitute for use in airconditioning equipment, which includes room air conditioners. DOE analyzed R-407C to 

determine whether it offers efficiency improvement over R-410A, using the energy model 

developed and used throughout the engineering analysis. The results indicate that the efficiency 

of R-407C is less than that of R-410A for room air conditioners operating at rating conditions. 

As a result, DOE determined that use of R-407C refrigerant is not a viable design option. 

Additional details of this analysis are presented in chapter 3 of the direct final rule TSD. 

DOE also performed research to identify other potential alternative refrigerants during 

the preliminary analysis, but was unable to identify viable alternative refrigerants to R-410A. 

The research included a review of air-conditioning products, academic articles, industry 

publications, and interviews with component vendors. DOE sought to include refrigerants that 

were approved by the EPA for use in room air conditioners. For more detail, see chapter 3 of the 

direct final rule TSD. 

31 See the SNAP program website at http://www.epa.gov/ozone/snap/ 

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Suction Line Heat Exchangers 

An SLHX transfers heat between the high-temperature liquid refrigerant leaving the 

condenser and the low-temperature vaporized refrigerant leaving the evaporator. The heat 

exchanger lowers the outgoing temperature of the liquid refrigerant and raises the temperature of 

the outgoing vapor refrigerant. This heat transfer allows for the liquid refrigerant to be subcooled 

before entering the expansion device and offers the potential to increase the vapor-compression 

cycle’s cooling capacity. 

The California Utilities and NPCC argued that DOE should consider SLHXs based on 

possible performance improvements (California Utilities, No. 31 at pp. 14–15; NPCC, No. 32 at 

p. 4). The California Utilities comment cited the 1997 room air conditioner rulemaking, which 

cited a study by Allied-Signal demonstrating a 4 percent increase in system performance with the 

addition of a SLHX in a 2.5 ton split system AC application, and simulations by NIST for split32 system air conditioning applications showing EER improvement of 3.5 percent for R-410A 

systems using SLHX. (California Utilities, No. 31 at p. 14-15). 

DOE reviewed the room air conditioner rulemaking cited by the California Utilities and 

noted that the improvement was based on a comparison to a non-optimized system. DOE also 

33 considered the NIST simulation study referenced by the California Utilities. In this study, the 

EER improvement of 3.5 percent occurred for an outdoor temperature of 131 °F. The paper 

includes performance data for an outdoor temperature condition of 95 °F (which is used in the 

32 This efficiency increase was described in the source as reduction of an EER loss of 6.5 percent (when comparing 

R-410A performance to HCFC-22, at 131° F outdoor temperature) to 3.2 percent. 

33 National Institute of Standards and Technology. Performance of R-22 and its Alternatives Working at High 

Outdoor Temperatures. In Eighth International Refrigeration Conference at Purdue University, 2000. West 

Lafayette, IN – July 25-28, 2000 pp. 47-54 

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34 DOE Test Procedure), for which the EER improvement was 1.0 percent using a SLHX. These 

results were simulated for systems using reciprocating-type compressors, and the analyzed 

systems were not optimized to maximize performance of individual fluids. There is no indication 

in the paper that the simulations address room air conditioners because it does not mention 

outdoor air moisture content, which would be an important parameter affecting performance of 

room air conditioners. While the simulations show a potential for slight performance 

improvement, it is not clear that the simulations are applicable for room air conditioners, and the 

results were not validated experimentally. DOE therefore concludes that the cited studies do not 

support the conclusion that SLHXs will significantly improve room air conditioner efficiency. 

During interviews conducted during the preliminary and final rule analysis, 

manufacturers did not indicate that SLHX could be used to improve system performance. 

Furthermore, use of SLHX’s may be inconsistent with the operating temperature limits for 

compressors. The technology significantly raises the temperature of the suction gas entering the 

compressor. Because hermetic compressors are cooled by the suction gas, the compressor will 

overheat if the suction gas temperature exceeds limits specified by the compressor manufacturer. 

DOE notes that 65 °F is typically the highest allowable suction temperature for R-410A rotary 

compressors. DOE noted that a SLHX operating at close to 50% effectiveness (as analyzed in the 

NIST study) would raise suction temperature roughly 20  ̊F, thus significantly exceeding the 

specified limit. For additional details of this analysis, see chapter 3 of the TSD. Use of this 

technology would adversely affect the reliability of the compressor, and consequently, DOE 

cannot consider SLHX as a design option. 

34 Again, expressed as reduction of an EER loss of 2.5 percent (when comparing R-410A performance to HCFC-22, 

at a 95° F outdoor temperature) to 1.5 percent. 

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Flooded Evaporator Coils 

Flooded evaporator coils are evaporators for which refrigerant flow is higher than the 

amount that can be evaporated. As a result, a portion of the refrigerant leaves such an evaporator 

unevaporated (that is, still in the liquid phase). Such a design assures that liquid is available for 

boiling heat transfer throughout the evaporator. Because boiling heat transfer is much more 

effective than vapor phase heat transfer, the evaporator’s heat transfer characteristics can be 

improved. However, the liquid refrigerant leaving the evaporator cannot be routed to the 

compressor, because (1) compressors cannot tolerate significant amounts of liquid without 

damage; and (2) this would represent lost cooling and lost efficiency. The liquid refrigerant 

returns to a reservoir from which it can be redirected to the evaporator. The reservoir inventory is 

controlled to allow low pressure vapor to exit to the compressor, while “fresh” refrigerant from 

the condenser enters through an expansion valve that may vary flow based on the reservoir liquid 

level. 

The California Utilities stated that DOE should consider flooded evaporator coils as a 

design option, as this technology is used in some refrigerant systems (California Utilities, No. 31 

at p. 14). Oak Ridge National Laboratories (ORNL) tests on window air conditioners found that 

35 a flooded evaporator coil setup using R-22 increased cooling capacity by 8 percent.

DOE considered the ORNL study referenced by the California Utilities. The article 

describes work in which a room air conditioner was tested, modified to have a flooded 

35 V.C. Mei and F.C. Chen, et al. Experimental Analysis of a Window Air Conditioner with R-22 and Zeotropic 

Mixture of R-32/125/134a. Energy Renewable and Research Section, Energy Division, Oak Ridge National 

Laboratory: Oak Ridge, TN. August 1995. 

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evaporator, and then retested. Data provided in the article shows that the evaporator of the 

unmodified unit was very poorly controlled. A plot graph of heat exchanger tube temperature 

versus evaporator length shows the tube temperature rising after the refrigerant liquid had 

traveled 60 percent of the heat exchanger tube length, indicating that the refrigerant liquid has 

evaporated. Air conditioner designs that incorporate flooded evaporator coils are not optimized, 

and the performance of such designs could have improved significantly with much less costly 

changes than converting to a flooded evaporator. As a result, DOE does not believe that the cited 

ORNL study supports analyzing flooded evaporator coils as a technology option in the room air 

conditioner engineering analysis. 

Automatic Timers 

The California Utilities stated that DOE should consider automatic timers as a design 

option in its analysis, arguing that many room air conditioner models currently feature an 

automatic timer that shuts off operation after a pre-determined amount of time, thus avoiding 

unnecessary cooling (California Utilities, No. 31 at p. 14). The California Utilities argued that 

this is a simple and inexpensive option that can be implemented to improve consumer utility and 

provide potential energy savings. 

DOE notes that automatic timers may save energy by preventing cooling of the space 

when occupants have left. However, the benefits of automatic timers would not be measured by 

the current or amended test procedures, unless the test procedure allocation of hours to full-load 

and standby or off mode were adjusted based on presence of the automatic timer. Information to 

allow proper allocation of the hours in this fashion is not available, thus the test procedure 

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rulemaking did not establish adjustment of hours to address this technology. DOE acknowledges 

the importance of conducting appropriate test programs to provide a basis for crediting 

technologies such as automatic timers. DOE will consider supporting such work to assist in a 

future test procedure rulemaking. At this time, however, DOE cannot consider automatic timers 

in the engineering analysis. 

B. Screening Analysis 

DOE uses the following four screening criteria to determine which technology options 

are suitable for further consideration in a standards rulemaking: 

1. Technological feasibility. DOE will consider technologies incorporated in commercial 

products or in working prototypes to be technologically feasible. (The technological feasibility of 

options was discussed in the preceding section as part of the market and technology assessment.) 

2. Practicability to manufacture, install, and service. If mass production and reliable 

installation and servicing of a technology in commercial products could be achieved on the scale 

necessary to serve the relevant market at the time the standard comes into effect, then DOE will 

consider that technology practicable to manufacture, install, and service. 

3. Adverse impacts on product utility or product availability. If DOE determines a 

technology would have significant adverse impact on the utility of the product to significant 

subgroups of consumers, or would result in the unavailability of any covered product type with 

performance characteristics (including reliability), features, sizes, capacities, and volumes that 

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are substantially the same as products generally available in the United States at the time, it will 

not consider this technology further. 

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider this technology further. 

10 CFR part 430, subpart C, appendix A, (4)(a)(4) and (5)(b). 

Technologies that pass through the screening analysis are referred to as “design options” 

in the engineering analysis. Details of the screening analysis are in chapter 4 of the direct final 

rule TSD. 

1. Clothes Dryers 

In the preliminary analysis, DOE identified the following technology options that could 

improve the efficiency of clothes dryers, as shown in Table IV.5. 

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Table IV.5 Technology Options for Residential Clothes Dryers 

Dryer Control or Drum Upgrades 

Improved termination 

Increased insulation 

Modified operating conditions 

Improved air circulation 

Reverse tumble 

Improved drum design 

Methods of Exhaust Heat Recovery (vented models only) 

Recycle exhaust heat 

Inlet air preheat 

Inlet air preheat, condensing mode 

Heat Generation Options 

Heat pump, electric only 

Microwave, electric only 

Modulating, gas only 

Water-cooling, ventless electric only 

Indirect heating 

Component Improvements 

Improved motor efficiency 

Improved fan efficiency 

Standby Power Improvements 

Switching power supply 

Transformerless power supply with auto-powerdown 

For the preliminary analysis, DOE considered eliminating the following clothes dryer 

technology options from consideration: 

Microwave, electric only 

DOE’s research suggested that significant technical and safety issues would be 

introduced with microwave drying by the potential arcing from metallic objects in the fabric 

load, including zippers, buttons, or “stray” items such as coins. While DOE noted that efforts 

have been made to mitigate the conditions that are favorable to arcing, or to detect incipient 

arcing and terminate the cycle, the possibility of fabric damage could not be completely 

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eliminated. Thus, for these reasons of consumer utility and adverse impacts on safety, microwave 

drying was not considered further for analysis. 

Water-cooling, ventless electric only 

DOE noted that water-cooling for ventless electric clothes dryers, which uses water as a 

cooling fluid to condense the moisture in the air exiting the drum, would require significant 

plumbing to circulate water through a heat exchanger in the dryer and add to the complexity of 

maintenance. Such home renovations would require installing a water hook-up and drain in the 

laundry area, which is not typically done for clothes dryers. Therefore, DOE determined in the 

preliminary analysis that the water-cooling for ventless electric dryers technology option does 

not meet the criterion of practicability to install and service on a scale necessary to serve the 

relevant market at the time of the compliance date of a new standard and proposed screening it 

out of the analysis. DOE did not receive any comments objecting to this determination. For these 

reasons, DOE is continuing to screen out water-cooling for ventless electric clothes dryers in 

today’s final rule. 

Indirect Heating 

DOE tentatively concluded in the preliminary analysis that indirect heating would be 

viable only in residences which use a hydronic heating system. An energy conservation standard 

that required indirect heating would require homes without a hydronic heating system to have 

such a system installed. DOE also notes that there would be added maintenance requirements 

because the home’s hydronic heating system because it would be used more frequently (that is, 

year-round). Also, to derive dryer heat energy from the home’s heating system, significant 

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plumbing work would be required to circulate heated water through a heat exchanger in the 

dryer. Therefore, DOE determined that this technology option does not meet the criterion of 

practicability to install on a scale necessary to serve the relevant market at the time of the 

compliance date of a new standard and did not consider it further in the preliminary analysis. 

In response, ACEEE commented that DOE should reconsider its decision to leave watercooled clothes dryers unregulated because these products are very water-intensive. ACEEE 

stated that, although water-cooled clothes dryers are currently of very limited use in the United 

States, this technology is used overseas and could find a larger market niche in the United States 

if left unregulated. (ACEEE, No. 24 at pp. 2–3) DOE believes that the current unavailability of 

such products in the Unites States, along with the reasons noted above, confirms its initial 

conclusion regarding the failure of this technology to meet the screening criteria of practicability 

to install and service on the scale necessary to serve the relevant market at the time of the 

effective date of a new standard. In addition, EPCA does not authorize DOE to set waterefficiency standards for clothes dryers. (42 U.S.C. 6291(6), 6295(g)) Therefore, DOE continues 

to screen out this technology option. 

No other comments were received objecting to the technology options which were 

screened out in the preliminary analysis, or to the initial determination that the remaining design 

options met all of the screening criteria listed above. Therefore, DOE considered the same design 

options in the final rule as those evaluated in the preliminary analysis (see Table IV.6). 

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Table IV.6 Retained Design Options for Residential Clothes Dryers 

Dryer Control or Drum Upgrades 

Improved termination 

Increased insulation 

Modified operating conditions 

Improved air circulation 

Reverse tumble 

Improved drum design 

Methods of Exhaust Heat Recovery (vented models only) 

Recycle exhaust heat 

Inlet air preheat 

Inlet air preheat, condensing mode 

Heat Generation Options 

Heat pump, electric only 

Modulating, gas only 

Component Improvements 

Improved motor efficiency 

Improved fan efficiency 

Standby Power Improvements 

Switching power supply 

Transformerless power supply with auto-powerdown 

2. Room Air Conditioners 

In the preliminary analysis, DOE identified the following technology options that could 

improve the efficiency of room air conditioners, as shown in Table IV.7. 

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Table IV.7 Technology Options for Room Air Conditioners 

Increased Heat Transfer Surface Area 

Increased frontal coil area 

Increased depth of coil (add tube rows) 

Increased fin density 

Add subcooler to condenser coil 

Increased Heat Transfer Coefficients 

Improved fin design 

Improved tube design 

Hydrophilic film coating on fins 

Spray condensate onto condenser coil 

Microchannel heat exchangers 

Component Improvements 

Improved indoor blower and outdoor fan efficiency 

Improved blower/fan motor efficiency 

Improved compressor efficiency 

Part-Load Technology Improvements 

Two-speed, variable-speed, or modulating-capacity compressors 

Thermostatic or electronic expansion valves 

Thermostatic cyclic controls 

Standby Power Improvements 

Switching power supply 

For the preliminary analysis, DOE tentatively concluded that all room air conditioner 

technology options met the screening criteria listed above and did not propose to eliminate any 

of these technology options from consideration. DOE did not receive any comments objecting to 

this list of technology options and, therefore, retained all of the technologies in Table IV.7 as 

room air conditioner design options. As described and explained below in section IV.C.1.b 

below, however, some of the technologies were not considered in the engineering analysis. 

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C. Engineering Analysis 

The engineering analysis develops cost-efficiency relationships to show the 

manufacturing costs of achieving increased efficiency. DOE has identified the following three 

methodologies to generate the manufacturing costs needed for the engineering analysis: (1) The 

design-option approach, which provides the incremental costs of adding to a baseline model 

design options that will improve its efficiency; (2) the efficiency-level approach, which provides 

the relative costs of achieving increases in energy efficiency levels, without regard to the 

particular design options used to achieve such increases; and (3) the cost-assessment (or reverse 

engineering) approach, which provides “bottom-up” manufacturing cost assessments for 

achieving various levels of increased efficiency, based on detailed data as to costs for parts and 

material, labor, shipping/packaging, and investment for models that operate at particular 

efficiency levels. 

DOE conducted the engineering analyses for this rulemaking using the efficiency-level 

approach for clothes dryers and room air conditioners. For this analysis, DOE relied upon 

efficiency data published in multiple databases, including those published by CEC, the 

Consortium for Energy Efficiency (CEE), and ENERGY STAR, which were supplemented with 

laboratory testing, data gained through engineering analysis, and primary and secondary 

research. Details of the engineering analysis are in chapter 5 of the direct final rule TSD. 

1. Technologies Not Analyzed 

In performing the engineering analysis, DOE did not consider for analysis certain 

technologies that were not evaluated for one or more of the following reasons: (1) data are not 

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available to evaluate the energy efficiency characteristics of the technology; (2) available data 

suggest that the efficiency benefits of the technology are negligible; and (3) for the reasons stated 

in the TP Final Rule, DOE did not amend the test procedure to measure the energy impact of 

these technologies. 

In the preliminary analysis, DOE did not include the following design options: 

a. Clothes Dryers 

Reverse Tumble 

As discussed in section IV.A.5.a, NRDC commented that the DOE clothes dryer test 

procedure may be underestimating the efficiency improvement associated with reverse tumble 

due to the composition of the test cloth. (NRDC, Public Meeting Transcript, No. 21.4 at pp. 42– 

43) Because DOE did not amend the specifications for the test cloth composition in the TP Final 

Rule (as discussed in section III.A.1.d), and in the absence of comments providing information 

on the efficacy of reverse tumble for the existing DOE test cloth, DOE continues to conclude that 

no measurable energy savings are associated with this design option. Thus, this design option 

was not considered further in the analysis for today’s final rule. 

Improved Termination 

For the reasons noted in section III.A.1.b, DOE did not adopt amendments to its clothes 

dryer test procedure to better account for automatic cycle termination. Therefore, energy savings 

due to improved termination technologies cannot be measured according to the test procedure, 

and this design option was not considered further in the analysis for today’s direct final rule. 

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b. Room Air Conditioners 

DOE eliminated the following technologies from further consideration due to the three 

criteria mentioned above. 

1. Improved fin design 

2. Improved tube design 

3. Hydrophilic-film coating on fins 

4. Spray condenser onto condenser coil 

5. Improved indoor blower and outdoor fan efficiency 

6. Variable speed compressors 

7. Thermostatic or electronic expansion valves 

8. Thermostatic cyclic controls 

Of these technologies, numbers 1 through 4 are used in baseline products. Information 

indicating efficiency improvement potential is not available for number 5. Any potential energy 

savings of technologies 6 through 8 cannot be measured with the established energy use metric 

because those technologies are associated with part-load performance. As discussed in Section 

III.A.2.d above, DOE did not amend the test procedure to measure part-load performance of 

room air conditioners. Chapter 5 of the direct final rule TSD discusses these reasons in greater 

detail. 

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2. Efficiency Levels and Cost-Efficiency Results 

a. Clothes Dryers 

In the preliminary analysis, DOE analyzed active mode and standby mode separately to 

develop integrated cost-efficiency results. For vented clothes dryer product classes, DOE 

proposed the active mode efficiency levels shown in Table IV.8, which were based on EF values 

measured using the previous clothes dryer test procedure. For ventless clothes dryer product 

classes, DOE proposed the active mode efficiency levels shown in Table IV.9, which were based 

on EF values measured using the previous clothes dryer test procedure without the requirement 

to install an exhaust simulator. DOE proposed the standby power levels shown in Table IV.10 

for all clothes dryer product classes. 

Table IV.8 Clothes Dryer Active Mode Efficiency Levels (EF) – Vented Product Classes 

Level Efficiency Level Description 

Efficiency Level (EF) lb/kWh 

Electric 

Standard 

Electric 

Compact 

(120V) 

Electric 

Compact 

(240V) 

Gas 

Baseline DOE Standard 3.01 3.13 2.90 2.67 

1 Gap Fill 3.10 3.22 2.98 2.75 

2 Gap Fill 3.16 3.29 3.09 2.85 

3 Gap Fill/Maximum Available 3.4 3.54 3.2 3.02 

4 Max-Tech 4.51 4.70 4.35 

Table IV.9 Clothes Dryer Active Mode Efficiency Levels (EF) – Ventless Product Classes 

Level Efficiency Level Description 

Efficiency Level (EF) lb/kWh 

Electric Compact 

(240V) 

Electric Combination 

Washer/Dryer 

Baseline DOE Test Data 2.37 1.95 

1 Gap Fill 2.39 2.21 

2 Gap Fill 2.59 2.42 

3 Max-tech 3.55 3.32 

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Table IV.10 Clothes Dryer Standby Power Levels 

Level Standby Power Source Power Input W 

Baseline DOE Test Data and Analysis 2.0 

1 DOE Test Data 1.5 

2 DOE Test Data (Max-Tech) 0.08 

In the preliminary analyses, DOE developed integrated efficiency levels based on the 

integrated EF (IEF) metric proposed as an alternative option in the TP NOPR. The IEF is 

calculated as the clothes dryer test load weight in lb divided by the sum of active mode per-cycle 

energy use and standby/off mode per-cycle energy use in kWh. Table IV.11 through Table IV.13 

show the integrated efficiency levels proposed in the preliminary analyses. 

Table IV.11 Clothes Dryer Integrated Efficiency Levels (IEF) – Vented Product Classes 

Level Efficiency Level Description 

Integrated Efficiency Level (IEF) lb/kWh 

Electric 

Standard 

Electric 

Compact 

(120V) 

Electric 

Compact 

(240V) 

Gas 

Baseline DOE Standard + 2.0 W Standby 2.96 3.00 2.79 2.63 

1 Gap Fill + 2.0 W Standby 3.04 3.08 2.86 2.71 

2 Gap Fill + 2.0 W Standby 3.10 3.15 2.96 2.80 

3 Gap Fill/Maximum Available + 2.0 W Standby 3.33 3.37 3.06 2.97 

4 Maximum Available + 1.5 W Standby 3.35 3.41 3.10 2.98 

5 Maximum Available + 0.08 W Standby 3.40 3.53 3.19 3.02 

6 Heat Pump (Max-tech) + 0.08 W Standby 4.52 4.69 4.34 

Table IV.12 Clothes Dryer Integrated Efficiency Levels (IEF) – Ventless Electric Compact 

(240V) 

Level Efficiency Level Description 

Integrated Efficiency Level (IEF) 

lb/kWh 

Electric Compact (240 V) 

Baseline Baseline + 2.0 W Standby 2.29 

1 Baseline + 1.5 W Standby 2.31 

2 Baseline + 0.08 W Standby 2.37 

3 Gap Fill + 0.08 W Standby 2.39 

4 Gap Fill + 0.08 W Standby 2.59 

5 Heat Pump (Max-Tech) + 0.08 W Standby 3.54 

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Table IV.13 Clothes Dryer Integrated Efficiency Levels (IEF) – Ventless Electric 

Combination Washer/Dryers 

Level Efficiency Level Description 

Integrated Efficiency Level (IEF) 

lb/kWh 

Electric Combination Washer/Dryer 

Baseline Baseline + 2.0 W Standby 1.90 

1 Gap Fill + 2.0 W Standby 2.15 

2 Gap Fill + 2.0 W Standby 2.34 

3 Gap Fill + 1.5 W Standby 2.36 

4 Gap Fill + 0.08 W Standby 2.42 

5 Heat Pump (Max-Tech) + 0.08 W Standby 3.31 

DOE also noted that it was considering revisions to the clothes dryer test procedure for 

active mode, standby mode, and off mode, and that those potential amendments would affect the 

calculated IEF. (IEF has since been renamed CEF for this direct final rule to avoid confusion 

with an existing industry standard). AHAM commented that, to ensure a rigorous analysis and to 

mitigate confusion, DOE should modify the baseline efficiency level to account for a revised 

initial RMC in the clothes dryer test procedure. (AHAM, No. 25 at p. 10) The TP Final Rule was 

published on January 6, 2011, and DOE has adjusted the efficiency levels, including the baseline 

level, as discussed later in this section to account for the impacts of all test procedure revisions, 

including those pertaining to initial RMC. 

Integrated Efficiency Metric 

DOE received comments from interested parties on the adequacy of IEF as the energy 

efficiency metric for clothes dryer energy conservation standards. AHAM supported the 

incorporation of standby mode and off mode power into the total energy use of clothes dryers, 

and commented that the integrated metric is appropriate. (AHAM, No. 25 at p. 2) 

Whirlpool commented that standby power technologies should not be considered as 

separate design options associated with specific TSLs, and that doing so would avoid the 

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requirement that standby power be incorporated into the total energy use of the clothes dryer. 

Whirlpool also stated that standby levels should not vary by TSL. (Whirlpool, No. 22 at p. 5) 

DOE notes that the CEF metric at each TSL incorporates a measure of standby power as a 

contributor to energy use along with energy use in active mode, as required by EPCA. Because 

CEF does not preferentially weight the energy use contributions attributable to either active or 

standby mode, improvements in CEF due to standby power reductions are considered equally to 

those due to active mode design options. For these reasons, DOE believes that technologies 

associated with standby power reductions should be considered in the definition of efficiency 

levels and thus TSLs. In today’s direct final rule, DOE analyzes some TSLs that would require 

standby power reductions only, and some that would require reductions to both standby power 

and active mode power, as shown later in this section. 

The NRDC/ECOS report stated that the fact that natural gas clothes dryers tend to have 

lower average energy factors than electric clothes dryers could lead consumers to believe that 

electric dryers are generally more efficient. NRDC/ECOS report stated that conventional gas 

clothes dryers that have been available for 30 years have significantly less source energy use and 

environmental impact than today’s efficient electric clothes dryers. The NRDC/ECOS report 

added that heat pump clothes dryers that may reach the U.S. market in the future have only 

slightly lower impacts than conventional gas clothes dryers. (NRDC, No. 30 at pp. 17–18) The 

NRDC/ECOS report further stated that the current EF metric is not intuitive and fails to capture 

meaningful differences between electric and natural gas models. According to the NRDC/ECOS 

report, converting natural gas consumption into equivalent electrical consumption on a site basis 

ignores all of the losses that occur in the electrical generation and transmission process. The 

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NRDC/ECOS report stated that this draws attention from the substantial advantage of most gas 

clothes dryers—that they convert their fuel directly into heat at the site where it is needed, 

avoiding upstream losses. According to the NRDC/ECOS report, there are three ways to 

compare gas and electric clothes dryers more fairly: (1) source Btu basis, (2) total CO2 emissions 

basis, and (3) energy cost basis. The NRDC/ECOS report presented test results which showed 

that the standard natural gas clothes dryer uses less source energy, costs less, and emits less CO2 

per lb of water removed than any other option except (in some cases) a heat pump clothes dryer. 

(NRDC, No. 30 at pp. 32–33) NRDC commented that DOE should consider reporting actual 

kWh and Btu consumption rather than converting to site equivalent kWh. NRDC stated that it 

would be more useful to consumers to have information on actual kWh of electricity and Btu of 

gas consumed. According to NRDC, organizations such as EnergyGuide, ENERGY STAR, and 

Top Ten could use this information to more accurately inform prospective buyers on CO2 

emitted or operating costs of a given clothes dryer. (NRDC, No. 26 at pp. 1, 3) 

In response, DOE notes that EPCA defines “energy conservation standard” in relevant 

part as either: (1) a performance standard which prescribes a minimum level of energy efficiency 

or a maximum quantity of energy use; or (2) for certain products, including clothes dryers but 

not including room air conditioners, a design requirement; the term also includes any other 

requirements that DOE may prescribe under 42 U.S.C. 6295(r). (42 U.S.C. 6291(6)) EPCA also 

provides definitions for the terms “energy use” and “energy efficiency”. Specifically, “energy 

use” refers to the quantity of energy directly consumed by a consumer product at the point of 

use, and “energy efficiency” means the ratio of the useful output of services from a consumer 

product to the energy use of such product. (42 U.S.C. 6291(4)–(5)) Therefore, an energy 

156 
 

 

 

 

 

 

 

 

 

 

 

 

conservation standard metric based on source energy use, emissions, or annual energy cost 

would be inconsistent with the definitions set forth in EPCA. In addition, DOE promulgates test 

procedures for all product classes of clothes dryers that calculate energy use or energy efficiency 

on a consistent basis, regardless of the type of energy used. The energy content of either the 

electricity or fossil fuels used at the site of the clothes dryer may be equally and interchangeably 

expressed in any unit of energy measurement, including kWh and Btu. DOE notes that, for other 

covered products which may consume gas as well as electricity, such as cooking products, DOE 

define an energy efficiency metric (EF) in which any contributory site gas energy use is 

expressed in equivalent kWh. DOE continues to believe that the measure of CEF in terms of lb 

of clothes load per kWh is meaningful and representative of the performance for both electric 

and gas clothes dryers, and thus is not adopting alternative measures of energy use or energy 

efficiency. 

NRDC and the California Utilities recommended that the metric be based on the water 

removed in the clothes load per kWh. The NRDC/ECOS report stated that the efficiency using 

this approach would be measured by converting the lbs. of water removed into kWh with a 

conversion factor of 0.308 (the kWh necessary to evaporate a 1 lb. of water,) then dividing by the 

measured energy consumption. According to the NRDC/ECOS report, this metric would be more 

meaningful because it would measure the work actually being performed by the clothes dryer. 

The NRDC/ECOS report provided as an example the case in which a clothes dryer removed 3 

lbs. of water from either a heavily saturated small load of absorbent fabrics such as cotton or a 

lightly saturated larger load of synthetics. According to the NRDC/ECOS report, testing and 

reporting the results for both situations would help consumers choose the most efficient clothes 

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dryers. The California Utilities stated that the metric should be based on lbs. of water removed 

per kWh, and that this metric would correct for small variations in actual test load or moisture 

content. The California Utilities also stated that this approach would eliminate the need for the 

0.66 correction factor (in sections 4.1–4.3 of the current clothes dryer test procedure), which 

corrects for the RMC change during the test. (California Utilities, No. 31 at pp. 11–12; NRDC, 

Public Meeting Transcript, No. 21.4 at pp. 49–50; NRDC, No. 26 at pp. 1–3; NRDC, No. 30 at 

pp. 8, 32) 

As noted above, DOE did not amend the clothes dryer test procedure to allow for testing 

materials other than the current 50-50 cotton-polyester test cloth. In addition, test conditions that 

would allow the test load size or initial RMC to vary would only be allowable if the resulting 

measured energy efficiency metric was independent of such variations, implying that the metric 

would need to be a linear function of these test conditions. DOE testing indicates that the 

efficacy of moisture removal becomes significantly non-linear as the RMC in the clothes load 

approaches low values, particularly near the 5-percent maximum allowable RMC for the 

conclusion of the test cycle according to the clothes dryer test procedure. Therefore, test loads 

with different initial RMC that are allowed to dry to a range of final RMCs, or differences in test 

load size, would not produce repeatable and consistent measures of energy efficiency 

performance due to this non-linearity of efficiency through the drying process. In order for 

testing results to be comparable, the test procedure would need to be amended to specific an 

exact starting and ending RMC, which would likely represent a significant testing burden. In 

addition, DOE does not believe that a metric based on lbs. of water removed per kWh, as 

commented by NRDC/ECOS, would be more meaningful to consumers, who may not be aware 

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of how much water is contained in their test load. For these reasons, and because DOE has 

insufficient data to suggest that a metric based on lbs. of water removed per kWh instead of lb of 

test cloth per kWh is a more accurate or representative measure of clothes dryer energy use, 

DOE is not amending the clothes dryer energy conservation standards as suggested by NRDC 

and the California Utilities. 

The California Utilities recommended that DOE consider a prescriptive design 

requirement that all vented clothes dryers have a standard 4-inch round port for air intake, which 

would be the same diameter as the exhaust duct. According to the California Utilities, there 

would be negligible cost associated with this design, and would allow consumers the option to 

install outdoor intake air in the future. (California Utilities, No. 31 at pp. 8, 12) As noted in 

section IV.A.5.a, DOE concluded that consideration of HVAC energy use associated with 

outdoor intake air was inconsistent with EPCA’s requirement that a test procedure measure the 

energy use or energy efficiency of a covered product. As a result, DOE did not consider this 

technology in its analysis and is not adopting a prescriptive design standard addressing the 

potential implementation of outdoor intake air. 

PG&E inquired whether DOE would consider a performance metric that would include 

the non-energy benefit of clothing life if such data were available. (PG&E, Public Meeting 

Transcript, No. 21.4 at p. 129) DOE is not aware of such data and notes that EPCA provides that 

any test procedures prescribed or amended under this section shall be reasonably designed to 

produce test results which measure energy efficiency, energy use, water use, or estimated annual 

operating cost of a covered product during a representative average use cycle or period of use. 

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(42 U.S.C. 6293(b)(3)) DOE believes that a clothes dryer metric incorporating the non-energy 

benefit of clothing life would be inconsistent with this requirement. Therefore, DOE did not 

consider such a metric in the TP Final Rule. DOE is required, however, to consider any lessening 

of utility or performance in establishing energy conservation standards. 42 U.S.C. 

6295(o)(2)(B)(i)(IV). 

The NRDC/ECOS report stated that, due to the complexity of the current DOE clothes 

washer test procedure and energy use calculations, it might be simpler for manufacturers to 

report total energy used to wash and dry one load. (NRDC, No. 30 at p. 32) EPCA provides 

separate standards for clothes dryers and clothes washers, and directs DOE to consider amended 

energy conservation standards for each product separately. (42 U.S.C. 6295(g)) Therefore, DOE 

is unable to adopt a single standard based on overall energy use of the wash and dry cycles in 

total. 

Comments on Preliminary Analysis Integrated Efficiency Levels 

DOE also received comments from interested parties on the efficiency levels proposed in 

the preliminary analysis. The California Utilities stated that, with the low or negative incremental 

costs of the standby power design options, such design options should be implemented at lower 

efficiency levels. According to the California Utilities, this implementation would not affect 

clothes dryers with electromechanical controls, which have zero standby and are thus receiving a 

“free” benefit of 2.0 W. (California Utilities, No. 31 at pp. 11–12) DOE agrees that the low cost 

of the standby power design options should result in these technologies being included in the 

initial efficiency levels above the baseline. Thus, the clothes dryer efficiency levels analyzed in 

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this direct final rule implement the standby power design options at the efficiency levels where 

they are most cost-effective. As noted by the California Utilities, these changes would impact 

only those clothes dryers that consume standby power, that is, those products with electronic 

controls. 

Earthjustice commented that EPCA contains an “anti‐backsliding provision” that 

constrains DOE’s authority in revising energy efficiency standards. According to Earthjustice, 

some of the clothes dryer efficiency levels that DOE is considering would violate the antibacksliding requirement. Earthjustice commented that adding standby power consumption 

factors into the existing metrics reduces the stringency of each metric. Earthjustice provided an 

example for vented electric compact (120 V) clothes dryers in which the addition of the 2 W of 

standby power lowers the EF rating of the baseline efficiency level from 3.13 to 3.00. If DOE 

adopts efficiency level 1, with an IEF of 3.08, such a standard would violate EPCA’s 

anti‐backsliding provision. NRDC commented that if an existing vented electric compact (120V) 

clothes dryer model with electromechanical controls (which DOE has shown to consume no 

power in standby mode) has an EF of 3.10, it would be barred from the U.S. market by the 

existing standard. However, it would meet an IEF standard set at 3.08 (which DOE proposed as 

efficiency level 1 in the preliminary TSD). Earthjustice commented that implementing an IEF 

standard set at 3.08 would have the effect of decreasing the minimum required energy efficiency 

as is prohibited by the anti-backsliding provisions. (EJ, No. 28 at pp. 1–2; EJ, Public Meeting 

Transcript, No. 21.4 at p. 58) Earthjustice also commented that DOE’s proposed approach to the 

integration of standby and off mode energy consumption into the performance standards for 

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clothes dryers would require DOE to adopt standards that increase EF sufficiently to avoid 

violating EPCA’s anti‐backsliding provision. (EJ, No. 28 at p. 1) 

EPCA contains what is commonly known as an “anti-backsliding” provision. This 

provision prohibits DOE from prescribing any amended standard that either increases the 

maximum allowable energy use or decreases the minimum required energy efficiency of a 

covered product or equipment. (42 U.S.C. 6295(o)(1)) Congress also directed DOE to 

incorporate standby and off mode energy use in a single amended or new standard, or to 

prescribe a separate standard if such incorporation is not feasible, pursuant to 42 U.S.C. 6295(o). 

(42 U.S.C. 6295(gg)(3)) Today’s final rule incorporates additional measures of energy 

consumption in the energy conservation standards for clothes dryers (that is, standby and off 

mode energy use). DOE notes that clothes dryers and room air conditioners that consume energy 

in standby and off modes have always used energy in these modes, and that today’s final rule 

now accounts for that energy as directed by 42 U.S.C. 6295(gg). Given the Congressional 

directive to account for standby and off mode energy use, DOE does not believe that accounting 

for energy use in these modes could result in backsliding under 42 U.S.C. 6295(o)(1). In 

addition, DOE evaluated the clothes dryer TSLs to ensure that no product currently on the 

market could be determined compliant with the new energy conservation standards while 

consuming more energy in active mode than was allowable under the previous standards. 

NPCC commented that the clothes dryer test procedure does not measure the efficiency 

improvement associated with improved automatic termination controls such as moisture sensing. 

NPCC stated that because moisture sensing would require switching from electromechanical 

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controls to electronic controls, part of the incremental manufacturing cost associated with 

electronic controls would be accounted for in the improved automatic cycle termination design 

option. However, NPCC also stated that all clothes dryers have some form of automatic cycle 

termination for which the current test procedure uses a fixed field use factor. NPCC commented 

that because moisture sensing requires electronic controls and thus consumes standby power, the 

cost of the implementing electronic controls is inappropriately accounted for only in the standby 

power design options because the test procedure does not measure the efficiency improvement 

associated with moisture sensing. NPCC stated that part of the costs for implementing electronic 

controls should be accounted for in the costs associated with improved automatic cycle 

termination with moisture sensing. (NPCC, Public Meeting Transcript, No. 21.4 at pp. 58–60, 

61–62) NPCC commented that if a product is receiving the 1.04 field use factor for automatic 

cycle termination, then the cost of that type of device (that is, the cost of electronic controls) 

needs to be in the baseline cost analysis. (NPCC, Public Meeting Transcript, No. 21.4 at p. 60) 

DOE first notes that electronic controls are not required to implement automatic cycle 

termination. Clothes dryers are currently available on the market that use inputs from exhaust air 

temperature sensors to control or modify the length of the drying cycle without the use of 

electronic controls. For this reason, DOE did not include the cost of electronic controls in the 

baseline cost, unless the baseline product already incorporated electronic controls (such as, 

ventless electronic compact (240V) and ventless electric combination washer/dryers). As 

discussed below, DOE noted that baseline efficiency clothes dryers implement both 

electromechanical controls and electronic controls. As a result, DOE analyzed baseline 

efficiency products available on the market, and weighted the contribution of the 2 W baseline 

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standby power as well as the efficiency improvement and incremental manufacturing cost for 

standby power design changes based on the percentage of baseline efficiency products that used 

electronic controls. 

BSH commented that DOE should analyze and implement evenly distributed efficiency 

levels to help consumers make purchasing decisions. BSH also commented that the 

implementation of the proposed efficiency levels in the preliminary analyses would cause 

confusion to consumers. According to BSH, with a relatively small improvement in efficiency in 

the lower efficiency levels, a better rating can be achieved, and at the high end of the efficiency 

levels, much more effort must be taken to improve the rating. In addition, according to BSH, 

consumers will not support the higher efficiency level because they cannot see the advantage of 

paying a significantly higher price for a small change in product efficiency. (BSH, No. 23 at pp. 

3–4) BSH also commented that DOE should use the same efficiency scale to analyze ventless 

and vented clothes dryers. According to BSH, ventless clothes dryers, especially those with heat 

pump technology, will be penalized by keeping a lower number of efficiency levels. (BSH, No. 

23 at p. 4) 

DOE notes that the efficiency levels analyzed for the preliminary analyses were derived 

from the distribution of efficiencies for products available on the market from data provided in 

the CEC and NRCan product databases. DOE also notes that the efficiency levels for the ventless 

clothes dryer product classes were based on product testing as well as scaling of the efficiency 

improvements associated with vented clothes dryer product classes. The efficiency levels 

analyzed are not being established for a product marketing classification system for consumers to 

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make purchasing decisions (as is done in the European energy class system). As a result, DOE 

does not intend to create an energy class system for product marketing based on evenly 

distributed efficiency levels. 

BSH commented that a separate classification of heat pump clothes dryers will not be 

possible because the European market shows large variation within this class of clothes dryers. 

According to BSH, heat pump clothes dryers in Europe differ by up to 40 percent in energy 

efficiency. (BSH, No. 23 at pp. 3–4) DOE notes that the efficiency levels established by DOE for 

the max-tech heat pump design are based on research and discussions with manufacturers. In 

addition, DOE does not intend to create a marketing classification system that would create a 

“heat pump” label from which consumers may perceive that all heat pump clothes dryers have 

the same efficiency. For these reasons, DOE continued to analyze the efficiency levels associated 

with heat pump clothes dryers presented in the preliminary analyses for today’s direct final rule. 

BSH commented that the gap between conventional and heat pump dryers is not filled 

with intermediate levels to show consumers the large improvement in efficiency they would be 

paying for when making purchasing decisions. (BSH, No. 23 at p. 6) DOE is not aware of 

products available on the market at efficiency levels between the maximum-available (on the 

U.S. market) efficiency levels and the max-tech heat pump efficiency level. In addition, DOE 

does not have any information indicating that design options are available that may be 

implemented to achieve efficiencies between the maximum-available and max-tech heat pump 

efficiency levels. As discussed above, DOE is not creating a marketing classification system for 

165 
 

 

 

 

 

 

 

 

 

 

 

 

consumers to make purchasing decisions. As a result, DOE did not analyze additional 

intermediate efficiency levels between those associated with conventional and heat pump dryers. 

Integrated Efficiency Levels – Final Rule 

As discussed in section III.A, DOE recently published the TP Final Rule amending the 

clothes dryer test procedure. DOE conducted testing on a sample of representative clothes dryers 

to evaluate the effects of the amendments to the clothes dryer test procedure on the measured EF. 

As discussed in section III.A.3.a, DOE test results showed that the measured EF according to the 

amended test procedure resulted in an average increase of about 20.1 percent for vented electric 

standard clothes dryers. For vented gas clothes dryers, the measured EF increased by an average 

of about 19.8 percent. For vented electric compact-size 120V and 240V clothes dryers, the 

measured EF increased by an average of about 15.6 and 12.8 percent, respectively. For the 

ventless clothes dryer product classes, the preliminary analyses were based on the DOE test 

procedure with only the proposed amendments to for ventless clothes dryers. DOE also 

conducted testing according to the final amended test procedure (that is, including changes to the 

initial RMC, water temperature for test load preparation, etc.). Test results showed that for 

ventless electric compact 240V clothes dryers and ventless electric combination washer/dryers, 

the measured EF increased by an average of about 13.6 and 11.4 percent, respectively. DOE 

applied these results for each product class to adjust the active mode efficiency levels to account 

for the amendments to the DOE clothes dryer test procedure in the TP Final Rule. In addition, 

DOE revised the active mode efficiency level 1 for vented electric standard clothes dryers and 

vented gas clothes dryers from 3.10 EF to 3.11 EF and from 2.75 to 2.76 EF, respectively. The 

revisions were based on discussions with manufacturers and the efficiency improvement 

166 
 

 

 

 

 

 

 

 

 

 

 

associated with the design options modeled by DOE. See chapter 5 of the direct final rule TSD 

for more details. DOE subsequently integrated the standby power efficiency levels to convert 

these EF values to CEF. For the preliminary analyses, DOE only incorporated incremental 

standby power levels into IEF efficiency levels above which electronic controls would be 

required as part of the active mode design option changes. At that point, DOE incorporated the 

incremental standby power levels where it determined them to be most cost effective. Chapter 5 

of the direct final rule TSD provides details of the active mode and standby mode efficiency 

levels for each product class. The revised CEF efficiency levels for each product class are shown 

below in Table IV.14 through Table IV.16. 

Table IV.14 Clothes Dryer Integrated Efficiency Levels (CEF) – Vented Product Classes 

Level Efficiency Level Description 

Integrated Efficiency Level (CEF) lb/kWh 

Electric 

Standard 

Electric 

Compa 

ct 

(120V) 

Electric 

Compact 

(240V) 

Gas 

Baseline DOE Standard + 2.0 W Standby 3.55 3.43 3.12 3.14 

1 DOE Standard + 1.5 W Standby 3.56 3.48 3.16 3.16 

2 DOE Standard + 0.08 W Standby 3.61 3.61 3.27 3.20 

3 Gap Fill + 0.08 W Standby 3.73 3.72 3.36 3.30 

4 Gap Fill + 0.08 W Standby 3.81 3.80 3.48 3.42 

5 Gap Fill/Maximum Available + 0.08 W 

Standby 4.08 4.08 3.60 3.61 

6 Heat Pump (Max-tech) + 0.08 W Standby 5.42 5.41 4.89 

Table IV.15 Clothes Dryer Integrated Efficiency Levels (CEF) – Ventless Electric Compact 

(240V) 

Level Efficiency Level Description 

Integrated Efficiency Level 

(CEF) lb/kWh 

Electric Compact (240 V) 

Baseline Baseline + 2.0 W Standby 2.55 

1 Baseline + 1.5 W Standby 2.59 

2 Baseline + 0.08 W Standby 2.69 

3 Gap Fill + 0.08 W Standby 2.71 

4 Gap Fill + 0.08 W Standby 2.80 

5 Heat Pump (Max-Tech) + 0.08 W 

Standby 4.03 

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Table IV.16 Clothes Dryer Integrated Efficiency Levels (CEF) – Ventless Electric 

Combination Washer/Dryers 

Level Efficiency Level Description 

Integrated Efficiency Level 

(CEF) lb/kWh 

Electric Combination 

Washer/Dryer 

Baseline Baseline + 2.0 W Standby 2.08 

1 Gap Fill + 2.0 W Standby 2.35 

2 Gap Fill + 1.5 W Standby 2.38 

3 Gap Fill + 0.08 W Standby 2.46 

4 Gap Fill + 0.08 W Standby 2.56 

5 Heat Pump (Max-Tech) + 0.08 W 

Standby 3.69 

Cost-Efficiency Results – Preliminary Analysis 

For the preliminary analysis, DOE first analyzed design options separately for active 

mode and standby mode and developed the cost-efficiency relationships based on product 

teardowns and cost modeling. Details of the active mode and standby mode cost-efficiency 

relationships for each product class are presented in chapter 5 of the preliminary TSD. DOE then 

developed overall cost-efficiency relationships for the IEF efficiency levels presented in the 

preliminary analyses. Table IV.17 through Table IV.22 shows DOE’s estimates of incremental 

manufacturing cost for improvement of clothes dryer IEF above the baseline. Also shown below 

are the technologies DOE analyzed for each efficiency level to develop incremental 

manufacturing costs. Detailed descriptions of the design options associated with each efficiency 

level are also presented in chapter 5 of the preliminary TSD. DOE used an efficiency level 

approach, noting that different manufacturers may implement different design changes to achieve 

certain efficiency levels. 

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Table IV.17 Preliminary Analysis: Cost-Efficiency Relationship for Vented Electric 

Standard Clothes Dryers 

Integrated Efficiency 

Level (IEF), lb/kWh Technology Incremental Manufacturing Cost 

Baseline (2.96) DOE Standard + 2.0 W Standby $0 

1 (3.04) DOE Standard + Change in Airflow Patterns, 

Dedicated Heater Duct, Open-Cylinder Drum $11.89 

2 (3.10) IEL 2 + Inlet Air Pre-Heating $63.56 

3 (3.33) IEL 2 + Modulating Heat $97.48 

4 (3.35) IEL 3 + 1.5 W Standby $98.78 

5 (3.40) IEL 3 + 0.08 W Standby $98.14 

6 (4.52) Heat Pump + 0.08 W Standby $259.13 

Table IV.18 Preliminary Analysis: Cost-Efficiency Relationship for Vented Electric 

Compact (120V) Clothes Dryers 

Integrated Efficiency 

Level (IEF), lb/kWh Technology Incremental Manufacturing Cost 

Baseline (3.00) DOE Standard + 2.0 W Standby $0 

1 (3.08) DOE Standard + Change in Airflow Patterns, 

Dedicated Heater Duct, Open-Cylinder Drum $10.95 

2 (3.15) IEL 2 + Inlet Air Pre-Heating $63.37 

3 (3.37) IEL 2 + Modulating Heat $96.45 

4 (3.41) IEL 3 + 1.5 W Standby $97.75 

5 (3.53) IEL 3 + 0.08 W Standby $97.11 

6 (4.69) Heat Pump + 0.08 W Standby $246.35 

Table IV-19 Preliminary Analysis: Cost-Efficiency Relationship for Vented Electric 

Compact (240V) Clothes Dryers 

Integrated Efficiency 

Level (IEF), lb/kWh Technology Incremental Manufacturing Cost 

Baseline (2.79) DOE Standard + 2.0 W Standby $0 

1 (2.86) DOE Standard + Change in Airflow Patterns, 

Dedicated Heater Duct, Open-Cylinder Drum $10.95 

2 (2.96) IEL 2 + Inlet Air Pre-Heating $63.37 

3 (3.06) IEL 2 + Modulating Heat $96.45 

4 (3.10) IEL 3 + 1.5 W Standby $97.75 

5 (3.19) IEL 3 + 0.08 W Standby $97.11 

6 (4.34) Heat Pump + 0.08 W Standby $246.35 

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Table IV.20 Preliminary Analysis: Cost-Efficiency Relationship for Vented Gas Clothes 

Dryers 

Integrated Efficiency 

Level (IEF), lb/kWh Technology Incremental Manufacturing Cost 

Baseline (2.63) DOE Standard + 2.0 W Standby $0 

1 (2.71) DOE Standard + Change in Airflow Patterns, 

Dedicated Heater Duct, Open-Cylinder Drum $14.79 

2 (2.80) IEL 2 + Inlet Air Pre-Heating $65.36 

3 (2.97) IEL 2 + Modulating Heat $156.01 

4 (2.98) IEL 3 + 1.5 W Standby $157.31 

5 (3.02) IEL 3 + 0.08 W Standby $156.67 

Table IV.21 Preliminary Analysis: Cost-Efficiency Relationship for Ventless Electric 

Compact (240V) Clothes Dryers 

Integrated Efficiency 

Level (IEF), lb/kWh Technology Incremental Manufacturing Cost 

Baseline (2.29) Baseline + 2.0 W Standby $0 

1 (2.31) Baseline + 1.5 W Standby $1.30 

2 (2.37) Baseline + 0.08 W Standby $0.66 

3 (2.39) IEL 2 + Change in Airflow Patterns, OpenCylinder Drum $13.01 

4 (2.59) IEL 3 + Modulating Heat $69.02 

5 (3.54) Heat Pump + 0.08 W Standby $216.37 

Table IV.22 Preliminary Analysis: Cost-Efficiency Relationship for Ventless Electric 

Combination Washer/Dryers 

Integrated Efficiency 

Level (IEF), lb/kWh Technology Incremental Manufacturing Cost 

Baseline (1.90) Baseline + 2.0 W Standby $0 

1 (2.15) Baseline + 2.0 W Standby + Baseline 

Automatic Termination $0.81 

2 (2.34) IEL 1 + Modulating Heat $54.04 

3 (2.36) IEL 2 + 1.5 W Standby $55.34 

4 (2.42) IEL 2 + 0.08 W Standby $54.70 

5 (3.31) Heat Pump + 0.08 W Standby $230.83 

DOE received comments from interested parties on the whether the baseline clothes dryer 

manufacturing costs should be adjusted to reflect the cost of complying with the Underwriters 

Laboratory (UL) Standard 2158 “Electric Clothes Dryers” (UL 2158) fire containment 

requirements. AHAM commented that it would need to look into and understand how the fire 

containment regulation in UL 2158 would affect the cost similar to the refrigerant change from 

R-22 to R-410a for room air conditioners. (AHAM, Public Meeting Transcript, No. 21.4 at p. 

170 
 

 

 

 

 

 

 

153) AHAM commented that when manufacturers submitted incremental clothes dyer 

manufacturing cost estimates to DOE in late 2008, costs to comply with UL 2158 were not 

included. According to AHAM, while the new UL requirements may not directly impact energy 

efficiency, the requirements place significant cumulative regulatory burden on clothes dryer 

manufacturers. AHAM commented that DOE should evaluate an additional step for clothes 

dryers, where the costs to implement the UL fire containment requirements are incorporated into 

the baseline analysis, similar to the approach used to evaluate the phase‐out of R-22 to R-410A 

for room air conditioners. AHAM commented that DOE should evaluate these costs through 

manufacturer interviews and determine how this cost affects the incremental costs to reach 

higher efficiency. (AHAM, No. 25 at p. 5) DOE notes that it attempted to obtain data on the 

incremental manufacturing cost associated with complying with the fire containment 

requirements in UL 2158 during manufacturing interviews. While manufacturers noted that 

different manufacturers will be required to make different changes to their product design to 

meet the fire containment requirements, DOE did not receive sufficient data to determine the 

incremental manufacturing costs to baseline clothes dryers to comply with the fire containment 

requirements of UL 2158. In addition, DOE did not receive sufficient information to indicate that 

the cost associated with complying with UL 2158 would vary at efficiency levels above the 

baseline. As a result, DOE did not include additional cost to comply with UL 2158 in the 

baseline manufacturing production cost. As discussed below in section IV.I.3.b, DOE has 

investigated the costs of complying with the fire containment requirements in UL 2158 in the 

cumulative regulatory burden for the MIA. 

Cost-Efficiency Results – Final Rule 

171 
 

 

 

 

 

 

 

 

For today’s final rule, DOE updated the cost-efficiency analysis from the preliminary 

analyses by updating the costs of raw materials and purchased components, as well as updating 

costs for manufacturing equipment, labor, and depreciation. 

`In addition, based on discussions with clothes dryer manufacturers, DOE revised the 

design options analyzed for each integrated efficiency level in the preliminary analyses. Based 

on these discussions, DOE believes that manufacturers would apply a two-stage modulating 

heater design (which would also require moisture sensing and multi-speed airflow) to achieve 

integrated efficiency level 4 for all clothes dryer product classes. In addition, based on 

discussions with manufacturers, DOE believes that inlet-air preheating (which would require 

better airflow control and more advanced control systems), along with the design options for the 

lower efficiency levels (that is, changes in airflow patterns, open cylinder drum, dedicated heater 

duct, two-stage modulating heat, and standby power changes), would be applied to achieve 

integrated efficiency level 5 (maximum-available) for vented clothes dryer product classes. As a 

result, the max-tech efficiency level for vented gas clothes dryers would correspond to inlet air 

pre-heating. 

As discussed above, DOE also believes that the low cost of the standby power design 

options should result in these technologies being included in the initial efficiency levels above 

the baseline. As a result, DOE revised the order of the design options and efficiency levels 

presented in the preliminary analyses. As discussed above in this section, DOE previously 

incorporated incremental standby power levels into integrated efficiency levels above which 

electronic controls would be required as part of the active mode design option changes. At that 

172 
 

 

 

 

 

 

 

 

 

 

point, DOE incorporated the incremental standby power levels where it determined them to be 

most cost effective. For today’s final rule, DOE applied the standby power levels immediately 

above the baseline level because they were determined to be the most cost-effective design 

option. The revised order of design options are shown below in Table IV.23 through Table 

IV.28. DOE also noted that for the integrated efficiency levels where electronic controls are not 

required for the design changes, the standby power level changes would impact only those 

clothes dryers that consume standby power, that is, those products with electronic controls. As a 

result, DOE analyzed baseline efficiency products available on the market, and weighted the 

efficiency improvement and incremental manufacturing cost based on the percentage of baseline 

36 efficiency products that have electronic controls. For the integrated efficiency levels for which 

electronic controls would be required as part of the active mode design changes, DOE assumed 

that the standby power levels and incremental manufacturing costs affected 100 percent of 

clothes dryer models. 

Table IV.23 through Table IV.28 shows the cost-efficiency results, along with the 

technologies DOE analyzed for each efficiency level to develop incremental manufacturing 

costs. Details of the cost-efficiency analysis and descriptions of the technologies associated with 

each design change are presented in chapter 5 of the direct final rule TSD. 

36 DOE’s review of currently available models with baseline efficiency showed that roughly 74 percent of models 

have electronic controls. 

173 
 

 

 

 

 

 

 

 

 

 

 

 

Table IV.23 Cost-Efficiency Relationship for Vented Electric Standard Clothes Dryers 

Integrated Efficiency 

Level (CEF), lb/kWh Technology 

Incremental 

Manufacturing 

Cost 

Baseline (3.55) DOE Standard + 2.0 W Standby $0 

1 (3.56) DOE Standard + 1.5 W Standby $0.68 

2 (3.61) DOE Standard + 0.08 W Standby $0.82 

3 (3.73) 

IEL 2 + Change in Airflow Patterns, 

Dedicated Heater Duct, Open-Cylinder 

Drum 

$8.74 

4 (3.81) IEL 3 + 2-Stage Modulating Heat $50.67 

5 (4.08) IEL 4 + Inlet Air Pre-Heating $88.89 

6 (5.42) Heat Pump + 0.08 W Standby $280.54 

Table IV.24 Cost-Efficiency Relationship for Vented Electric Compact (120V) Clothes 

Dryers 

Integrated Efficiency 

Level (CEF), lb/kWh Technology 

Incremental 

Manufacturing 

Cost 

Baseline (3.43) DOE Standard + 2.0 W Standby $0 

1 (3.48) DOE Standard + 1.5 W Standby $0.68 

2 (3.61) DOE Standard + 0.08 W Standby $0.82 

3 (3.72) 

IEL 2 + Change in Airflow Patterns, 

Dedicated Heater Duct, Open-Cylinder 

Drum 

$21.46 

4 (3.80) IEL 3 + 2-Stage Modulating Heat $62.76 

5 (4.08) IEL 4 + Inlet Air Pre-Heating $109.31 

6 (5.41) Heat Pump + 0.08 W Standby $267.48 

Table IV.25 Cost-Efficiency Relationship for Vented Electric Compact (240V) Clothes 

Dryers 

Integrated Efficiency 

Level (CEF), lb/kWh Technology 

Incremental 

Manufacturing 

Cost 

Baseline (3.12) DOE Standard + 2.0 W Standby $0 

1 (3.16) DOE Standard + 1.5 W Standby $0.68 

2 (3.27) DOE Standard + 0.08 W Standby $0.82 

3 (3.36) 

IEL 2 + Change in Airflow Patterns, 

Dedicated Heater Duct, Open-Cylinder 

Drum 

$21.46 

4 (3.48) IEL 3 + 2-Stage Modulating Heat $62.76 

5 (3.60) IEL 4 + Inlet Air Pre-Heating $109.31 

6 (4.89) Heat Pump + 0.08 W Standby $267.48 

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Table IV.26 Cost-Efficiency Relationship for Vented Gas Clothes Dryers 

Integrated Efficiency 

Level (CEF), lb/kWh Technology 

Incremental 

Manufacturing 

Cost 

Baseline (3.14) DOE Standard + 2.0 W Standby $0 

1 (3.16) DOE Standard + 1.5 W Standby $0.68 

2 (3.20) DOE Standard + 0.08 W Standby $0.82 

3 (3.30) 

IEL 2 + Change in Airflow Patterns, 

Dedicated Heater Duct, Open-Cylinder 

Drum 

$9.12 

4 (3.42) IEL 3 + 2-Stage Modulating Heat $72.32 

5 (3.61) IEL 4 + Inlet Air Pre-Heating $109.98 

Table IV.27 Cost-Efficiency Relationship for Ventless Electric Compact (240V) Clothes 

Dryers 

Integrated Efficiency 

Level (CEF), lb/kWh Technology 

Incremental 

Manufacturing 

Cost 

Baseline (2.55) Baseline + 2.0 W Standby $0 

1 (2.59) Baseline + 1.5 W Standby $0.93 

2 (2.69) Baseline + 0.08 W Standby $1.11 

3 (2.71) IEL 2 + Change in Airflow Patterns, 

Open-Cylinder Drum $26.42 

4 (2.80) IEL 3 + 2-Stage Modulating Heat $57.80 

5 (4.03) Heat Pump + 0.08 W Standby $242.36 

Table IV.28 Cost-Efficiency Relationship for Ventless Electric Combination 

Washer/Dryers 

Integrated Efficiency 

Level (CEF), lb/kWh Technology 

Incremental 

Manufacturing 

Cost 

Baseline (2.08) Baseline + 2.0 W Standby $0 

1 (2.35) Baseline + 2.0 W Standby + Baseline 

Automatic Termination $1.51 

2 (2.38) IEL 1 + 1.5 W Standby $2.44 

3 (2.46) IEL 2 + 0.08 W Standby $2.62 

4 (2.56) IEL 3 + 2-Stage Modulating Heat $31.69 

5 (3.69) Heat Pump + 0.08 W Standby $297.54 

b. Room Air Conditioners 

During the preliminary analysis, DOE performed the room air conditioner engineering 

analysis as follows: 

175 
 

 

 

 

 

 

 

 

 

 

reverse engineering and teardown for 21 room air conditioners across 6 product classes. 

interviews with room air conditioner manufacturers to obtain greater insight into design 

strategies and their associated costs to improve efficiency, including designs incorporating R410A refrigerant. 

energy modeling for room air conditioner designs using R-410A refrigerant. 

DOE selected teardown products covering the range of available efficiency levels at a 

group of selected capacities. The products selected for teardown were designed for HCFC-22 

refrigerant because DOE conducted this work before the January 1, 2010 phaseout of this 

refrigerant for new products was required. 74 FR 66450 (Dec. 19, 2009). DOE modeled the 21 

HCFC-22 teardown units to calibrate the model before modeling the R-410A efficiency levels. 

DOE also identified one R-410A room air conditioner during the preliminary analysis and 

analyzed it in the reverse engineering analysis. 

From these analyses, DOE produced R-410A cost-efficiency curves for each of the 

analyzed product classes. Details of the engineering analysis are provided in the direct final rule 

TSD chapter 5. 

DOE received several comments from interested parties on its approach to the 

engineering analysis, as described below. Stakeholders commented on (1) the availability of R410A products and data for incorporation into the engineering analysis, and (2) limitations on the 

maximum size of room air conditioners. 

176 
 

 

 

 

 

 

 

 

 

Conversion to R-410a 

During the preliminary analysis public meeting, DOE requested comments on the 

approach for the engineering analysis for room air conditioners, specifically on the use of both 

energy modeling and manufacturer cost modeling. DOE explained that this was the best 

approach for the preliminary engineering analysis. An efficiency level analysis based on only 

teardowns of specific products at different efficiency levels would have been based on HCFC-22 

and would not have been representative of the R-410A products that would be available on the 

compliance date for the rule. 

ACEEE suggested that DOE’s analysis should be updated due to the transition from 

HCFC-22 refrigerant (ACEEE, No. 24 at p. 4). ACEEE and the California Utilities 

recommended that DOE revise its analysis using current R-410A models for product teardowns, 

as it would enable DOE to more accurately determine the energy use of new room air 

conditioners (ACEEE, No. 24 at p. 4; California Utilities, No. 31 at p. 17). In addition, the 

California Utilities recommended that DOE conduct testing of products that contain R-410A 

refrigerant. (California Utilities, No. 31 at p. 17) 

During the preliminary analysis phase of this rulemaking, DOE indicated that there was 

only one R-410A product available on the market for analysis. Subsequently, however, DOE 

examined information associated with commercialized R-410A products and made appropriate 

adjustments based on the new information, as described below. 

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In the engineering analysis supporting today’s final rule, DOE purchased and conducted 

teardowns on four R-410A products to update and validate the analysis performed during the 

preliminary analysis. Table IV.29 lists the R-410A products used. DOE focused this effort on the 

largest and most efficient units. 

Table IV.29. R-410A Room Air Conditioners Selected for Teardown 

Product Class Capacity 

Btu/hr 

EER 

1 5000 9.7 

2 6,000 12.0 

3 12,000 10.8 

5B 28,500 8.5 

The new information obtained from the four R-410A product teardowns, and examination 

of product information of available R-410A products, confirmed that the baseline product 

designs, design option costs, and design pathways chosen during the preliminary analysis, 

developed based on teardowns of HCFC-22 units, provided accurate results for calculating the 

cost-efficiency curves for R-410A designs. 

SCE noted that a study conducted by NIST for split systems indicated that R-410A 

dropped in efficiency compared with R-22 only in systems with condensing temperatures above 

95 ° F. (SCE, Public Meeting Transcript, No. 21.4 at p. 69) 

DOE notes that its modeling of room air conditioners indicates that they operate with 

condensing temperatures between 110 °F and 130 °F under DOE test conditions, depending on 

the sizes of the heat exchangers. DOE’s analysis confirms that the impact of the switch to R410A is more severe as condensing temperatures increase above 95 °F, and that additional 

178 
 

 

 

 

 

 

 

 

 

improvements in efficiency (larger heat exchangers, more efficient components, and similar 

improvements) are required to reach comparable efficiencies to HCFC-22. Energy modeling of 

R-410A and HCFC-22 room air conditioners shows that a system modeled with HCFC-22 

experiences an efficiency reduction if a “drop-in” of R-410A is considered (that is, switch 

refrigerant and make no other system changes). 

As discussed previously, DOE conducted the engineering analysis based on use of R410A refrigerant. DOE sought information on the performance of R-410A rotary compressors of 

varying efficiency levels for all of the products under analysis. In many cases, the range of 

efficiency for which compressor vendors were able to provide performance data was limited. 

Because conducting the analysis generally required knowledge not just of design point capacity 

and EER, DOE requested performance data for a representative range of evaporating and 

condensing conditions. In some cases, the trends of compressor performance as a function of 

operating conditions were extrapolated from the trends exhibited by a compressor of the same 

refrigerant of nearly the same capacity. During the preliminary analysis, DOE considered the 

available performance data for R-410A rotary compressors, noting that discussions with 

compressor vendors revealed that many vendors were still developing their R-410A compressor 

lines and could only provide preliminary data. The compressors for which performance data was 

available varied significantly in EER, depending on their capacity. DOE did not consider 

increases in compressor efficiency as a design option, because no higher-efficiency compressor 

data was available. 

179 
 

 

 

The California Utilities commented that concern over the cost and availability of R-410A 

compressors may be mitigated as designs and efficiency of these compressors improve, and as 

the market grows and availability of compressors increases. (California Utilities, No. 31 at p. 17) 

EEI asked whether DOE conducted testing on R-410A compressors during its analysis. (EEI, 

Public Meeting Transcript, No. 21.4 at pp. 67–68) 

DOE did not conduct tests on R-410A compressors during the engineering analysis, but 

has no reason to believe that the manufacturers’ performance data is incorrect. During the final 

rule analyses, however, DOE obtained additional data regarding R-410A compressor 

performance and did consider EER improvement, as described below. 

During interviews conducted during the final rule phase of today’s final rule, individual 

manufacturers reported that vendor selections of R-410A rotary compressors were still limited, 

and that compressor vendors, where they had once offered up to three different efficiency tiers of 

compressors, now only offered one or two tiers. One manufacturer reported a need to source 

from many different vendors to achieve performance goals. Individual manufacturers identified 

10 EER as the maximum available efficiency for R-410A compressors, but reported testing of 

higher efficiency compressors. 

DOE also reviewed R-410A compressor options available on compressor vendors’ 

websites, and also contacted compressor vendors to discuss their current R-410A compressor 

options. 

180 
 

 

 

 

 

 

 

 

 

In the analysis for today’s final rule, DOE added a design option to its engineering 

analysis for increasing compressor efficiency to the identified maximum compressor EER level. 

During the preliminary analysis, DOE sought information on the performance of R-410A 

rotary compressors of varying efficiency levels for all of the products under analysis. In many 

cases, the range of efficiency for which vendors provided performance data for R-410A 

compressors was limited. In most cases, compressor vendors had developed sufficiently for use 

in products compressors at only one efficiency level at each of the relevant capacities that DOE 

examined. These efficiency levels varied widely, depending on the available compressors. Due 

to the lack of maturity of the R-410A rotary compressor market at that time, DOE could not 

confidently project that higher efficiency levels would be made available. 

. 

During the final rule analysis, DOE again reviewed the R-410A compressor market and 

the available compressors and found that many more R-410A rotary compressor options at 

varying efficiency levels had been developed. The highest available nominal EER for R-410A 

rotary compressors with capacities less than 18,000 Btu/h is 10 EER, while the highest available 

EER for compressors with capacities greater than 18,000 Btu/h is 10.3 EER. Interviews with 

individual manufacturers supported these observations. 

Consequently, DOE has concluded that 10 EER is a reasonable maximum available EER 

for rotary R-410A compressors in capacities suitable for product classes 1 (room air conditioners 

without reverse cycle, with louvered sides, and capacity less than 6,000 Btu/h); 3 (room air 

conditioners without reverse cycle, with louvered sides, and capacities 8,000 to 13,999 Btu/h); 

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8A (room air conditioners without reverse cycle, without louvered sides, and capacities 8,000 to 

10,999 Btu/h); and 8B (room air conditioners without reverse cycle, without louvered sides, and 

capacities 11,000 to 13,999 Btu/h). Also, DOE concluded that 10.3 EER is a reasonable 

maximum available EER for rotary R-410A compressors in capacities suitable for product 

classes 5A (room air conditioners without reverse cycle, with louvered sides, and capacities 

20,000 to 27,999 Btu/h) and 5B (room air conditioners without reverse cycle, with louvered 

sides, and capacity 28,000 Btu/h or more). Thereby, DOE selected 10.0 EER as the maximum 

EER compressor level for the analysis of product classes 1, 3, 8A, and 8B; and 10.3 EER as the 

maximum compressor level for the analysis of product classes 5A and 5B. 

During the analysis for today’s final rule, in cases where compressor data was 

unavailable for the two maximum EER levels selected by DOE (as discussed above), the trends 

of compressor performance as a function of operating conditions were extrapolated. Compressor 

performance was extrapolated from the trends exhibited by a compressor currently offered on the 

market that used the same refrigerant of nearly the same capacity. DOE extrapolated compressor 

data for 10 EER compressors from similar compressors with ratings ranging from 9.4 EER to 9.7 

EER, and compressor data for 10.3 EER compressor from similar compressor with 10 EER 

ratings. DOE noted the rapid pace of development of R-410A compressors (over the course of 

this rulemaking); manufacturer interviews suggested that this rapid development is on-going and 

is likely to continue. Thus, the data suggests that manufacturers will be able to incorporate R410A rotary compressors of capacities for which data was not available into air conditioners by 

the new energy standard’s compliance date in 2014. DOE notes that compressors at the selected 

max-tech EER levels (for some capacity levels analyzed) are already available on the market, 

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and some products may already use these compressors. DOE has determined that such 

compressors are currently manufactured at many more capacity levels than were observed during 

the preliminary analysis. Additional details of this analysis are available in chapter 5 of the direct 

final rule TSD. 

The greater availability of rotary compressors also caused DOE to eliminate 

consideration of scroll compressors. DOE had used scroll compressors as a design option during 

the preliminary analysis. However, the higher EER of high-capacity rotary compressors that are 

now available shifts the economic attractiveness of scroll compressor technology such that it is 

no longer cost effective. 

Size Increases 

In the preliminary analysis, DOE considered chassis size increases to increase the 

efficiency of window units, which corresponded to product classes 1, 3, and 5. DOE believes 

increases in coil frontal area and package size are among the primary factors contributing to EER 

improvements in the higher-efficiency teardown units for product classes 1, 3, and 5. 

DOE selected baseline, medium, and large chassis sizes based on the range of sizes of 

available room air conditioners. DOE did not consider chassis size increases beyond the range of 

available products, and considered both the physical volume and the weight of the unit. DOE 

performed cost modeling and energy modeling of these larger chassis sizes to calculate cost and 

efficiency impacts due to chassis size increases, based on product teardowns. 

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During the preliminary analysis public meeting, DOE requested comment on the 

approach for determining appropriate maximum sizes for different product classes and 

capacities. DOE received stakeholder comments on both non-louvered room air conditioner sizes 

and louvered room air conditioner sizes. 

Non-louvered Room Air Conditioner Sizes 

PG&E commented that the size of through-the-wall room air conditioners (products 

without louvers) would not necessarily be constrained if allowed to project into the outdoor 

space. (PG&E, Public Meeting Transcript, No. 21.4 at p. 77) In response, GE stated that existing 

wall sleeves do not allow for additional growth in depth, and through-the-wall units are typically 

slid into an existing wall sleeve. (GE, Public Meeting Transcript, No. 21.4 at p. 77) To achieve 

additional depth, the existing wall sleeve would need to be replaced. AHAM also noted that 

while additional heat exchanger coils may increase efficiency, placing these coils too deep within 

the unit will actually decrease the heat transfer efficiency. (AHAM, No. 25 at p. 7) 

DOE did not consider chassis size growths as a design option for product class 8 (room 

air conditioners without reverse cycle, without louvered sides, and capacities 8,000 to 13,999 

Btu/h) in the preliminary analysis. According to manufacturer interviews, the majority of nonlouvered products are replacement products that must fit into existing building sleeves. Building 

sleeves are often built into the existing structure and are fixed components. Replacing them 

would require altering the size of the opening, which would generally be cost-prohibitive. Due to 

these constraints, replacement products must fit into existing sleeves, which clearly limit product 

height and width. Increases in product depth can be limited by the design of the sleeve, and 

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consumers may be unwilling to accept products that extend further into the interior. DOE also 

notes that any increases in product depth would present very limited potential in improvement, 

because it would not allow for the unit’s heat exchangers to grow in width or height. 

For these reasons, DOE has chosen to retain the preliminary analysis assumption for nonlouvered products that size increase cannot be used to increase efficiency. 

Louvered Room Air Conditioner Sizes 

DOE received the following comments from stakeholders on room air conditioner sizes 

for louvered products. AHAM commented that there are a range of product depths and weights, 

which may suggest that increased depths and weights may be feasible. (AHAM, No. 25 at pp. 6– 

7) AHAM noted, however, that UL requirements are an issue when considering increases in 

room air conditioner depth, as the units require that mounting brackets be designed to ensure that 

the room air conditioner remains in the window. Ensuring that these brackets are used in each 

installation can be a potential safety concern, in particular for smaller units installed by 

consumers. Id. AHAM also noted that smaller products (especially those in product classes 1 

(room air conditioners without reverse cycle, with louvered sides, and capacities less than 6,000 

Btu/h) and 2 (room air conditioners without reverse cycle, with louvered sides, and capacities 

6,000 to 7,999 Btu/h)) would be most negatively impacted by an increase in weight. AHAM 

indicated that the Occupational Safety and Health Administration (OSHA) recommends an 

additional person for lifting and installing products weighing over 50 lb. AHAM stated that the 

50 lb. limit is expected to influence consumer acceptance of these products. Id. 

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NPCC recommended that DOE compare the maximum unit dimensions in each analyzed 

product class to the dimensions of the highest efficiency model available on the market. (NPCC, 

No. 32 at pp. 4–5) NPCC recommended that, if these two product dimensions are similar, DOE 

assume that all units can be equally as large. NPCC also recommended that, if the market unit is 

smaller than the unit proposed by DOE, that DOE determine whether a redesign of the proposed 

unit would eliminate the size constraint. (Id.) DOE received no additional stakeholder comments 

addressing maximum acceptable product sizes for louvered products. 

DOE has chosen to use the 50 lb. weight limitation for product class 1 (room air 

conditioners without reverse cycle, without louvered sides, and capacities less than 6,000 Btu/h). 

The National Institute for Occupational Safety and Health (NIOSH) and OSHA guidance 

recommends against handling loads greater than 50 lbs. for a single person. NIOSH lists among 

its hazard evaluation checklist the handling of loads exceeding 50 lbs. as a risk factor used to 

37 identify potential problems. OSHA, in its “Ergonomics eTool: Solutions for Electrical 

Contractors,” states that lifting loads heavier than 50 lb will increase the risk of injury, and 

38 recommends use of more than one person to lift weights larger than 50 lbs. These guidelines 

calling for additional personnel for product lifting represent distinct changes in consumer utility 

for products that currently weigh less than 50 lbs. This would not be true for products that 

already exceed this limit. DOE notes that all but the smallest room air conditioners weigh more 

than 50 lbs. The baseline R-410A designs of the analyses were all determined to have weights 

greater than this limit, except for product class 1 (room air conditioners without reverse cycle, 

with louvered sides, and capacities less than 6,000 Btu/h). DOE adjusted the analysis for product 

37 http://www.cdc.gov/niosh/docs/2007-131/ 

38 http://www.osha.gov/SLTC/etools/electricalcontractors/materials/heavy.html 

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class 1 to limit its weight to 50 lbs., but did not make similar adjustments for any of the other 

product classes. Additional details regarding these adjustments for the product class 1 analysis is 

presented in chapter 5 of the direct final rule TSD. 

For the other product classes with louvered sides, the maximum height and width 

considered is consistent with these dimensions for max-tech available products. These are the 

dimensions that determine that available size for heat exchangers; DOE’s analysis of product 

classes with louvered sides contains heat exchangers with the same dimensions as max-tech 

available units. DOE observed that all max-tech products for room air conditioners are produced 

primarily by one manufacturer, and that the depth of these max-tech available products was 

much greater in proportion to other dimensions than the depths observed in other manufacturers’ 

products. DOE’s analysis indicated that depths consistent with the proportions observed in these 

other manufacturers’ non-max-tech products are sufficient to provide max-tech performance. In 

particular, DOE’s analysis indicated that the smaller depth was enough to achieve the requisite 

condenser airflow, enabling appropriate heat transfer by the larger heat exchangers. Thus, DOE’s 

analyses did not use the larger product depths observed in the max-tech available products. 

Instead, DOE used smaller product depths, consistent with the proportions observed in other 

products. This approach was adopted for product classes 3 (room air conditioners without reverse 

cycle, with louvered sides, and capacities 8,000 to 13,999 Btu/h); 5A (room air conditioners 

without reverse cycle, with louvered sides, and capacities 20,000 to 27,999 Btu/h); and 5B (room 

air conditioners without reverse cycle, with louvered sides, and capacities 28,000 Btu/h or more). 

Additional details of this analysis are available in chapter 5 of the direct final rule TSD. 

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Engineering Analysis Adjustments 

A summary table of the key adjustments made to the product class structure and the 

engineering analysis during the final rule phase of the rulemaking is presented in Table IV.30. 

Table IV.30. Summary of Key Adjustments to the Engineering Analysis for Room Air 

Conditioners 

Parameter Preliminary Changes for the Direct Final Rule 

Product Classes No changes considered Split of product classes 5 and 8 into two 

product classes each (5A, 5B, 8A, 8B) 

based on stakeholder comments 

Compressor 

Efficiency 

Based on available 

compressor data 

during preliminary 

analysis 

Max-efficiency increased to 10 EER for 

product classes 1, 3, 8A, and 8B, and 

10.3 EER for product classes 5A and 5B 

50 lbs Limit Not considered Introduced a 50 lb weight limit for the 

analysis of design options for product 

class 1 

Chassis Sizes for 

Louvered Products 

Based on analysis of 

HCFC-22 units. 

Adjusted based on additional market 

research and teardowns of R-410A units 

Scroll Compressors Considered for product 

class 5 analysis 

Not considered, since they provide no 

additional improvement over 10.3 EER 

rotary compressors, and are much more 

expensive. This design option is less 

cost-effective than the design options 

selected by DOE for analysis, so it was 

not considered. 

D. Markups Analysis 

The markups analysis develops appropriate markups in the distribution chain to convert 

the estimates of manufacturer cost derived in the engineering analysis to consumer prices. At 

each step in the distribution channel, companies mark up the price of the product to cover 

business costs and profit margin. DOE estimated the markups associated with the main parties in 

the distribution channel. For clothes dryers and room air conditioners, these are manufacturers 

and retailers. 

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DOE developed an average manufacturer markup by examining the annual Securities and 

Exchange Commission (SEC) 10-K reports filed by four publicly traded manufacturers primarily 

engaged in appliance manufacturing and whose combined product range includes residential 

clothes dryers and room air conditioners. 

For retailers, DOE developed separate markups for baseline products (baseline markups) 

and for the incremental cost of more-efficient products (incremental markups). Incremental 

markups are coefficients that relate the change in the manufacturer sales price of higherefficiency models to the change in the retailer sales price. 

Commenting on the preliminary TSD, AHAM filed comments that criticized DOE’s 

application of “incremental” markups to the incremental manufacturer selling price of products 

more efficient than the baseline products. (AHAM, No. 25 at p. 3) In Exhibit B accompanying 

this comment, AHAM stated that (1) DOE provides no empirical evidence to validate that 

retailers obtain only incremental markups on products with greater features and costs; and (2) 

DOE is asserting a normative approach without any support showing that its model reflects 

actual retail practices. These comments criticized two of the key assumptions in DOE’s 

theoretical construct: (1) that the costs incurred by appliance retailers can be divided into costs 

that vary in proportion to the MSP (variable costs), and costs that do not vary with the MSP 

(fixed costs); (2) that retailer prices vary in proportion to retailer costs included in the balance 

sheets. 

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Regarding the first assumption, AHAM stated that DOE has offered no evidence that the 

fixed/variable cost mix of a retailer has anything to do in practice with the markups that will be 

earned by a retailer on products that meet a new energy conservation standard. It added that DOE 

uses an incorrect analogy to HVAC contractors as a basis for considering the costs of a retailer, 

and that DOE did not analyze the actual drivers of retail costs. The retail cost structure has 

considerably different characteristics than those of an HVAC contractor. AHAM stated that DOE 

has not presented any data or analysis that would yield a fixed versus variable cost allocation 

applicable to retailers. Regarding DOE’s second assumption, AHAM stated that DOE’s approach 

depends on the presence of a relatively high level of competition in the retail industry. AHAM 

presented data showing that the four firm concentration ratio (FFCR) of the sectors that sell 

major appliances ranges from 42 to 65 percent, which does not support DOE’s assumption of a 

39 high level of competition in the retail industry.

In conclusion, AHAM viewed DOE’s incremental markup approach as lacking a credible 

theoretical underpinning and demonstrated reliability and asserted that the data required for the 

approach are not available. AHAM stated that DOE should return to its traditional practice of 

using average markups for both the baseline products and for the added costs of efficiency 

improvements. In AHAM’s view, the stability of markups in the retailing sectors leads to the 

reasonable inference that such markups will continue and apply to higher-efficiency products in 

the future when they become the bulk of sales under amended standards. (AHAM, No. 34, 

Exhibit B, p. 12) 

39 The FFCR represents the market share of the four largest firms in the relevant sector. Generally, an FFCR of less 

than 40 percent indicates that a sector is not concentrated and an FFCR of more than 70 percent indicates that a 

sector is highly concentrated. 

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In response to the above comments, DOE extensively reviewed its incremental markup 

approach. DOE assembled and analyzed relevant data from other retail sectors and found that 

empirical evidence is lacking with respect to appliance retailer markup practices when a product 

increases in cost due to increased efficiency or other factors. DOE understands that real-world 

retailer markup practices vary depending on market conditions and on the magnitude of the 

change in cost of goods sold (CGS) associated with an increase in appliance efficiency. 

Given this uncertainty with respect to actual markup practices in appliance retailing, 

DOE uses an approach that reflects two key concepts. First, changes in the efficiency of the 

appliances sold are not expected to increase retailers’ economic profits. Thus, DOE calculates 

markups/gross margins to allow cost recovery for retailers (including changes in the cost of 

capital) without changes in company profits. Second, efficiency improvements only impact some 

distribution costs. DOE sets markups to cover only the variable costs expected to change with 

efficiency. 

Market competition is another reason why DOE believes that profit margins would not 

change in a significant way. Regarding AHAM’s assertion that the degree of competition in 

appliance retailing is not sufficient to support DOE’s model, DOE believes that AHAM’s 

measure of competition is inaccurate. AHAM measured the FFCR of three retail channels: 

electronics and appliance stores, building and material and supplies dealers, and general 

merchandise stores. These values represent competitiveness within each sector, but clothes dryers 

and room air conditioners are sold across all three sectors, preventing major retailers in each 

sector from exercising significant market power. To properly measure the competitiveness within 

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appliance retailing, DOE believes that one should measure the FFCR for only the appliance subsector within the above channels and accordingly estimated the “appliance sales” FFCR as equal 

to the sector FFCR times the percent of appliance sales within each sector. DOE estimated that 

these sub-sector FFCRs are under the 40 percent threshold. Furthermore, “Household Appliance 

Stores,” a subsector of the electronics and appliance stores sector that specifically represents 

appliance retailers, rather than computer or other electronics stores, has an FFCR of 17 percent, 

signifying an unconcentrated sector. 

DOE’s separation of operating expenses into fixed and variable components to estimate 

an incremental markup follows from the above concepts. In separating retailer costs, DOE did 

not directly use information from the HVAC contractor industry. Instead, DOE defined fixed 

expenses as including labor and occupancy expenses because these costs are not likely to 

increase as a result of a rise in CGS due to amended efficiency standards. All other expenses, as 

well as the net profit, are assumed to vary in proportion to the change in CGS. DOE’s method 

results in an outcome in which retailers are assumed to cover their costs while maintaining their 

profit margins when the CGS of appliances changes. DOE seeks additional information from 

interested parties to help refine its allocation approach. 

Regarding AHAM’s observation about the relative stability of average markups for the 

major retail channels that sell home appliances, DOE believes that the usefulness of this 

information for estimating markups on specific product lines is limited. The markups implied by 

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40 gross margin at the level of major retail channels are averaged over multiple product lines and 

many different store types. The empirical data at this level do not provide useful guidance for 

estimating what happens to the markup on specific products when their costs change. Applying 

the same markup as CGS increases, as AHAM recommends, would mean that the increase in 

CGS associated with higher-efficiency products would translate into higher retail gross margins 

for that product line. Because the majority of operating expenses would not be affected by the 

increase in CGS, the result would be an increase in net profit as a share of sales. While such an 

outcome could occur in the short run, DOE believes that competitive forces in the market would 

tend to decrease the profit margin over time. 

Based on the above considerations, DOE has decided to continue to apply an incremental 

markup to the incremental MSP of products with higher efficiency than the baseline products. As 

part of its review, DOE developed a new breakdown into fixed and variable components using 

the latest expense data provided by the U.S. Census for Electronics and Appliance Stores, which 

cover 2002. The newly-derived incremental markup, which would be applied to an incremental 

change in CGS, is 1.17, which is slightly higher than the value of 1.15 that DOE used in the 

preliminary analysis. Chapter 6 of the direct final rule TSD provides a description of both the 

method and its current application using the aforementioned data. 

E. Energy Use Analysis 

DOE’s analysis of the energy use of clothes dryers and room air conditioners estimated 

the energy use of these products in the field, that is, as they are actually used by consumers. The 

40 The channels for which AHAM provided gross margin data for 1993-2007 are electronics and appliance stores, 

general merchandise stores, and building material and supplies dealers. According to AHAM, these channels 

accounted for 43 percent, 31 percent and 17 percent of major appliance sales in 2007, respectively. 

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energy use analysis provided the basis for other analyses DOE performed, particularly 

assessments of the energy savings and the savings in consumer operating costs that could result 

from DOE’s adoption of amended standards. In contrast to the DOE test procedure, which 

provides a measure of the energy use, energy efficiency or annual operating cost of a covered 

product during a representative average use cycle or period of use, the energy use analysis seeks 

to capture the range of operating conditions for clothes dryers and room air conditioners in U.S. 

homes. 

To determine the field energy use of products that would meet possible amended standard 

levels, DOE used data from the EIA’s 2005 RECS, which was the most recent such survey 

41 available at the time of DOE’s analysis. RECS is a national sample survey of housing units that 

collects statistical information on the consumption of and expenditures for energy in housing 

units along with data on energy-related characteristics of the housing units and occupants. RECS 

provides sufficient information to establish the type (product class) of clothes dryer or room air 

conditioner used in each household. As a result, DOE was able to develop household samples for 

each of the considered product classes. DOE developed a separate building sample for 

commercial-sector use of room air conditioners and accounted for the distinct features of room 

air conditioner utilization in commercial buildings. 

A more detailed description of DOE’s energy use analysis for clothes dryers and room air 

conditioners is contained in chapter 7 of the direct final rule TSD. 

41 For information on RECS, see http://www.eia.doe.gov/emeu/recs/. 

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1. Clothes Dryers 

For clothes dryers with a specific efficiency, the annual energy consumption depends on 

the annual number of cycles. In the preliminary analysis, DOE used a distribution of values with 

an average of 283 cycles/year based on RECS data. Whirlpool stated that a range of 278–300 

annual dryer cycles is reasonable, based on P&G data which indicate 278 annual dryer cycles, 

and internal data which indicate 288 annual dryer cycles. (Whirlpool, No. 22 at p. 3) AHAM 

stated that P&G data indicate 278 annual dryer loads, which verifies the RECS data. (AHAM, 

No. 25 at p. 9) DOE acknowledges the above comments and has retained the approach used in 

the preliminary analysis, which resulted in an average of 283 cycles/year, for its final rule 

analysis. This average value matches the number of cycles/yr in the most current DOE clothes 

dryers test procedure and is within the range of the values submitted by the commenters. 

In the preliminary analysis, DOE estimated that clothes dryers take on average 60 

minutes to complete a cycle. EEI stated that DOE should consider manufacturer data, consumer 

reports, or data from other third parties to determine typical cycle time for clothes dryers. (EEI, 

Public Meeting Transcript, No. 21.4 at pp. 106–107) ALS stated that cycle time should be 

derived based on RMC, assuming that a sensor will be included in all future models. (ALS, 

Public Meeting Transcript, No. 21.4 at pp. 110–111) NRDC stated that there is a 20-minute 

variation in cycle time, based on whether the sensors work accurately. (NRDC, Public Meeting 

Transcript, No. 21.4 at p. 106) The NRDC/ECOS report stated that a typical drying cycle is 

much different than the constant drying cycle duration fixed at 60 minutes that is used in the 

LCC. (NRDC, No. 30 at p. 11) 

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DOE acknowledges that there is variation in cycle time and that it is dependent on the 

RMC and the sensors’ accuracy. In the final rule analysis, DOE revised the cycle time to match 

the most current DOE test procedure average value of 30 minutes. Overall, the cycle time has 

very little impact on the calculation of energy use because it is only used for the determination of 

standby energy use. 

In the preliminary analysis, DOE assigned an RMC value to each sample unit using a 

42 distribution of clothes washer RMC values from the CEC directory ranging from 30 percent to 

61 percent, with an average of 46 percent. In response, AHAM suggested DOE use a RMC value 

of 47 percent because it is representative of products likely to be sold in the 2015 timeframe. 

(AHAM, No. 25 at pp. 9–10) Whirlpool stated that they support the use of AHAM data, which 

indicate a shipment-weighted average RMC of 47 percent. (Whirlpool, No. 22 at p. 4) 

In its analysis for the final rule, DOE incorporated new information about the RMC value 

developed during DOE’s recent clothes dryers test procedure rulemaking. In response to 

comments on the clothes dryers test procedure NOPR, DOE issued an SNOPR in which it 

proposed a revision of the average RMC value. FR 75 37594 (June 29, 2010). The revision 

addresses the fact that the RMC values listed in the CEC directory are multiplied by a correction 

factor and therefore do not represent the actual cloth moisture content at the end of the clothes 

washer spin cycle. In keeping with this revision, for the final rule analysis DOE used a 

distribution of cloth washer RMC values from the CEC directory multiplied by a correction 

factor to match the average RMC value of 57.5 percent assumed in the proposed test procedure. 

42 California Energy Commission. Appliance Efficiency Database: Clothes Washers. July 2010. URL: 

http://www.appliances.energy.ca.gov/ 

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In the preliminary analysis, DOE assigned load weights to each sample household by 

developing a distribution based on the CEC directory. The average load weights for standard-size 

units ranged from 5.1 lbs. to 10 lbs., with a mean value of 8.1 lbs. 

AHAM stated that the shipment-weighted residential clothes washer drum volume for 

3 standard size products in 2008 was 3.24 ft , which corresponds to an average load size of 8.15 

lbs., which is consistent with the value proposed by DOE, using the alternative CEC approach. 

AHAM also stated that the load size should be 4.70 lbs. for compact clothes dryers, based on the 

3 shipment-weighted drum volume of 1.5 ft . (AHAM, No. 25 at p. 10) BSH stated that load size 

should increase linearly with drum size. (BSH, No. 23 at p. 5) The NRDC/ECOS Report 

suggested that the values used in the preliminary analysis may be too low. It stated that today’s 

dryers can comfortably accommodate loads between 10 and 17 lbs., and that there are more dryer 

3 3 models on the market today between 7 and 8 ft than there are models smaller than 7 ft . (NRDC, 

No. 30 at p. 35) 

In its analysis for the final rule, DOE used the average load size value of 8.45 lbs. from 

the TP Final Rule. To represent a range of load size values in the field, DOE used a distribution 

of load sizes ranging from 3.80 to 13.7 lbs., with a mean value of 8.45 lbs. Chapter 7 of the TSD 

presents the details of the DOE’s load size analysis. 

DOE received several comments recommending that it use the same values for number of 

cycles, RMC, and load weights in both the engineering analysis and the LCC and PBP analysis, 

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and that it revise the test procedure to reflect the values used in its analysis. (AHAM, No. 25 at 

pp. 9–10; Whirlpool, No. 22 at pp. 3–4) The California Utilities stated that DOE should consider 

all changes in the test procedure in additional analysis of clothes dryer energy use. (California 

Utilities, No. 31 at p. 13) 

For its LCC and payback period analysis DOE developed distributions of values for 

number of cycles, RMC, and load weights that reflect its best estimate of the range of practices 

found in U.S. homes. In the engineering analysis, DOE uses the test procedure to evaluate the 

relative improvement in energy efficiency provided by different design options. As discussed in 

section III.A, DOE has modified the clothes dryer test procedure to reflect current field 

conditions, and these changes are also incorporated in the analysis for the final rule. 

In the preliminary analysis, DOE estimated an average energy use of 519 kWh per year 

for the baseline vented electric standard clothes dryer. ACEEE stated that DOE should revisit the 

approach to determining annual energy consumption, and it noted that the baseline average unit 

energy consumption (UEC) of 519 kWh/year in DOE’s analysis is much lower than the values 

found in field studies and metered evaluations of clothes dryer models. (ACEEE, No. 24 at p. 2) 

The California Utilities stated that a Florida Solar Energy Center survey found that field-average 

UEC for electric standard clothes dryers was around 900 kWh/year, the 2001 RECS lists 1079 

kWh/year, and a 1999 Progress Energy Florida study shows 885 kWh/year. They noted that these 

numbers are significantly higher than DOE's average UEC. (California Utilities, No. 31 at p. 12) 

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As described above, DOE made several changes to its approach for estimating clothes 

dryer energy use for the final rule (increased initial RMC value and clothes dryer load size). As a 

result, the average annual energy use for the baseline vented electric clothes dryer derived for the 

final rule is 718 kWh. This value is lower than those found in the surveys mentioned above 

primarily because it reflects more recent clothes washer technology and clothes dryer utilization 

than the surveys discussed in the comment. In particular, this value reflects the lower initial 

RMC associated with newer clothes washers and the lower number of clothes dryer cycles per 

year seen in recent P&G data and 2005 RECS data. The value from 2001 RECS was derived 

using conditional demand analysis that utilized assumptions based on the previous clothes dryer 

test procedure. The Florida surveys date from 1999, when initial RMC and annual number of 

dryer cycles were higher significantly higher than the values used in the final rule analysis. In 

addition, the sample size of these surveys is small and not necessarily representative of the 

nation. 

In the preliminary analysis, DOE considered the impact of clothes dryer operation on 

home heating and cooling loads. A clothes dryer releases heat to the surrounding environment. If 

the dryer is located indoors, its use will tend to slightly reduce the heating load during the 

heating season and slightly increase the cooling load during the cooling season. DOE believed 

that the effect is the same for all of the considered efficiency levels because the amount of air 

passing through the clothes dryer does not vary, and thus it did not include this factor in its 

preliminary analysis. 

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ACEEE, NRDC, NEEP and NPCC and the California Utilities stated that DOE should 

consider the impact on space conditioning loads from clothes dryer use. (ACEEE, No. 24 at p. 2; 

NRDC, No. 26 at p. 2; NEEP, No. 27 at p. 3; NPCC, No. 32 at p. 3; California Utilities, No. 31 

at p. 9) The California Utilities stated that the HVAC load created by dryers can amount to as 

much as 3 kWh/cycle. (California Utilities, No. 31 at p. 9) 

As discussed in section III.A.1, DOE believes that accounting for the effects of clothes 

dryers on HVAC energy use in a DOE test procedure is inconsistent with the EPCA requirement 

that a test procedure measure the energy efficiency, energy use, or estimated annual operating 

cost of a covered product. As a result, DOE did not consider the impact of standards on HVAC 

energy use, is permissible under 42 U.S.C. 6295(o) in developing the energy conservation 

standards established in today’s direct final rule. 

Deleted: believes, however, that consideration of 

significant indirect effects of potential standards, 

such as 

Deleted: ). Therefore, for 

Deleted: , DOE further evaluated the impact of 

clothes dryer use on home heating and cooling loads 

To calculate this impact, DOE first estimated whether the clothes dryer in a RECS 

sample home is located in conditioned space (referred to as indoors) or in unconditioned space 

(such as garages, unconditioned basements, outdoor utility closets, or attics). Based on the 2005 

RECS and the 2009 American Housing Survey (AHS), DOE assumed that 50 percent of vented 

standard electric and gas dryers are located indoors, while 100 percent of compact and ventless 

clothes dryers are located indoors. For these installations, DOE utilized the results from a 

European Union study about the impacts of clothes dryers on home heating and cooling loads to 

43 determine a the appropriate factor to apply to the total clothes dryer energy use. This study 

reported that for vented dryers there is a factor of negative 3 to 9 percent (average 6 percent) and 

43 Rüdenauer, Ina and Gensch, Carl-Otto. Energy demand of tumble dryers with respect to differences in technology 

and ambient conditions. Report commissioned by European Committee of Domestic Equipment Manufacturers 

(CECED). January 13, 2004. 

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for ventless dryers there is a factor of positive 7 to 15 percent (average 11 percent). For the 

reasons stated earlier, DOE assumed that the effect is the same for all considered efficiency 

levels. 

2. Room Air Conditioners 

For room air conditioners with a specific size and EER, the annual energy use depends on 

the annual hours of operation. In the preliminary analysis, for units in the residential sector, DOE 

calculated the number of operating hours for each room air conditioner in the residential sample 

using the reported energy use for room air conditioning in the 2005 RECS, along with estimates 

of the EER of the room air conditioner(s) in each sample home. DOE based the latter on the 

reported age of the unit and historical data on shipment-weighted average EER. 

For units used in the commercial sector, DOE calculated the number of operating hours 

for each room air conditioner in the commercial sample by establishing a relationship between 

cooling degree-days and operating hours for a number of building types and building schedule 

combinations. DOE assumed that a room air conditioner is operated when the outdoor air 

conditions are above the comfort zone described by ANSI/ASHRAE Standard 55-2004 Thermal 

Environmental Conditions for Human Occupancy. For a given location, the number of annual 

hours above the ASHRAE Standard 55 comfort zone varies by building operating schedule, 

which refers to the time that a building is in operation. 

AHAM stated that it opposes the use of RECS and CBECS data to estimate energy 

consumption of room air conditioners in the LCC and payback period calculations, and it 

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requested confirmation that DOE’s estimates for both residential and commercial room air 

conditioner use are realistic. (AHAM, No. 25 at pp. 8–9) AHAM questioned the validity of 

DOE’s analysis for residential use of room air conditioners. AHAM stated that RECS data do not 

provide information on room air conditioner capacity or a direct measurement of room air 

conditioner energy use. (AHAM, No. 25 at p. 2) AHAM also questioned DOE’s estimate of the 

capacity of the unit (or units) based on the reported total cooled area, as well as the approach 

DOE used to distribute the capacity sizes among the various product classes evaluated. (AHAM, 

No. 25 at pp. 8–9) 

Regarding the use of RECS data to estimate the capacity of the unit (or units), DOE 

believes that the reported total cooled area is an important indicator of the capacity of the unit (or 

units). The reason is that for room air conditioners this is the primary sizing criteria used by 

manufacturers, contractors, and programs such as ENERGY STAR. Therefore, DOE continued 

to use reported total cooled area to estimate the room air conditioner capacity. To improve the 

accuracy of the estimate, for the final rule DOE also considered additional factors that are likely 

to influence the capacity selection: the number of occupants, local weather, and building 

characteristics such as envelope insulation and shading. In addition, for the final rule analysis 

DOE revised its criteria for assigning room air conditioner units for the RECS household sample 

associated with each product class. DOE took into consideration AHAM’s suggestion and did 

not assign smaller-size units in the sample for the largest product class. 

In addition to the above changes, DOE applied an adjustment to the values for annual 

operating hours derived from the 2005 RECS to account for the warmer-than-average weather in 

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2005. (DOE used long-term national average cooling degree-day values as a basis for the 

adjustment). DOE also adjusted the values to account for the fact that the stock of homes in 2014 

is likely to have slightly more floor area and have better insulation than homes in 2005. DOE 

based the adjustment on projections in AEO2010. These modifications are described in chapter 7 

of the direct final rule TSD. 

Regarding DOE’s use of CBECS for estimating the commercial use of room air 

conditioners, AHAM stated that (1) DOE made substantial assumptions regarding the number of 

room air conditioners per commercial application and the room air conditioner capacities 

employed at these locations; and (2) it appears that DOE, to obtain enough data for statistical 

analysis, overlapped the units in each product class. (That is, units calculated as having > 20,000 

Btu/hr capacity have also been included in the analysis of the < 6,000 Btu/hr and 8,000 – 13,999 

Btu/hr product classes.) It stated that the latter approach is misleading and unacceptable. 

(AHAM, No. 25 at p. 3) 

DOE believes that the assumptions made in the preliminary analysis are consistent with 

the CBECS and AHAM shipments data that are available for evaluating commercial use of room 

air conditioners. Therefore, DOE retained the approach used in the preliminary analysis for the 

final rule analysis. Regarding the overlapping of units among product classes, DOE believes that 

its approach is reasonable given that there is no information available on the number of air 

conditioner units in a building, so a building could have one or more units in any of the 

considered product classes. 

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AHAM stated that DOE’s approach for estimating room air conditioner energy use is not 

consistent with the law, which requires that the test procedure be used to determine energy use 

and energy savings. (AHAM, No. 25 at p. 2) AHAM elaborated on this statement and made 

arguments that can be summarized as follows (AHAM, No. 25 at pp. 7–8): 

1. While use of RECS data has proven useful over the years to provide general 

guidance to DOE on residential energy use, this is the first time that DOE proposes to use it to 

estimate actual energy consumption in the field and to justify a new energy efficiency standard; 

2. It is inconsistent for DOE to use RECS data and statistical regression techniques 

to estimate energy use for determining the life cycle cost and payback period used to justify an 

appliance standard, while it uses the applicable test procedure as the sole source of energy use 

data for purposes of determining compliance with the standard. 

3. Reliance on the test procedure for the energy data used in LCC and payback 

period calculations to set new appliance standards is the tried and true method that has a clear 

statutory basis. 

4. The law on labeling prohibits manufacturers, distributors, and retailers from 

making energy use representations about their products based on anything other than the results 

of a test procedure, so it is irrational if DOE’s analysis makes energy claims that sellers cannot 

make. 

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AHAM also stated that DOE should use 750 annual operating hours (the value in the 

current test procedure) to maintain consistency while additional surveys or testing are completed 

to determine a representative number of annual operating hours. (AHAM, No. 25 at p. 9) 

In response, DOE notes that EPCA specifies particular uses of the applicable test 

procedure, such as when DOE ascertains whether the consumer costs associated with the 

purchase of a product that complies with the proposed standard level is less than three times the 

value of the energy savings the consumer will receive during the first year of ownership. (42 

U.S.C. 6295(o)(2)(B)(iii)) This calculation is separate from the payback periods calculated in the 

LCC and payback period analysis. The latter analysis helps DOE to evaluate two of the factors 

that EPCA directs DOE to consider in determining whether an energy conservation standard for 

a particular covered product is economically justified. The first of these is the economic impact 

of potential standards on the manufacturers and the consumers of the covered products. (42 

U.S.C. 6295(o)(2)(B)(i)(I)) The second factor is the savings in operating costs throughout the 

estimated average life of the covered product in the type (or class) compared to any increase in 

the price of, or in the initial charges for, or maintenance expenses of, the covered products which 

are likely to result from the imposition of the standard. (42 U.S.C. 6295(o)(2)(B)(i)(II)) 

To evaluate economic impacts on consumers and the savings in operating costs as 

accurately as possible, DOE needs to determine the energy savings that are likely to result from a 

given standard. Such a determination requires knowledge of the range of actual use of covered 

products by consumers. Because it is a recent nationally-representative survey of U.S. 

households, RECS provides information that helps DOE to determine such use. In addition, DOE 

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uses RECS data because it is consistent with the guidance contained in 10 CFR part 430, subpart 

C, appendix A—“Procedures, Interpretations and Policies for Consideration of New or Revised 

Energy Conservation Standards for Consumer Products.” Specifically, section 11 of appendix A 

lists variation in consumer impacts as one of the principles for the analysis of impacts on 

consumers. Because RECS provides considerable information about each household in the 

sample, it allows DOE to evaluate factors that contribute to variation in the energy use of 

covered products. In turn, this allows DOE to estimate the fraction of consumers that will benefit 

from standards at various efficiency levels. 

Consistent with the EPCA and DOE’s regulatory guidance, DOE has used RECS data in 

a variety of ways over the past decade. In most cases, DOE has used the relevant DOE test 

procedure or a similar procedure as the basis for the energy use calculation, and used RECS data 

to provide a range for key input variables concerning the operation of covered products. 

Examples include the standards rulemaking for water heaters concluded in 2001 (66 FR 4474 

(Jan. 17, 2001)), and the recently-concluded rulemaking that amended standards for water 

heaters. 75 FR 20112, 20112–20236 (Apr. 16, 2010). In both rulemakings, DOE used data for 

each of the households in the RECS sample to estimate the amount of household daily hot water 

use, and to specify certain factors that affect water heater operating conditions. Additionally, 

DOE’s 2001 final rule for central air conditioners and heat pumps relied on annual energy use 

based on the annual end-use energy consumption values in RECS. 66 FR 7070, 7170–7200 (Jan. 

22, 2001). DOE determined that basing the energy use on RECS household data provided an 

accurate measure of the savings possible from more-efficient equipment, and accounted for 

variability due to climatic conditions and consumer behavior. 

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Regarding AHAM’s suggestion that DOE should use the test procedure only to estimate 

energy use for the purposes of its analysis of standards, DOE notes that test procedures must be 

designed to produce test results which measure energy efficiency, energy use or estimated annual 

operating cost of a covered product during a representative average use cycle or period of use. 

(42 U.S.C. 6293(b)(3)) For the purposes of evaluating two of the factors that EPCA directs DOE 

to consider in determining whether an energy conservation standard for covered products is 

economically justified, determining energy use based on only a representative average use cycle 

or period of use does not provide an accurate measure of the range of possible energy savings. 

Thus, doing so would not be consistent with EPCA and the above-cited guidance of appendix A 

to subpart C of part 430. 

In addition, EPCA requires that manufacturers and DOE use the DOE test procedures 

prescribed pursuant to 42 U.S.C. 6293 in determining compliance. Determining compliance 

requires a metric that provides repeatable and consistent results for appliances in a given product 

class, a purpose best served by the test procedure. Similarly, energy labeling of appliances is 

designed to provide consumers with information that allows comparison of the technical 

performance of different products with respect to energy efficiency. Measurement of such 

performance is best conducted with a standard metric such as the applicable test procedure. The 

LCC and PBP analysis, in contrast, seeks to estimate the impact of alternative standard levels on 

consumers. This requires an evaluation of variation in energy use in the field, which is provided 

by analysis of the RECS data. 

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DOE included a “rebound effect” in its analysis of room air conditioner energy use. A 

rebound effect could occur when a piece of equipment that is more efficient is used more 

intensively, so that the expected energy savings from the efficiency improvement may not fully 

materialize. A rebound effect of 10 percent implies that 90 percent of the expected energy 

44 savings from more efficient equipment will actually occur. Based on the data available, DOE 

incorporated a rebound effect of 15 percent for room air conditioners in the analysis for the final 

rule. 

F. Life-Cycle Cost and Payback Period Analyses 

DOE conducts LCC and PBP analyses to evaluate the economic impacts on individual 

consumers of potential energy conservation standards for clothes dryers and room air 

conditioners. The LCC is the total consumer expense over the life of a product, consisting of 

purchase and installation costs plus operating costs (expenses for energy use, maintenance, and 

repair). To compute the operating costs, DOE discounts future operating costs to the time of 

purchase and sums them over the lifetime of the product. The PBP is the estimated amount of 

time (in years) it takes consumers to recover the increased purchase cost (including installation) 

of a more efficient product through lower operating costs. DOE calculates the PBP by dividing 

the change in purchase cost (normally higher) due to a more stringent standard by the change in 

average annual operating cost (normally lower) that results from the standard. 

For any given efficiency level, DOE measures the PBP and the change in LCC relative to 

an estimate of the base-case appliance efficiency levels. The base-case estimate reflects the 

44 S. Sorrell, J. Dimitropoulos, and M. Sommerville Empirical estimates of the direct rebound effect: a review 

Energy Policy, 2009 37, pp. 1356–71. 

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market in the absence of new or amended energy conservation standards, including the market 

for products that exceed the current energy conservation standards. 

For each considered efficiency level in each product class, DOE calculated the LCC and 

PBP for a nationally representative set of housing units. For the preliminary analysis and the 

analysis for today’s rule, DOE developed household samples from the 2005 RECS. For each 

sample household, DOE determined the energy consumption for the clothes dryer or room air 

conditioner and the appropriate electricity or natural gas price. By developing a representative 

sample of households, the analysis captured the variability in energy consumption and energy 

prices associated with the use of residential clothes dryers and room air conditioners. DOE 

developed a separate building sample for commercial-sector use of room air conditioners and 

accounted for the distinct features of room air conditioner utilization in commercial buildings. 

Inputs to the calculation of total installed cost include the cost of the product—which 

includes manufacturer costs, manufacturer markups, retailer and distributor markups, and sales 

taxes—and installation costs. Inputs to the calculation of operating expenses include annual 

energy consumption, energy prices and price projections, repair and maintenance costs, product 

lifetimes, discount rates, and the year that compliance with standards is required. DOE created 

distributions of values for some inputs, with probabilities attached to each value, to account for 

their uncertainty and variability. DOE used probability distributions to characterize product 

lifetime, discount rates, and sales taxes. 

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The computer model DOE uses to calculate the LCC and PBP, which incorporates 

Crystal Ball (a commercially available software program) relies on a Monte Carlo simulation to 

incorporate uncertainty and variability into the analysis. The Monte Carlo simulations randomly 

sample input values from the probability distributions and clothes dryer and room air conditioner 

user samples. The model calculated the LCC and PBP for products at each efficiency level for 

10,000 housing units per simulation run. Details of the spreadsheet model, and of all the inputs to 

the LCC and PBP analyses, are contained in chapter 8 of the direct final rule TSD and its 

appendices. 

Table IV.31 summarizes the approach and data DOE used to derive inputs to the LCC 

and PBP calculations. The table provides the data and approach DOE used for the preliminary 

TSD, as well as the changes made for today’s direct final rule. The subsections that follow 

discuss the initial inputs and methods and the changes DOE made for the final rule. 

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* Table IV.31 Summary of Inputs and Methods in the LCC and PBP Analysis 

Inputs Preliminary TSD Changes for the Final Rule 

Installed Costs 

Product Cost Derived by multiplying manufacturer 

cost by manufacturer and retailer 

markups and sales tax, as appropriate. 

Used a product-specific price/cost 

adjustment factor based on 

experience curves that forecasts 

changes in price relative to inflation 

in the over-all economy. 

Installation Costs Based on RS Means, assumed no change 

with efficiency level. 

Based on RS Means; included 

additional installation cost for heat 

pump dryers and higher-efficiency 

room air conditioners due to their 

larger dimensions and weight. 

Operating Costs 

Annual Energy Use Clothes Dryers: Used DOE test 

procedure with data on cycles from the 

2005 RECS, market data on RMC, and 

load weights from test procedure. 

Room Air Conditioners: Based on 

calculation of operating hours for each 

2005 RECS sample unit. 

Clothes Dryers: Same approach, but 

RMC and load weight revised to 

account for proposed changes in 

DOE test procedure. 

Room Air Conditioners: No change. 

Energy Prices Electricity (clothes dryers): Based on 

EIA’s Form 861 data for 2007. 

Electricity (room air conditioners): Used 

utility tariff data to develop monthly 

marginal electricity prices for each 

sample household. 

Natural gas: Based on EIA’s Natural Gas 

Monthly data for 2007. 

Variability: Regional energy prices 

determined for 13 regions for clothes 

dryers; tariffs determined for sample 

households for room air conditioners. 

Electricity (clothes dryers): 

Updated using Form 861 data for 

2008. 

Electricity (room air conditioners): 

No change. 

Natural gas: Updated using Natural 

Gas Monthly data for 2009. 

Variability: No change. 

Energy Price Trends Forecasted using AEO2009 price 

forecasts. 

Forecasts updated using AEO2010. 

Repair and 

Maintenance Costs 

Not included. Derived annualized maintenance 

and repair frequencies and costs per 

service call based on RS Means and 

equipment cost. 

Present Value of Operating Cost Savings 

Product Lifetime Estimated using survey results from 

RECS (1990, 1993, 1997, 2001, 2005) 

and the U.S. Census American Housing 

Survey (2005, 2007), along with historic 

data on appliance shipments. 

Variability: Characterized using Weibull 

probability distributions. 

No change. 

Discount Rates Identified all possible debt or asset 

classes that might be used to purchase 

No change. 

Deleted: No change. 

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the considered appliances, or might be 

affected indirectly. Primary data source 

was the Federal Reserve Board’s SCF ** 

for 1989, 1992, 1995, 1998, 2001, 2004 

and 2007. 

Compliance Date 2014. No change. 

* References for the data sources mentioned in this table are provided in the sections following the table or in 

chapter 8 of the direct final rule TSD. 

** Survey of Consumer Finances. 

As discussed in section IV.E, DOE takes into account the rebound effect associated with 

more efficient room air conditioners. The take-back in energy consumption associated with the 

rebound effect provides consumers with increased value (for example, a cooler or warmer indoor 

environment). The net impact on consumers is thus the sum of the change in the cost of owning 

the room air conditioner (that is, life-cycle cost) and the increased value for the more 

comfortable indoor environment. The consumer effectively pays for the increased value of a 

more comfortable environment in his or her utility bill. Because the monetary cost of this added 

value is equivalent to the value of the foregone energy savings, the economic impacts on 

consumers measured in the LCC analysis are the same regardless of the rebound effect. 

1. Product Cost 

To calculate consumer product costs, DOE multiplied the manufacturer selling prices 

developed in the engineering analysis by the supply-chain markups described above (along with 

sales taxes). DOE used different markups for baseline products and higher-efficiency products 

because, as discussed previously, DOE applies an incremental markup to the MSP increase 

associated with higher efficiency products. 

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On February 22, 2011, DOE published a Notice of Data Availability (NODA, 76 FR 

9696) stating that DOE may consider improving regulatory analysis by addressing equipment 

price trends. Consistent with the NODA, DOE examined historical producer price indices (PPI) 

for room air conditioners and household laundry equipment and found a consistent, long-term 

declining real price trend for both products. Consistent with the method proposed in the NODA, 

DOE used experience curve fits to forecast a price scaling index to forecast product costs into the 

future for this rulemaking. DOE also considered the public comments that were received in 

response to the NODA and refined the evaluation of its experience curve trend forecasting 

estimates. Many commenters were supportive of DOE moving from an assumption-based 

equipment price trend forecasting method to a data-driven methodology for forecasting price 

trends. Other commenters were skeptical that DOE could accurately forecast price trends given 

the many variables and factors that can complicate both the estimation and the interpretation of 

the numerical price trend results and the relationship between price and cost. DOE evaluated 

these concerns and determined that retaining the assumption-based approach of a constant real 

price trend was not consistent with the historical data for the products covered in this rule though 

this scenario does represent a reasonable upper bound on the future equipment price trend. DOE 

also performed an initial evaluation of the possibility of other factors complicating the estimation 

of the long-term price trend, and developed a range of potential price trend values that were 

consistent with the available data and justified by the amount of data available to DOE. DOE 

recognizes that its price trend forecasting methods are likely to be modified as more data and 

information becomes available to enhance the statistical certainty of the trend estimate and the 

completeness of the model. Additional data should enable an improved evaluation of the 

potential impacts of more of the factors that can influence equipment price trends over time. 

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To evaluate the impact of the uncertainty of the price trend estimates, DOE performed 

price trend sensitivity calculations in the national impact analysis to examine the dependence of 

the analysis results—specifically annualized net national benefits—on different analytical 

assumptions. DOE also included a zero real price trend assumption as a sensitivity scenario 

representing an upper bound on the forecast price trend DOE found that for the selected standard 

levels the benefits outweighed the burdens under all scenarios. 

A more detailed discussion of price trend modeling and calculations is provided in 

Appendix 8-J of the TSD. Comment [A8]: Change recommended by OIRA. 

2. Installation Cost 

Installation cost includes labor, overhead, and any miscellaneous materials and parts 

needed to install the equipment. For the preliminary analysis, DOE derived baseline installation 

costs for clothes dryers and room air conditioners from data in the RS Means 2008. DOE found 

no evidence that installation costs would be impacted with increased efficiency levels. 

Commenting on DOE’s assumption, Whirlpool stated that heat pump dryers would be 

considerably heavier than conventional dryers, leading to increased installation costs. 

(Whirlpool, No. 22 at p. 4) AHAM made a similar comment. (AHAM, Public Meeting 

Transcript, No. 21.4 at pp. 89–90) 

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For the final rule analysis, DOE included an additional installation cost for heat pump 

dryers due to their larger dimensions and weight. DOE added 0.5 hour of additional labor (or 

about $20) to the installation cost. For room air conditioners, DOE also added additional labor 

hours for higher efficiency equipment with significant larger dimensions and/or weight based on 

RS Means labor hour estimates for room air conditioners with different capacities. 

3. Annual Energy Consumption 

For each sampled household, DOE determined the energy consumption for a clothes 

dryer or room air conditioner at different efficiency levels using the approach described above in 

section IV.E. 

4. Energy Prices 

For clothes dryers, DOE derived average annual energy prices for 13 geographic areas 

consisting of the nine U.S. Census divisions, with four large states (New York, Florida, Texas, 

and California) treated separately. For Census divisions containing one of these large states, 

DOE calculated the regional average excluding the data for the large state. 

DOE calculated average residential electricity prices for each of the 13 geographic areas 

using data from EIA’s Form EIA-861 Database (based on “Annual Electric Power Industry 

45 Report”). DOE calculated an average annual regional residential price by: (1) estimating an 

average residential price for each utility (by dividing the residential revenues by residential 

sales); and (2) weighting each utility by the number of residential consumers it served in that 

45 Available at: http://www.eia.doe.gov/cneaf/electricity/page/eia861.html 

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region. For the preliminary TSD, DOE used the data for 2007. The final rule analysis updated the 

data for 2008, the most recent data available. 

DOE calculated average residential natural gas prices for each of the 13 geographic areas 

46 using data from EIA’s “Natural Gas Monthly.” DOE calculated average annual regional 

residential prices by: (1) estimating an average residential price for each state; and (2) weighting 

each state by the number of residential consumers. For the preliminary TSD, DOE used EIA data 

for 2007. The final rule analysis updated the data for 2009, the most recent data available. 

For the preliminary analysis, for room air conditioners DOE used utility tariff data to 

develop monthly marginal electricity prices for each sample household used in the LCC analysis. 

The marginal prices were calculated by taking account of the difference between the household’s 

electricity expenditures for the base case electricity use and for a candidate standard level, in 

combination with the associated change in energy use expected as a result of a particular 

standard level. The price used was based on the default (non-TOU) tariffs, because TOU tariffs 

are optional and very few customers opt for such rates. DOE then applied the monthly prices to 

the estimated electricity use by the room air conditioner in each corresponding month. This 

approach applies summer rates to the estimated consumption in summer months. DOE also used 

tariff data to develop marginal electricity prices for each commercial building in the LCC 

sample. DOE used the same approach for today’s final rule. 

46 Available at: http://www.eia.gov/oil_gas/natural_gas/data_publications/natural_gas_monthly/ngm.html 

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5. Energy Price Projections 

To estimate energy prices in future years for the preliminary TSD, DOE multiplied the 

above average regional energy prices by the forecast of annual average residential energy price 

47 changes in the Reference Case from AEO2009. AEO2009 forecasted prices through 2030. For 

today’s proposed rule, DOE updated its energy price forecasts using AEO2010, which has an end 

48 year of 2035. To estimate the price trends after 2035, DOE used the average annual rate of 

change in prices from 2020 to 2035. 

6. Maintenance and Repair Costs 

Repair costs are associated with repairing or replacing components that have failed in the 

appliance, whereas maintenance costs are associated with maintaining the operation of the 

equipment. In its preliminary analysis, DOE did not have information suggesting that these costs 

would change with higher efficiency levels. 

Commenting on DOE’s approach, AHAM stated that repair costs are typically estimated 

using a 1:1 ratio with part costs, so if component costs increase by 10 percent, repair costs are 

expected to also increase by 10 percent. AHAM stated that DOE should incorporate these higher 

repair costs into its analysis of clothes dryers and room air conditioners to provide a more 

representative evaluation of total consumer cost for higher efficiency products. (AHAM, No. 25 

at p. 12) 

47 The spreadsheet tool that DOE used to conduct the LCC and PBP analyses allows users to select price forecasts
 

from either AEO’s High Economic Growth or Low Economic Growth Cases. Users can thereby estimate the
 

sensitivity of the LCC and PBP results to different energy price forecasts.
 48 U.S. Energy Information Administration. Annual Energy Outlook 2010. Washington, DC. April 2010.
 

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For clothes dryers, Whirlpool stated that the repair and maintenance costs generally do 

not vary by efficiency, but for heat pump dryers, this assumption is not valid. Whirlpool stated 

that new technologies such as these would cost two to three times more to repair than 

conventional dryers due to their complex nature and the cost of disconnecting and reconnecting 

water sources. (Whirlpool, No. 22 at p. 4) AHAM stated that maintenance costs generally will 

not vary by efficiency level, but a heat pump clothes dryer is expected to have higher 

maintenance costs because of the heat pump and the addition of refrigerant. AHAM stated that 

maintenance for these units would be similar to that for standard air conditioning equipment or 

heat pump water heaters. (AHAM, No. 25 at p. 11) 

For the final rule analysis, DOE modified the maintenance and repair costs for both 

clothes dryers and room air conditioners. For clothes dryers, DOE derived annualized 

maintenance and repair frequencies based on Consumer Reports data on repair and maintenance 

issues for clothes dryers during the first 4 years of ownership. DOE estimated that on average 1.5 

percent of electric and 1.75 percent of gas clothes dryers are maintained or repaired each year. 

49 Based on RS Means Facilities Maintenance & Repair 2010 Cost Data, DOE also estimated that 

an average service call and any necessary repair or maintenance takes about 2.5 hours. DOE 

further estimated that the average material cost is equal to one-half of the equipment cost. The 

values for cost per service call were then annualized by multiplying by the frequencies and 

dividing by the average equipment lifetime of 16 years. 

For room air conditioners, based on data on repair frequencies for central air 

conditioners, DOE assumed that repair frequencies are low and increase for the higher-capacity 

49 Available at: http://rsmeans.reedconstructiondata.com/60300.aspx 

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units due to their more expensive equipment cost. DOE assumed that 1 percent of small sized 

units (below 6,000 Btu/hr), 2.5 percent of medium sized units (8,000 to 14,000 Btu/hr), and 5 

percent of large sized units (above 20,000 Btu/hr) are maintained or repaired each year. Based on 

the above-cited RS Means data, DOE also estimated that an average service call and any 

necessary repair or maintenance takes about 1 hour for small and medium-sized units and 2 

hours for large units. DOE further estimated that the average material cost is equal to one-half of 

the incremental equipment cost. The values for cost per service call were then annualized by 

multiplying by the frequencies and dividing by the average equipment lifetime of 10.5 years. 

7. Product Lifetime 

Because the lifetime of appliances varies depending on utilization and other factors, DOE 

develops a distribution of lifetimes from which specific values are assigned to the appliances in 

the samples. In the preliminary analysis, DOE conducted an analysis of actual lifetime in the 

field using a combination of shipments data, the stock of the considered appliances, and 

responses in RECS on the age of the appliances in the homes. The data allowed DOE to estimate 

a survival function, which provides a distribution of lifetimes. This analysis yielded an average 

lifetime of approximately 16 years for clothes dryers and approximately 10.5 years for room air 

conditioners. 

For clothes dryers, the ECOS report (prepared for NRDC) stated that the typical lifetime 

of a clothes dryer is about 12 years. (NRDC, No. 30 at p. 8) AHAM stated that DOE should 

modify average clothes dryer lifetime to 13 years because both Appliance Magazine and 

confidential industry data support that value. (AHAM, No. 25 at p. 11) Whirlpool stated that 

219 
 

 

 

 

 

 

 

 

 

 

Appliance Magazine shows 12 years as the expected lifetime for clothes dryers, which is largely 

consistent with their internal estimates. (Whirlpool, No. 22 at p. 5) 

For the final rule analysis, DOE retained the approach used to estimate clothes dryer 

lifetime in the preliminary analysis because it relies on field data, and because the sources used 

by Appliance Magazine and the confidential industry data were unavailable for analysis by DOE. 

For room air conditioners, AHAM stated that the average lifetime of 10.5 years from the 

preliminary analysis appears reasonable, and is consistent with the value of 10 years reported by 

Appliance Magazine. (AHAM, No. 25 at p. 11) AHAM stated, however, that there could be a 

very large difference in room air conditioner lifetime between product classes. (AHAM, Public 

Meeting Transcript, No. 21.4 at p. 126) While DOE acknowledges that there may be differences 

in room air conditioner lifetime among the product classes, DOE continued to use the same 

lifetime distribution for all room air conditioner product classes because it is not aware of any 

data that would provide a basis for using different lifetimes. 

See chapter 8 of the direct final rule TSD for further details on the method and sources 

DOE used to develop product lifetimes. 

8. Discount Rates 

In the calculation of LCC, DOE applies discount rates to estimate the present value of 

future operating costs. DOE estimated a distribution of residential discount rates for clothes 

dryers and room air conditioners, and also estimated a distribution of commercial discount rates 

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for commercial users of room air conditioners. See chapter 8 in the direct final rule TSD for 

further details on the development of consumer discount rates. 

a. Residential Discount Rates 

In its preliminary analysis, to establish residential discount rates for the LCC analysis, 

DOE identified all debt or asset classes that might be used to purchase refrigeration products, 

including household assets that might be affected indirectly. It estimated the average percentage 

shares of the various debt or asset classes for the average U.S. household using data from the 

Federal Reserve Board’s “Survey of Consumer Finances” (SCF) for 1989, 1992, 1995, 1998, 

2001, 2004, and 2007. Using the SCF and other sources, DOE then developed a distribution of 

rates for each type of debt and asset to represent the rates that may apply in the year in which 

amended standards would take effect. DOE assigned each sample household a specific discount 

rate drawn from one of the distributions. The average rate across all types of household debt and 

equity, weighted by the shares of each class, is 5.1 percent. DOE used the same approach for 

today’s final rule. 

b. Commercial Discount Rates 

In its preliminary analysis, DOE derived discount rates for commercial-sector customers 

from the cost of capital of publicly-traded firms in the sectors that purchase room air 

conditioners. The firms typically finance equipment purchases through debt, equity capital, or 

both. DOE estimated the cost of the firms’ capital as the weighted average of the cost of equity 

financing and the cost of debt financing for recent years for which data were available (2001 

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through 2008). The estimated average discount rate for companies that purchase room air 

conditioners is 5.7 percent. DOE used the same approach for today’s final rule. 

9. Compliance Date of Amended Standards 

DOE is required by consent decree to publish a final rule establishing any amended 

energy conservation standards by June 30, 2011. In the absence of any adverse comment on 

today’s direct final rule that may provide a reasonable basis for withdrawing the rule, compliance 

with amended standards for clothes dryers and room air conditioners will be required on 

[INSERT DATE three years after date of publication in the Federal Register]. DOE calculated 

the LCC and PBP for clothes dryers and room air conditioners as if consumers would purchase 

new products in the year compliance with the standard is required. If adverse comment that may 

provide a reasonable basis for withdrawing the rule is received, DOE will proceed with the 

NOPR published elsewhere in today’s Federal Register, and compliance with any amended 

standards would be required 3 years after the date of publication of any final standards. As noted 

above, DOE is required by consent decree to publish a final rule establishing any amended 

standards by June 30, 2011. 

10. Base Case Efficiency Distribution 

To accurately estimate the share of consumers that would be affected by a standard at a 

particular efficiency level, DOE’s LCC analysis considered the projected distribution of product 

efficiencies that consumers purchase under the base case (that is, the case without new energy 

efficiency standards). DOE refers to this distribution of product of efficiencies as a base-case 

efficiency distribution. 

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In the preliminary analysis, DOE primarily relied on data submitted by AHAM to 

estimate the efficiency distributions in recent years for each of the product classes that were 

analyzed in the LCC and PBP analysis. DOE assumed that these market shares would remain 

constant through 2014. Whirlpool supported DOE’s approach to forecast base-case market 

shares. (Whirlpool, No. 22 at p. 5) 

For the final rule analysis, DOE retained the approach used in the preliminary analysis 

for clothes dryers. For room air conditioners, however, DOE modified its approach for 

estimating base-case efficiency distributions for the final rule analysis based on historical trends 

of penetration of ENERGY STAR models. DOE believes that this data support a constant growth 

rate of energy efficiency of 0.25 percent per year. For further information on DOE’s estimate of 

base-case efficiency distributions, see chapter 8 of the direct final rule TSD. 

11. Inputs to Payback Period Analysis 

The payback period is the amount of time it takes the consumer to recover the additional 

installed cost of more efficient products, compared to baseline products, through energy cost 

savings. The simple payback period does not account for changes in operating expense over time 

or the time value of money. Payback periods are expressed in years. Payback periods that exceed 

the life of the product mean that the increased total installed cost is not recovered in reduced 

operating expenses. 

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The inputs to the PBP calculation are the total installed cost of the equipment to the 

customer for each efficiency level and the average annual operating expenditures for each 

efficiency level. The PBP calculation uses the same inputs as the LCC analysis, except that 

discount rates are not used. 

12. Rebuttable-Presumption Payback Period 

As noted above, EPCA, as amended, establishes a rebuttable presumption that a standard 

is economically justified if the Secretary finds that the additional cost to the consumer of 

purchasing a product complying with an energy conservation standard level will be less than 

three times the value of the energy (and, as applicable, water) savings during the first year that 

the consumer will receive as a result of the standard, as calculated under the test procedure in 

place for that standard. (42 U.S.C. 6295(o)(2)(B)(iii)) For each considered efficiency level, DOE 

determined the value of the first year’s energy savings by calculating the quantity of those 

savings in accordance with the applicable DOE test procedure, and multiplying that amount by 

the average energy price forecast for the year in which compliance with the amended standard 

would be required. The results of the rebuttable payback period analysis are summarized in 

section V.B.1.c of this notice. 

G. National Impact Analysis–National Energy Savings and Net Present Value Analysis 

The NIA assesses the national energy savings (NES) and the NPV of total consumer costs 

and savings that would be expected to result from new or amended standards at specific 

efficiency levels. (“Consumer” in this context refers to consumers of the product being 

regulated.) DOE calculates the NES and NPV based on projections of annual appliance 

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shipments, along with the annual energy consumption and total installed cost data from the 

energy use and LCC analyses. For the final rule analysis, DOE forecasted the energy savings, 

operating cost savings, product costs, and NPV of consumer benefits for products sold from 2014 

through 2043. 

DOE evaluates the impacts of new and amended standards by comparing base-case 

projections with standards-case projections. The base-case projections characterize energy use 

and consumer costs for each product class in the absence of new or amended energy 

conservation standards. DOE compares these projections with projections characterizing the 

market for each product class if DOE adopted new or amended standards at specific energy 

efficiency levels (that is, the TSLs or standards cases) for that class. For the base case forecast, 

DOE considers historical trends in efficiency and various forces that are likely to affect the mix 

of efficiencies over time. For the standards cases, DOE also considers how a given standard 

would likely affect the market shares of efficiencies greater than the standard. 

DOE uses an MS Excel spreadsheet model to calculate the energy savings and the 

national consumer costs and savings from each TSL. The direct final rule TSD and other 

documentation that DOE provides during the rulemaking help explain the models and how to use 

them, and interested parties can review DOE’s analyses by changing various input quantities 

within the spreadsheet. The NIA spreadsheet model uses typical values as inputs (as opposed to 

probability distributions). 

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For the current analysis, the NIA used projections of energy prices and housing starts 

from the AEO2010 Reference case. In addition, DOE analyzed scenarios that used inputs from 

the AEO2010 Low Economic Growth and High Economic Growth cases. These cases have 

higher and lower energy price trends compared to the Reference case, as well as higher and 

lower housing starts, which result in higher and lower appliance shipments to new homes. NIA 

results based on these cases are presented in appendix 10-A of the direct final rule TSD. 

Table IV-32 summarizes the inputs and key assumptions DOE used for the NIA analysis 

for the preliminary analysis and the changes to the analyses for the direct final rule. Discussion 

of these inputs and changes follows the table. See chapter 10 of the direct final rule TSD for 

further details. 

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Table IV-32 Summary of Inputs and Key Assumptions for the National Impact Analysis 

Inputs Preliminary TSD Changes for the Proposed Rule 

Shipments Annual shipments from shipments 

model. 

No change in approach. 

Compliance Date 

of Standard 

2014. No change. 

Base-Case 

Forecasted 

Efficiencies 

For clothes dryers and room air 

conditioners, efficiency distributions 

are maintained unchanged during the 

forecast period 

For clothes dryers, no change in 

basic approach; modified 

efficiency distributions based on 

new information. For room air 

conditioners, used an efficiency 

trend based on historical market 

data. 

Standards-Case 

Forecasted 

Efficiencies 

For clothes dryers and air conditioners, 

used a “roll-up” scenario. 

For clothes dryers, no change in 

basic approach; modified 

efficiency distributions based on 

new information. For room air 

conditioners, used a “roll-up + 

shift” scenario to establish the 

distribution of efficiencies. 

Annual Energy 

Consumption per 

Unit 

Annual weighted-average values as a 

function of CEF * (clothes dryers) and 

SWCEER ** (room air conditioners). 

No change. 

Total Installed 

Cost per Unit 

Annual weighted-average values as a 

function of CEF * (clothes dryers) and 

SWCEER ** (room air conditioners). 

No change. 

Annual Energy 

Cost per Unit 

Annual weighted-average values as a 

function of the annual energy 

consumption per unit and energy 

prices. 

No change. 

Repair and 

Maintenance Cost 

per Unit 

Annual values as a function of 

efficiency level. 

No change. 

Energy Prices AEO2009 forecasts (to 2035) and 

extrapolation through 2043. 

Updated using AEO2010 

forecasts. 

Energy Site-toSource Conversion 

Factor 

Varies yearly and is generated by 

NEMS-BT. 

No change. 

Discount Rate Three and seven percent real. No change. 

Present Year Future expenses discounted to 2011, 

when the final rule is published. 

No change. 

* Combined Energy Factor 

** Shipments-Weighted (stand by) Combined Energy Efficiency Ratio 

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1. Shipments 

Forecasts of product shipments are needed to calculate the national impacts of standards 

on energy use, NPV, and future manufacturer cash flows. DOE develops shipment forecasts 

based on an analysis of key market drivers for each considered product. In DOE’s shipments 

model, shipments of products are driven by new construction, stock replacements, and other 

types of purchases. The shipments models take an accounting approach, tracking market shares 

of each product class and the vintage of units in the existing stock. Stock accounting uses 

product shipments as inputs to estimate the age distribution of in-service product stocks for all 

years. The age distribution of in-service product stocks is a key input to calculations of both the 

NES and NPV, because operating costs for any year depend on the age distribution of the stock. 

DOE also considers the impacts on shipments from changes in product purchase price and 

operating cost associated with higher energy efficiency levels. 

Commenting on the preliminary analysis, Whirlpool stated that clothes dryer base case 

shipments will not grow linearly as DOE assumes. Clothes dryers are a highly saturated product 

today, and homes without dryers are generally multi-family units that lack sufficient space for 

these products. Whirlpool stated that saturation of clothes dryers will not change. Hence, growth 

in this product category cannot exceed the growth of the housing stock. (Whirlpool, No. 22 at p. 

7) 

For the final rule analysis, DOE reviewed its approach for forecasting dryer purchases for 

first-time owners, which include consumers that currently do not have a dryer and consumers in 

new homes who purchase a dryer. To better account for constraints on purchase, such as those 

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mentioned by Whirlpool, DOE reduced its estimate of the number of purchases by first-time 

owners. As a result, its forecast for the final rule analysis shows shipments growing more slowly 

over the forecast period (an average of 0.8 percent per year) than in the forecast in the 

preliminary analysis. The average growth rate of 0.8 percent is slightly less than the average 

annual growth rate in the number of households projected in AEO2010 (1.0 percent in 2008– 

2035). 

To estimate the effects on product shipments from increases in product price projected to 

accompany amended standards at higher efficiency levels, DOE applied a price elasticity 

parameter. It estimated this parameter with a regression analysis that used purchase price and 

efficiency data specific to residential refrigerators, clothes washers, and dishwashers over the 

period 1980–2002. The estimated “relative price elasticity” incorporates the impacts from 

purchase price, operating cost, and household income, and it also declines over time. DOE 

estimated shipments in each standards case using the relative price elasticity along with the 

change in the relative price between a standards case and the base case. 

For details on the shipments analysis, see chapter 9 of the direct final rule TSD. 

2. Forecasted Efficiency in the Base Case and Standards Cases 

A key component of the NIA is the trend in energy efficiency forecasted for the base case 

(without new or amended standards) and each of the standards cases. Section IV.F.10 described 

how DOE developed a base-case energy efficiency distribution (which yields a shipmentweighted average efficiency) for each of the considered product classes for the first year of the 

229 
 

 

 

 

 

 

 

 

forecast period. To project the trend in efficiency over the entire forecast period, DOE 

considered recent trends and programs such as ENERGY STAR. For clothes dryers, DOE 

assumed no improvement of energy efficiency in the base case and held the base-case energy 

efficiency distribution constant throughout the forecast period. For room air conditioners, DOE 

applied a constant growth rate of energy efficiency of 0.25 percent per year, based on historical 

trends of penetration of ENERGY STAR products. 

To estimate efficiency trends in the standards cases, DOE has used “roll-up” and/or 

“shift” scenarios in its standards rulemakings. Under the roll-up scenario, DOE assumes: (1) 

product efficiencies in the base case that do not meet the standard level under consideration 

would roll-up to meet the new standard level; and (2) product efficiencies above the standard 

level under consideration would not be affected. Under the shift scenario, DOE re-orients the 

distribution above the new minimum energy conservation standard. 

In the preliminary analysis, DOE used a roll-up scenario in developing its forecasts of 

efficiency trends in the standards cases. The California Utilities stated that DOE should consider 

a “roll-up and market shift” scenario for room air conditioners in standards cases because, if the 

ENERGY STAR level is revised above the new standard, it may create a market incentive that 

increases the share of higher efficiency products. (California Utilities, No. 31 at p. 19) 

DOE agrees that amended standards for room air conditioners would likely result in 

changes to ENERGY STAR levels that would increase the share of products with energy 

efficiency above the standard based on the historical data reviewed for room air conditioners. 

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Therefore, for the final rule analysis, DOE applied a “roll-up and shift” scenario that accounts for 

such increase in share. For clothes dryers, DOE retained the approach used in the preliminary 

analysis for the final rule. For further details about the forecasted efficiency distributions, see 

chapter 10 of the direct final rule TSD. 

3. National Energy Savings 

For each year in the forecast period, DOE calculates the NES for each standard level by 

multiplying the stock of equipment affected by the energy conservation standards by the per-unit 

annual energy savings. As discussed in section IV.E, DOE incorporated the rebound effect 

utilized in the energy use analysis into its calculation of national energy savings for room air 

conditioners. 

To estimate the national energy savings expected from appliance standards, DOE uses a 

multiplicative factor to convert site energy consumption (at the home or commercial building) 

into primary or source energy consumption (the energy required to convert and deliver the site 

energy). These conversion factors account for the energy used at power plants to generate 

electricity and losses in transmission and distribution, as well as for natural gas losses from 

pipeline leakage and energy used for pumping. For electricity, the conversion factors vary over 

time due to projected changes in generation sources (that is, the power plant types projected to 

provide electricity to the country). The factors that DOE developed are marginal values, which 

represent the response of the system to an incremental decrease in consumption associated with 

appliance standards. 

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In the preliminary analysis, DOE used annual site-to-source conversion factors based on 

the version of NEMS that corresponds to AEO2009. For today’s rule, DOE updated its 

conversion factors based on the NEMS that corresponds to AEO2010, which provides energy 

forecasts through 2035. For 2036–2043, DOE used conversion factors that remain constant at the 

2035 values. 

Section 1802 of the Energy Policy Act of 2005 (EPACT 2005) directed DOE to contract 

a study with the National Academy of Science (NAS) to examine whether the goals of energy 

efficiency standards are best served by measurement of energy consumed, and efficiency 

improvements, at the actual point-of-use or through the use of the full-fuel-cycle, beginning at 

the source of energy production. (Pub. L. No. 109-58 (August 8, 2005)). NAS appointed a 

committee on “Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy Efficiency 

Standards” to conduct the study, which was completed in May 2009. The NAS committee 

defined full-fuel-cycle energy consumption as including, in addition to site energy use, the 

following: energy consumed in the extraction, processing, and transport of primary fuels such as 

coal, oil, and natural gas; energy losses in thermal combustion in power generation plants; and 

50 energy losses in transmission and distribution to homes and commercial buildings.

In evaluating the merits of using point-of-use and full-fuel-cycle measures, the NAS 

committee noted that DOE uses what the committee referred to as “extended site” energy 

consumption to assess the impact of energy use on the economy, energy security, and 

environmental quality. The extended site measure of energy consumption includes the energy 

50 The National Academies, Board on Energy and Environmental Systems, Letter to Dr. John Mizroch, Acting 

Assistant Secretary, U.S. DOE, Office of EERE from James W. Dally, Chair, Committee on Point-of-Use and FullFuel-Cycle Measurement Approaches to Energy Efficiency Standards, May 15, 2009. 

232 
 

 

 

 

consumed during the generation, transmission, and distribution of electricity but, unlike the fullfuel-cycle measure, does not include the energy consumed in extracting, processing, and 

transporting primary fuels. A majority of the NAS committee concluded that extended site 

energy consumption understates the total energy consumed to make an appliance operational at 

the site. As a result, the NAS committee recommended that DOE consider shifting its analytical 

approach over time to use a full-fuel-cycle measure of energy consumption when assessing 

national and environmental impacts, especially with respect to the calculation of greenhouse gas 

emissions. The NAS committee also recommended that DOE provide more comprehensive 

information to the public through labels and other means, such as an enhanced website. For those 

appliances that use multiple fuels (such as water heaters), the NAS committee indicated that 

measuring full-fuel-cycle energy consumption would provide a more complete picture of energy 

consumed and permit comparisons across many different appliances, as well as an improved 

assessment of impacts. 

In response to the NAS committee recommendations, DOE issued, on August 20, 2010 a 

Notice of Proposed Policy proposing to incorporate a full-fuel cycle analysis into the methods it 

uses to estimate the likely impacts of energy conservation standards on energy use and 

emissions. FR 75 51423. Specifically, DOE proposed to use full-fuel-cycle (FFC) measures of 

energy and greenhouse gas (GHG) emissions, rather than the primary (extended site) energy 

measures it currently uses. Additionally, DOE proposed to work collaboratively with the Federal 

Trade Commission (FTC) to make FFC energy and GHG emissions data available to the public 

th to enable consumers to make cross-class comparisons. On October 7 , DOE held an informal 

public meeting to discuss and receive comments on its planned approach. The Notice, a 

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transcript of the public meeting and all public comments received by DOE are available at: 

http://www.regulations.gov/search/Regs/home.html#docketDetail?R=EERE-2010-BT-NOA0028. DOE intends to develop a final policy statement on these subjects and then take steps to 

begin implementing that policy in future rulemakings and other activities. 

4. Net Present Value of Consumer Benefit 

The inputs for determining the NPV of the total costs and benefits experienced by 

consumers of the considered appliances are: (1) total annual installed cost, (2) total annual 

savings in operating costs, and (3) a discount factor. DOE calculates net savings each year as the 

difference between the base case and each standards case in total savings in operating costs and 

total increases in installed costs. DOE calculates operating cost savings over the life of each 

product shipped in the forecast period. 

DOE multiplies the net savings in future years by a discount factor to determine their 

present value. For the preliminary analysis and today’s final rule, DOE estimated the NPV of 

appliance consumer benefits using both a 3-percent and a 7-percent real discount rate. DOE uses 

these discount rates in accordance with guidance provided by the Office of Management and 

51 Budget (OMB) to Federal agencies on the development of regulatory analysis. The 7-percent 

real value is an estimate of the average before-tax rate of return to private capital in the U.S. 

economy. The 3-percent real value represents the “societal rate of time preference,” which is the 

rate at which society discounts future consumption flows to their present value. 

51 OMB Circular A-4 (Sept. 17, 2003), section E, “Identifying and Measuring Benefits and Costs. Available at: 

http://www.whitehouse.gov/omb/memoranda/m03-21.html. 

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As noted above, DOE is accounting for the rebound effect associated with more efficient 

room air conditioners in its determination of national energy savings. The take-back in energy 

consumption associated with the rebound effect provides consumers with increased value (that 

is, a cooler or warmer indoor environment). The net impact on consumers is thus the sum of the 

change in the cost of owning the room air conditioner (that is, life-cycle cost) and the increased 

value for the more comfortable indoor environment. The consumer effectively pays for the 

increased value of a more comfortable environment in his or her utility bill. Because the 

monetary cost of this added value is equivalent to the value of the foregone energy savings, the 

economic impacts on consumers, as measured in the NPV are the same regardless of the rebound 

effect. 

5. Benefits from Effects of Standards on Energy Prices 

Reduction in electricity consumption associated with amended standards for clothes 

dryers and room air conditioners could reduce the electricity prices charged to consumers in all 

sectors of the economy and thereby reduce their electricity expenditures. In chapter 2 of the 

preliminary TSD, DOE explained that, because the power industry is a complex mix of fuel and 

equipment suppliers, electricity producers and distributors, it did not plan to estimate the value of 

potentially reduced electricity costs for all consumers associated with amended standards for 

refrigeration products. In response, NEEP urged DOE to quantify electricity demand reductions 

achieved by these updated standards in financial terms. (NEEP, No. 27 at p. 1) 

For this rule, DOE used NEMS-BT to assess the impacts of the reduced need for new 

electric power plants and infrastructure projected to result from standards. In NEMS-BT, 

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changes in power generation infrastructure affect utility revenue requirements, which in turn 

affect electricity prices. DOE estimated the impact on electricity prices associated with each 

considered TSL. Although the aggregate benefits for electricity users are potentially large, there 

may be negative effects on some of the actors involved in electricity supply, particularly power 

plant providers and fuel suppliers. Because there is uncertainty about the extent to which the 

benefits for electricity users from reduced electricity prices would be a transfer from actors 

involved in electricity supply to electricity consumers, DOE has concluded that, at present, it 

should not give a heavy weight to this factor in its consideration of the economic justification of 

new or amended standards. DOE is continuing to investigate the extent to which electricity price 

changes projected to result from standards represent a net gain to society. 

H. Consumer Subgroup Analysis 

In analyzing the potential impact of new or amended standards on consumers, DOE 

evaluates the impact on identifiable subgroups of consumers (such as low-income households) 

that may be disproportionately affected by a national standard. DOE evaluates impacts on 

particular subgroups of consumers primarily by analyzing the LCC impacts and PBP for those 

particular consumers from alternative standard levels. For this rule, DOE analyzed the impacts of 

the considered standard levels on low-income consumers and senior citizens. Section V.B.1.b 

summarizes the results of the consumer subgroup analysis, and chapter 11 in the direct final rule 

TSD describes the analysis method. 

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I. Manufacturer Impact Analysis 

The following sections address the various steps taken to analyze the impacts of the 

amended standards on manufacturers. These steps include conducting a series of analyses, 

interviewing manufacturers, and evaluating the comments received from interested parties during 

this rulemaking. 

1. Overview 

In determining whether an amended energy conservation standard for residential clothes 

dryers and room air conditioners subject to this rulemaking is economically justified, DOE is 

required to consider “the economic impact of the standard on the manufacturers and on the 

consumers of the products subject to such standard.” (42 U.S.C. 6295(o)(2)(B)(i)(I)) The statute 

also calls for an assessment of the impact of any lessening of competition as determined by the 

Attorney General that is likely to result from the adoption of a standard. (42 U.S.C. 

6295(o)(2)(B)(i)(V)) DOE conducted the MIA to estimate the financial impact of amended 

energy conservation standards on manufacturers of clothes dryers and room air conditioners, and 

to assess the impacts of such standards on employment and manufacturing capacity. 

The MIA is both a quantitative and qualitative analysis. The quantitative part of the MIA 

relies on the Government Regulatory Impact Model (GRIM), an industry cash-flow model 

customized for the clothes dryer and room air conditioners covered in this rulemaking. See 

section IV.I.2 below, for details on the GRIM analysis. The qualitative part of the MIA addresses 

factors such as product characteristics, characteristics of particular firms, and market trends. The 

qualitative discussion also includes an assessment of the impacts of standards on manufacturer 

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subgroups. The complete MIA is discussed in chapter 12 of the direct final rule TSD. DOE 

conducted the MIA in the three phases described below. 

a. Phase 1, Industry Profile 

In Phase 1 of the MIA, DOE prepared a profile of the clothes dryers and room air 

conditioner industries based on the market and technology assessment prepared for this 

rulemaking. Before initiating the detailed impact studies, DOE collected information on the 

present and past structure and market characteristics of each industry. This information included 

market share data, product shipments, manufacturer markups, and the cost structure for various 

manufacturers. The industry profile includes: (1) further detail on the overall market and product 

characteristics; (2) estimated manufacturer market shares; (3) financial parameters such as net 

plant, property, and equipment; selling, general and administrative (SG&A) expenses; cost of 

goods sold, and other similar information; and (4) trends in the number of firms, market, and 

product characteristics. The industry profile included a top-down cost analysis of manufacturers 

in each industry that DOE used to derive preliminary financial inputs for the GRIM (such as 

revenues, depreciation, SG&A, and research and development (R&D) expenses). DOE also used 

public sources of information to further calibrate its initial characterization of each industry, 

52 53 including Security and Exchange Commission 10–K filings, Standard & Poor’s stock reports,

and corporate annual reports. DOE supplemented this public information with data released by 

privately held companies. 

52 Available online at http://www.sec.gov.
 53 Available online at http://www2.standardandpoors.com.
 

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b. Phase 2, Industry Cash Flow Analysis 

Phase 2 focused on the financial impacts of potential amended energy conservation 

standards on each industry as a whole. Amended energy conservation standards can affect 

manufacturer cash flows in three distinct ways: (1) by creating a need for increased investment, 

(2) by raising production costs per unit, and (3) by altering revenue due to higher per-unit prices 

and/or possible changes in sales volumes. DOE used the GRIMs to perform two cash-flow 

analyses: one for the clothes dryers industry and one for room air conditioners. In performing 

these analyses, DOE used the financial values derived during Phase 1 and the shipment 

assumptions from the NIA. 

c. Phase 3, Sub-Group Impact Analysis 

Using average cost assumptions to develop an industry-cash-flow estimate may not 

adequately assess differential impacts of amended energy conservation standards among 

manufacturer subgroups. For example, small manufacturers, niche players, or manufacturers 

exhibiting a cost structure that differs significantly from the industry average could be more 

negatively affected. To address this possible impact, DOE used the results of the industry 

characterization analysis in Phase 1 to group manufacturers that exhibit similar production and 

cost structure characteristics. During the manufacturer interviews, DOE discussed financial 

topics specific to each manufacturer and obtained each manufacturer’s view of the industry as a 

whole. 

DOE reports the MIA impacts of amended energy conservation standards by grouping 

together the impacts on manufacturers of certain product classes. While DOE did not identify 

239 
 

 

 

 

 

 

 

 

 

any other subgroup of manufacturers of clothes dryers or room air conditioners that would 

warrant a separate analysis, DOE specifically investigated impacts on small business 

manufacturers. See section VI.B for more information. 

2. GRIM Analysis 

DOE uses the GRIM to quantify the changes in cash flow that result in a higher or lower 

industry value. The GRIM analysis is a standard, annual cash-flow analysis that incorporates 

manufacturer costs, manufacturer selling prices, shipments, and industry financial information as 

inputs, and models changes in costs, distribution of shipments, investments, and manufacturer 

margins that would result from amended energy conservation standards. The GRIM spreadsheet 

uses the inputs to arrive at a series of annual cash flows, beginning with the base year of the 

analysis, 2011 (which accounts for the investments needed to bring products into compliance by 

2014), and continuing to 2043. DOE calculated INPVs by summing the stream of annual 

discounted cash flows during this period. For clothes dryers and room air conditioners, DOE uses 

a real discount rate of 7.2 percent for all products. 

DOE used the GRIM to calculate cash flows using standard accounting principles and to 

compare changes in INPV between a base case and various TSLs (the standards cases). The 

difference in INPV between the base and standards cases represents the financial impact of the 

amended standard on manufacturers. DOE collected this information from a number of sources, 

including publicly available data and interviews with a number of manufacturers (described in 

the next section). Additional details about the GRIM can be found in chapter 12 of the direct 

final rule TSD. 

240 
 

 

 

 

 

 

 

 

 

a. GRIM Key Inputs 

Manufacturer Production Costs 

DOE used the manufacturer production costs (MPCs) calculated in the engineering 

analysis for each efficiency level for the year 2009, as described in section IV.C above, and 

further detailed in chapter 5 of the direct final rule TSD. For both clothes dryers and room air 

conditioners, DOE calculated the 2009 MPCs using cost models based on product tear downs. 

The cost models also provide a breakdown of MPCs into material, labor, overhead, and 

depreciation. Manufacturing a higher-efficiency product is typically more expensive than 

manufacturing a baseline product due to the use of more complex components and higher-cost 

raw materials. The changes in the MPCs of the analyzed products can affect revenues, gross 

margins, and cash flow of the industry, making these product cost data key GRIM inputs for 

DOE’s analysis. 

Base-Case Shipments Forecast 

The GRIM estimates manufacturer revenues based on total unit shipment forecasts and 

the distribution of these values by efficiency level. Changes in the efficiency mix at each 

standard level affect manufacturer finances. For this analysis, the GRIM uses the NIA shipments 

forecasts from 2011 to 2043, the end of the analysis period. 

In the shipments analysis, DOE also estimated the distribution of efficiencies in the base 

case for all product classes. For clothes dryers, DOE held the base-case energy efficiency 

distribution constant throughout the forecast period. For the room air conditioner industry, DOE 

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assumed a migration of the market toward higher efficiency over time. See section IV.G.1, 

above, for additional details. 

Product and Capital Conversion Costs 

Amended energy conservation standards will cause manufacturers to incur conversion 

costs to bring their production facilities and product designs into compliance. For the MIA, DOE 

classified these costs into two major groups: (1) product conversion costs and (2) capital 

conversion costs. Product conversion costs are investments in research, development, testing, 

marketing, and other non-capitalized costs focused on making product designs comply with the 

amended energy conservation standard. Capital conversion costs are investments in property, 

plant, and equipment to adapt or change existing production facilities so that new product 

designs can be fabricated and assembled. 

For both clothes dryers and room air conditioners, DOE based its conversion cost 

estimates that would be required to meet each TSL on information obtained from manufacturer 

interviews, the design pathways analyzed in the engineering analysis, and market information 

about the number of products that would require modification at each efficiency level. Because 

no energy label is currently prescribed for clothes dryers, and because clothes dryers are not part 

of the ENERGY STAR program, the best source of clothes dryer efficiency information is the 

CEC product database. DOE segmented each product on the CEC website into its appropriate 

product class using energy source, drum capacity, voltage, and combination unit information. 

DOE then searched manufacturer websites and numerous retail websites to determine which 

clothes dryers were current products. DOE assigned each product currently produced into 

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efficiency levels using the reported energy factor. Finally, DOE assigned each of these products 

into product lines, classifying each group of products made by same manufacturer with identical 

drum capacities and energy factors into the same product line. 

DOE calculated the product and capital conversion costs at each efficiency level for 

every product class by multiplying the total number of product lines that fell below the required 

efficiency by an estimate of the conversion costs to reach that efficiency level. DOE calculated 

the total product development required at each efficiency level by estimating the necessary 

engineering resources required to implement the design options in the engineering analysis at the 

efficiency level across a product line. DOE calculated the total capital conversion costs required 

at each efficiency level by estimating the additional equipment and changes to existing 

equipment that would be required to implement the design option in the engineering analysis at 

that efficiency level across a product line. 

While DOE’s calculation of conversion costs for room air conditioners was similar to the 

calculation of conversion costs for clothes dryers, DOE used a slightly different approach to 

determine the number of product lines at each efficiency level. DOE used the CEC appliance 

database to determine what models currently exist on the market for room air conditioners and 

verified these current products through manufacturer and retail websites. DOE eliminated 

products in the database that were discontinued due to the recent refrigerant switch to R-410A. 

DOE segmented each product from the CEC database into its appropriate product class using 

cooling capacity, the existence of louvers, and type of room air conditioner. DOE assigned each 

product currently produced into efficiency levels using the reported EER. Finally, DOE 

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determined a representative distribution of the industry by extrapolating the information for 

manufacturers for which it had complete efficiency information to account for the product lines 

of all manufacturers. 

Like its method for clothes dryers, DOE calculated the industry wide conversion costs by 

multiplying the number of product lines in each product class that fell below the required 

efficiency by its estimate of the product and capital conversion costs. DOE’s estimate was based 

on the design options at each efficiency level in the engineering analysis. DOE’s per line product 

conversion costs were calculated by estimating the product development time required to make 

the design change across a product family. For component switch outs, DOE assumed that design 

changes for components that interacted with other parts of the room air conditioner would be 

more costly than one-for-one switch outs because these components would require greater 

engineering effort to be adapted into new product designs. For capital conversion costs, DOE 

assumed based on manufacturer feedback that the only design changes that would require 

changes to existing equipment were larger chassis volumes, evaporator changes, and condenser 

changes. 

DOE’s estimates of the total capital conversion and production conversion costs for 

clothes dryer and room air conditioners by TSL can be found in section V.B.2 of today’s direct 

final rule. The estimates of the total capital conversion and product conversion costs by product 

class and efficiency level can be found in chapter 12 of the direct final rule TSD. 

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b. GRIM Scenarios 

Clothes Dryer Standards-Case Shipment Forecasts 

The GRIM used the shipments developed in the NIA for clothes dryers. To determine 

efficiency distributions for the standards case, DOE used a roll-up scenario. In this scenario, 

products that fall below the amended energy conservation standard are assumed to “roll-up” to 

the new standard in 2014. DOE also assumed there was a relative price elasticity in the clothes 

dryers market, meaning amended energy conservation standards that increase the first cost of 

clothes dryers would result in lower total shipments. See section IV.G.1 of this direct final rule, 

and chapter 10 of the direct final rule TSD for more information on the clothes dryer standardscase shipment scenarios. 

Room Air Conditioner Standards-Case Shipment Forecasts 

The GRIM used the shipments developed in the NIA for room air conditioners. As stated 

in IV.I.2.a, the base case shipments assume that there is a migration over time to more efficient 

products based on historical trends of penetration of ENERGY STAR products. In the standards 

case, DOE used a “roll-up + shift” scenario. In this scenario, DOE assumed that amended 

standards for room air conditioners would likely result in changes to ENERGY STAR levels that 

would increase the share of products with energy efficiency above the standard. DOE also 

assumed there was a relative price elasticity in the room air conditioner market, meaning that 

amended energy conservation standards that increase the first cost of room air conditioners 

would result in lower total shipments. See section IV.G.1 of this direct final rule and chapter 10 

of the direct final rule TSD for more information on the room air conditioner standards-case 

shipment scenarios. 

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Markup Scenarios 

In the GRIM, DOE used the MSPs calculated in the engineering analysis for each product 

class and efficiency level. MSPs include direct manufacturing production costs (that is, labor, 

material, and overhead estimated in DOE’s MPCs) and all non-production costs (that is, SG&A, 

R&D, and interest), along with profit. For clothes dryers, DOE did not separate shipping costs 

from the manufacturer markup because shipping costs are not a function of the design options 

analyzed. The MSP for clothes dryers is equal to the MPC times the manufacturer markup. For 

room air conditioners, DOE separated the shipping costs from the markup multiplier for the 

analysis to explicitly account for the design options that would result in higher shipping costs 

due to weight increases. DOE calculated the MSP for room air conditioners by multiplying the 

MPC by the manufacturer markup and adding shipping costs. 

For the MIA, DOE modeled two standards-case markup scenarios to represent the 

uncertainty regarding the potential impacts on prices and profitability for manufacturers 

following the implementation of amended energy conservation standards: (1) a flat markup 

scenario, and (2) a preservation of operation profit scenario. Modifying these markups from the 

base case to the standards cases yields different sets of impacts on manufacturers’ changing 

industry revenue and cash flow. 

The flat markup scenario assumes that the cost of goods sold for each product is marked 

up by a flat percentage to cover standard SG&A expenses, R&D expenses, and profit. The flat 

markup scenario uses the baseline manufacturer markup (discussed in chapter 6 of the direct 

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final rule TSD) for all products in both the base case and the standards case. To derive this 

percentage, DOE evaluated publicly available financial information for manufacturers of major 

household appliances whose product offerings include clothes dryers and room air conditioners. 

DOE also requested feedback on this value during manufacturer interviews. This scenario 

represents the upper bound of industry profitability in the standards case because under this 

scenario, manufacturers are able to fully pass through additional costs due to standards to their 

customers. 

DOE also modeled a lower bound profitability scenario. In this scenario, the 

manufacturer markups are lowered such that, in the standards case, manufacturers are able to 

maintain only the base-case total operating profit in absolute dollars, despite higher product costs 

and investment. DOE implemented this scenario in GRIM by lowering the manufacturer 

markups at each TSL to yield approximately the same earnings before interest and taxes in the 

standards case in the year after the compliance date of the amended standards as in the base case. 

For clothes dryers in the preservation of operating profit scenario, DOE assumed that the 

industry wide impacts would occur under the new minimum efficiency levels. DOE altered the 

markups only for the minimally compliant products in this scenario, with margin impacts not 

occurring for products that already exceed the amended energy conservation standard. For room 

air conditioners, DOE assumed that the margin impacts would affect the minimally compliant 

products at the amended energy conservation standards and the next highest efficiency level. The 

NIA analyzed an efficiency migration in both the base case and the standards case due to the 

assumption that manufacturers will produce increasingly more efficient room air conditioners as 

ENERGY STAR levels for these products change over time. Therefore, under amended energy 

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conservation standards the shipment weighted average efficiency increases from the new 

minimum standard to higher efficiency levels. DOE assumed this market shift caused by 

standards would impact margins on products that also become the de facto minimally efficient 

product over time. For both clothes dryers and room air conditioners, the preservation of 

operating profit represents the lower bound of industry profitability following amended energy 

conservation standards because under this scenario, higher production costs and the investments 

required to comply with the amended energy conservation standard do not yield additional 

operating profit. 

While DOE used the same markup scenarios for clothes dryers and room air conditioners, 

DOE captured different concerns for each industry by modeling the preservation of operating 

profit scenario. For clothes dryers, manufacturers were particularly concerned about the inability 

to markup the full cost of production. Because there is currently no energy label requirement or 

ENERGY STAR program for clothes dryers, the lack of consumer information makes it more 

difficult for customers to calculate individual payback and energy savings. Consequently, the 

manufacturing cost for more efficient clothes dryers could not be fully marked up because 

energy efficiency, unlike price and other features, is not a factor in the purchasing decision of 

most consumers. Manufacturers also cited the highly competitive market, the concentrated retail 

market that represents the majority of sales, and price points that are fixed partly by paired 

washing machines as other reasons that additional production costs would not yield higher 

profits in the standards case. For room air conditioners, manufacturers stated that higher 

production costs could severely harm profitability. Manufacturers already earn very little profit 

on the small, high-volume window units due to the enormous price pressure retailers exert 

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because of their purchasing power, and due to fierce competition within the room air conditioner 

industry. Manufacturers accept lower absolute profit on these units with the expectation of 

making a larger per unit profit on other more costly products. They also do so because 

maintaining high production volumes of these units allows manufacturers to keep factories 

utilized and to achieve purchasing economies. In addition, because many purchases are impulse 

buys during periods of atypically warm weather for products that are used sparingly, any 

increase in first cost could impact these types of sales. Therefore, manufacturers were skeptical 

that customers would accept the full additional cost of production. 

3. Discussion of Comments 

During the March 2010 public meeting, interested parties commented on the assumptions 

and results of the manufacturer impacts presented in the preliminary analysis. Oral and written 

comments discussed several topics, including the classification of small business manufacturers, 

the cumulative regulatory burden on manufacturers, the impact of R-410A conversion, and direct 

employment impacts. DOE addresses these comments below. 

a. Small Businesses 

In the preliminary analysis, DOE stated it did not identify any small business 

manufacturers of residential clothes dryers but that it did identify at least one room air 

conditioner manufacturer that was designated as a small business by the U.S. Small Business 

Administration criteria. DOE requested comment on this assertion. AHAM stated that it agreed 

with DOE’s assessment regarding the number of small businesses for room air conditioners and 

clothes dryers. (AHAM, No. 25 at p. 12) Whirlpool similarly stated that it did not know of any 

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qualifying small businesses for residential clothes dryers. (Whirlpool, No. 22 at p. 4) HTC, 

however, stated that it is a small business registered under the Central Contracting Registration 

and the appropriate NAICS code for the residential clothes dryers covered by this rulemaking 

(335224 – household laundry equipment manufacturers). HTC requested consideration by DOE 

as a small business and asserted that it would be negatively impacted if DOE decided not to 

include its technologies in the standards for residential clothes dryers (HTC, No. FDMS DRAFT 

0068 at pp. 6, 10) 

For clothes dryers, DOE notes that it could not locate HTC as a small business on the 

SBA website (http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm) or under the Central Contracting 

Registration (https://www.bpn.gov/CCRSearch/Search.aspx). DOE does not question HTC’s 

assertion that it is a small business, but DOE does not believe that HTC would be directly 

impacted by this rule. HTC has developed a technology that can be incorporated into clothes 

dryers. DOE acknowledges in section IV.A.5.a that HTC’s technology is a potential design 

option but also notes this technology is not commercially available. DOE does not believe this 

rulemaking would affect HTC’s ability to commercialize or sell its technology. Therefore, DOE 

does not believe HTC will be impacted by this rulemaking. 

For room air conditioners, DOE amends its conclusion of the number of small 

manufacturers in today’s direct final rule. The one manufacturer previously identified by DOE as 

a small business was since acquired by a company and exceeds the 750-employee threshold 

under NAICS code 333415 (air conditioning and warm air heating equipment manufacturers and 

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commercial and industrial refrigeration equipment manufacturers). As such, DOE believes there 

are no qualifying small business manufacturers in the room air conditioner industry. 

For more information on the potential impact on small business manufacturers, see 

section VI.B. 

b. Cumulative Regulatory Burden 

Several interested parties responded to DOE’s request for comment during the 

preliminary analysis period on regulations that could impose a burden on manufacturers of 

clothes dryers and room air conditioners. BSH stated that DOE should consider potential 

greenhouse gas regulations and the EPA ban on hydrochlorofluorocarbon (HCFC) refrigerants in 

new products since these regulations are relevant for heat pump clothes dryers. (BSH, No. 23 at 

p. 5) In contrast, NPCC stated that DOE should not include the cost of converting to alternative 

refrigerants such as R-410A in its manufacturer impact analysis for room air conditioners since 

the HCFC ban has already taken effect. (NPCC, No. 32 at p. 4) 

DOE acknowledges that the phase-out of hydrofluorocarbons (HFC) or similar 

refrigerants could necessitate changes to heat pump clothes dryers if current products offered on 

the market have to be redesigned. DOE also notes that the most efficient electric clothes dryers 

on the U.S. market today do not use heat pump technology, so a change in the available 

refrigerants would not currently impact products on the U.S. market. Because heat pump 

technology passed the screening criteria, it is analyzed as in technology that could increase the 

efficiency of residential clothes dryers DOE has analyzed heat pump clothes dryers as the max251 
 

 

 

 

 

 

 

 

 

 

 

 

tech units for electric clothes dryer product classes. In its engineering analysis for these relevant 

product classes, DOE assumed that these products would utilize refrigerants that are currently 

available on the market. However, DOE does not include the impacts of a potential change in 

available refrigerant for heat pump clothes dryers because it would be speculative to predict the 

passage of legislation or the outcome of future rulemakings that would alter available 

refrigerants. 

In response to the inclusion of the ban on HCFC refrigerants, DOE notes that the ban is 

relevant to both heat pump clothes dryer manufactures and room air conditioner manufacturers. 

The ban on R-22 became effective on January 1, 2010, so all products currently produced must 

comply with this regulation. This ban, which required manufacturers to cease using virgin R-22 

in new equipment, necessitated substantial product design changes and capital investments. DOE 

accounts for these design changes in its engineering analysis by basing its analysis for room air 

conditioners on the use of R-410A refrigerant, as described in section IV.C.2.b. This allows DOE 

to capture the impacts of the refrigerant change on product cost and efficiency. 

The ban also caused manufacturers to incur significant product and capital conversion 

costs. Manufacturers had to redesign units for new compressors and other new components and 

conduct extensive testing, and in some cases manufacturers devoted full-time engineering 

resources to this conversion for up to 2 years. Additionally, manufacturers had to purchase new 

heat exchanger equipment and make other capital investments. DOE did not include the costs of 

converting to alternative refrigerants in the GRIM because these changes were not driven by the 

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standards established in today’s final rule. DOE describes the HCFC ban in further detail as part 

of the cumulative regulatory burden in chapter 12 of the direct final rule TSD. 

Several manufacturers also responded to DOE’s request for comment on the UL fire 

safety regulation for clothes dryers. Whirlpool stated that this regulation has no effect on energy 

efficiency, but added that DOE should include it as a regulatory burden. (Whirlpool, No. 22 at p. 

2) BSH noted that the regulation takes effect in 2013. (BSH, No. 23 at p. 6) ALS speculated that 

each clothes dryer manufacturer will have its own concerns about this regulation and its impacts. 

(ALS, Public Meeting Transcript, No. 21.4 at p. 154) HTC stated that it has successfully passed 

UL 2158 safety guidelines for electric clothes dryers and requested consideration of this 

compliance. (HTC, No. FDMS DRAFT 0068 at p. 7) 

DOE appreciates this input on the UL fire safety regulations for clothes dryers. While 

DOE did not receive enough information to calculate the cost of changes to baseline clothes 

dryers to comply with UL 2158 in the engineering analysis, DOE agrees with Whirlpool that this 

regulation would not impact energy efficiency and consequently would not change the 

incremental costs calculated in the engineering analysis. While the UL 2158 is not a Federal 

regulation, UL certification is a de facto requirement for selling products in the U.S. because of 

local building codes requiring all installed products meet safety regulations and to avoid 

litigation. DOE included the conversion costs for manufacturers to comply with UL 2158 as part 

of the cumulative regulatory burden. 

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Additional information on the cumulative regulatory burden on clothes dryer and room 

air conditioner manufacturers is included in chapter 12 of the direct final rule TSD, including 

details on how DOE treated the conversion costs for the UL 2158 regulation. 

c. Employment Impacts 

Two interested parties commented on DOE’s characterization of the domestic 

employment impacts for room air conditioner manufacturers. EEI stated that if DOE concluded 

no room air conditioner production remains in the United States, there should be no domestic 

impacts on employment. EEI stated that further analysis may be necessary to capture impacts on 

these manufacturers. (EEI, Public Meeting Transcript, No. 21.4 at pp. 31–34) To follow up on 

this issue, GE stated that revenue from non-domestic manufacturing helps fund the R&D and 

domestic production of other products that room air conditioner manufacturers produce. 

Therefore, the effects of room air conditioner manufacturing spill over into other industries. (GE, 

Public Meeting Transcript, No. 21.4 at p. 33–34) 

DOE’s direct employment impact assessment focuses on domestic employment impacts. 

These employment impacts are calculated in the GRIM based on the domestic expenditures and 

labor content of room air conditioner production. Because all room air conditioners are 

manufactured abroad, any change in labor content resulting from amended standards would 

impact labor requirements in non-domestic facilities and would not be quantified in DOE’s direct 

employment impact assessment. While many room air conditioner manufacturers produce other 

products and a company’s revenues in one industry may impact its overall revenues and 

operations, DOE does not analyze spillover effects among different business segments in its 

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direct employment impact assessment. DOE does analyze indirect employment impacts in the 

domestic economy in section IV.J. 

4. Manufacturer Interviews 

DOE interviewed manufacturers representing more than 90 percent of clothes dryer sales 

and approximately 50 percent of room air conditioner sales. These interviews were in addition to 

those DOE conducted as part of the engineering analysis. DOE used these interviews to tailor the 

GRIM to incorporate unique financial characteristics for each industry. All interviews provided 

information that DOE used to evaluate the impacts of potential amended energy conservation 

standards on manufacturer cash flows, manufacturing capacities, and employment levels. See 

appendix 12-A of the direct final rule TSD for additional information on the MIA interviews. 

The following sections describe the most significant issues identified by manufacturers. 

a. Clothes Dryer Key Issues 

Test Procedure 

Manufacturers indicated that a key concern for this rulemaking was ensuring that the test 

procedure accurately measured actual energy use. In particular, manufacturers indicated that 

proposed changes to the RMC value and the average number of annual cycles needed to be 

updated. Manufacturers indicated that without these changes, consumers could be negatively 

impacted by amended energy conservation standards because clothes dryers have a limited 

number of improvements that would be cost effective for most consumers. 

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UL Fire Containment Standard 

Most manufacturers indicated that they had not fully investigated the exact technical 

changes that will be required to meet the UL fire containment regulation (UL 2158). However, 

manufacturers were concerned that this regulation would require changes to all their products 

around the same time that they would be required to meet amended energy conservation 

standard. Most manufacturers agreed that even if the exact approach of meeting UL 2158 is 

different or unknown by individual manufactures, DOE should still treat the regulation as an 

overall burden. 

Heat Pump Technology 

Manufacturers indicated that the high capital conversion and product conversion costs for 

clothes dryers at the second gap fill levels or the maximum available units were significant and 

would represent a substantial burden. Manufacturers also indicated that the pathways to meeting 

those levels, while potentially costly, were well-defined, proven in the market, and could be 

made within their existing production facilities. Manufacturers also indicated, however, that heat 

pump technology at the max-tech levels for electric product classes would represent a significant 

departure from current products and add significantly to the product and capital conversion costs. 

A heat pump standard would require a total renovation of existing facilities. The changes 

required to manufacture heat pumps would require revamping most existing production 

equipment and redesigning a new platform. The capital conversion costs would include 

equipment for new drum lines, assembly line testing equipment, stamping equipment for 

cabinets, and other production equipment to manufacturer the sealed systems. In addition to the 

large development costs to develop new platforms, manufacturers would have the additional 

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expense of developing the sealed system. Other increases to the product development costs for 

head pump clothes dryers that concerned manufacturers were the significant retraining costs for 

their servicers and the marketing costs to educate consumers and ensure they accept the new 

technology. With the substantial change that would be required to develop, manufacture, and 

educate consumers about heat pump clothes dryers, manufacturers were concerned they might 

not be able to make all the required changes with a 3-year lead time between the announcement 

of the final rule and the compliance date of the amended energy conservation. 

Manufacturers also indicated that an energy conservation standard at a level that 

effectively required a heat pump clothes dryer would force them to consider off-shoring any 

remaining production in the United States. Besides the significant capital and product conversion 

costs, manufacturers indicated that the much higher labor content of a heat pump clothes dryer 

would put additional pressure on moving production out of the United States. Finally, 

manufacturers believed that repair and maintenance costs would increase if an energy 

conservation standard effectively required heat pump clothes dryers. Repair and maintenance 

costs would increase due to the more expensive components, potential lint management 

problems, and some manufacturers’ inexperience with the technology. 

Impacts on Profitability 

Manufacturers indicated that an amended energy conservation standard would likely 

impact profits in the clothes dryer market. Because there is currently no energy label requirement 

and no ENERGY STAR program for clothes dryers, manufacturers indicated that, unlike clothes 

washers, efficiency does not command any premium in the market (either in percentage or 

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absolute terms). Because it is difficult to communicate any energy benefit to consumers, it is 

very unlikely that they could benefit from higher production costs caused by amended energy 

conservation standards. 

In addition, manufacturers indicated that the large incremental cost jumps at some of the 

higher efficiency levels, including heat pump clothes dryers, were unlikely to be fully passed on 

to their customers. Beside the inability to show the energy benefit of the products, manufacturers 

indicated that the concentrated number of players in the retail market would put pressure on all 

manufacturers to keep costs down in response to amended energy conservation standards. 

Manufacturers also indicated that many of their sales are from pairs of clothes washers and 

dryers that have similar price points. If the cost of clothes dryers increased, manufacturers felt 

that retailers would not accept any price increase to keep the retail prices of the matched pair 

similar. 

b. Room Air Conditioner Key Issues 

Impact on Manufacturer Profitability 

Several manufacturers stated that they expect amended energy conservation standards to 

negatively impact the profitability of room air conditioners. Higher component, tooling, and 

development costs for more efficient products would increase MPCs, but manufacturers believed 

these higher costs could not necessarily be passed on to consumers due to the nature of the 

industry. A few large retailers dominate the industry and exert downward pressure on prices. 

Retailers demand low prices because consumers have come to expect room air conditioners at 

particular price points. For example, consumers expect many product offerings of product class 1 

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for under $100, and retailers have successfully maintained that price point through competitive 

bidding. This has resulted in price pressure on the most popular units as manufacturers accept 

lower absolute profit on those units in the hopes of making a larger per unit profit on other more 

costly products. Many room air conditioner purchases are weather-dependent, so consumers 

could easily forgo the purchase of a room air conditioner unit altogether if prices increased. 

Consequently, manufacturers believed that cost increases would be at least partly absorbed by 

manufacturers to keep retail prices from rising sharply. 

If amended energy conservation standards led to a significant reduction in profitability, 

some manufacturers could exit the market (as a number of large players have in recent years). 

Many manufacturers source room air conditioner lines from overseas and do not own the 

production equipment. This arrangement would allow manufacturers to exit the industry without 

stranded assets. 

Impact on Product Utility 

Manufacturers believed a negative profitability impact could also indirectly affect 

product utility. Several manufacturers indicated that other features that do not affect efficiency 

could be removed or component quality could be sacrificed to meet amended standard levels and 

maintain product prices at levels that would be acceptable to consumers. 

Manufacturers also expressed concern that the energy savings from more stringent energy 

conservation standards would not be great enough to justify passing through the added costs to 

consumers. Currently, manufacturers bundle higher efficiency with other desirable features to 

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justify higher prices for ENERGY STAR models. According to manufacturers, if amended 

standards caused prices to increase, the lower operating costs would not justify higher prices 

because the energy savings would be low compared to the initial price of the unit. Therefore, the 

increased cost of meeting the amended efficiency requirements may cause manufacturers to 

reduce the number of features to retain a reasonable price point. 

The value of future ENERGY STAR levels is also a concern for manufacturers. Many 

retailers and other distribution channels require ENERGY STAR products. Because the features 

bundled with ENERGY STAR products are the selling point to consumers, manufacturers were 

concerned that a higher ENERGY STAR level after amended standards would result in products 

with fewer features. 

Manufacturers also stated that the financial burden of developing products to meet 

amended energy conservation standards has an opportunity cost due to limited capital and R&D 

dollars. Investments incurred to meet amended energy conservation standards reflect foregone 

investments in innovation and the development of new features that consumers value and on 

which manufacturers earn higher absolute profit. 

Component Availability 

Several manufacturers stated they were concerned about component availability. 

Compressor availability since the conversion to R-410A was the main problem cited by 

manufacturers. Some manufacturers stated that component suppliers do not give priority to room 

air conditioning because the market is exclusive to North America and smaller than some of the 

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other markets they supply. Since the conversion R-410A, manufacturers noted the total 

production capacity of compressor suppliers has not fully rebounded. In addition, compressor 

suppliers have yet to offer the same range of compressor capacities and efficiency tiers. 

Size Constraints 

A number of manufacturers expressed concerns about physical limitations of how large 

room air conditioners could grow. Most residential buildings have standardized window 

openings. Because a large portion of air conditioners are installed in these standardized openings, 

products must still fit in these typical windows after they have been redesigned. Manufacturers 

were largely concerned that the limited opportunity for growth also limited opportunities for 

efficiency improvements. Increasing the size of units also presents a problem for smaller air 

conditioners, which typically operate at under 10,000 Btu/hr. Much of the appeal of these units is 

that they can be lifted and installed by one person. Increasing the size of these units would 

greatly alter the market and may cause consumers to purchase less efficient portable airconditioning units. 

Manufacturers mentioned refrigerant charge as another reason why room air conditioners 

are constrained by size. If manufacturers used increased coil size and a smaller compressor 

capacity to improve efficiency, the larger heat exchangers combined with the reduced nominal 

compressor capacity could lead to a system refrigerant charge amount that exceeds the 

recommended level. Exceeding recommended charge levels could damage the compressor, 

thereby limiting the extent of efficiency improvements associated with coil size growth. To 

counteract the increase in charge levels, some manufacturers have used smaller tubing in their 

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heat exchangers. However, North American suppliers are not currently properly equipped to 

support smaller tube sizes and might not be willing to make the investment required to do so. 

Several manufacturers stated that size is also a concern because moving from a smaller 

chassis to larger chassis would cause material costs to increase dramatically due to more costly 

components and the potential capital costs required for development. If the adopted standards 

required significant rather than incremental increases in efficiency, the largest units in each 

capacity range would likely have to move to the next largest or a new chassis in order to meet the 

required efficiency levels. This is a notable concern for capacities above 28,000 Btu/hr because 

manufacturers could choose to no longer offer these product lines due to the conversion cost. 

Numerous manufacturers stated that size constraints pose a problem for non-louvered 

units in particular. Non-louvered units inherently have less room for efficiency improvement 

because they need to fit into the existing sleeves in buildings. They are also constrained by air 

flow, increasing the depth does not result in significant efficiency gains because air on the 

condenser side must still flow through the rear face. Additionally, increasing depth creates a 

product that is less aesthetically pleasing and could decrease the available space in the room. 

Product Switching 

Some manufacturers noted that higher consumer prices after an amended energy 

conservation standard could result in product switching along the upper capacity boundaries of a 

product class if efficiency requirements are not implemented proportionally across product 

classes. For example, if after energy conservation standards are amended the first cost of units in 

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product class 1 is not proportionally lower than units in product class 3, consumers who would 

have purchased product class 1 units are likely to purchase less efficient, slightly higher capacity 

units in product class 3. Without a significant price differential between product classes, 

consumers would be more likely to buy units with higher capacity, potentially lowering the 

calculated energy savings. 

J. Employment Impact Analysis 

DOE considers employment impacts in the domestic economy as one factor in selecting a 

proposed standard. Employment impacts consist of direct and indirect impacts. Direct 

employment impacts are any changes in the number of employees of manufacturers of the 

appliance products that are the subject of this rulemaking, their suppliers, and related service 

firms. Indirect employment impacts are changes in national employment that occur due to the 

shift in expenditures and capital investment caused by the purchase and operation of more 

efficient appliances. The MIA discussed above in Section IV.I. addresses the direct employment 

impacts that concern manufacturers of clothes dryers and room air conditioners. The 

employment impact analysis addresses the indirect employment impacts. 

Indirect employment impacts from standards consist of the net jobs created or eliminated 

in the national economy, other than in the manufacturing sector being regulated, due to: (1) 

reduced spending by end users on energy; (2) reduced spending on new energy supply by the 

utility industry; (3) increased spending on new products to which the new standards apply; and 

(4) the effects of those three factors throughout the economy. DOE expects the net monetary 

savings from standards to be redirected to other forms of economic activity. DOE also expects 

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these shifts in spending and economic activity to affect the demand for labor in the short term, as 

explained below. 

One method for assessing the possible effects on the demand for labor of such shifts in 

economic activity is to compare sectoral employment statistics developed by the Labor 

54 Department’s Bureau of Labor Statistics (BLS). The BLS regularly publishes its estimates of 

the number of jobs per million dollars of economic activity in different sectors of the economy, 

as well as the jobs created elsewhere in the economy by this same economic activity. Data from 

BLS indicate that expenditures in the utility sector generally create fewer jobs (both directly and 

indirectly) than expenditures in other sectors of the economy. There are many reasons for these 

differences, including wage differences and the fact that the utility sector is more capital 

intensive and less labor intensive than other sectors.55 

Energy conservation standards have the effect of reducing consumer utility bills. Because 

reduced consumer expenditures for energy likely lead to increased expenditures in other sectors 

of the economy, the general effect of efficiency standards is to shift economic activity from a 

less labor-intensive sector (i.e., the utility sector) to more labor-intensive sectors (e.g., the retail 

and service sectors). Thus, based on the BLS data alone, DOE believes net national employment 

will increase due to shifts in economic activity resulting from amended standards for clothes 

dryers and room air conditioners. 

54 Data on industry employment, hours, labor compensation, value of production, and the implicit price deflator for 

output for these industries are available upon request by calling the Division of Industry Productivity Studies (202­

691-5618) or by sending a request by e-mail to dipsweb@bls.gov. Available at: 

http://www.bls.gov/news.release/prin1.nr0.htm. 55 See: Bureau of Economic Analysis. Regional Multipliers: A User Handbook for the Regional Input-Output 

Modeling System (RIMS II). 1192. U.S. Department of Commerce: Washington, DC 

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For the standard levels considered in today’s direct final rule, DOE estimated indirect 

national employment impacts using an input/output model of the U.S. economy called Impact of 

Sector Energy Technologies (ImSET). ImSET is a spreadsheet model of the U.S. economy that 

focuses on 187 sectors most relevant to industrial, commercial, and residential building energy 

56 use. ImSET is a special purpose version of the “U.S. Benchmark National Input-Output” (I–O) 

model, which has been designed to estimate the national employment and income effects of 

energy-saving technologies. The ImSET software includes a computer-based I–O model with 

structural coefficients to characterize economic flows among the 187 sectors. ImSET’s national 

economic I–O structure is based on a 2002 U.S. benchmark table, specially aggregated to the 187 

sectors. DOE estimated changes in expenditures using the NIA spreadsheet. Using ImSET, DOE 

then estimated the net national, indirect employment impacts by sector of potential amended 

efficiency standards for clothes dryers and room air conditioners. 

For more details on the employment impact analysis and the results of this analysis, see 

direct final rule TSD chapter 13. 

K. Utility Impact Analysis 

The utility impact analysis estimates several important effects on the utility industry of 

the adoption of new or amended standards. For this analysis, DOE used the NEMS-BT model to 

generate forecasts of electricity consumption, electricity generation by plant type, and electric 

generating capacity by plant type, that would result from each TSL. DOE obtained the energy 

56 J. M. Roop, M. J. Scott, and R. W. Schultz. ImSET 3.1: Impact of Sector Energy Technologies. 2009. Pacific 

Northwest National Laboratory: Richland, WA. PNNL-18412. Available at: 

http://www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf 

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savings inputs associated with efficiency improvements to considered products from the NIA. 

DOE conducts the utility impact analysis as a scenario that departs from the latest AEO 

Reference case. In the analysis for today’s rule, the estimated impacts of standards are the 

differences between values forecasted by NEMS–BT and the values in the AEO2010 Reference 

case. 

As part of the utility impact analysis, DOE used NEMS-BT to assess the impacts on 

electricity prices of the reduced need for new electric power plants and infrastructure projected to 

result from the considered standards. In NEMS-BT, changes in power generation infrastructure 

affect utility revenue requirements, which in turn affect electricity prices. DOE estimated the 

change in electricity prices projected to result over time from each TSL. For further discussion, 

see section IV.G.5. 

For more details on the utility impact analysis and the results of this analysis, see chapter 

14 of the direct final rule TSD. 

L. Environmental Assessment 

Pursuant to the National Environmental Policy Act and the requirements of 42 U.S.C. 

6295(o)(2)(B)(i)(VI), DOE prepared an environmental assessment (EA) of the impacts of the 

standards for clothes dryers and room air conditioners in today’s direct final rule, which it has 

included as chapter 15 of the direct final rule TSD. DOE found that the environmental effects 

associated with the standards for clothes dryers and room air conditioners were not significant. 

Therefore, DOE issued a Finding of No Significant Impact (FONSI) pursuant to NEPA, the 

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regulations of the Council on Environmental Quality (40 CFR parts 1500–1508), and DOE’s 

regulations for compliance with NEPA (10 CFR part 1021). The FONSI is available in the 

docket for this rulemaking. 

In the EA, DOE estimated the reduction in power sector emissions of CO2, NOX, and Hg 

using the NEMS–BT computer model. In the EA, NEMS–BT is run similarly to the AEO 

NEMS, except that clothes dryer and room air conditioner energy use is reduced by the amount 

of energy saved (by fuel type) due to each TSL. The inputs of national energy savings come from 

the NIA spreadsheet model, while the output is the forecasted physical emissions. The net benefit 

of each TSL in today’s direct final rule is the difference between the forecasted emissions 

estimated by NEMS–BT at each TSL and the AEO 2010 Reference Case. NEMS–BT tracks CO2 

emissions using a detailed module that provides results with broad coverage of all sectors and 

inclusion of interactive effects. Because the on-site operation of gas clothes dryers requires use 

of fossil fuels and results in emissions of CO2, NOX and sulfur dioxide (SO2), DOE also 

accounted for the reduction in these emissions due to standards at the sites where these 

appliances are used. 

DOE has determined that SO2 emissions from affected fossil fuel fired combustion 

devices (also known as Electric Generating Units (EGUs)) are subject to nationwide and regional 

emissions cap and trading programs that create uncertainty about the standards’ impact on SO2 

emissions. Title IV of the Clean Air Act, 42 U.S.C. 7401-7671q, sets an annual emissions cap on 

SO2 for affected EGUs in the 48 contiguous states and the District of Columbia (D.C.). SO2 

emissions from 28 eastern States and D.C. are also limited under the Clean Air Interstate Rule 

(CAIR, 70 F.R. 25162 (May 12, 2005)), which created an allowance-based trading program. 

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Although CAIR has been remanded to the EPA by the U.S. Court of Appeals for the District of 

Columbia (D.C. Circuit), see North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008), it remains 

in effect temporarily, consistent with the D.C. Circuit’s earlier opinion in North Carolina v. EPA, 

531 F.3d 896 (D.C. Cir. 2008). On July 6, 2010, EPA issued the Transport Rule proposal, a 

replacement for CAIR, which would limit emissions from EGUs in 32 states, potentially through 

the interstate trading of allowances, among other options. 75 FR 45210 (Aug. 2, 2010). 

The attainment of the emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

and under the Transport Rule if it is finalized, any excess SO2 emission allowances resulting 

from the lower electricity demand caused by the imposition of an efficiency standard could be 

used to permit offsetting increases in SO2 emissions by any regulated EGU. However, if the 

standard resulted in a permanent increase in the quantity of unused emission allowances, there 

would be an overall reduction in SO2 emissions from the standards. While there remains some 

uncertainty about the ultimate effects of efficiency standards on SO2 emissions covered by the 

existing cap and trade system, the NEMS-BT modeling system that DOE uses to forecast 

emissions reductions currently indicates that no physical reductions in power sector emissions 

would occur for SO2. 

A cap on NOX emissions, affecting electric generating units in the CAIR region, means 

that standards on clothes dryers and room air conditioners may have little or no physical effect 

on NOX emissions in the 28 eastern States and the D.C. covered by CAIR, or any states covered 

by the proposed Transport Rule if the Transport Rule is finalized. The standards would, however, 

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reduce NOX emissions in those 22 States not affected by the CAIR. As a result, DOE used 

NEMS–BT to forecast emission reductions from the standards considered for today’s direct final 

rule. 

Similar to emissions of SO2 and NOX, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 28606 

(May 18, 2005). CAMR would have permanently capped emissions of mercury for new and 

existing coal-fired power plants in all States by 2010. However, on February 8, 2008, the D.C. 

Circuit issued its decision in New Jersey v. Environmental Protection Agency, in which it 

vacated CAMR. 517 F.3d 574 (D.C. Cir. 2008). EPA has decided to develop emissions standards 

for power plants under the Clean Air Act (Section 112), consistent with the D.C. Circuit’s 

opinion on the CAMR. See 

http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending EPA's 

forthcoming revisions to the rule, DOE is excluding CAMR from its environmental assessment. 

In the absence of CAMR, a DOE standard would likely reduce Hg emissions and DOE plans to 

use NEMS-BT to estimate these emission reductions. However, DOE continues to review the 

impact of rules that reduce energy consumption on Hg emissions, and may revise its assessment 

of Hg emission reductions in future rulemakings. 

The operation of gas clothes dryers requires use of fossil fuels and results in emissions of 

CO2, NOX, and SO2 at the sites where these appliances are used. NEMS-BT provides no means 

for estimating such emissions. DOE calculated the effect of the standards in today’s rule on the 

above site emissions based on emissions factors derived from the literature. 

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Commenting on the preliminary TSD, AHAM stated that if DOE includes values for CO2 

reductions, it should also include CO2 emissions that result indirectly from changes in a standard, 

including increased manufacturing emissions, increased transportation emissions, and reduced 

carbon emissions from peak load reductions. (AHAM, No. 25 at p. 12) In response, DOE notes 

that the inputs to the EA for national energy savings come from the NIA. In the NIA, DOE 

accounts for only the primary energy savings associated with considered standards. In so doing, 

EPCA directs DOE to consider (when determining whether a standard is economically justified) 

“the total projected amount of energy . . . savings likely to result directly from the imposition of 

the standard.” 42 U.S.C. 6295(o)(2)(B)(i)(III) DOE interprets “directly from the imposition of 

the standard” to include energy used in the generation, transmission, and distribution of fuels 

used by appliances. In addition, DOE is evaluating the full-fuel-cycle measure, which includes 

the energy consumed in extracting, processing, and transporting primary fuels (see section 

IV.G.3). Both DOE’s current accounting of primary energy savings and the full-fuel-cycle 

measure are directly linked to the energy used by appliances. In contrast, energy used in 

manufacturing and transporting appliances is a step removed from the energy used by appliances. 

Thus, DOE did not consider such energy use in either the NIA or the EA. DOE did include CO2 

emissions reductions resulting from projected impacts of revised standards on electricity 

demand. 

M. Monetizing Carbon Dioxide and Other Emissions Impacts 

As part of the development of this direct final rule, DOE considered the estimated 

monetary benefits likely to result from the reduced emissions of CO2 NOX that are expected to 

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result from each of the TSLs considered. In order to make this calculation similar to the 

calculation of the NPV of consumer benefit, DOE considered the reduced emissions expected to 

result over the lifetime of products shipped in the forecast period for each TSL. This section 

summarizes the basis for the monetary values used for each of these emissions and presents the 

benefits estimates considered. 

For today’s direct final rule, DOE is relying on a set of values for the social cost of 

carbon (SCC) that was developed by an interagency process. A summary of the basis for these 

values is provided below, and a more detailed description of the methodologies used is provided 

in appendix 15-A of the direct final rule TSD. 

1. Social Cost of Carbon 

Under Executive Order 12866, agencies must, to the extent permitted by law, “assess 

both the costs and the benefits of the intended regulation and, recognizing that some costs and 

benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned 

determination that the benefits of the intended regulation justify its costs.” The purpose of the 

SCC estimates presented here is to allow agencies to incorporate the monetized social benefits of 

reducing CO2 emissions into cost-benefit analyses of regulatory actions that have small, or 

“marginal,” impacts on cumulative global emissions. The estimates are presented with an 

acknowledgement of the many uncertainties involved and with a clear understanding that they 

should be updated over time to reflect increasing knowledge of the science and economics of 

climate impacts. 

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As part of the interagency process that developed these SCC estimates, technical experts 

from numerous agencies met on a regular basis to consider public comments, explore the 

technical literature in relevant fields, and discuss key model inputs and assumptions. The main 

objective of this process was to develop a range of SCC values using a defensible set of input 

assumptions grounded in the existing scientific and economic literatures. In this way, key 

uncertainties and model differences transparently and consistently inform the range of SCC 

estimates used in the rulemaking process. 

a. Monetizing Carbon Dioxide Emissions 

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited to) 

changes in net agricultural productivity, human health, property damages from increased flood 

risk, and the value of ecosystem services. Estimates of the SCC are provided in dollars per metric 

ton of carbon dioxide. 

When attempting to assess the incremental economic impacts of carbon dioxide 

emissions, the analyst faces a number of serious challenges. A recent report from the National 

57 Research Council points out that any assessment will suffer from uncertainty, speculation, and 

lack of information about (1) future emissions of greenhouse gases, (2) the effects of past and 

future emissions on the climate system, (3) the impact of changes in climate on the physical and 

biological environment, and (4) the translation of these environmental impacts into economic 

damages. As a result, any effort to quantify and monetize the harms associated with climate 

57 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use. 

National Academies Press: Washington, DC. 2009. 

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change will raise serious questions of science, economics, and ethics and should be viewed as 

provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates can be 

useful in estimating the social benefits of reducing carbon dioxide emissions. Consistent with the 

directive quoted above, the purpose of the SCC estimates presented here is to make it possible 

for agencies to incorporate the social benefits from reducing carbon dioxide emissions into costbenefit analyses of regulatory actions that have small, or “marginal,” impacts on cumulative 

global emissions. Most Federal regulatory actions can be expected to have marginal impacts on 

global emissions. 

For such policies, the agency can estimate the benefits from reduced (or costs from 

increased) emissions in any future year by multiplying the change in emissions in that year by 

the SCC value appropriate for that year. The net present value of the benefits can then be 

calculated by multiplying each of these future benefits by an appropriate discount factor and 

summing across all affected years. This approach assumes that the marginal damages from 

increased emissions are constant for small departures from the baseline emissions path, an 

approximation that is reasonable for policies that have effects on emissions that are small relative 

to cumulative global carbon dioxide emissions. For policies that have a large (non-marginal) 

impact on global cumulative emissions, there is a separate question of whether the SCC is an 

appropriate tool for calculating the benefits of reduced emissions. DOE does not attempt to 

answer that question here. 

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At the time of the preparation of this notice, the most recent interagency estimates of 

the potential global benefits resulting from reduced CO2 emissions in 2010, expressed in 2009$, 

were $4.9, $22.1, $36.3, and $67.1 per metric ton avoided. For emission reductions that occur in 

later years, these values grow in real terms over time. Additionally, the interagency group 

determined that a range of values from 7 percent to 23 percent should be used to adjust the global 

58 SCC to calculate domestic effects, although preference is given to consideration of the global 

benefits of reducing CO2 emissions. 

It is important to emphasize that the interagency process is committed to updating these 

estimates as the science and economic understanding of climate change and its impacts on 

society improves over time. Specifically, the interagency group has set a preliminary goal of 

revisiting the SCC values within 2 years or at such time as substantially updated models become 

available, and to continue to support research in this area. In the meantime, the interagency group 

will continue to explore the issues raised by this analysis and consider public comments as part 

of the ongoing interagency process. 

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

To date, economic analyses for Federal regulations have used a wide range of values to 

estimate the benefits associated with reducing carbon dioxide emissions. In the final model year 

2011 CAFE rule, the Department of Transportation (DOT) used both a “domestic” SCC value of 

$2 per ton of CO2 and a “global” SCC value of $33 per ton of CO2 for 2007 emission reductions 

58 It is recognized that this calculation for domestic values is approximate, provisional, and highly speculative. There 

is no a priori reason why domestic benefits should be a constant fraction of net global damages over time. 

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59 (in 2007 dollars), increasing both values at 2.4 percent per year. See Average Fuel Economy 

Standards Passenger Cars and Light Trucks Model Year 2011, 74 FR 14196 (March 30, 2009); 

Final Environmental Impact Statement Corporate Average Fuel Economy Standards, Passenger 

Cars and Light Trucks, Model Years 2011-2015 at 3-90 (Oct. 2008) (Available at: 

http://www.nhtsa.gov/fuel-economy). It also included a sensitivity analysis at $80 per ton of 

CO2. A domestic SCC value is meant to reflect the value of damages in the United States 

resulting from a unit change in carbon dioxide emissions, while a global SCC value is meant to 

reflect the value of damages worldwide. 

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per ton of CO2 

(in 2006 dollars) for 2011 emission reductions (with a range of $0-$14 for sensitivity analysis), 

also increasing at 2.4 percent per year. See Average Fuel Economy Standards, Passenger Cars 

and Light Trucks, Model Years 2011-2015, 73 FR 24352 (May 2, 2008); Draft Environmental 

Impact Statement Corporate Average Fuel Economy Standards, Passenger Cars and Light 

Trucks, Model Years 2011-2015 at 3-58 (June 2008) (Available at: http://www.nhtsa.gov/fueleconomy). A regulation for packaged terminal air conditioners and packaged terminal heat 

pumps finalized by DOE in October of 2008 used a domestic SCC range of $0 to $20 per ton 

CO2 for 2007 emission reductions (in 2007 dollars). 73 FR 58772, 58814 (Oct. 7, 2008) In 

addition, EPA’s 2008 Advance Notice of Proposed Rulemaking for Greenhouse Gases identified 

what it described as “very preliminary” SCC estimates subject to revision. See Regulating 

Greenhouse Gas Emissions Under the Clean Air Act, 73 FR 44354 (July 30, 2008). EPA’s global 

mean values were $68 and $40 per ton CO2 for discount rates of approximately 2 percent and 3 

percent, respectively (in 2006 dollars for 2007 emissions). 

59 Values per ton of CO2 given in this section refer to metric tons. 

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In 2009, an interagency process was initiated to offer a preliminary assessment of how 

best to quantify the benefits from reducing carbon dioxide emissions. To ensure consistency in 

how benefits are evaluated across agencies, the Administration sought to develop a transparent 

and defensible method, specifically designed for the rulemaking process, to quantify avoided 

climate change damages from reduced CO2 emissions. The interagency group did not undertake 

any original analysis. Instead, it combined SCC estimates from the existing literature to use as 

interim values until a more comprehensive analysis could be conducted. The outcome of the 

preliminary assessment by the interagency group was a set of five interim values: global SCC 

estimates for 2007 (in 2006 dollars) of $55, $33, $19, $10, and $5 per ton of CO2. 

These interim values represent the first sustained interagency effort within the U.S. 

government to develop an SCC for use in regulatory analysis. The results of this preliminary 

effort were presented in several proposed and final rules and were offered for public comment in 

connection with proposed rules, including the joint EPA-DOT fuel economy and CO2 tailpipe 

emission proposed rules. See CAFE Rule for Passenger Cars and Light Trucks Draft EIS and 

Final EIS, cited above. 

c. Current Approach and Key Assumptions 

Since the release of the interim values, the interagency group reconvened on a regular 

basis to generate improved SCC estimates, which were used in this direct final rule. Specifically, 

the group considered public comments and further explored the technical literature in relevant 

fields. 

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The interagency group relied on three integrated assessment models (IAMs) commonly 

60 used to estimate the SCC: the FUND, DICE, and PAGE models. These models are frequently 

cited in the peer-reviewed literature and were used in the last assessment of the 

Intergovernmental Panel on Climate Change. Each model was given equal weight in the SCC 

values that were developed. 

Each model takes a slightly different approach to model how changes in emissions result 

in changes in economic damages. A key objective of the interagency process was to enable a 

consistent exploration of the three models while respecting the different approaches to 

quantifying damages taken by the key modelers in the field. An extensive review of the literature 

was conducted to select three sets of input parameters for these models: climate sensitivity, 

socio-economic and emissions trajectories, and discount rates. A probability distribution for 

climate sensitivity was specified as an input into all three models. In addition, the interagency 

group used a range of scenarios for the socio-economic parameters and a range of values for the 

discount rate. All other model features were left unchanged, relying on the model developers’ 

best estimates and judgments. 

The interagency group selected four SCC values for use in regulatory analyses. Three 

values are based on the average SCC from three integrated assessment models, at discount rates 

th of 2.5, 3, and 5 percent. The fourth value, which represents the 95 percentile SCC estimate 

across all three models at a 3-percent discount rate, is included to represent higher-than-expected 

impacts from temperature change further out in the tails of the SCC distribution. For emissions 

60 The models are described in appendix 15-A of the final rule TSD.. 

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(or emission reductions) that occur in later years, these values grow in real terms over time, as 

depicted in Table IV-33. 

Table IV-33 Social Cost of CO2, 2010–2050 (in 2007 dollars per metric ton) 

Discount Rate 

5% 3% 2.5% 3% 

Avg Avg Avg 95th 

2010 4.7 21.4 35.1 64.9 

2015 5.7 23.8 38.4 72.8 

2020 6.8 26.3 41.7 80.7 

2025 8.2 29.6 45.9 90.4 

2030 9.7 32.8 50.0 100.0 

2035 11.2 36.0 54.2 109.7 

2040 12.7 39.2 58.4 119.3 

2045 14.2 42.1 61.7 127.8 

2050 15.7 44.9 65.0 136.2 

It is important to recognize that a number of key uncertainties remain, and that current 

SCC estimates should be treated as provisional and revisable since they will evolve with 

improved scientific and economic understanding. The interagency group also recognizes that the 

existing models are imperfect and incomplete. The National Research Council report mentioned 

above points out that there is tension between the goal of producing quantified estimates of the 

economic damages from an incremental ton of carbon and the limits of existing efforts to model 

these effects. There are a number of concerns and problems that should be addressed by the 

research community, including research programs housed in many of the agencies participating 

in the interagency process to estimate the SCC. 

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The U.S. government intends to periodically review and reconsider estimates of the SCC 

used for cost-benefit analyses to reflect increasing knowledge of the science and economics of 

climate impacts, as well as improvements in modeling. In this context, statements recognizing 

the limitations of the analysis and calling for further research take on exceptional significance. 

The interagency group offers the new SCC values with all due humility about the uncertainties 

embedded in them and with a sincere promise to continue work to improve them. 

In summary, in considering the potential global benefits resulting from reduced CO2 

emissions, DOE used the most recent values identified by the interagency process, adjusted to 

2009$ using the GDP price deflator values for 2008 and 2009. For each of the four cases 

specified, the values used for emissions in 2010 were $4.9, $22.1, $36.3, and $67.1 per metric 

ton avoided (values expressed in 2009$). To monetize the CO2 emissions reductions expected to 

result from amended standards for clothes dryers and room air conditioners in 2014–2043, DOE 

used the values identified in Table A1 of the “Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866,” which is reprinted in appendix 16-A of the direct final 

61 rule TSD, appropriately adjusted to 2009$. To calculate a present value of the stream of 

monetary values, DOE discounted the values in each of the four cases using the specific discount 

rate that had been used to obtain the SCC values in each case. 

2. Valuation of Other Emissions Reductions 

DOE investigated the potential monetary benefit of reduced NOX emissions from the 

TSLs it considered. As noted above, amended energy conservation standards would reduce NOX 

61 Table A1 presents SCC values through 2050. For DOE’s calculation, it derived values after 2050 using the 3­

percent per year escalation rate used by the interagency group. 

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emissions in those 22 States that are not affected by the CAIR, in addition to the reduction in site 

NOX emissions nationwide. DOE estimated the monetized value of NOX emissions reductions 

resulting from each of the TSLs considered for today’s direct final rule based on environmental 

damage estimates from the literature. Available estimates suggest a very wide range of monetary 

values, ranging from $370 per ton to $3,800 per ton of NOX from stationary sources, measured in 

62 2001$ (equivalent to a range of $447 to $4,591 per ton in 2009$). In accordance with OMB 

guidance, DOE conducted two calculations of the monetary benefits derived using each of the 

economic values used for NOX, one using a real discount rate of 3 percent and another using a 

63 real discount rate of 7 percent.

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

used in evaluating the potential economic benefits of reduced Hg emissions. DOE has decided to 

await further guidance regarding consistent valuation and reporting of Hg emissions before it 

once again monetizes Hg in its rulemakings. 

Commenting on the preliminary TSD, Whirlpool stated that CO2 emissions should not be 

monetized because the market value cannot be readily determined, the impact is negligible, and it 

is already included in energy savings. (Whirlpool, No. 22 at p. 6) DOE acknowledges that the 

market value of future CO2 emissions reductions is uncertain, and for this reason it uses a wide 

range of potential values, as described above. The impact of revised standards for room air 

conditioners and clothes dryers on future CO2 emissions, described in section V.6 of this notice, 

62 For additional information, refer to U.S. Office of Management and Budget, Office of Information and Regulatory 

Affairs. 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on 

State, Local, and Tribal Entities. 2006. Washington, DC. 63 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 

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is not negligible. In addition, the value of CO2 emissions reductions is not included in energy 

cost savings because the energy prices that DOE used to calculate those savings do not include 

any taxes or other charges to account for the CO2 emissions associated with the use of electricity 

or natural gas by the considered appliances. 

V. Analytical Results 

The following section addresses the results from DOE’s analyses with respect to potential 

energy conservation standards for the products examined as part of this rulemaking. It addresses 

the TSLs examined by DOE, the projected impacts of each of these levels if adopted as energy 

conservation standards for clothes dryers and room air conditioners, and the standards levels that 

DOE sets forth in today’s direct final rule. Additional details regarding the analyses conducted 

by the agency are contained in the publicly available direct final rule TSD supporting this notice. 

A. Trial Standard Levels 

DOE analyzed the benefits and burdens of a number of TSLs for the products that are the 

subject of today’s direct final rule. A description of each TSL DOE analyzed is provided below. 

DOE attempted to limit the number of TSLs considered for the final rule by excluding efficiency 

levels that do not exhibit significantly different economic or engineering characteristics from the 

efficiency levels already selected as a TSL. While DOE presents the results for only those 

efficiency levels in TSL combinations, DOE presents the results for all efficiency levels that it 

analyzed in chapter 10 of the direct final rule TSD. 

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Table V-1 presents the TSLs and the corresponding product class efficiency levels for 

clothes dryers. TSL 1 consists of the efficiency levels with the largest market share with a 

positive NPV (at a 3-percent discount rate). TSL 2 consists of the efficiency levels with the 

highest NPV (at a 3-percent discount rate). TSL 3 consists of the efficiency levels with the 

highest energy savings and a positive NPV (at a 3-percent discount rate). TSL 4 consists of the 

efficiency levels that reflect 5-percent efficiency increase above the baseline. TSL 4 also 

corresponds to the standards recommended by the Joint Petitioners. TSL 5 consists of non heat 

pump design efficiency levels with the highest energy savings. TSL 6 consists of the max-tech 

efficiency levels. 

Table V-1 Trial Standard Levels for Clothes Dryers 

Product Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

CEF 

Vented Electric Standard 3.56 3.61 3.73 3.73 4.08 5.42 

Vented Electric Compact 120V 3.43 3.61 3.61 3.61 4.08 5.41 

Vented Electric Compact 240V 3.12 3.27 3.27 3.27 3.60 4.89 

Vented Gas 3.16 3.20 3.20 3.30 3.61 3.61 

Ventless Electric Compact 240V 2.55 2.69 2.69 2.55 2.80 4.03 

Ventless Electric Combination 

Washer/Dryer 

2.08 2.56 2.56 2.08 2.56 3.69 

Table V-2 presents the TSLs and the corresponding product class efficiency levels for 

room air conditioners. TSL 1 consists of the efficiency levels with the largest market share with a 

positive NPV (at a 3-percent discount rate). TSL 2 consists of the ENERGY STAR levels for 

each product class. TSL 3 consists of the efficiency levels with the highest NPV (at a 3-percent 

discount rate). TSL 4 consists of the efficiency levels set forth in the Joint Petition presented to 

DOE. TSL 5 consists of the efficiency levels with the highest energy savings and a positive NPV 

(at a 7-percent discount rate). TSL 6 consists of the max-tech efficiency levels. 

282 
 

 

 

 

 

 

 

Table V-2 Trial Standard Levels for Room Air Conditioners 

Product Class TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

CEER 

Group 1 – includes PC 1 10.10 10.60 10.10 11.10 11.10 11.67 

Group 2 – includes PC 2, 3, 4, 11 10.70 10.70 10.90 10.90 11.50 11.96 

Group 3 – includes PC 5A, 9, 13 9.40 9.40 8.47 9.40 8.47 10.15 

Group 4 – includes PC 5B, 10 9.40 9.40 8.48 9.00 8.48 9.80 

Group 5 – includes PC 6, 7, 8A, 12 9.30 9.30 9.60 9.60 10.00 10.35 

Group 6 – includes PC 8B, 14, 15, 16 9.30 9.30 9.50 9.50 9.50 10.02 

283 
 

 

 

 

 

 

 

 

 

 

B. Economic Justification and Energy Savings 

1. Economic Impacts on Individual Consumers 

a. Life-Cycle Cost and Payback Period 

Consumers affected by new or amended standards usually experience higher purchase 

prices and lower operating costs. Generally, these impacts on individual consumers are best 

captured by changes in life-cycle costs and by the payback period. Therefore, DOE calculated 

the LCC and PBP analyses for the potential standard levels considered in this rulemaking. 

DOE’s LCC and PBP analyses provided key outputs for each TSL, which are reported by clothes 

dryer product class in Table V-3 through Table V-8, and by room air conditioner product class in 

Table V-9 through Table V-14. Each table includes the average total LCC and the average LCC 

savings, as well as the fraction of product consumers for which the LCC will either decrease (net 

benefit), or increase (net cost), or exhibit no change (no impact) relative to the base-case 

forecast. The last output in the tables is the median PBP for the consumer purchasing a design 

that complies with the TSL. DOE presents the median PBP because it is the most statistically 

robust measure of the PBP. The results for each potential standard level are relative to the 

efficiency distribution in the base case (no amended standards). DOE based the LCC and PBP 

analyses on the range of energy consumption under conditions of actual product use. 

Table V-3 LCC and Payback Period Results for Electric Standard Dryers 

Payback 

Life-Cycle Cost 2009$ LCC Savings Period 

TSL CEF 

years 

Installed Discounted Average Percent of households 

that experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1 3.56 455 867 1,323 $0 0.7 97.6 1.7 3.9 

2 3.61 456 856 1,311 2 0.3 78.7 21.0 0.2 

3, 4 3.73 467 829 1,296 14 19.0 24.8 56.3 5.3 

5 4.08 583 761 1,343 -30 75.3 1.0 23.7 19.1 

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6 5.42 879 580 1,459 -146 81.0 0.0 19.0 22.1 

Table V-4 LCC and Payback Period Results for Electric Compact 120V Dryers 

Payback 

Life-Cycle Cost 2009$ LCC Savings Period 

TSL CEF 

years 

Installed Discounted Average Percent of households 

that experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1 3.43 $470 $384 $854 n/a 0 100 0 n/a 

2, 3, 4 3.61 471 369 840 14 4.0 0.0 96.0 0.9 

5 4.08 627 325 953 -99 95.5 0.0 4.5 36.1 

6 5.41 875 243 1,118 -264 95.4 0.0 4.6 40.1 

Table V-5 LCC and Payback Period Results for Electric Compact 240V Dryers 

Payback 

Life-Cycle Cost 2009$ LCC Savings Period 

TSL CEF 

years 

Installed Discounted Average Percent of households 

that experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1 3.12 $470 $427 $896 n/a 0 100 0 n/a 

2, 3, 4 3.27 471 411 882 8 2.3 41.4 56.3 0.9 

5 3.60 627 373 1,000 -99 93.3 4.2 2.5 45.1 

6 4.89 875 272 1,147 -246 94.5 0.0 5.5 38.2 

Table V-6 LCC and Payback Period Results for Gas Dryers 

Payback 

Life-Cycle Cost 2009$ LCC Savings Period 

TSL CEF 

years 

Installed Discounted Average Percent of households 

that experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1 3.16 $554 $445 $999 n/a 0 100 0 n/a 

2, 3 3.20 555 440 995 $0 0.5 92.9 6.6 2.2 

4 3.30 555 427 983 2 0.3 84.5 15.2 0.5 

5, 6 3.61 658 404 1,062 -69 87.7 10.5 1.8 73.3 

Table V-7 LCC and Payback Period Results for Ventless 240V Dryers 

Payback 

Life-Cycle Cost 2009$ LCC Savings Period 

TSL CEF years 

Installed 

Cost 

Discounted 

Operating LCC Average Savings 

Percent of households 

that experience Median 

285 
 

 

 

Cost 2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1, 4 2.55 $1,093 $452 $1,545 n/a 0 100 0 n/a 

2, 3 2.69 1,094 431 1,525 20 0.0 0.0 100.0 0.9 

5 2.80 1,176 411 1,587 -42 92.5 0.0 7.5 25.3 

6 4.03 1,462 261 1,722 -177 88.5 0.0 11.5 26.9 

Table V-8 LCC and Payback Period Results for Ventless Combination Washer/Dryers 

Payback 

Life-Cycle Cost 2009$ LCC Savings Period 

TSL CEF 

years 

Installed Discounted Average Percent of households 

that experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1, 4 2.08 $1,533 $565 $2,098 n/a 0 100 0 n/a 

2, 3, 5 2.56 1,579 446 2,025 73 20.6 0.0 79.4 5.3 

6 3.69 1,981 282 2,263 -166 82.4 0.0 17.6 22.4 

Table V-9 LCC and Payback Period Results for Room Air Conditioners, <6,000 Btu/h, 

with Louvers 

Payback 

TSL CEER Life-Cycle Cost 2009$ LCC Savings Period 

years 

Installed Discounted Average Percent of households that 

experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1, 3 10.10 361 357 718 $9 21.2 30.7 48.1 4.1 

2 10.60 374 341 715 11 32.8 30.7 36.6 5.8 

4, 5 11.10 393 326 719 7 64.6 1.2 34.2 8.6 

6 11.67 472 311 784 -58 90.4 0.0 9.6 20.9 

Table V-10 LCC and Payback Period Results for Room Air Conditioners, 8,000–13,999 

Btu/h, with Louvers 

Payback 

TSL CEER Life-Cycle Cost 2009$ LCC Savings Period 

years 

Installed Discounted Average Percent of households 

that experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1, 2 10.70 493 557 1,050 16 9.3 60.5 30.2 0.0 

3, 4 10.90 497 547 1,045 22 33.6 2.2 64.1 2.8 

5 11.50 525 519 1,044 22 55.7 0.8 43.4 7.1 

6 11.96 605 500 1,104 -38 77.3 0.5 22.2 14.7 

286 
 

 

 

Table V-11 LCC and Payback Period Results for Room Air Conditioners, 20,000–24,999 

Btu/h, with Louvers 

Payback 

TSL CEER Life-Cycle Cost 2009$ LCC Savings Period 

years 

Installed Discounted Average 

Percent of households 

that experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

3, 5 8.47 $857 $750 $1,607 n/a 0 100 0 n/a 

1, 2, 

4 9.40 887 672 1,559 6 5.1 85.3 9.6 4.3 

6 10.15 1,159 626 1,785 -214 97.6 2.1 0.3 73.8 

Table V-12 LCC and Payback Period Results for Room Air Conditioners, >25,000 Btu/h, 

with Louvers 

Payback 

TSL CEER Life-Cycle Cost 2009$ LCC Savings Period 

years 

Installed Discounted Average Percent of households that 

experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

3, 5 8.48 $979 $823 $1,802 n/a 0 100 0 n/a 

4 9.00 1,019 777 1,796 $1 8.9 87.6 3.5 10.1 

1, 2 9.40 1,058 739 1,797 1 11.0 85.3 3.7 10.3 

6 9.80 1,313 712 2,025 -227 99.8 0.0 0.2 107.7 

Table V-13 LCC and Payback Period Results for Room Air Conditioners, 8,000–10,999 

Btu/h, without Louvers 

Payback 

TSL CEER Life-Cycle Cost 2009$ LCC Savings Period 

years 

Installed Discounted Average Percent of households 

that experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1, 2 9.30 495 490 986 $4 0.9 89.9 9.2 1.5 

3, 4 9.60 498 476 974 13 12.3 25.2 62.5 2.1 

5 10.00 512 454 966 20 38.0 5.6 56.3 4.9 

6 10.35 615 440 1,055 -66 91.8 1.9 6.2 25.2 

287 
 

 

 

 

 

Table V-14 LCC and Payback Period Results for Room Air Conditioners, >11,000 Btu/h, 

without Louvers 

Payback 

TSL CEER Life-Cycle Cost 2009$ LCC Savings Period 

years 

Installed Discounted Average Percent of households that 

experience Median Cost Operating 

Cost 

LCC Savings 

2009$ Net 

Cost 

No 

Impact 

Net 

Benefit 

1, 2 9.30 590 698 1,288 $5 2.2 89.9 7.9 2.6 

3, 4, 

5 9.50 596 684 1,279 11 22.7 30.6 46.6 3.7 

9.80 611 660 1,271 18 36.0 17.3 46.6 5.3 

6 10.02 707 647 1,354 -64 92.6 0.0 7.3 25.9 

b. Consumer Sub-Group Analysis 

As described in section IV.H, DOE determined the impact of the considered TSLs on 

low-income households and senior-only households. 

Table V-15 and Table V-16 compare the average LCC savings at each efficiency level for 

the two consumer subgroups with the average LCC savings for the entire sample for each 

product class for clothes dryers and room air conditioners, respectively. DOE found that the 

average LCC savings for low-income households and senior-only households at the considered 

efficiency levels are not substantially different from the average for all households. Chapter 11 

of the direct final rule TSD presents the complete LCC and PBP results for the two subgroups. 

288 
 

 

 

 

Table V-15 Clothes Dryers: Comparison of Average LCC Savings for Consumer 

Subgroups and All Households 

Electric Standard Vented 120V Vented 240V 

CEF Senior LowIncome All CEF Senior LowIncome All CEF Senior LowIncome All 

3.56 $0 $0 $0 3.48 $3 $3 $4 3.16 $2 $2 $2 

3.61 2 2 2 3.61 14 13 14 3.27 9 8 8 

3.73 7 12 14 3.72 -8 -5 -5 3.36 -8 -6 -5 

3.81 -40 -30 -27 3.80 -63 -57 -56 3.48 -54 -47 -47 

4.08 -62 -38 -30 4.08 -113 -99 -99 3.60 -110 -99 -99 

5.42 -245 -170 -146 5.41 -306 -262 -264 4.89 -291 -243 -246 

Gas Ventless 240V Ventless Combination 

CEF Senior LowIncome All CEF Senior LowIncome All CEF Senior LowIncome All 

3.16 $0 $0 $0 2.59 $5 $5 $5 2.35 $49 $76 $75 

3.20 2 2 2 2.69 20 19 20 2.38 54 80 79 

3.30 -1 2 2 2.71 -14 -14 -13 2.46 68 93 93 

3.41 -76 -69 -69 2.80 -49 -42 -42 2.56 41 73 73 

3.61 -115 -100 -100 4.03 -234 -175 -177 3.69 -253 -162 -166 

Table V-16 Room Air Conditioners: Comparison of Average LCC Savings for Consumer 

Subgroups and All Households 

<6,000 Btu/h, with Louvers 8,000–13,999 Btu/h, with Louvers 20,000–24,999 Btu/h, with Louvers 

CEER Senior LowIncome All CEER Senior LowIncome All CEER Senior LowIncome All 

10.10 $5 $12 $9 10.20 $8 $10 $9 9.00 $1 $7 $3 

10.60 4 17 11 10.70 13 18 16 9.40 3 13 6 

11.10 -5 17 7 10.90 17 24 22 9.80 -17 8 -10 

11.38 -17 9 -3 11.50 14 27 22 10.15 -223 -187 -214 

11.67 -75 -44 -58 11.96 -49 -31 -38 - - - -

>25,000 Btu/h, with Louvers 8,000–10,999 Btu/h, without 

Louvers >11,000 Btu/h, without Louvers 

CEER Senior LowIncome All CEER Senior LowIncome All CEER Senior LowIncome All 

9.00 $0 $4 $1 9.30 $4 $5 $4 9.30 $4 $6 $5 

9.40 -1 7 1 9.60 11 15 13 9.50 9 13 11 

9.80 -234 -209 -227 10.00 16 23 20 9.80 13 21 18 

- - - - 10.35 -73 -62 -66 10.02 -71 -60 -64 

c. Rebuttable Presumption Payback 

As discussed above, EPCA provides a rebuttable presumption that an energy 

conservation standard is economically justified if the increased purchase cost for a product that 

meets the standard is less than three times the value of the first-year energy savings resulting 

289 
 

 

 

 

 

 

 

 

from the standard. In calculating a rebuttable presumption payback period for the considered 

standard levels, DOE used discrete values rather than distributions for input values, and, as 

required by EPCA, based the energy use calculation on the DOE test procedures for the 

considered products. As a result, DOE calculated a single rebuttable presumption payback value, 

and not a distribution of payback periods, for each efficiency level. Table V-17 and Table V-18 

present the average rebuttable presumption payback periods for those efficiency levels where the 

increased purchase cost for a product that meets a standard at that level is less than three times 

the value of the first-year energy savings resulting from the standard. 

Table V-17 Clothes Dryers: Efficiency Levels With Rebuttable Payback Period Less Than 

Three Years 

Product Class CEF PBP (years) 

Electric standard 3.61 0.95 

Electric compact 120V 3.48 

3.61 

2.49 

0.86 

Electric compact 240V 3.16 

3.27 

2.57 

0.85 

Gas 3.20 1.81 

Ventless compact 240V 2.59 

2.69 

2.33 

0.83 

Ventless combination 

washer/dryers 

2.46 

2.46 

2.46 

0.42 

0.68 

0.74 

Table V-18 Room Air Conditioners: Efficiency Levels With Rebuttable Payback Period 

Less Than Three Years 

Product Class CEER PBP (years) 

Room Air Conditioners (8000–13,999 Btu/h), with 

Louvers 

10.2 

10.7 

10.9 

1.1 

1.6 

1.8 

Room Air Conditioners (20,000–24,999 Btu/h), with 

Louvers 

9.0 

9.4 

9.8 

0.9 

1.1 

1.9 

Room Air Conditioners (>25,000 Btu/h), with Louvers 9.0 

9.4 

2.1 

2.4 

Room Air Conditioners (8000–10,999 Btu/h), without 9.3 0.6 

290 
 

 

 

 

 

 

Louvers 9.6 

10.0 

0.7 

1.3 

Room Air Conditioners (>11,000 Btu/h), without 

Louvers 

9.3 

9.5 

9.8 

1.3 

1.4 

1.9 

While DOE examined the rebuttable-presumption criterion, it considered whether the 

standard levels considered for today’s rule are economically justified through a more detailed 

analysis of the economic impacts of these levels pursuant to 42 U.S.C. 6295(o)(2)(B)(i). The 

results of this analysis serve as the basis for DOE to definitively evaluate the economic 

justification for a potential standard level (thereby supporting or rebutting the results of any 

preliminary determination of economic justification). 

2. Economic Impacts on Manufacturers 

DOE performed an MIA to estimate the impact of amended energy conservation 

standards on manufacturers of clothes dryers and room air conditioners. The section below 

describes the expected impacts on manufacturers at each TSL. Chapter 12 of the direct final rule 

TSD explains the analysis in further detail. 

a. Industry Cash Flow Analysis Results 

The tables below depict the financial impacts on manufacturers (represented by changes 

in INPV) and the conversion costs DOE estimates manufacturers would incur at each TSL. Each 

set of results below shows two tables of INPV impacts: the first table reflects the lower (less 

severe) bound of impacts and the second represents the upper bound. To evaluate this range of 

cash-flow impacts on each industry, DOE modeled two different scenarios using different 

markup assumptions. These assumptions correspond to the bounds of a range of market 

291 
 

 

 

 

 

 

 

 

 

responses that DOE anticipates could occur in the standards case. Each scenario results in a 

unique set of cash flows and corresponding industry value at each TSL. 

The INPV results refer to the difference in industry value between the base case and the 

standards case, which DOE calculated by summing the discounted industry cash flows from the 

base year (2011) through the end of the analysis period. The discussion also notes the difference 

in cash flow between the base case and the standards case in the year before the compliance date 

of potential amended energy conservation standards. This figure provides a proxy for the 

magnitude of the required conversion costs, relative to the cash flow generated by the industry in 

the base case. 

Cash Flow Analysis Results for Clothes Dryers 

To assess the lower (less severe) end of the range of potential impacts on the residential 

clothes dryer industry, DOE modeled the flat markup scenario. The flat markup scenario 

assumes that in the standards case manufacturers would be able to pass the higher productions 

costs required for more efficient products on to their customers. Specifically, the industry would 

be able to maintain its average base-case gross margin, as a percentage of revenue, despite higher 

product costs. In general, the larger the product price increases, the less likely manufacturers are 

to achieve the cash flow from operations calculated in this scenario because the less likely it is 

that manufacturers would be able to fully markup these larger cost increases. 

To assess the higher (more severe) end of the range of potential impacts on the residential 

clothes dryer industry, DOE modeled the preservation of operating profit markup scenario. The 

292 
 

 

 

 

 

 

 

scenario represents the upper end of the range of potential impacts on manufacturers because no 

additional operating profit is earned on the higher production costs, eroding profit margins as a 

percentage of total revenue. 

DOE used the main NIA shipment scenario for the both the lower- and higher-bound 

MIA scenarios that were used to characterize the potential INPV impacts. The shipment forecast 

is an important driver of the INPV results below (Table V-19 and Table V-20). The main NIA 

shipment scenario includes a price elasticity effect, meaning higher prices in the standards case 

result in lower shipments. Lower shipments also reduce industry revenue, and, in turn, INPV. 

Table V-19 Manufacturer Impact Analysis for Clothes Dryers – Flat Markup Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 5 6 

INPV 2009$ 

millions 1,003.6 1,001.1 1,000.0 962.5 939.2 827.1 699.7 

Change in 

INPV 

2009$ 

millions - -2.6 -3.6 -41.13 -64.46 -176.5 -303.9 

% - -0.3% -0.4% -4.1% -6.4% -17.6% -30.3% 

Product 

Conversion 

Costs 

2009$ 

millions - 4 5 18 24 166 383 

Capital 

Conversion 

Costs 

2009$ 

millions - 0 2 48 71 328 536 

Total 

Conversion 

Costs 

2009$ 

millions - 4 7 66 95 494 919 

293 
 

 

 

 

 

 

 

 

 

 

Table V-20 Manufacturer Impact Analysis for Clothes Dryers – Preservation of Operating 

Profit Markup Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 5 6 

INPV 2009$ 

millions 1,003.6 1,001.0 998.7 948.2 923.0 606.2 273.6 

Change in 

INPV 

2009$ 

millions - -2.6 -4.) -55.46 -80.63 -397.4 -730.0 

% - -0.3% -0.5% -5.5% -8.0% -39.6% -72.7% 

Product 

Conversion 

Costs 

2009$ 

millions - 4 5 18 24 166 383 

Capital 

Conversion 

Costs 

2009$ 

millions - 0 2 48 71 328 536 

Total 

Conversion 

Costs 

2009$ 

millions - 4 7 66 95 494 919 

TSL 1 represents the baseline CEF for 120V electric compact clothes dryers (product 

class 2), 240V electric compact clothes dryers (product class 3), 240V compact ventless clothes 

dryers (product class 5), and electric combination ventless clothes dryers (product class 6). TSL 

1 represents a CEF of 3.56 for standard-size vented electric clothes dryers (product class 1) and a 

CEF of 3.16 for gas vented clothes dryers (product class 4). At TSL 1, DOE estimates impacts on 

INPV to range -$2.55 million to -$2.62 million, or a change in INPV of -0.3 percent. At this 

proposed level, industry free cash flow is estimated to decrease by approximately 1.6 percent to 

$68.6 million, compared to the base-case value of $69.7 million in the year leading up to the 

proposed energy conservation standards. 

The design options DOE analyzed for product class 1 and 4 include lowering standby 

power consumption only. Standby power changes would result in only minor changes to baseline 

products and would take a minimal effort by manufacturers to comply with the amended energy 

294 
 

 

 

 

 

 

 

 

 

 

 

 

conservation standards. The standby power changes at TSL 1 would require relatively small 

product development efforts to reach the CEF levels and would not change the assembly of 

currently products, greatly limiting the necessary capital conversion costs. In addition, the design 

options for standby power do not add significant costs to existing products. Therefore, the impact 

on manufacturers is very small at TSL 1. 

TSL 2 represents a CEF of 3.61 for product class 1, a CEF of 3.61 for product class 2, a 

CEF of 3.27 for product class 3, a CEF of 3.20 for product class 4, a CEF of 2.69 for product 

class 5, and a CEF of 2.56 for product class 6. At TSL 2, DOE estimates impacts on INPV to 

range -$3.6 million to -$4.9 million, or a change in INPV of -0.4 percent to -0.5 percent. At this 

proposed level, industry free cash flow is estimated to decrease by approximately 3.0 percent to 

$67.6 million, compared to the base-case value of $69.7 million in the year leading up to the 

proposed energy conservation standards. 

The design options analyzed at TSL 2 for product classes 1 through 5 represent 

improvements to standby power consumption only. The changes required at TSL 2 would not 

greatly alter baseline products for these product classes because these analyzed design options 

are small component changes for standby power for product classes 1 through 5.The design 

options analyzed for product class 6 include changes to active mode power consumption. 

However, these active mode changes for product class 6 are also relatively minor and would take 

a minimal effort by manufacturers to comply with the amended energy conservation standards. 

For product class 6, the analyzed design option for active mode is automatic cycle termination 

technology which adds very little cost to the product and takes minimal capital and product 

295 
 

 

 

 

 

 

 

 

 

 

 

 

conversion costs to implement. Because the changes for product class 1 through 5 only include 

standby power changes and the active mode changes for product class 6 are minor, the impact on 

manufacturers is very small at TSL 2. 

The efficiency requirements for product classes 2 to 6 are the same at TSL 3 as at TSL 2. 

TSL 3, however, represents a further improvement to a CEF of 3.73 for product class 1. At TSL 

3, DOE estimates impacts on INPV to range from -$41.1 million to -$55.5 million, or a change 

in INPV of -4.1 percent to -5.5 percent. At this proposed level, industry free cash flow is 

estimated to decrease by approximately 34.2 percent to $45.9 million, compared to the base-case 

value of $69.7 million in the year leading up to the proposed energy conservation standards. 

The design options DOE analyzed for product class 1 include improvements to standby 

and active power consumption (airflow improvements, a dedicated heater duct, and an open 

cylinder drum). While the actual design path taken by manufacturers could vary at TSL 3, these 

technologies represent incremental improvements and are well known in the industry. The 

changes for design options analyzed for product class 1 would require both changes to 

production equipment and product development costs. These design options would not greatly 

alter the production process for product class 1 and could be made within most existing products. 

The conversion costs to implement these changes are also relatively low compared to the total 

value of the industry. The industry impacts would increase at TSL 3, however, because for 

product class 1, manufacturers would have to make changes for a large volume of the common 

standard-size electric models. 

296 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

TSL 4 represents the baseline efficiency for product classes 5 and 6. TSL 4 also 

represents the same efficiency requirements for product classes 2 and 3 as TSL 2 and TSL 3. 

TSL 4 also has the same efficiency requirements for product class 1 as TSL 3, but represents a 

3.30 CEF for product class 4. At TSL 4, DOE estimates impacts on INPV to range -$64.5 million 

to -$80.6 million, or a change in INPV of -6.4 percent to -8.0 percent. At this proposed level, 

industry free cash flow is estimated to decrease by approximately 49.8 percent to $35.0 million, 

compared to the base-case value of $69.7 million in the year leading up to the proposed energy 

conservation standards. 

The impacts at TSL 4 are due primarily to the efficiency requirements for product classes 

1 and 4 because all other product classes are at baseline efficiency or could be met with changes 

to standby power consumption. For both product classes 1 and 4, DOE analyzed changes to 

standby power consumption and the same improvements to active mode power consumption for 

both gas and electric units (airflow improvements, a dedicated heater duct, and an open cylinder 

drum). As with TSL 3, while the actual design path taken by manufacturers could vary at TSL 4, 

these technologies represent incremental improvements to most products and are well known in 

the industry. Industry impacts would increase at TSL 4, however, because for both product 

classes 1 and 4, the changes would require improvements in the most common standard-size gas 

and electric products on the market today. The changes for design options analyzed for product 

class 1 and 4 would require both changes to production equipment and product development 

costs. These design options would not greatly alter the production processes for either product 

class and could be made within most existing products. The conversion costs to implement these 

297 
 

 

 

 

 

 

 

 

 

 

 

 

changes for both product class 1 and 4 are still relatively low compared to the total value of the 

industry. 

TSL 5 represents a CEF of 4.08 for product class 1, a CEF of 4.08 for product class 2, a 

CEF of 3.60 for product class 3, a CEF of 3.61 for product class 4, a CEF of 2.80 for product 

class 5, and a CEF of 2.56 for product class 6. At TSL 5, DOE estimates impacts on INPV to 

range -$176.5 million to -$397.4 million, or a change in INPV of -17.6 percent to -39.6 percent. 

At this proposed level, industry free cash flow is estimated to decrease by approximately 249.7 

percent to -$104.4 million, compared to the base-case value of $69.7 million in the year leading 

up to the proposed energy conservation standards. 

Most of the impacts on INPV at TSL 5 are due to the efficiency requirements for product 

classes 1 through 4. Very few products on the market today meet the efficiency requirements at 

TSL 5, and for product classes 1 through 4, TSL 5 represents the most efficient units currently on 

the market. The design options DOE analyzed for these product classes included similar design 

options for all product classes as for product classes 1 and 4 at TSL 4 (airflow improvements, a 

dedicated heater duct, and an open cylinder drum) plus additional changes. In addition to airflow 

improvements, a dedicated heater duct, and an open cylinder drum, the design options analyzed 

by DOE also include modulating heat, inlet air preheating, and a more efficient fan motor. Out of 

all these design options used the reach the required efficiencies at TSL 5, inlet air preheating 

would require the most substantial changes to existing products because it would change the 

ducting system. This change would impact drum stamping equipment and, possibly, the 

fabrication of the cabinets for some product lines. The impacts also increase dramatically at TSL 

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5 due to the large increase in production costs for the additional design options beyond those 

needed to reach the required efficiencies at TSL 4. The large incremental costs result in lower 

shipments due to the price elasticity. These additional costs also cause a greater impact on INPV 

if manufactures are unable to earn additional profit on these added costs (under the preservation 

of operating profit markup scenario). 

TSL 6 represents the max-tech level for all product classes. The max-tech level 

corresponds to a CEF of 5.42 for product class 1, a CEF of 5.41 for product class 2, a CEF of 

4.89 for product class 3, a CEF of 3.61 for product class 4, a CEF of 4.03 for product class 5, and 

a CEF of 3.69 for product class 6. At TSL 6, DOE estimates impacts on INPV to range -$303.9 

million to -$730.0 million, or a change in INPV of -30.3 percent to -72.7 percent. At this 

proposed level, industry free cash flow is estimated to decrease by approximately 467.5 percent 

to -$256.2 million, compared to the base-case value of $69.7 million in the year leading up to the 

proposed energy conservation standards. 

At TSL 6, the efficiency requirements for all electric clothes dryers would effectively 

require a heat pump clothes dryer. Currently, there are no heat pump clothes dryers on the market 

in the United States. Manufacturing exclusively heat pump clothes dryers would be extremely 

disruptive to existing manufacturing facilities. A heat pump standard would require a total 

renovation of existing facilities and would force the industry to design completely new clothes 

dryer platforms. The capital conversion costs for these changes are extremely large―more than 

double the capital conversion costs calculated for these products to meet TSL 5. The product 

development costs to manufacturer heat pump clothes dryers also increase substantially because 

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manufacturers must not only redesign clothes washer platforms, but also design the heat pump 

system. Manufacturers also indicated that training their service and installation network to use a 

completely different technology would be extremely costly, as would the cost to educate 

consumers. Finally, the impacts on INPV are also great at TSL 6 because the cost of a heat pump 

clothes dryer is more than double a minimally compliant clothes dryer in the market today. If 

manufactures are unable to earn additional profit on these production costs, profitability is 

severely impacted. 

Cash Flow Analysis Results for Room Air Conditioners 

To assess the lower (less severe) end of the range of potential impacts on the room air 

conditioner industry, DOE modeled the flat markup scenario. The flat markup scenario assumes 

that in the standards case manufacturers would be able to pass the higher productions costs 

required for more efficient products on to their customers. Specifically, the industry would be 

able to maintain its average base-case gross margin, as a percentage of revenue, despite higher 

product costs. In general, the larger the product price increases, the less likely manufacturers are 

to achieve the cash flow from operations calculated in this scenario because the less likely it is 

that manufacturers would be able to fully markup these larger cost increases. 

To assess the higher (more severe) end of the range of potential impacts on the room air 

conditioner industry, DOE modeled the preservation of operating profit markup scenario. 

Through its discussion with manufacturers, DOE found that manufacturers are faced with 

significant market pressure to keep prices low. Consumers are accustomed to certain price points 

for room air conditioners, and they could forgo their purchases if prices increased significantly 

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because many purchases are weather-dependent impulse buys. As a result, several key retailers 

exert their purchasing power to pressure manufacturers to offer product lines at low prices. 

Higher efficiency units that earn a premium in the base case are bundled with additional features 

that drive higher prices. Thus, manufacturers are skeptical that customers would accept higher 

prices for increased energy efficiency because it does not command higher margins in the current 

market. Under such a scenario, it follows that the large retailers that compose the relatively 

concentrated customer base of the industry would not accept manufacturers fully passing through 

the additional cost of improved efficiency because consumers would be wary of higher prices. 

Therefore, to assess the higher (more severe) end of the range of potential impacts, DOE 

modeled the preservation of operating profit markup scenario in which higher energy 

conservation standards result in lower manufacturer markups. This markup is applied to both the 

minimum standard level and the de facto minimally efficient products due to the modeled 

efficiency migration over time. This scenario models manufacturers’ concerns that the higher 

costs of more efficient technology would harm profitability if the full cost increases cannot be 

passed on. The scenario represents the upper end of the range of potential impacts on 

manufacturers because no additional operating profit is earned on the investments required to 

meet the proposed amended energy conservation standards, while higher production costs erode 

profit margins and result in lower cash flows from operations. 

DOE used the main NIA shipment scenario for the both the lower- and higher-bound 

MIA scenarios that were used to characterize the potential INPV impacts. The shipment forecast 

is an important driver of the INPV results below (Table V-21 and Table V-22). The main NIA 

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shipment scenario includes a price elasticity effect, meaning higher prices in the standards case 

result in lower shipments. Lower shipments also reduce industry revenue, and, in turn, INPV. 

Table V-21 Manufacturer Impact Analysis for Room Air Conditioners – Flat Markup 

Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 5 6 

INPV 2009$ 

millions 956.0 911.8 890.6 890.3 844.7 869.5 875.9 

Change in 

INPV 

2009$ 

millions - (44.2) (65.4) (65.7) (111.3) (86.6) (80.2) 

% - -4.6% -6.8% -6.9% -11.6% -9.1% -8.4% 

Product 

Conversion 

Costs 

2009$ 

millions - 22 29 41 61 74 117 

Capital 

Conversion 

Costs 

2009$ 

millions - 46 69 61 109 101 193 

Total 

Conversion 

Costs 

2009$ 

millions - 68 98 102 171 176 310 

Table V-22 Manufacturer Impact Analysis for Room Air Conditioners – Preservation of 

Operating Profit Markup Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 5 6 

INPV 2009$ 

millions 956.0 871.1 843.3 843.6 778.4 771.6 611.5 

Change in 

INPV 

2009$ 

millions - (84.9) (112.7) (112.4) (177.6) (184.4) (344.5) 

(% - -8.9% -11.8% -11.8% -18.6% -19.3% -36.0% 

Product 

Conversion 

Costs 

2009$ 

millions - 22 29 41 61 74 117 

Capital 

Conversion 

Costs 

2009$ 

millions - 46 69 61 109 101 193 

Total 

Conversion 

Costs 

2009$ 

millions - 68 98 102 171 176 310 

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TSL 1 represents a CEER of 9.30 for product class 8A (without reverse cycle and without 

louvered sides―8,000 to 10,999 Btu/h) and product class 8B (without reverse cycle and without 

louvered sides―11,000 to 13,999 Btu/h); 9.40 for product class 5A (without reverse cycle and 

with louvered sides―20,000 to 24,999 Btu/h) and product class 5B (without reverse cycle and 

with louvered sides―25,000 Btu/h and more); 10.10 for product class 1 (without reverse cycle 

and with louvered sides―less than 6,000 Btu/h); and 10.70 for product class 3 (without reverse 

cycle and with louvered sides―8,000 to 13,999 Btu/h). At TSL 1, DOE estimates impacts on 

INPV to range from -$44.2 million to -$84.9 million, or a change in INPV of -4.6 percent to -8.9 

percent. At this proposed level, industry free cash flow is estimated to decrease by approximately 

27.7 percent to $62.4 million, compared to the base-case value of $86.3 million in the year 

leading up to the proposed energy conservation standards. 

The INPV impacts at TSL 1 are relatively minor, in part because the vast majority of 

manufacturers produce units that exceed this level (such as, ENERGY STAR and other high 

efficiency units) in significant volumes. Approximately 60 percent of product class 3 shipments, 

85 percent of product class 5A and 5B shipments, and 90 percent of product class 8A and 8B 

shipments currently meet this TSL. By contrast, the vast majority of product class 1 shipments 

are baseline units. Although most of the design options DOE analyzed at this proposed level are 

one-for-one component swaps, some more complex design options that would be required at 

TSL 1 necessitate more substantial changes. These design options that have a significant impact 

on conversion costs at TSL 1 are heat exchanger changes and increased chassis volumes. 

Changes to the condenser or evaporator require machinery for new dies for every product line 

and require greater design effort than component swaps. Increased chassis volumes require a 

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complete redesign of the product and substantial tooling to make the unit larger. Although some 

room air conditioners, particularly those in product class 1, will require these changes at TSL 1, 

these changes would not be required across the entire industry because the majority of units in 

most product classes already meet TSL 1. As such, DOE estimated total product conversion costs 

of $22 million and capital conversion costs of $46 million, which is relatively low compared to 

the industry value of $956 million. 

The efficiency requirements for product class 3, product class 5A, product class 5B, 

product class 8A, and product class 8B are the same at TSL 2 as TSL 1. Thus, the only change 

from TSL 1 occurs for product class 1, which requires a CEER of 10.60 at TSL 2. DOE 

estimates the INPV impacts at TSL 2 range from -$65.4 million to -$112.7 million, or a change 

in INPV of -6.8 percent to -11.8 percent. At this proposed level, the industry cash flow is 

estimated to decrease by approximately 40.5 percent to $51.4 million, compared to the base-case 

value of $86.3 million in the year leading up to the proposed energy conservation standard. 

The additional impacts at TSL 2 relative to TSL 1 result from the further improvements 

manufacturers must make to meet a CEER of 10.6 for product class 1. Most units in product 

class 1 would need to increase their chassis size even further than at TSL 1 in order to meet TSL 

2, resulting in estimated product and capital conversion costs of $29 million and $69 million, 

respectively. 

TSL 3 represents different efficiency levels for every product class compared to TSL 2. 

TSL 3 represents the baseline CEERs of 8.47 and 8.48 for product classes 5A and 5B, 

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respectively, meaning that no amended standards would be set and no impacts on INPV would 

occur. TSL 3 represents a CEER of 9.50 for product class 8B, 9.60 for product class 8A, 10.10 

for product class 1, and 10.90 for product class 3. DOE estimates the INPV impacts at TSL 3 to 

range from -$65.7 million to -$112.4 million, or a change in INPV of -6.9 percent to -11.8 

percent. At this proposed level, the industry cash flow is estimated to decrease by approximately 

40.5 percent to $51.4 million, compared to the base-case value of $86.3 million in the year 

leading up to the standards. 

At TSL 3, several product classes require design options that increase conversion costs. 

For product class 1, some units would require increased chassis volumes, though not as 

substantially as at TSL 2. For product class 3, all smaller units would require chassis changes, 

driving the majority of the conversion costs at TSL 3. For product classes 8A and 8B, some 

changes to the heat exchangers would be required. However, no conversion costs would be 

applied to product classes 5A and 5B, resulting in total product and capital conversion costs at 

TSL 3 of $41 million and $61 million, respectively. 

TSL 4 represents the same efficiency requirements as TSL 3 for product classes 3, 8A, 

and 8B. For product class 5B, TSL 4 represents a CEER of 9.00. For product class 5A, TSL 4 

represents a CEER of 9.40, and for product class 1, TSL 4 represents a CEER of 11.10. DOE 

estimates the INPV impacts at TSL 4 to range from -$111.3 million to -$177.6 million, or a 

change in INPV of -11.6 percent to -18.6 percent. At this proposed level, the industry cash flow 

is estimated to decrease by approximately 69.1 percent to $26.7 million, compared to the basecase value of $86.3 million in the year leading up to the proposed energy conservation standards. 

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At TSL 4, significant changes to the manufacturing process would be required. Product 

classes 1, 5A, and 5B would all require increased chassis volumes, and product classes 1 and 5A 

would also require heat exchanger changes. These design options drive increases of $20 million 

in product conversion costs and $48 million in capital conversion costs compared to TSL 3. 

TSL 5 represents the same efficiency requirements as TSL 4 for product classes 1 and 

8B. For product classes 5A and 5B, TSL 5 represents the baseline CEERs of 8.47 and 8.48, 

respectively, so all impacts of TSL 4 on these product classes, such as chassis changes, would 

not be required. For product class 8A, TSL 5 represents a CEER of 10.00, and for product class 

3, TSL 5 represents a CEER of 11.50. DOE estimates the INPV impacts at TSL 5 to range from ­

$86.6 million to -$184.4 million, or a change in INPV of -9.1 percent to -19.3 percent. At this 

proposed level, the industry cash flow is estimated to decrease by approximately 69.3 percent to 

$26.5 million, compared to the base-case value of $86.3 million in the year leading up to the 

proposed energy conservation standards. 

At TSL 5, impacts are negative under both scenarios due to the high conversion costs that 

exist at TSL 5. Although capital conversion costs would be $8 million lower at TSL 5 than at 

TSL 4 due to the removal of any capital costs associated with product classes 5A and 5B (despite 

higher capital costs for product class 3), product conversion costs are $13 million higher at TSL 

5 compared to TSL 4 because a greater number of product lines would need to be redesigned at 

this level. 

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TSL 6 represents max-tech for all room air conditioners. The max-tech level corresponds 

to CEERs of 9.80, 10.02, 10.15, 10.35, 11.67, and 11.96 for product classes 5B, 8B, 5A, 8A, 1, 

and 3, respectively. DOE estimates the INPV impacts at TSL 6 to range from -$80.2 million to ­

$344.5 million, or a change in INPV of -8.4 percent to -36.0 percent. At this proposed level, the 

industry cash flow is estimated to decrease by 124.8 percent to -$21.4 million, compared to the 

base-case value of $86.3 million in the year leading up to the proposed energy conservation 

standards. 

At TSL 6, all products would need to be fully redesigned, resulting in large product and 

capital conversion costs of $117 million and $193 million, respectively. These conversion costs 

are mostly driven by the high-volume product classes 1 and 3 and their associated chassis and 

heat exchanger changes. 

. 

b. Impacts on Employment 

Clothes Dryer Employment Impacts 

For clothes dryers, DOE used the GRIM to estimate the domestic labor expenditures and 

number of domestic production workers in the base case and at each TSL from 2011 to 2043. 

DOE used statistical data from the most recent U.S. Census Bureau’s 2008 “Annual Survey of 

Manufacturers,” the results of the engineering analysis, and interviews with manufacturers to 

determine the inputs necessary to calculate industry-wide labor expenditures and domestic 

employment levels. Labor expenditures for the manufacture of a product are a function of the 

labor intensity of the product, the sales volume, and an assumption that wages in real terms 

remain constant. 

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In the GRIM, DOE used the labor content of each product and the manufacturing 

production costs from the engineering analysis to estimate the annual labor expenditures in the 

clothes dryers and room air conditioner industries. DOE used Census data and interviews with 

manufacturers to estimate the portion of the total labor expenditures that is attributable to 

domestic labor. 

The production worker estimates in this section only cover workers up to the linesupervisor level who are directly involved in fabricating and assembling a product within an 

Original Equipment Manufacturer (OEM) facility. Workers performing services that are closely 

associated with production operations, such as material handing with a forklift, are also included 

as production labor. DOE’s estimates account only for production workers who manufacture the 

specific products covered by this rulemaking. 

The employment impacts shown in Table V-23 represent the potential production 

employment that could result following amended energy conservation standards. The upper end 

of the results in this table estimates the total potential increase in the number of production 

workers after amended energy conservation standards. To calculate the total potential increase, 

DOE assumed that manufacturers continue to produce the same scope of covered products in 

domestic production facilities and domestic production is not shifted to lower-labor-cost 

countries. Because there is a real risk of manufacturers evaluating sourcing decisions in response 

to amended energy conservation standards, the lower end of the range of employment results in 

Table V-23 includes the estimated total number of U.S. production workers in the industry who 

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could lose their jobs if all existing production were moved outside of the United States. While 

the results present a range of employment impacts following the compliance date of amended 

energy conservation standards, the discussion below also includes a qualitative discussion of the 

likelihood of negative employment impacts at the various TSLs. Finally, the employment 

impacts shown are independent of the employment impacts from the broader U.S. economy, 

which are documented in chapter 13 of the direct final rule TSD. 

Using the GRIM, DOE estimates that in the absence of amended energy conservation 

standards, there would be 4,426 domestic production workers involved in manufacturing 

residential clothes dryers in 2014. Using 2008 Census Bureau data and interviews with 

manufacturers, DOE estimates that approximately three-quarters of clothes dryers sold in the 

United States are manufactured domestically. Table V-23 shows the range of the impacts of 

potential amended energy conservation standards on U.S. production workers in the clothes dryer 

industry. 

Table V-23 Potential Changes in the Total Number of Domestic Clothes Dryer Production 

Workers in 2014 

Base 

Case 

1 2 3 4 5 6 

Total Number of 

Domestic Production 

Workers in 2014 3,962 3,962 3,965 4,370 4,420 5,040 6,218 

(without changes in 

production locations) 

Potential Changes in 

Domestic Production 

Workers in 2014 * 

- 0 ­

(3,962) 

3 ­

(3,962) 

408 ­

(3,962) 

458 ­

(3,962) 

1,078 ­

(3,962) 

2,256 ­

(3,962) 

* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers. 

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All examined TSLs show relatively minor impacts on domestic employment levels at the 

lower end of the range. In particular, the design options used in the engineering analysis for TSL 

1 and TSL 2 almost exclusively involve changes to standby power. These TSLs would not 

measurably impact domestic employment levels. 

At TSL 3 through TSL 5, DOE analyzed design options for the most common product 

classes that would add labor content to the final product. If manufacturers continue to produce 

these more complex products in house, it is likely that employment would increase in response to 

the energy conservation standards. At TSL 3 through 5, greater levels of domestic production 

employment are also likely because, while requiring more labor, the product changes could be 

made within existing platforms. The ability to make product changes within existing platforms 

mitigates some of the pressure to find lower labor costs because this decision would add 

disruptions with suppliers and add capital costs. However, TSL 6 would effectively require heat 

pump clothes dryers for all electric units. Manufacturers indicated that such a drastic change to 

existing products could force them to consider moving domestic production to countries with 

lower labor costs. Besides the large capital conversion costs, the much higher labor content in 

heat pump clothes dryers would also put pressure on manufacturers to consider a lower-laborcost country. 

Room Air Conditioner Employment Impacts 

DOE’s research suggests that currently no room air conditioners are made domestically. 

All manufacturers or their domestic distributors do maintain offices in the United States to 

handle design, technical support, training, certification, and other requirements. As amended 

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energy conservation standards for room air conditioners are implemented, however, DOE does 

not anticipate any changes in domestic employment levels. 

c. Impacts on Manufacturing Capacity 

Clothes Dryers 

At TSL 1 through TSL 5, manufacturers could maintain capacity levels and continue to 

meet market demand under amended energy conservation standards. While the changes required 

at these TSLs would require changes that could be made within most existing designs, TSL 6, 

which would effectively require heat pump technology, could result in short-term capacity 

constraints. Significant changes to production facilities would be required if amended energy 

conservation standards effectively mandated heat pump clothes dryers at TSL 6. Several 

manufacturers stated that they could move all or part of their production if they were required 

exclusively manufacture heat pump clothes dryers. Because of these drastic changes, a 3-year 

time period between the announcement of the final rule and the compliance date of the amended 

energy conservation standard might not be sufficient to design and manufacture products that 

have yet to be introduced in the United States and which would require new dryer designs from 

each manufacturer that continued to offer electric clothes dryers for the United States market. 

Room Air Conditioners 

DOE anticipates that amended energy conservation standards would not significantly 

affect the production capacity of room air conditioner manufacturers. Manufacturers mentioned 

two issues that could potentially constrain capacity. One is the availability of high efficiency 

compressors, which are currently difficult to obtain. Because amended energy conservation 

311 
 

 

 

 

 

 

 

 

 

standards would cause the demand for high efficiency compressors to increase, manufacturers 

worried that they would not be able to obtain the quantities they need to maintain desired 

production levels. DOE understands that compressor availability is a concern at present. DOE 

does not believe this shortage will continue when amended standards take effect in 2014 because 

the number of R-410A compressors available for the room air conditioner industry has already 

greatly expanded since the ban on R-22 took effect. Because there is a 3-year delay between the 

announcement of the final rule and the compliance date of the amended energy conservation 

standard, DOE believes suppliers will have sufficient time to anticipate demand and ramp up 

production of high efficiency compressors for room air conditioners. 

The second potential capacity constraint involves changes to existing chassis sizes, which 

could be required by amended energy conservation standards. Manufacturers stated that 

increasing chassis volume requires significant product development and capital investments, 

which could severely disrupt production at their facilities. DOE understands that increasing 

chassis volume causes substantial conversion costs, which are quantified in the GRIM. DOE 

does not believe, however, that the proposed standards would significantly affect production 

capacity. Even though chassis size increases require large capital and product conversion costs, 

this design option is not required across all analyzed product classes. In addition, manufacturers 

were more concerned about the capital and product conversion costs to make these changes than 

having a three year implementation period to do so, and DOE has accounted for these costs in the 

establishment of the room air conditioner standards. DOE believes that room air conditioner 

manufacturers will be able to increase chassis volumes by 2014 while maintaining production 

312 
 

 

 

 

 

 

 

capacity levels and continuing to meet market demand for all room air conditioner standard 

levels. 

d. Impacts on Sub-Groups of Manufacturers 

Using average cost assumptions to develop an industry cash-flow estimate is not adequate 

for assessing differential impacts among manufacturer subgroups. Small manufacturers, niche 

equipment manufacturers, and manufacturers exhibiting a cost structure substantially different 

from the industry average could be affected disproportionately. While DOE analyzed the impacts 

to small business in section VI.B, DOE did not identify any other subgroups for clothes dryers or 

room air conditioners for this rulemaking based on the results of the industry characterization. 

e. Cumulative Regulatory Burden 

While any one regulation may not impose a significant burden on manufacturers, the 

combined effects of several impending regulations may have serious consequences for some 

manufacturers, groups of manufacturers, or an entire industry. Assessing the impact of a single 

regulation may overlook this cumulative regulatory burden. In addition to energy conservation 

standards, other regulations can significantly affect manufacturers’ financial operations. Multiple 

regulations affecting the same manufacturer can strain profits and can lead companies to 

abandon product lines or markets with lower expected future returns than competing products. 

For these reasons, DOE conducts an analysis of cumulative regulatory burden as part of its 

rulemakings pertaining to appliance efficiency. 

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During previous stages of this rulemaking DOE identified a number of requirements, in 

addition to amended energy conservation standards for clothes dryers and room air conditioners, 

with which manufacturers of these products will be required to comply. Manufacturers provided 

comment on some of these regulations during the preliminary analysis period, including UL 

2158, which deals with fire containment in electric clothes dryers, and the Montreal Protocol, 

which banned R-22 refrigerant in new room air conditioners. DOE summarizes and addresses 

these comments in section IV.I.3.b and provides additional details of the cumulative regulatory 

burden analysis in chapter 12 of the direct final rule TSD. 

3. National Impact Analysis 

a. Significance of Energy Savings 

To estimate the energy savings through 2043 attributable to potential standards for 

clothes dryers and room air conditioners, DOE compared the energy consumption of these 

products under the base case to their anticipated energy consumption under each TSL. As 

discussed in section IV.E, the results account for a rebound effect of 15 percent for room air 

conditioners (that is, 15 percent of the total savings from higher product efficiency are “taken 

back” by consumers through more intensive use of the product). 

Table V-24 and Table V-25 present DOE’s forecasts of the national energy savings for 

each TSL for clothes dryers and room air conditioners, respectively. The savings were calculated 

using the approach described in section IV.G. Chapter 10 of the direct final rule TSD presents 

tables that also show the magnitude of the energy savings if the savings are discounted at rates of 

7 and 3 percent. Discounted energy savings represent a policy perspective in which energy 

314 
 

 

 

 

 

 

 

 

 

 

 

savings realized farther in the future are less significant than energy savings realized in the 

nearer term. 

Table V-24 Clothes Dryers: Cumulative National Energy Savings in Quads 

Product Class Trial Standard Level 

1 2 3 4 5 6 

Vented Electric Standard 0.000 0.038 0.347 0.347 1.268 2.923 

Vented Electric Compact 120V 0.000 0.000 0.000 0.000 0.002 0.003 

Vented Electric Compact 240V 0.000 0.001 0.001 0.001 0.006 0.016 

Vented Gas 0.000 0.009 0.009 0.038 0.164 0.164 

Ventless Electric Compact 240V 0.000 0.002 0.002 0.000 0.004 0.016 

Ventless Electric Combination 

Washer/Dryer 

0.000 0.011 0.011 0.000 0.011 0.023 

Total 0.00 0.062 0.37 0.386 1.455 3.145 

Table V-25 Room Air Conditioners: Cumulative National Energy Savings in Quads 

Product Class Trial Standard Level 

1 2 3 4 5 6 

Group 1 – 

includes PC 1 0.046 0.083 0.046 0.133 0.133 0.171 

Group 2 – 

includes PC 2, 

3, 4, 11 0.051 0.115 0.161 0.161 0.327 0.445 

Group 3 – 

includes PC 

5A, 9, 13 0.001 0.001 0.000 0.001 0.000 0.008 

Group 4 – 

includes PC 5B, 

10 0.000 0.000 0.000 0.000 0.000 0.003 

Group 5 – 

includes PC 6, 

7, 8A, 12 0.004 0.004 0.006 0.006 0.014 0.021 

Group 6 – 

includes PC 8B, 

14, 15, 16 0.002 0.002 0.004 0.004 0.004 0.016 

Total 0.105 0.205 0.218 0.305 0.477 0.665 

DOE also performed a sensitivity to investigate the impact of adding the rebound effect 

on the NES for the six energy efficiency TSLs for clothes dryers in appendix 10-C of the TSD. 

315 
 

 

 

 

 

 

 

 

As described in more detail in the TSD, at least one study estimated a potential rebound effective 

of 5 percent for clothes dryers. The NES results for this sensitively show a consistent, small 

decrease in potential energy savings from a standard. (refer to section IV.E for a discussion of 

the rebound effect). 

DOE recognizes that there may be forms of direct consumer rebound that have not been 

measured in previous studies. For example if automatic termination of clothes dryer cycles 

leaves clothes feeling humid or damp, then consumers may change to longer timed drying cycles. 

DOE is addressing this type of rebound effect in updates of its clothes dryer test procedure which 

provides for a field use factor that relates tested clothes dryer energy use to in-field energy use. 

If DOE detects a significant rebound effect from changing characteristics of clothes dryers, DOE 

will consider such effects in updates of its test procedure regulations and in future amendments 

to the energy conservation standards, as appropriate. 

b. Net Present Value of Consumer Costs and Benefits 

DOE estimated the cumulative NPV to the nation of the total costs and savings for 

consumers that would result from particular standard levels for clothes dryers and room air 

conditioners. In accordance with the OMB’s guidelines on regulatory analysis (OMB Circular A4, section E, September 17, 2003), DOE calculated NPV using both a 7-percent and a 3-percent 

real discount rate. The 7-percent rate is an estimate of the average before-tax rate of return to 

private capital in the U.S. economy, and reflects the returns to real estate and small business 

capital as well as corporate capital. DOE used this discount rate to approximate the opportunity 

cost of capital in the private sector, since recent OMB analysis has found the average rate of 

Comment [A9]: Change recommended by OIRA. 

316 
 

 

 

 

 

 

 

 

 

return to capital to be near this rate. In addition, DOE used the 3-percent rate to capture the 

potential effects of standards on private consumption (for example, through higher prices for 

products and the purchase of reduced amounts of energy). This rate represents the rate at which 

society discounts future consumption flows to their present value. This rate can be approximated 

by the real rate of return on long-term government debt (that is, yield on Treasury notes minus 

annual rate of change in the Consumer Price Index), which has averaged about 3 percent on a 

pre-tax basis for the last 30 years. 

. 

Table V-26 through Table V-29 show the consumer NPV results for each TSL DOE 

considered for clothes dryers and room air conditioners, using both a 7-percent and a 3-percent 

discount rate. In each case, the impacts cover the lifetime of products purchased in 2014–2043. 

See chapter 10 of the direct final rule TSD for more detailed NPV results. 

Table V-26 Cumulative Net Present Value of Consumer Benefits for Clothes Dryers, 3-

Percent Discount Rate 

Product Class 

Trial Standard Level 

1 2 3 4 5 6 

Billion 2009$ 

Vented Electric Standard 0.00 0.40 2.779 2.779 2.125 0.563 

Vented Electric Compact 120V 0.00 0.005 0.005 0.005 -0.013 -0.029 

Vented Electric Compact 240V 0.00 0.014 0.014 0.014 -0.066 -0.12 

Vented Gas 0.00 0.094 0.094 0.215 -1.906 -1.906 

Ventless Electric Compact 240V 0.00 0.019 0.019 0.00 -0.010 -0.036 

Ventless Electric Combination Washer/Dryer 0.00 0.086 0.086 0.00 0.086 0.00 

Total 0.00 0.619 2.998 3.013 0.216 -1.528 

317 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-27 Cumulative Net Present Value of Consumer Benefits for Clothes Dryers, 7-

Percent Discount Rate 

Product Class 

Trial Standard Level 

1 2 3 4 5 6 

Billion 2009$ 

Vented Electric Standard 0.00 0.168 1.017 1.017 -1.079 -5.025 

Vented Electric Compact 120V 0.00 0.002 0.002 0.002 -0.011 -0.024 

Vented Electric Compact 240V 0.00 0.006 0.006 0.006 -0.051 -0.101 

Vented Gas 0.00 0.039 0.039 0.051 -1.474 -1.474 

Ventless Electric Compact 240V 0.00 0.008 0.008 0.00 -0.013 -0.050 

Ventless Electric Combination Washer/Dryer 0.00 0.031 0.031 0.00 0.031 -0.043 

Total 0.00 0.254 1.104 1.076 -2.596 -6.716 

Table V-28 Cumulative Net Present Value of Consumer Benefits for Room Air 

Conditioners, 3-Percent Discount Rate 

Product Class 

Trial Standard Level 

1 2 3 4 5 6 

Billion 2009$ 

Group 1 – includes PC 1 0.276 0.362 0.276 0.245 0.245 -1.838 

Group 2 – includes PC 2, 3, 4, 11 0.427 0.902 1.162 1.162 1.121 -2.374 

Group 3 – includes PC 5A, 9, 13 -0.001 -0.003 0.00 -0.003 0.00 -0.481 

Group 4 – includes PC 5B, 10 -0.002 -0.008 0.00 -0.002 0.00 -0.229 

Group 5 – includes PC 6, 7, 8A, 12 0.036 0.036 0.049 0.049 0.066 -0.379 

Group 6 – includes PC 8B, 14, 15, 16 0.011 0.011 0.024 0.024 0.024 -0.314 

Total 0.747 1.30 1.511 1.474 1.456 -5.616 

Table V-29 Cumulative Net Present Value of Consumer Benefits for Room Air 

Conditioners, 7-Percent Discount Rate 

Product Class 

Trial Standard Level 

1 2 3 4 5 6 

Billion 2009$ 

Group 1 – includes PC 1 0.117 0.12 0.117 -0.02 -0.02 -1.386 

Group 2 – includes PC 2, 3, 4, 11 0.21 0.438 0.558 0.558 0.307 -2.084 

Group 3 – includes PC 5A, 9, 13 -0.002 -0.003 0.00 -0.003 0.00 -0.317 

Group 4 – includes PC 5B, 10 -0.002 -0.006 0.00 -0.002 0.00 -0.169 

Group 5 – includes PC 6, 7, 8A, 12 0.019 0.019 0.025 0.025 0.029 -0.262 

Group 6 – includes PC 8B, 14, 15, 16 0.006 0.006 0.012 0.012 0.012 -0.223 

Total 0.349 0.575 0.712 0.57 0.328 -4.441 

318 
 

 

 

 

 

 

 

 

 

DOE investigated the impact of different learning rates on the NPV for the six energy 

efficiency TSLs for room air conditioners and clothes dryers. The NPV results presented above 

in Table V.26 to Table V.29 are based on learning rates of 38.9% for room air conditioners and 

41.6% for clothes dryers, both of which are referred to as the “default” learning rates. DOE 

considered three learning rate sensitivities: (1) a “high learning” rate; (2) a “low learning” rate; 

and (3) a “no learning” rate. In addition, for clothes dryers there is a fourth sensitivity: “Clothes 

Dryers Only”. The “high learning” rates are 41.4-percent for room air conditioners and 42.9­

percent for clothes dryers. The “low learning’ rates are 31.0-percent for room air conditioners 

and 33.9-percent for clothes dryers. The “no learning” rate sensitivity, which is zero-percent for 

all products, assumes constant real prices over the entire forecast period. For clothes dryers, 

“clothes dryers only” is based on limited set of historical price data specifically for clothes dryers 

and the earning rate is 52.2-percent. Refer to section IV.F.1 for details on the development of the 

above learning rates. 

For room air conditioners, Table V.31 provides the annualized NPV of consumer benefits 

at a 7-percent discount rate for each of the six energy efficiency TSLs for the “default” learning 

rate and the three sensitivity cases. Table V.32 provides the same annualized NPVs but at a 3­

percent discount rate. For clothes dryers, Table V.33 provides the annualized NPV of consumer 

benefits at a 7-percent discount rate for each of the six energy efficiency TSLs for the “default” 

learning rate and the four sensitivity cases. Table V.34 provides the same annualized NPVs but 

at a 3-percent discount rate. Included as part of the annualized NPV in Table V.31 through 

Table V.34 is the annualized present value of monetized benefits from CO2 and NOX emissions 

reductions. Section V.B.6 below provides a complete description and summary of the monetized 

319 
 

 

 

 

 

 

 

 

 

 

 

 

 

benefits from CO2 and NOX emissions reductions. For details on the development of the 

learning rate sensitivities and the corresponding NPV results, see appendix 10-C of the final rule 

TSD. 

Table V-30 Room Air Conditioners: Annualized Net Present Value of Consumer Benefits 

including Annualized Present Value of Monetized Benefits from CO2 and NOX Emissions 

Reductions for Energy Efficiency TSLs for Products Shipped in 2014-2043 (3 Percent 

Discount Rate) 

Learning Rate (LR) 

Trial 

Standard 

Level 

Default: 

LRRoomAC =38.9% 

Low Sensitivity: 

LRRoomAC =31.0% 

High Sensitivity: 

LRRoomAC =41.4% 

No Learning: 

LR = 0% 

(constant real prices) 

Billion 2009$ 

1 0.079 0.075 0.081 0.059 

2 0.080 0.076 0.082 0.061 

3 0.092 0.088 0.093 0.072 

4 0.096 0.088 0.098 0.061 

5 0.106 0.091 0.111 0.037 

6 (0.241) (0.289) (0.226) (0.463) 

Parentheses indicate negative (-) values. 

Table V-31 Room Air Conditioners: Annualized Net Present Value of Consumer Benefits 

including Annualized Present Value of Monetized Benefits from CO2 and NOX Emissions 

Reductions for Energy Efficiency TSLs for Products Shipped in 2014-2043 (7 Percent 

Discount Rate) 

Learning Rate (LR) 

Trial 

Standard 

Level 

Default: 

LRRoomAC =38.9% 

Low Sensitivity: 

LRRoomAC =31.0% 

High Sensitivity: 

LRRoomAC =41.4% 

No Learning: 

LR = 0% 

(constant real prices) 

Billion 2009$ 

1 0.059 0.055 0.060 0.041 

2 0.060 0.057 0.061 0.043 

3 0.072 0.068 0.073 0.056 

4 0.066 0.060 0.069 0.037 

5 0.058 0.045 0.062 (0.000) 

6 (0.313) (0.355) (0.300) (0.502) 

Parentheses indicate negative (-) values. 

Table V-32 Clothes Dryer: Annualized Net Present Value of Consumer Benefits including 

Annualized Present Value of Monetized Benefits from CO2 and NOX Emissions Reductions 

for Energy Efficiency TSLs for Products Shipped in 2014-2043 (3 Percent Discount Rate) 

Learning Rate (LR) 

320 
 

 

 

 

 

 

 

 

Trial 

Standard 

Level 

Default: 

LRCD =41.6% 

Low 

Sensitivity: 

LRCD =33.9% 

High 

Sensitivity: 

LRCD =42.9% 

No Learning: 

LR = 0% 

(constant real 

prices) 

Sensitivity 

(Clothes 

Dryers 

Only): 

LR = 52.2% 

Billion 2009$ 

1 0.001 0.001 0.001 0.001 0.001 

2 0.036 0.036 0.036 0.035 0.036 

3 0.178 0.173 0.179 0.158 0.183 

4 0.180 0.175 0.181 0.156 0.186 

5 0.110 0.033 0.121 (0.220) 0.199 

6 0.185 0.018 0.209 (0.531) 0.378 

Parentheses indicate negative (-) values. 

Table V-33 Clothes Dryer: Annualized Net Present Value of Consumer Benefits including 

Annualized Present Value of Monetized Benefits from CO2 and NOX Emissions Reductions 

for Energy Efficiency TSLs for Products Shipped in 2014-2043 (7 Percent Discount Rate) 

Learning Rate (LR) 

Trial 

Standard 

Level 

Default: 

LRCD =41.6% 

Low 

Sensitivity: 

LRCD =33.9% 

High 

Sensitivity: 

LRCD =42.9% 

No Learning: 

LR = 0% 

(constant real 

prices) 

Sensitivity 

(Clothes 

Dryers 

Only): 

LR = 52.2% 

Billion 2009$ 

1 0.001 0.001 0.001 0.001 0.001 

2 0.025 0.024 0.025 0.024 0.025 

3 0.114 0.110 0.114 0.098 0.118 

4 0.113 0.108 0.113 0.094 0.118 

5 (0.111) (0.176) (0.103) (0.375) (0.041) 

6 (0.282) (0.421) (0.263) (0.853) (0.130) 

Parentheses indicate negative (-) values. 

c. Impacts on Employment 

DOE develops estimates of the indirect employment impacts of potential standards on the 

economy in general. As discussed above, DOE expects energy conservation standards for clothes 

dryers and room air conditioners to reduce energy bills for consumers of these products, and the 

Comment [A10]: Change recommended by 

OIRA. 

321 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

resulting net savings to be redirected to other forms of economic activity. These expected shifts 

in spending and economic activity could affect the demand for labor. As described in section 

IV.J, to estimate these effects DOE used an input/output model of the U.S. economy. Table V-34 

presents the estimated net indirect employment impacts in 2020 and 2043 for the TSLs that DOE 

considered in this rulemaking. Chapter 13 of the direct final rule TSD presents more detailed 

results. 

Table V-34 Net Increase in Jobs from Indirect Employment Effects Under Clothes Dryer 

and Room Air Conditioner Trial Standard Levels 

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

thousands 

Residential Clothes Dryers 

2020 0.00 0.00 0.41 0.36 -1.37 -3.16 

2043 0.01 0.01 1.82 1.75 4.25 9.30 

Room Air Conditioners 

2020 0.90 0.88 0.97 1.34 2.04 3.22 

2043 0.74 0.73 0.74 1.16 1.94 3.07 

The input/output model suggests that today’s proposed standards are likely to increase the 

net demand for labor in the economy. The projected gains are very small, however, relative to 

total national employment (currently approximately 120 million). Moreover, neither the BLS 

data nor the input/output model DOE uses includes the quality or wage level of the jobs. 

4. Impact on Utility or Performance of Products 

As presented in section III.D.1.d of this notice, DOE concluded that none of the TSLs 

considered in this notice would reduce the utility or performance of the clothes dryers or room 

air conditioners under consideration in this rulemaking. DOE also notes that manufacturers of 

322 
 

 

 

 

 

 

 

 

 

 

 

these products currently offer clothes dryers and room air conditioners that meet or exceed 

today’s standards. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) 

5. Impact of Any Lessening of Competition 

DOE has also considered any lessening of competition that is likely to result from 

amended standards. The Attorney General determines the impact, if any, of any lessening of 

competition likely to result from a proposed standard, and transmits such determination to DOE, 

together with an analysis of the nature and extent of such impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) 

and (B)(ii)) 

DOE published a NOPR containing energy conservation standards identical to those set 

forth in today’s direct final rule and transmitted a copy of today’s direct final rule and the 

accompanying TSD to the Attorney General, requesting that the DOJ provide its determination 

on this issue. DOE will consider DOJ’s comments on the rule in determining whether to proceed 

with the direct final rule. DOE will also publish and respond to DOJ’s comments in the Federal 

Register in a separate notice. 

6. Need of the Nation to Conserve Energy 

An improvement in the energy efficiency of the products subject to today’s rule is likely 

to improve the security of the nation’s energy system by reducing overall demand for energy. 

Reduced electricity demand may also improve the reliability of the electricity system. As a 

measure of this reduced demand, Table V-35 presents the estimated reduction in electricity 

generating capacity in 2043 for the TSLs that DOE considered in this rulemaking. 

323 
 

 

 

 

 

 

 

 

 

 

 

Table V-35 Reduction in Electric Generating Capacity in 2043 Under Clothes Dryer and 

Room Air Conditioner Trial Standard Levels 

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

Gigawatts 

Clothes Dryers 0.002 0.060 0.358 0.345 1.27 2.27 

Room Air Conditioners 0.348 0.429 0.436 0.632 1.01 1.46 

Energy savings from amended standards for clothes dryers and room air conditioners are 

expected to produce environmental benefits in the form of reduced emissions of air pollutants 

and greenhouse gases associated with electricity production. Table V-36 provides DOE’s 

estimate of cumulative CO2, NOX, and Hg emissions reductions that would be expected to result 

from the TSLs considered in this rulemaking. In the environmental assessment (chapter 15 of the 

direct final rule TSD), DOE reports annual CO2, NOX, and Hg emissions reductions for each 

TSL. 

IV.L, DOE has not reported SO2 emissions reductions from 

power plants because there is uncertainty about the effect of energy conservation standards on 

the overall level of SO2 emissions in the United States due to SO2 emissions caps. DOE also did 

not include NOX emissions reduction from power plants in States subject to CAIR because an 

energy conservation standard would not affect the overall level of NOX emissions in those States 

due to the emissions caps mandated by CAIR. 

324 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-36 Emissions Reduction Estimated for Clothes Dryer and Room Air Conditioner 

Trial Standard Levels (cumulative for 2014 through 2043) 

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

Clothes Dryers 

CO2 million metric tons 0.119 2.99 17.75 18.67 70.47 186.6 

NOX thousand tons 0.097 2.41 14.26 15.14 57.26 151.3 

Hg tons 0.000 0.009 0.053 0.051 0.188 0.569 

Room Air Conditioners 

CO2 million metric tons 9.83 11.88 12.49 17.4 26.89 37.68 

NOX thousand tons 8.02 9.69 10.2 14.2 21.91 30.69 

Hg tons 0.012 0.015 0.017 0.022 0.032 0.044 

DOE also estimated monetary benefits likely to result from the reduced emissions of CO2 

and NOX that DOE estimated for each of the TSLs considered for clothes dryers and room air 

conditioners. In order to make this calculation similar to the calculation of the NPV of consumer 

benefit, DOE considered the reduced emissions expected to result over the lifetime of products 

shipped in 2014-2043. Thus, the emissions reductions extend past 2043. 

As discussed in section IV.M, DOE used values for the SCC developed by an interagency 

process. The four values for CO2 emissions reductions resulting from that process (expressed in 

2009$) are $4.9/ton (the average value from a distribution that uses a 5-percent discount rate), 

$22.1/ton (the average value from a distribution that uses a 3-percent discount rate), $36.3/ton 

(the average value from a distribution that uses a 2.5-percent discount rate), and $67.1/ton (the 

th 95 -percentile value from a distribution that uses a 3-percent discount rate). These values 

correspond to the value of emission reductions in 2010; the values for later years are higher due 

to increasing damages as the magnitude of climate change increases. For each of the four cases, 

DOE calculated a present value of the stream of annual values using the same discount rate as 

was used in the studies upon which the dollar-per-ton values are based. Table V-37 and Table 

325 
 

 

 

 

 

 

 

 

V-38 present the global values of CO2 emissions reductions at each TSL. DOE calculated 

domestic values as a range from 7 percent to 23 percent of the global values, and these results are 

presented in Table V-39 and Table V-40 . 

Table V-37 Clothes Dryers: Estimates of Global Present Value of CO2 Emissions Reduction 

Under Trial Standard Levels 

TSL 

Million 2009$ 

5% discount 

rate, 

average * 

3% discount 

rate, average * 

2.5% discount 

rate, average * 

3% discount 

rate, 95th 

percentile * 

1 1 3 5 10 

2 15 79 134 239 

3 88 465 793 1417 

4 93 489 834 1490 

5 351 1848 3148 5626 

6 929 4894 8339 14902 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table incorporate the escalation of the SCC over 

time. 

Table V-38 Room Air Conditioners: Estimates of Global Present Value of CO2 Emissions 

Reduction Under Trial Standard Levels 

TSL 

Million 2009$ 

5% discount 

rate, 

average * 

3% discount 

rate, average * 

2.5% discount 

rate, average * 

3% discount 

rate, 95th 

percentile * 

1 43 212 357 648 

2 52 259 436 790 

3 55 271 455 826 

4 77 382 642 1164 

5 118 591 996 1803 

6 166 833 1404 2541 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table incorporate the escalation of the SCC over 

time. 

326 
 

 

 

 

 

 

 

 

 

Table V-39 Clothes Dryers: Estimates of Domestic Present Value of CO2 Emissions 

Reduction Under Trial Standard Levels 

TSL 

Million 2009$ * 

5% discount 

rate, average ** 

3% discount 

rate, average ** 

2.5% discount 

rate, average ** 

3% discount rate, 

95th percentile ** 

1 0.042 to 0.14 0.22 to 0.72 0.37 to 1.22 0.67 to 2.19 

2 1.04 to 3.43 5.50 to 18.1 9.37 to 30.8 16.7 to 55.0 

3 6.19 to 20.3 32.6 to 107 55.5 to 182 99.2 to 326 

4 6.51 to 21.4 34.3 to 113 58.4 to 192 104 to 343 

5 24.6 to 80.7 129 to 425 220 to 724 394 to 1294 

6 65.1 to 214 343 to 1126 584 to 1918 1043 to 3428 

* Domestic values are presented as a range between 7 percent and 23 percent of the global values. 

** Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table incorporate the escalation of the SCC over 

time. 

Table V-40 Room Air Conditioners: Estimates of Domestic Present Value of CO2 Emissions 

Reduction Under Trial Standard Levels 

TSL 

Million 2009$ * 

5% discount 

rate, average ** 

3% discount 

rate, average ** 

2.5% discount 

rate, average ** 

3% discount rate, 

95th percentile ** 

1 3.00 to 9.85 14.9 to 48.8 25.0 to 82.1 45.4 to 149 

2 3.64 to 12.0 18.1 to 59.6 30.5 to 100 55.3 to 182 

3 3.83 to 12.6 18.9 to 62.3 31.9 to 105 57.8 to 190 

4 5.36 to 17.6 26.7 to 87.8 45.0 to 148 81.5 to 268 

5 8.29 to 27.2 41.4 to 136 69.7 to 229 126 to 415 

6 11.6 to 38.3 58.3 to 192 98.3 to 323 178 to 584 

* Domestic values are presented as a range between 7 percent and 23 percent of the global values. 

** Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table incorporate the escalation of the SCC over 

time. 

DOE is well aware that scientific and economic knowledge about the contribution of CO2 

and other GHG emissions to changes in the future global climate and the potential resulting 

damages to the world economy continues to evolve rapidly. Thus, any value placed in this 

rulemaking on reducing CO2 emissions is subject to change. DOE, together with other Federal 

agencies, will continue to review various methodologies for estimating the monetary value of 

327 
 

 

 

 

 

 

reductions in CO2 and other GHG emissions. This ongoing review will consider the comments 

on this subject that are part of the public record for this and other rulemakings, as well as other 

methodological assumptions and issues. However, consistent with DOE’s legal obligations, and 

taking into account the uncertainty involved with this particular issue, DOE has included in this 

final rule the most recent values and analyses resulting from the ongoing interagency review 

process. 

DOE also estimated a range for the cumulative monetary value of the economic benefits 

associated with NOX emissions reductions anticipated to result from amended standards for 

clothes dryers and room air conditioners. The dollar-per-ton values that DOE used are discussed 

in section IV.M. Table V-41 and Table V-42 present the cumulative present values for each 

TSL calculated using seven-percent and three-percent discount rates. 

Table V-41 Clothes Dryers: Estimates of Present Value of NOX Emissions Reduction Under 

Trial Standard Levels 

TSL 

3% discount rate 

Million 2009$ 

7% discount rate 

Million 2009$ 

1 0.031 to 0.314 0.013 to 0.136 

2 0.759 to 7.8 0.328 to 3.37 

3 4.49 to 46.2 1.94 to 19.98 

4 4.77 to 49.02 2.06 to 21.2 

5 18.0 to 185 7.8 to 80.2 

6 47.6 to 490 20.6 to 212 

328 
 

 

 

 

 

 

 

 

 

 

 

 

Table V-42 Room Air Conditioners: Estimates of Present Value of NOX Emissions 

Reduction Under Trial Standard Levels 

TSL 

3% discount rate 

Million 2009$ 

7% discount rate 

Million 2009$ 

1 2.34 to 24.0 1.25 to 12.9 

2 2.83 to 29.1 1.50 to 15.4 

3 2.99 to 30.7 1.61 to 16.6 

4 4.16 to 42.7 2.2 to 22.6 

5 6.40 to 65.8 3.35 to 34.4 

6 8.96 to 92.1 4.64 to 47.7 

The NPV of the monetized benefits associated with emissions reductions can be viewed 

as a complement to the NPV of the consumer savings calculated for each TSL considered in this 

rulemaking. Table V-43 shows an example of the calculation of the combined NPV including 

benefits from emissions reductions for the case of TSL 4 for clothes dryers. Table V-44 through 

Table V-47 present the NPV values that result from adding the estimates of the potential 

economic benefits resulting from reduced CO2 and NOX emissions in each of four valuation 

scenarios to the NPV of consumer savings calculated for each TSL considered in this 

rulemaking, at both a 7-percent and 3-percent discount rate. The CO2 values used in the columns 

of each table correspond to the four scenarios for the valuation of CO2 emission reductions 

presented in section IV.M. 

329 
 

 

 

 

 

Table V-43 Adding Net Present Value of Consumer Savings to Present Value of Monetized 

Benefits from CO2 and NOX Emissions Reductions at TSL 4 for Clothes Dryers 

Category Present Value 

billion 2009$ 

Discount 

Rate 

Benefits 

Operating Cost Savings 

1.726 7% 

4.099 3% 

CO2 Reduction Monetized Value 

(at $4.9/metric ton) * 

0.093 5% 

CO2 Reduction Monetized Value 

(at $22.1/metric ton) * 

0.489 3% 

CO2 Reduction Monetized Value 

(at $36.3/metric ton) * 

0.834 2.5% 

CO2 Reduction Monetized Value 

(at $67.1/metric ton) * 

1.49 3% 

NOX Reduction Monetized Value 

(at $2,519/ton) * 

0.012 7% 

0.027 3% 

Total Monetary Benefits ** 2.227 7% 

4.615 3% 

Costs 

Total Incremental Installed Costs 0.65 7% 

1.086 3% 

Net Benefits/Costs 

Including CO2 and NOX 

** 1.58 7% 

3.53 3% 

* These values represent global values (in 2009$) of the SCC in 2010 under several scenarios. The values of $4.9, 

$22.1, and $36.3 per ton are the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent 

discount rates, respectively. The value of $67.1 per ton represents the 95th percentile of the SCC distribution 

calculated using a 3-percent discount rate. See section IV.M for details. The value for NOX (in 2009$) is the average 

of the low and high values used in DOE’s analysis. 

** Total Monetary Benefits for both the 3-percent and 7-percent cases utilize the central estimate of social cost of 

CO2 emissions calculated at a 3% discount rate, which is equal to $22.1/ton in 2010 (in 2009$). 

330 
 

 

 

 

 

 

 

Table V-44 Results of Adding Net Present Value of Consumer Savings (at 7-Percent 

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

Reductions Under Trial Standard Levels for Clothes Dryers 

TSL 

Consumer NPV at 7% Discount Rate added with: 

SCC Value of 

$4.9/metric ton 

CO2 

* and Low 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$22.1/metric ton 

CO2 

* and Medium 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$36.3/metric ton 

CO2 

* and Medium 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$67.1/metric ton 

CO2 

* and High 

Value for NOX 

** 

Billion 2009$ 

1 0.00061 0.00320 0.00540 0.00965 

2 0.0152 0.0804 0.136 0.243 

3 0.0903 0.476 0.804 1.437 

4 0.0950 0.501 0.846 1.512 

5 0.359 1.892 3.192 5.707 

6 0.950 5.010 8.455 15.114 

* These label values represent the global SCC in 2010, in 2009$. Their present values have been calculated with 

scenario-consistent discount rates. See section IV.M for a discussion of the derivation of these values. 

** Low Value corresponds to $447 per ton of NOX emissions. Medium Value corresponds to $2,519 per ton of NOX 

emissions. High Value corresponds to $4,591 per ton of NOX emissions. 

331 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-45 Results of Adding Net Present Value of Consumer Savings (at 3-Percent 

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

Reductions Under Trial Standard Levels for Clothes Dryers 

TSL 

Consumer NPV at 3% Discount Rate added with: 

SCC Value of 

$4.9/metric ton 

CO2 

* and Low 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$22.1/metric ton 

CO2 

* and Medium 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$36.3/metric ton 

CO2 

* and Medium 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$67.1/metric ton 

CO2 

* and High 

Value for NOX 

** 

Billion 2009$ 

1 0.00062 0.00330 0.00550 0.00983 

2 0.0157 0.0829 0.138 0.247 

3 0.0929 0.491 0.818 1.463 

4 0.0977 0.516 0.861 1.539 

5 0.369 1.949 3.250 5.812 

6 0.977 5.163 8.608 15.392 

* These label values represent the global SCC in 2010, in 2009$. Their present values have been calculated with 

scenario-consistent discount rates. See section IV.M for a discussion of the derivation of these values. 

** Low Value corresponds to $447 per ton of NOX emissions. Medium Value corresponds to $2,519 per ton of NOX 

emissions. High Value corresponds to $4,591 per ton of NOX emissions. 

Table V-46 Results of Adding Net Present Value of Consumer Savings (at 7-Percent 

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

Reductions Under Trial Standard Levels for Room Air Conditioners 

TSL 

Consumer NPV at 7% Discount Rate added with: 

SCC Value of 

$4.9/metric ton 

CO2 

* and Low 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$22.1/metric ton 

CO2 

* and Medium 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$36.3/metric ton 

CO2 

* and Medium 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$67.1/metric ton 

CO2 

* and High 

Value for NOX 

** 

Billion 2009$ 

1 0.044 0.219 0.364 0.661 

2 0.054 0.267 0.444 0.805 

3 0.0563 0.280 0.464 0.843 

4 0.0788 0.394 0.655 1.187 

5 0.122 0.610 1.015 1.838 

6 0.171 0.859 1.430 2.588 

* These label values represent the global SCC in 2010, in 2009$. Their present values have been calculated with 

scenario-consistent discount rates. See section IV.M for a discussion of the derivation of these values. 

** Low Value corresponds to $447 per ton of NOX emissions. Medium Value corresponds to $2,519 per ton of NOX 

emissions. High Value corresponds to $4,591 per ton of NOX emissions. 

332 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-47 Results of Adding Net Present Value of Consumer Savings (at 3-Percent 

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

Reductions Under Trial Standard Levels for Room Air Conditioners 

TSL 

Consumer NPV at 3% Discount Rate added with: 

SCC Value of 

$4.9/metric ton 

CO2 

* and Low 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$22.1/metric ton 

CO2 

* and Medium 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$36.3/metric ton 

CO2 

* and Medium 

Value for NOX 

** 

billion 2009$ 

SCC Value of 

$67.1/metric ton 

CO2 

* and High 

Value for NOX 

** 

Billion 2009$ 

1 0.045 0.226 0.370 0.672 

2 0.055 0.275 0.452 0.819 

3 0.0576 0.288 0.472 0.857 

4 0.0807 0.405 0.666 1.207 

5 0.125 0.627 1.032 1.869 

6 0.175 0.884 1.454 2.633 

* These label values represent the global SCC in 2010, in 2009$. Their present values have been calculated with 

scenario-consistent discount rates. See section IV.M for a discussion of the derivation of these values. 

** Low Value corresponds to $447 per ton of NOX emissions. Medium Value corresponds to $2,519 per ton of NOX 

emissions. High Value corresponds to $4,591 per ton of NOX emissions. 

Although adding the value of consumer savings to the values of emission reductions 

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

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

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

assessments of operating cost savings and the SCC are performed with different methods that use 

quite different time frames for analysis. The national operating cost savings is measured for the 

lifetime of products shipped in 2014–2043. The SCC values, on the other hand, reflect the 

present value of future climate-related impacts resulting from the emission of one ton of carbon 

dioxide in each year. These impacts continue well beyond 2100. 

333 
 

 

 

 

 

 

 

 

 

7. Other Factors 

The Secretary of Energy, in determining whether a standard is economically justified, 

may consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(VI))) In developing the direct final rule, DOE has also considered the Joint 

Petition submitted to DOE. DOE recognizes the value of consensus agreements submitted by 

parties in accordance with 42 U.S.C. 6295(p)(4) and has weighed the value of such consensus in 

establishing the standards set forth in today’s final rule. DOE has encouraged the submission of 

consensus agreements as a way to get diverse stakeholders together, to develop an independent 

and probative analysis useful in DOE standard setting, and to expedite the rulemaking process. 

DOE also believes that standard levels recommended in the consensus agreement may increase 

the likelihood for regulatory compliance, while decreasing the risk of litigation. 

C. Proposed Standards 

When considering proposed standards, the new or amended energy conservation standard 

that DOE adopts for any type (or class) of covered product shall be designed to achieve the 

maximum improvement in energy efficiency that DOE determines is technologically feasible and 

economically justified. (42 U.S.C. 6295(o)(2)(A)) In determining whether a standard is 

economically justified, DOE must determine whether the benefits of the standard exceed its 

burdens to the greatest extent practicable, in light of the seven statutory factors discussed 

previously. (42 U.S.C. 6295(o)(2)(B)(i)) The new or amended standard must also “result in 

significant conservation of energy.” (42 U.S.C. 6295(o)(3)(B)) 

334 
 

 

 

 

 

 

 

 

 

The Department considered the impacts of standards at each trial standard level, 

beginning with maximum technologically feasible level, to determine whether that level was 

economically justified. Where the max-tech level was not economically justified, DOE then 

considered the next most efficient level and undertook the same evaluation until it reached the 

highest efficiency level that is both technologically feasible and economically justified and saves 

a significant amount of energy. 

To aid the reader as DOE discusses the benefits and burdens of each trial standard level, 

DOE has included tables that present a summary of the results of DOE’s quantitative analysis for 

each TSL. In addition to the quantitative results presented in the tables, DOE also considers other 

burdens and benefits that affect economic justification. These include the impacts on identifiable 

subgroups of consumers, such as low-income households and seniors, who may be 

disproportionately affected by a national standard. Section V.B.1 presents the estimated impacts 

of each TSL for these subgroups. 

DOE also notes that the economics literature provides a wide-ranging discussion of how 

consumers trade off upfront costs and energy savings in the absence of government intervention. 

Much of this literature attempts to explain why consumers appear to undervalue energy 

efficiency improvements. This undervaluation suggests that regulation that promotes energy 

efficiency can produce significant net private gains (as well as producing social gains by, for 

example, reducing pollution). There is evidence that consumers undervalue future energy savings 

as a result of (1) a lack of information; (2) a lack of sufficient salience of the long-term or 

aggregate benefits; (3) a lack of sufficient savings to warrant delaying or altering purchases (for 

335 

Comment [A11]: Change recommended by 

OIRA. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

example, an inefficient ventilation fan in a new building or the delayed replacement of a water 

energy cost savings relative to available returns on other investments; (5) computational or other 

pump); (4) excessive focus on the short term, in the form of inconsistent weighting of future Comment [A12]: Change recommended by 

OIRA. 

Deleted: 3) inconsistent (that is, 

Deleted: ­

difficulties associated with the evaluation of relevant tradeoffs; and (6) a divergence in Deleted: )

incentives (that is, renter versus owner; builder vs. purchaser). Other literature indicates that with 

less than perfect foresight and a high degree of uncertainty about the future, consumers may 

trade off these types of investments at a higher than expected rate between current consumption 

and uncertain future energy cost savings. 

Deleted: 4 

Deleted: 5 

In its current regulatory analysis, potential changes in the benefits and costs of a 

regulation due to changes in consumer purchase decisions are included in two ways: (1) If 

consumers forego a purchase of a product in the standards case, this decreases sales for product 

manufacturers and the cost to manufacturers is included in the MIA, and (2) DOE accounts for 

energy savings attributable only to products actually used by consumers in the standards case; if 

a regulatory option decreases the number of products used by consumers, this decreases the 

potential energy savings from an energy conservation standard. DOE provides detailed estimates 

of shipments and changes in the volume of product purchases in chapter 9 of the TSD. However, 

DOE’s current analysis does not explicitly control for heterogeneity in consumer preferences, 

preferences across subcategories of products or specific features, or consumer price sensitivity 

variation according to household income (Reiss and White 2004). 

While DOE is not prepared at present to provide a fuller quantifiable framework for 

estimating the benefits and costs of changes in consumer purchase decisions due to an energy 

336 

Deleted: While DOE is not prepared at present to 

provide a fuller quantifiable framework for this 

discussion, DOE seeks comments on how to assess 

these possibilities. 

Comment [A13]: Change recommended by 

OIRA. 
 

 

 

 

 

 

 

conservation standard, DOE seeks comments on how to more fully assess the potential impact of 

energy conservation standards on consumer choice and how to quantify this impact in its 

regulatory analysis in future rulemakings. 

1. Benefits and Burdens of TSLs Considered for Clothes Dryers 

Table V-48 and Table V-49 present a summary of the quantitative impacts estimated for 

each TSL for clothes dryers. The efficiency levels contained in each TSL are described in section 

V.A. 

Comment [A14]: Change recommended by 

OIRA. 

337 
 

 

 

 

 

 

 

 

Table V-48 Summary of Results for Clothes Dryer Trial Standard Levels: National 

Impacts 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

National Energy Savings 

(quads) 0.00 0.062 0.37 0.39 1.45 3.14 

NPV of Consumer Benefits (2009$ billion) 

3% discount rate 0.00 0.62 3.00 3.01 0.22 (1.53) 

7% discount rate 0.01 0.25 1.10 1.08 (2.60) (6.72) 

Cumulative Emissions Reduction 

CO2 (million metric tons) 0.119 2.99 17.75 18.67 70.47 186.6 

NOX (thousand tons) 0.097 2.41 14.26 15.14 57.26 151.3 

Hg (ton) 0.000 0.009 0.053 0.051 0.188 0.569 

Value of Emissions Reduction 

CO2 (2009$ million) * 1 to 10 15 to 239 88 to 1417 93 to 1490 351 to 5626 929 to 14902 

NOX – 3% discount rate 

(2009 million) 

0.031 to 

0.314 0.759 to 7.8 4.49 to 46.2 4.77 to 49.0 18.0 to 185 47.6 to 490 

NOX – 7% discount rate 

(2009$ million) 

0.013 to 

0.136 

0.328 to 

3.37 1.94 to 20.0 2.06 to 21.2 7.8 to 80.2 20.6 to 212 

Generation Capacity 

Reduction (GW) ** 0.002 0.060 0.358 0.345 1.27 2.27 

Employment Impacts 

Total Potential Change in 

Domestic Production 

Workers in 2014 (thousands) 

0.00 to 

(3.96) 

0.00 to 

(3.96) 

0.41 to 

(3.96) 0.46 to (3.96) 1.08 to (3.96) 2.26 to (3.96) 

Indirect Domestic Jobs 

(thousands) ** 0.01 0.01 1.82 1.75 4.25 9.30 

Parentheses indicate negative (-) values. * Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** Changes in 2043. 

338 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-49 Summary of Results for Clothes Dryer Trial Standard Levels: Consumer and 

Manufacturer Impacts 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

Manufacturer Impacts 

Industry NPV (2009$ million) (2.5) to 

(2.5) 

(3.6) to 

(4.9) 

(41.1) to 

(55.5) 

(64.5) to 

(80.6) 

(176.5) to 

(397.4) 

(303.9) to 

(730.0) 

Industry NPV (% change) (0.3) to 

(0.3) 

(0.4) to 

(0.5) 

(4.1) to 

(5.5) 

(6.4) to 

(8.0) 

(17.6) to 

(39.6) 

(30.3) to 

(72.7) 

Consumer Mean LCC Savings * (2009$) 

Electric Standard $0 $2 $14 $14 ($30) ($146) 

Compact 120V $0 $14 $14 $14 ($99) ($264) 

Compact 240V $0 $8 $8 $8 ($99) ($246) 

Gas $0 $2 $2 $2 ($100) ($100) 

Ventless 240V $0 $20 $20 $0 ($42) ($177) 

Ventless Combination Washer/Dryer $0 $73 $73 $0 $73 ($166) 

Consumer Median PBP (years) ** 

Electric Standard 3.9 0.2 5.3 5.3 19.1 22.1 

Compact 120V n/a 0.9 0.9 0.9 36.1 40.1 

Compact 240V 0.0 0.9 0.9 0.9 45.1 38.2 

Gas 2.2 0.5 0.5 11.7 49.5 49.5 

Ventless 240V n/a 0.9 0.9 n/a 25.3 26.9 

Ventless Combination Washer/Dryer n/a 5.3 5.3 n/a 5.3 22.4 

Distribution of Consumer LCC Impacts 

Electric Standard 

Net Cost (%) 1% 0% 19% 19% 75% 81% 

No Impact (%) 98% 79% 25% 25% 1% 0% 

Net Benefit (%) 2% 21% 56% 56% 24% 19% 

Compact 120V 

Net Cost (%) 0% 4% 4% 4% 95% 95% 

No Impact (%) 100% 0% 0% 0% 0% 0% 

Net Benefit (%) 0% 96% 96% 96% 5% 5% 

Compact 240V 

Net Cost (%) 0% 2% 2% 2% 93% 95% 

No Impact (%) 100% 41% 41% 41% 4% 0% 

Net Benefit (%) 0% 56% 56% 56% 3% 5% 

Gas 

Net Cost (%) 1% 0% 0% 32% 95% 95% 

No Impact (%) 93% 85% 85% 42% 1% 1% 

Net Benefit (%) 7% 15% 15% 26% 4% 4% 

Ventless 240V 

Net Cost (%) 0% 0% 0% 0% 92% 88% 

No Impact (%) 100% 0% 0% 100% 0% 0% 

Net Benefit (%) 0% 100% 100% 0% 8% 12% 

Ventless Combination Washer/Dryer 

Net Cost (%) 0% 21% 21% 0% 21% 82% 

339 
 

 

 

 

 

 

 

 

 

 

 

 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

No Impact (%) 100% 0% 0% 100% 0% 0% 

Net Benefit (%) 0% 79% 79% 0% 79% 18% 

Parentheses indicate negative (-) values. * For LCCs, a negative value means an increase in LCC by the amount indicated. ** In some cases the standard level is the same as the baseline efficiency level, so no consumers are impacted and 

therefore calculation of a payback period is not applicable. 

DOE first considered TSL 6, which represents the max-tech efficiency levels. TSL 6 

would save 3.14 quads of energy, an amount DOE considers significant. Under TSL 6, the NPV 

of consumer benefit would be -$6.72 billion, using a discount rate of 7 percent, and -$1.53 

billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 6 are 186.6 Mt of CO2, 151.3 thousand tons 

of NOX, and 0.569 ton of Hg. The estimated monetary value of the CO2 emissions reductions at 

TSL 6 ranges from $929 million to $14,902 million. Total generating capacity in 2043 is 

estimated to decrease by 2.27 GW under TSL 6. 

At TSL 6, the average LCC impact is a cost (LCC increase) of $146 for electric standard 

clothes dryers, a cost of $264 for 120V compact clothes dryers, a cost of $246 for 240V compact 

clothes dryers, a cost of $100 for gas clothes dryers, a cost of $177 for ventless 240V clothes 

dryers, and a cost of $166 for combination washer/dryers. The median payback period is 22.1 

years for electric standard clothes dryers, 40.1 years for 120Vcompact clothes dryers, 38.2 years 

for 240V compact clothes dryers, 49.5 years for gas clothes dryers, 26.9 years for ventless 240V 

clothes dryers, and 22.4 years for combination washer/dryers. The fraction of consumers 

experiencing an LCC benefit is 19 percent for electric standard clothes dryers, 5 percent for 

340 
 

 

 

 

 

 

 

 

 

 

 

 

 

120V compact clothes dryers, 5 percent for 240V compact clothes dryers, 4 percent for gas 

clothes dryers, 12 percent for ventless 240V clothes dryers, and 18 percent for combination 

washer/dryers. The fraction of consumers experiencing an LCC cost is 81 percent for electric 

standard clothes dryers, 95 percent for 120Vcompact clothes dryers, 95 percent for 240V 

compact clothes dryers, 95 percent for gas clothes dryers, 88 percent for ventless 240V clothes 

dryers, and 82 percent for combination washer/dryers. 

At TSL 6, the projected change in INPV ranges from a decrease of $303.9 million to a 

decrease of $730.0 million. TSL 6 would effectively require heat pump clothes dryers for all 

electric clothes dryer product classes. Changing all electric models to use heat pump technology 

would be extremely disruptive to current manufacturing facilities and would require substantial 

product and capital conversion costs. In addition, the large cost increases would greatly harm 

manufacturer profitability if they were unable to earn additional operating profit on these 

additional costs. At TSL 6, DOE recognizes the risk of very large negative impacts if 

manufacturers’ expectations concerning reduced profit margins and large conversion costs are 

realized. If the high end of the range of impacts is reached as DOE expects, TSL 6 could result in 

a net loss of 72.6 percent in INPV to clothes dryer manufacturers. 

DOE concludes that at TSL 6 for residential clothes dryers, the benefits of energy 

savings, generating capacity reductions, emission reductions, and the estimated monetary value 

of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

benefits, the economic burden on a significant fraction of consumers due to the large increases in 

product cost, and the conversion costs and profit margin impacts that could result in a very large 

341 
 

 

 

 

 

 

 

 

 

 

 

 

 

reduction in INPV for the manufacturers. Consequently, the Secretary has concluded that TSL 6 

is not economically justified. 

DOE next considered TSL 5. TSL 5 would save 1.45 quads of energy, an amount DOE 

considers significant. Under TSL 5, the NPV of consumer benefit would be -$2.60 billion, using 

a discount rate of 7 percent, and $0.22 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 5 are 70.47 Mt of CO2, 57.26 thousand tons 

of NOX, and 0.188 tons of Hg. The estimated monetary value of the CO2 emissions reductions at 

TSL 5 ranges from $351 million to $5,626 million. Total generating capacity in 2043 is 

estimated to decrease by 1.27 GW under TSL 5. 

At TSL 5, the average LCC impact is a cost (LCC increase) of $30 for electric standard 

clothes dryers, a cost of $99 for 120Vcompact clothes dryers, a cost of $99 for 240V compact 

clothes dryers, a cost of $100 for gas clothes dryers, a cost of $42 for ventless 240V clothes 

dryers, and a savings of $73 for combination washer/dryers. The median payback period is 19.1 

years for electric standard clothes dryers, 36.1 years for 120Vcompact clothes dryers, 45.1 years 

for 240V compact clothes dryers, 49.5 years for gas clothes dryers, 25.3 years for ventless 240V 

clothes dryers, and 5.3 years for combination washer/dryers. The fraction of consumers 

experiencing an LCC benefit is 24 percent for electric standard clothes dryers, 5 percent for 

120Vcompact clothes dryers, 3 percent for 240V compact clothes dryers, 4 percent for gas 

clothes dryers, 8 percent for ventless 240V clothes dryers, and 79 percent for combination 

washer/dryers. The fraction of consumers experiencing an LCC cost is 75 percent for electric 

342 
 

 

 

 

 

 

 

 

 

standard clothes dryers, 95 percent for 120Vcompact clothes dryers, 93 percent for 240V 

compact clothes dryers, 95 percent for gas clothes dryers, 92 percent for ventless 240V clothes 

dryers, and 21 percent for combination washer/dryers. 

At TSL 5, the projected change in INPV ranges from a decrease of $176.5 million to a 

decrease of $397.4 million. While most changes at TSL 5 could be made within existing product 

design, redesigning units to the most efficient technologies on the market today would take 

considerable capital and product conversion costs. At TSL 5, DOE recognizes the risk of very 

large negative impacts if manufacturers are not able to earn additional operating profit from the 

additional production costs to reach TSL 5. If the high end of the range of impacts is reached as 

DOE expects, TSL 5 could result in a net loss of 39.6 percent in INPV to clothes dryer 

manufacturers. 

The Secretary concludes that at TSL 5 for residential clothes dryers, the benefits of 

energy savings, generating capacity reductions, emission reductions, and the estimated monetary 

value of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

benefits, the economic burden on a significant fraction of consumers due to the large increases in 

product cost, and the conversion costs and profit margin impacts that could result in a large 

reduction in INPV for the manufacturers. Consequently, the Secretary has concluded that TSL 5 

is not economically justified. 

343 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DOE then considered TSL 4. TSL 4 would save 0.39 quads of energy, an amount DOE 

considers significant. Under TSL 4, the NPV of consumer benefit would be $1.08 billion, using a 

discount rate of 7 percent, and $3.01 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 4 are 18.67 Mt of CO2, 15.14 thousand tons 

of NOX, and 0.051 ton of Hg. The estimated monetary value of the CO2 emissions reductions at 

TSL 4 ranges from $93 million to $1,490 million. Total generating capacity in 2043 is estimated 

to decrease by 0.345 GW under TSL 4. 

At TSL 4, DOE projects that the average LCC impact is a savings (LCC decrease) of $14 

for electric standard clothes dryers, a savings of $14 for 120Vcompact clothes dryers, a savings 

of $8 for 240V compact clothes dryers, a savings of $2 for gas clothes dryers, and no change for 

ventless 240V clothes dryers and combination washer/dryers. The median payback period is 5.3 

years for electric standard clothes dryers, 0.9 years for 120Vcompact clothes dryers, 0.9 years for 

240V compact clothes dryers, 11.7 years for gas clothes dryers, and is not applicable for ventless 

64 240V clothes dryers and combination washer/dryers. The fraction of consumers experiencing 

an LCC benefit is 56 percent for electric standard clothes dryers, 96 percent for 120Vcompact 

clothes dryers, 56 percent for 240V compact clothes dryers, 26 percent for gas clothes dryers, 

zero percent for ventless 240V clothes dryers, and zero percent for combination washer/dryers. 

The fraction of consumers experiencing an LCC cost is 19 percent for electric standard clothes 

dryers, 4 percent for 120Vcompact clothes dryers, 2 percent for 240V compact clothes dryers, 32 

64 For these product classes, the efficiency level at TSL 4 is the same as the baseline efficiency level, so no 

consumers are impacted and therefore calculation of a payback period is not applicable. 

344 
 

 

 

 

 

 

 

 

percent for gas clothes dryers, zero percent for ventless 240V clothes dryers, and zero percent for 

combination washer/dryers. 

At TSL 4, the projected change in INPV ranges from a decrease of $64.5 million to a 

decrease of $80.6 million. The design changes required at TSL 4 for the most common standardsize gas and electric products are incremental improvements that are well known in the industry 

but would still require moderate product and capital conversion costs to implement. At TSL 4, 

DOE recognizes the risk of negative impacts if manufacturers’ expectations concerning reduced 

profit margins are realized. If the high end of the range of impacts is reached as DOE expects, 

TSL 4 could result in a net loss of 8.0 percent in INPV to clothes dryer manufacturers. 

DOE concludes that at TSL 4 for residential clothes dryers, the benefits of energy 

savings, generating capacity reductions, emission reductions and the estimated monetary value of 

the CO2 emissions reductions, and positive NPV of consumer benefits outweigh the economic 

burden on some consumers due to the increases in product cost and the profit margin impacts 

that could result in a reduction in INPV for the manufacturers. 

In addition, the efficiency levels in TSL 4 correspond to the recommended levels in the 

consensus agreement, which DOE believes sets forth a statement by interested persons that are 

fairly representative of relevant points of view (including representatives of manufacturers of 

covered products, States, and efficiency advocates) and contains recommendations with respect 

to an energy conservation standard that are in accordance with 42 U.S.C. 6295(o). Moreover, 

DOE has encouraged the submission of consensus agreements as a way to get diverse 

345 
 

 

 

 

 

 

 

stakeholders together, to develop an independent and probative analysis useful in DOE standard 

setting, and to expedite the rulemaking process. DOE also believes that standard levels 

recommended in the consensus agreement may increase the likelihood for regulatory 

compliance, while decreasing the risk of litigation. 

After considering the analysis, comments to the preliminary TSD, and the benefits and 

burdens of TSL 4, the Secretary concludes that this trial standard level will offer the maximum 

improvement in efficiency that is technologically feasible and economically justified, and will 

result in the significant conservation of energy. Therefore, DOE today adopts TSL 4 for 

residential clothes dryers. The amended energy conservation standards for clothes dryers, 

expressed as CEF, are shown in Table V-50 . 

Table V-50 Amended Energy Conservation Standards for Clothes Dryers 

Residential Clothes Dryers 

Product Class 

Minimum CEF 

Levels 

lb/kWh 

1. Vented Electric, Standard (4.4 ft3 or greater capacity) 3.73 

2. Vented Electric, Compact (120 V) (less than 4.4 ft3 capacity) 3.61 

3. Vented Electric, Compact (240 V) (less than 4.4 ft3 capacity) 3.27 

4. Vented Gas 3.30 

5. Ventless Electric, Compact (240 V) (less than 4.4 ft3 capacity) 2.55 

6. Ventless Electric Combination Washer/Dryer 2.08 

2. Benefits and Burdens of TSLs Considered for Room Air Conditioners 

Table V-51 and Table V-52 present a summary of the quantitative impacts estimated for 

each TSL for room air conditioners. The efficiency levels contained in each TSL are described in 

section V.A. 

346 
 

 

 

 

 

 

 

Table V-51 Summary of Results for Room Air Conditioner Trial Standard Levels: National 

Impacts 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

National Energy Savings (quads) 0.105 0.205 0.218 0.305 0.477 0.665 

NPV of Consumer Benefits (2009$ billion) 

3% discount rate 0.75 1.30 1.51 1.47 1.46 (5.62) 

7% discount rate 0.35 0.57 0.71 0.57 0.33 (4.44) 

Cumulative Emissions Reduction 

CO2 (million metric tons) 9.83 11.9 12.5 17.4 26.9 37.7 

NOX (thousand tons) 8.02 9.69 10.2 14.2 21.9 30.7 

Hg (ton) 0.012 0.015 0.017 0.022 0.032 0.044 

Value of Emissions Reduction 

CO2 (2009$ million) * 43 to 648 52 to 790 55 to 826 77 to 1164 118 to 1803 166 to 2541 

NOX – 3% discount rate (2009$ 

million) 2.34 to 24.0 2.83 to 29.1 2.99 to 30.7 4.16 to 42.7 6.40 to 65.8 8.96 to 92.1 

NOX – 7% discount rate (2009$ 

million) 1.25 to 12.9 1.50 to 15.4 1.61 to 16.6 2.2 to 22.6 3.35 to 34.4 4.64 to 47.7 

Generation Capacity Reduction 

(GW) ** 0.348 0.429 0.436 0.632 1.01 1.46 

Employment Impacts 

Total Potential Changes in Domestic 

Production Workers in 2014 

(thousands) 

N/A N/A N/A N/A N/A N/A 

Indirect Domestic Jobs (thousands) ** 0.74 0.73 0.74 1.16 1.94 3.07 

Parentheses indicate negative (-) values. * Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions. 

** Changes in 2043. 

347 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-52 Summary of Results for Room Air Conditioner Trial Standard Levels: 

Consumer and Manufacturer Impacts 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

Manufacturer Impacts 

Industry NPV (2009$ million) (44.2) to 

(84.9) 

(65.4) to 

(112.7) 

(65.7) to 

(112.4) 

(111.3) to 

(177.6) 

(86.6) to 

(184.4) 

(80.2) to 

(344.5) 

Industry NPV (% change) (4.6) to 

(8.9) 

(6.8) to 

(11.8) 

(6.9) to 

(11.8) 

(11.6) to 

(18.6) 

(9.1) to 

(19.3) 

(8.4) to (36.0) 

Consumer Mean LCC Savings * (2009$) 

<6,000 Btu/h, with Louvers $9 $11 $9 $7 $7 ($58) 

8,000–13,999 Btu/h, with Louvers $16 $16 $22 $22 $22 ($38) 

20,000–24,999 Btu/h, with Louvers $6 $6 $0 $6 $0 ($214) 

>25,000 Btu/h, with Louvers $1 $1 $0 $1 $0 ($227) 

8,000–10,999 Btu/h, without Louvers $4 $4 $13 $13 $20 ($66) 

>11,000 Btu/h, without Louvers $5 $5 $11 $11 $11 ($64) 

Consumer Median PBP (years) ** 

<6,000 Btu/h, with Louvers 4.1 5.8 4.1 8.6 8.6 20.9 

8,000–13,999 Btu/h, with Louvers 0.0 0.0 2.8 2.8 7.1 14.7 

20,000–24,999 Btu/h, with Louvers 4.3 4.3 n/a 4.3 n/a 73.8 

>25,000 Btu/h, with Louvers 10.3 10.3 n/a 10.1 n/a 107.7 

8,000–10,999 Btu/h, without Louvers 1.5 1.5 2.1 2.1 4.9 25.2 

>11,000 Btu/h, without Louvers 2.6 2.6 3.7 3.7 3.7 25.9 

Distribution of Consumer LCC Impacts 

<6,000 Btu/h, with Louvers 

Net Cost (%) 21% 33% 21% 65% 65% 90% 

No Impact (%) 31% 31% 31% 1% 1% 0% 

Net Benefit (%) 48% 37% 48% 34% 34% 10% 

8,000–13,999 Btu/h, with Louvers 

Net Cost (%) 9% 9% 34% 34% 56% 77% 

No Impact (%) 60% 60% 2% 2% 1% 0% 

Net Benefit (%) 30% 30% 64% 64% 43% 22% 

20,000–24,999 Btu/h, with Louvers 

Net Cost (%) 5% 5% 0% 5% 0% 98% 

No Impact (%) 85% 85% 0% 85% 0% 2% 

Net Benefit (%) 10% 10% 0% 10% 0% 0% 

>25,000 Btu/h, with Louvers 

Net Cost (%) 11% 11% 0% 9% 0% 100% 

No Impact (%) 85% 85% 0% 88% 0% 0% 

Net Benefit (%) 4% 4% 0% 4% 0% 0% 

8,000–10,999 Btu/h, without Louvers 

Net Cost (%) 1% 1% 12% 12% 38% 92% 

No Impact (%) 90% 90% 25% 25% 6% 2% 

Net Benefit (%) 9% 9% 62% 62% 56% 6% 

>11,000 Btu/h, without Louvers 

348 
 

 

 

 

 

 

 

 

 

 

 

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 TSL 6 

Net Cost (%) 2% 2% 23% 23% 23% 93% 

No Impact (%) 90% 90% 31% 31% 31% 0% 

Net Benefit (%) 8% 8% 47% 47% 47% 7% 

Parentheses indicate negative (-) values. * For LCCs, a negative value means an increase in LCC by the amount indicated. ** In some cases the standard level is the same as the baseline efficiency level, so no consumers are impacted and 

therefore calculation of a payback period is not applicable. 

DOE first considered TSL 6, which represents the max-tech efficiency levels. TSL 6 

would save 0.665 quads of energy, an amount DOE considers significant. Under TSL 6, the NPV 

of consumer benefit would be -$4.44 billion, using a discount rate of 7 percent, and -$5.62 

billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 6 are 37.7 Mt of CO2, 30.7 thousand tons of 

NOX, and 0.044 tons of Hg. The estimated monetary value of the CO2 emissions reductions at 

TSL 6 ranges from $166 million to $2,541 million. Total generating capacity in 2043 is 

estimated to decrease by 1.46 GW under TSL 6. 

At TSL 6, the average LCC impact is a cost (LCC increase) of $58 for room air 

conditioners <6,000 Btu/h, with louvers; a cost of $38 for room air conditioners 8,000–13,999 

Btu/h, with louvers; a cost of $214 for room air conditioners 20,000–24,999 Btu/h, with louvers; 

a cost of $227 for room air conditioners >25,000 Btu/h, with louvers; a cost of $66 for room air 

conditioners 8,000–10,999 Btu/h, without louvers; and a cost of $64 for room air conditioners 

>11,000 Btu/h, without louvers. The median payback period is 20.9 years for room air 

conditioners <6,000 Btu/h, with louvers; 14.7 years for room air conditioners 8,000–13,999 

Btu/h, with louvers; 73.8 years for room air conditioners 20,000–24,999 Btu/h, with louvers; 

349 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

107.7 years for room air conditioners >25,000 Btu/h, with louvers; 25.2 years for room air 

conditioners 8,000–10,999 Btu/h, without louvers; and 25.9 years for room air conditioners 

>11,000 Btu/h, without louvers. The fraction of consumers experiencing an LCC benefit is 10 

percent for room air conditioners <6,000 Btu/h, with louvers; 22 percent for room air 

conditioners 8,000–13,999 Btu/h, with louvers; zero percent for room air conditioners 20,000– 

24,999 Btu/h, with louvers; zero percent for room air conditioners >25,000 Btu/h, with louvers; 6 

percent for room air conditioners 8,000–10,999 Btu/h, without louvers; and 7 percent for room 

air conditioners >11,000 Btu/h, without louvers. The fraction of consumers experiencing an LCC 

cost is 90 percent for room air conditioners <6,000 Btu/h, with louvers; 77 percent for room air 

conditioners 8,000–13,999 Btu/h, with louvers; 98 percent for room air conditioners 20,000– 

24,999 Btu/h, with louvers; 100 percent for room air conditioners >25,000 Btu/h, with louvers; 

92 percent for room air conditioners 8,000–10,999 Btu/h, without louvers; and 93 percent for 

room air conditioners >11,000 Btu/h, without louvers. 

At TSL 6, the projected change in INPV ranges from a decrease of $80.2 million to a 

decrease of $344.5 million. At TSL 6, DOE recognizes the risk of large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached as DOE expects, TSL 6 could result in a net loss of 36.0 percent 

in INPV to room air conditioner manufacturers. 

The Secretary concludes that at TSL 6 for room air conditioners, the benefits of energy 

savings, generating capacity reductions, emission reductions, and the estimated monetary value 

of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

350 
 

 

 

 

 

 

 

 

 

 

 

benefits, the economic burden on a significant fraction of consumers due to the large increases in 

product cost, and the capital conversion costs and profit margin impacts that could result in a 

large reduction in INPV for the manufacturers. Consequently, the Secretary has concluded that 

TSL 6 is not economically justified. 

DOE next considered TSL 5. TSL 5 would save 0.477 quads of energy, an amount DOE 

considers significant. Under TSL 5, the NPV of consumer benefit would be $0.33 billion, using a 

discount rate of 7 percent, and $1.46 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 5 are 26.9 Mt of CO2, 21.9 thousand tons of 

NOX, and 0.032 ton of Hg. The estimated monetary value of the CO2 emissions reductions at 

TSL 5 ranges from $118 million to $1,803 million. Total generating capacity in 2043 is 

estimated to decrease by 1.01 GW under TSL 5. 

At TSL 5, the average LCC impact is a savings (LCC decrease) of $7 for room air 

conditioners <6,000 Btu/h, with louvers; a savings of $22 for room air conditioners 8,000– 

13,999 Btu/h, with louvers; a savings of $0 for room air conditioners 20,000–24,999 Btu/h, with 

louvers; a savings of $0 for room air conditioners >25,000 Btu/h, with louvers; a savings of $20 

for room air conditioners 8,000–10,999 Btu/h, without louvers; and a savings of $11 for room air 

conditioners >11,000 Btu/h, without louvers. The median payback period is 8.6 years for room 

air conditioners <6,000 Btu/h, with louvers; 7.1 years for room air conditioners 8,000–13,999 

Btu/h, with louvers; not applicable for room air conditioners 20,000–24,999 Btu/h, with louvers 

351 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

65 or for room air conditioners >25,000 Btu/h, with louvers; 4.9 years for room air conditioners 

8,000–10,999 Btu/h, without louvers; and 3.7 years for room air conditioners >11,000 Btu/h, 

without louvers. The fraction of consumers experiencing an LCC benefit is 34 percent for room 

air conditioners <6,000 Btu/h, with louvers; 43 percent for room air conditioners 8,000–13,999 

Btu/h, with louvers; zero percent for room air conditioners 20,000–24,999 Btu/h, with louvers; 

zero percent for room air conditioners >25,000 Btu/h, with louvers; 56 percent for room air 

conditioners 8,000–10,999 Btu/h, without louvers; and 47 percent for room air conditioners 

>11,000 Btu/h, without louvers. The fraction of consumers experiencing an LCC cost is 65 

percent for room air conditioners <6,000 Btu/h, with louvers; 56 percent for room air 

conditioners 8,000–13,999 Btu/h, with louvers; zero percent for room air conditioners 20,000– 

24,999 Btu/h, with louvers; zero percent for room air conditioners >25,000 Btu/h, with louvers; 

38 percent for room air conditioners 8,000–10,999 Btu/h, without louvers; and 23 percent for 

room air conditioners >11,000 Btu/h, without louvers. 

At TSL 5, the projected change in INPV ranges from a decrease of $86.6 million to a 

decrease of $184.4 million. At TSL 5, DOE recognizes the risk of moderately negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached as DOE expects, TSL 5 could result in a net loss of 19.3 percent 

in INPV to room air conditioner manufacturers. 

The Secretary concludes that at TSL 5 for room air conditioners, the benefits of energy 

savings, positive NPV of consumer benefits, generating capacity reductions, emission 

65 In these cases the standard level is the same as the baseline efficiency level, so no consumers are impacted and 

therefore calculation of a payback period is not applicable. 

352 
 

 

 

 

 

 

 

 

 

 

 

reductions, and the estimated monetary value of the CO2 emissions reductions would be 

outweighed by the economic burden on a significant fraction of consumers in some product 

classes due to the large increases in product cost, and the capital conversion costs and profit 

margin impacts that could result in a moderate reduction in INPV for the manufacturers. In 

particular, the fraction of consumers experiencing an LCC cost is 56 percent for room air 

conditioners with 8,000–13,999 Btu/h, with louvers, which is the product class with the largest 

market share. Based on the above findings, the Secretary has concluded that TSL 5 is not 

economically justified. 

DOE then considered TSL 4. TSL 4 would save 0.305 quads of energy, an amount DOE 

considers significant. Under TSL 4, the NPV of consumer benefit would be $0.57 billion, using a 

discount rate of 7 percent, and $1.47 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 4 are 17.4 Mt of CO2, 14.2 thousand tons of 

NOX, and 0.022 ton of Hg. The estimated monetary value of the CO2 emissions reductions at 

TSL 4 ranges from $77 million to $1,164 million. Total generating capacity in 2043 is estimated 

to decrease by 0.632 GW under TSL 4. 

At TSL 4, DOE projects that the average LCC impact is a savings (LCC decrease) of $7 

for room air conditioners <6,000 Btu/h, with louvers; a savings of $22 for room air conditioners 

8,000–13,999 Btu/h, with louvers; a savings of $6 for room air conditioners 20,000–24,999 

Btu/h, with louvers; a savings of $1 for room air conditioners >25,000 Btu/h, with louvers; a 

savings of $13 for room air conditioners 8,000–10,999 Btu/h, without louvers; and a savings of 

353 
 

 

 

 

 

 

 

 

 

 

 

 

 

$11 for room air conditioners >11,000 Btu/h, without louvers. The median payback period is 8.6 

years for room air conditioners <6,000 Btu/h, with louvers; 2.8 years for room air conditioners 

8,000–13,999 Btu/h, with louvers; 4.3 years for room air conditioners 20,000–24,999 Btu/h, with 

louvers; 10.1 years for room air conditioners >25,000 Btu/h, with louvers; 2.1 years for room air 

conditioners 8,000–10,999 Btu/h, without louvers; and 3.7 years for room air conditioners 

>11,000 Btu/h, without louvers. The fraction of consumers experiencing an LCC benefit is 34 

percent for room air conditioners <6,000 Btu/h, with louvers; 64 percent for room air 

conditioners 8,000–13,999 Btu/h, with louvers; 10 percent for room air conditioners 20,000– 

24,999 Btu/h, with louvers; 4 percent for room air conditioners >25,000 Btu/h, with louvers; 62 

percent for room air conditioners 8,000–10,999 Btu/h, without louvers; and 47 percent for room 

air conditioners >11,000 Btu/h, without louvers. The fraction of consumers experiencing an LCC 

cost is 65 percent for room air conditioners <6,000 Btu/h, with louvers; 34 percent for room air 

conditioners 8,000–13,999 Btu/h, with louvers; 5 percent for room air conditioners 20,000– 

24,999 Btu/h, with louvers; 9 percent for room air conditioners >25,000 Btu/h, with louvers; 12 

percent for room air conditioners 8,000–10,999 Btu/h, without louvers; and 23 percent for room 

air conditioners >11,000 Btu/h, without louvers. 

At TSL 4, the projected change in INPV ranges from a decrease of $111.3 million to a 

decrease of $177.6 million. DOE recognizes the risk of moderately negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached as DOE expects, TSL 4 could result in a net loss of 18.6 percent 

in INPV to room air conditioner manufacturers. 

354 
 

 

 

 

 

 

 

 

 

The Secretary concludes that at TSL 4 for room air conditioners, the benefits of energy 

savings, generating capacity reductions, emission reductions and the estimated monetary value of 

the CO2 emissions reductions, positive NPV of consumer benefits and positive average consumer 

LCC savings outweigh the economic burden on some consumers (a significant fraction for one 

product class but small to moderate fractions for the other product classes) due to the increases in 

product cost, and the capital conversion costs and profit margin impacts that could result in a 

moderate reduction in INPV for the manufacturers. 

In addition, the efficiency levels in TSL 4 correspond to the recommended levels in the 

consensus agreement, which DOE believes sets forth a statement by interested persons that are 

fairly representative of relevant points of view (including representatives of manufacturers of 

covered products, States, and efficiency advocates) and contains recommendations with respect 

to an energy conservation standard that are in accordance with 42 U.S.C. 6295(o). Moreover, 

DOE has encouraged the submission of consensus agreements as a way to get diverse 

stakeholders together, to develop an independent and probative analysis useful in DOE standard 

setting, and to expedite the rulemaking process. DOE also believes that standard levels 

recommended in the consensus agreement may increase the likelihood for regulatory 

compliance, while decreasing the risk of litigation. 

After considering the analysis, comments on the preliminary TSD, and the benefits and 

burdens of TSL 4, DOE concludes that this trial standard level will offer the maximum 

improvement in efficiency that is technologically feasible and economically justified, and will 

result in the significant conservation of energy. Therefore, DOE today adopts TSL 4 for room air 

355 
 

 

 

 

 

 

 

 

 

 

 

 

 

conditioners. The amended energy conservation standards for room air conditioners, expressed 

as CEER, are shown in Table V-53 . 

Table V-53 Amended Energy Conservation Standards for Room Air Conditioners 

Room Air Conditioners 

Product Class 

Minimum 

CEER 

Levels 

Btu/Wh 

1. Without reverse cycle, with louvered sides, and less than 6,000 Btu/h 11.0 

2. Without reverse cycle, with louvered sides, and 6,000 to 7,999 Btu/h 11.0 

3. Without reverse cycle, with louvered sides, and 8,000 to 13,999 Btu/h 10.9 

4. Without reverse cycle, with louvered sides, and 14,000 to 19,999 Btu/h 10.7 

5a. Without reverse cycle, with louvered sides, and 20,000 to 24,999 Btu/h 9.4 

5b. Without reverse cycle, with louvered sides, and 25,000 Btu/h or more 9.0 

6. Without reverse cycle, without louvered sides, and less than 6,000 Btu/h 10.0 

7. Without reverse cycle, without louvered sides, and 6,000 to 7,999 Btu/h 10.0 

8a. Without reverse cycle, without louvered sides, and 8,000 to 10,999 

Btu/h 

9.6 

8b. Without reverse cycle, without louvered sides, and 11,000 to 13,999 

Btu/h 

9.5 

9. Without reverse cycle, without louvered sides, and 14,000 to 19,999 

Btu/h 

9.3 

10. Without reverse cycle, without louvered sides, and 20,000 Btu/h or 

more 

9.4 

11. With reverse cycle, with louvered sides, and less than 20,000 Btu/h 9.8 

12. With reverse cycle, without louvered sides, and less than 14,000 Btu/h 9.3 

13. With reverse cycle, with louvered sides, and 20,000 Btu/h or more 9.3 

14. With reverse cycle, without louvered sides, and 14,000 Btu/h or more 8.7 

15. Casement-Only 9.5 

16. Casement-Slider 10.4 

3. Summary of Benefits and Costs (Annualized) of the Standards 

The benefits and costs of today’s standards can also be expressed in terms of annualized 

values. The annualized monetary values are the sum of (1) the annualized national economic 

value, expressed in 2009$, of the benefits from operating products that meet the proposed 

356 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

standards (consisting primarily of operating cost savings from using less energy, minus increases 

in equipment purchase costs, which is another way of representing consumer NPV), and (2) the 

66 monetary value of the benefits of emission reductions, including CO2 emission reductions. The 

value of the CO2 reductions, otherwise known as the Social Cost of Carbon (SCC), is calculated 

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

monetary costs and benefits of cumulative emissions reductions are reported in 2009$ to permit 

comparisons with the other costs and benefits in the same dollar units. 

Although combining the values of operating savings and CO2 reductions provides a 

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

domestic U.S. consumer monetary savings that occur as a result of market transactions while the 

value of CO2 reductions is based on a global value. Second, the assessments of operating cost 

savings and CO2 savings are performed with different methods that use quite different time 

frames for analysis. The national operating cost savings is measured for the lifetime of products 

shipped in 2014–2043. The SCC values, on the other hand, reflect the present value of future 

climate-related impacts resulting from the emission of one ton of carbon dioxide in each year. 

These impacts go well beyond 2100. 

66 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. 

First, DOE calculated a present value in 2011, the year used for discounting the NPV of total consumer costs and 

savings, for the time-series of costs and benefits using discount rates of three and seven percent for all costs and 

benefits except for the value of CO2 reductions. For the latter, DOE used a range of discount rates, as shown in 

Table V.50. From the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in 

2011, that yields the same present value. The fixed annual payment is the annualized value. Although DOE 

calculated annualized values, this does not imply that the time-series of cost and benefits from which the annualized 

values were determined would be a steady stream of payments 

357 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-54 and Table V-55 show the annualized values for clothes dryers and room air 

conditioners, respectively. Using a 7-percent discount rate and the SCC value of $22.1/ton in 

2010 (in 2009$), the cost of the standards for clothes dryers in today’s rule is $52.3 million per 

year in increased equipment costs, while the annualized benefits are $139.1 million per year in 

reduced equipment operating costs, $25.0 million in CO2 reductions, and $0.9 million in reduced 

NOX emissions. In this case, the net benefit amounts to $112.7 million per year. DOE has 

calculated that the annualized increased equipment cost can range from $50.5 to $66.6 million 

per year depending on assumptions and modeling of equipment price trends. The high end of 

this range corresponds to a constant real equipment price trend. Using the central estimate of 

energy-related benefits, DOE estimates that calculated net benefits can range from $98.4 to 

$114.5 million per year. Using a 3-percent discount rate and the SCC value of $22.1/ton in 2010 

(in 2009$), the cost of the standards for clothes dryers in today’s rule is $55.4 million per year in 

increased equipment costs, while the benefits are $209.1 million per year in reduced operating 

costs, $25.0 million in CO2 reductions, and $1.4 million in reduced NOX emissions. In this case, 

Comment [A15]: Change recommended by 

OIRA. 

the net benefit amounts to $180.1 million per year. DOE has calculated that the range in the 

annualized increased equipment cost can range from $53.1 to $73.5 million per year depending 

on assumptions and modeling of equipment price trends. The high end of this range corresponds 

to a constant real equipment price trend. Using the central estimate of energy-related benefits, 

DOE estimates that calculated net benefits can range from $162.0 to $182.4 million per year. 

Using a 7-percent discount rate and the SCC value of $22.1/ton in 2010 (in 2009$), the cost of 

the standards for room air conditioners in today’s rule is $107.7 million per year in increased 

equipment costs, while the annualized benefits are $153.7 million per year in reduced equipment 

Comment [A16]: Change recommended by 

OIRA. 

358 
 

 

 

 

 

 

 

 

 

 

operating costs, $19.5 million in CO2 reductions, and $0.999 million in reduced NOX emissions. 

In this case, the net benefit amounts to $66.4 million per year. DOE has calculated that the 

annualized increased equipment cost can range from $105.7 to $136.6 million per year 

depending on assumptions and modeling of equipment price trends. The high end of this range 

corresponds to a constant real equipment price trend. Using the central estimate of energyrelated benefits, DOE estimates that calculated net benefits can range from $37.5 to $68.4 

million per year. Using a 3-percent discount rate and the SCC value of $22.1/ton in 2010 (in 

2009$), the cost of the standards for room air conditioners in today’s rule is $111.0 million per 

year in increased equipment costs, while the benefits are $186.2 million per year in reduced 

operating costs, $19.5 million in CO2 reductions, and $1.20 million in reduced NOX emissions. 

In this case, the net benefit amounts to $95.9 million per year. DOE has calculated that the range 

in the annualized increased equipment cost can range from $108.0 to $146.0 million per year 

depending on assumptions and modeling of equipment price trends. The high end of this range 

corresponds to a constant real equipment price trend. Using the central estimate of energyrelated benefits, DOE estimates that calculated net benefits can range from $60.9 to $98.9 

million per year. 

Comment [A17]: Change recommended by 

OIRA. 

Comment [A18]: Change recommended by 

OIRA. 

359 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-54 Annualized Benefits and Costs of Amended Standards (TSL 4) for Clothes 

Dryers Sold in 2014–2043 

Discount Rate 

Primary 

Estimate * Low Estimate * High Estimate * 

Monetized (million 2009$/year) 

Benefits 

Operating Cost Savings 

7% 139.1 120.6 158.3 

3% 209.1 177.4 241.3 

CO2 Reduction at $4.9/t ** 5% 6.0 6.0 6.0 

CO2 Reduction at $22.1/t ** 3% 25.0 25.0 25.0 

CO2 Reduction at $36.3/t ** 2.5% 39.8 39.8 39.8 

CO2 Reduction at $67.1/t ** 3% 76.0 76.0 76.0 

NOX Reduction at 

$2,519/ton ** 

7% 0.9 0.9 0.9 

3% 1.4 1.4 1.4 

Total† 

7% plus CO2 range 146.1 to 216.1 127.6 to 197.6 165.3 to 235.3 

7% 165.0 146.5 184.3 

3% 235.4 203.7 267.6 

3% plus CO2 range 216.5 to 286.5 184.8 to 254.8 248.7 to 318.7 

Costs 

Incremental Product Costs 

7% 52.3 66.6 50.5 

3% 55.4 73.5 53.1 

Total Net Benefits 

Total† 

7% plus CO2 range 93.7 to 163.7 61.0 to 131.0 114.8 to 184.8 

7% 112.7 79.9 133.8 

3% 180.1 130.2 214.5 

3% plus CO2 range 161.1 to 231.1 111.3 to 181.3 195.6 to 265.6 

* The Primary, Low, and High Estimates utilize forecasts of energy prices and housing starts from the AEO2010 

Reference case, Low Economic Growth case, and High Economic Growth case, respectively. Low estimate 

corresponds to the low net benefit estimate and uses the zero real price trend sensitivity for equipment prices, and 

the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate 

sensitivity for the equipment price trend. 

** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.9, $22.1, and $36.3 per ton are the averages of SCC distributions calculated using 5­

percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th 

percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2009$) is the 

average of the low and high values used in DOE’s analysis. 

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

discount rate, which is $22.1/ton in 2010 (in 2009$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

Deleted: 48.8 

Deleted: 55.9 

Deleted: 51.2 

Deleted: 59.6 

Deleted: 78.7 

Deleted: 148.7 

Deleted: 109.4 

Deleted: 179.4 

Deleted: 97.7 

Deleted: 128.3 

Deleted: 152.5 

Deleted: 208.1 

Deleted: 133.6 

Deleted: 203.6 

Deleted: 189.1 

Deleted: 259.1 

Comment [A19]: Change recommended by 

OIRA. 

360 
 

 

 

 

 

 

 

 

 

 

 

 

Table V-55 Annualized Benefits and Costs of Amended Standards (TSL 4) for Room Air 

Conditioners Sold in 2014–2043 

Discount Rate 

Primary 

Estimate * Low Estimate * High Estimate * 

Monetized (million 2009$/year) 

Benefits 

Operating Cost Savings 

7% 153.7 145.1 161.9 

3% 186.2 174.2 197.3 

CO2 Reduction at $4.9/t ** 5% 5.0 5.0 5.0 

CO2 Reduction at $22.1/t ** 3% 19.5 19.5 19.5 

CO2 Reduction at $36.3/t ** 2.5% 30.7 30.7 30.7 

CO2 Reduction at $67.1/t ** 3% 59.4 59.4 59.4 

NOX Reduction at 

$2,519/ton ** 

7% 0.999 0.999 0.999 

3% 1.197 1.197 1.197 

Total† 

7% plus CO2 range 159.6 to 214.0 151.1 to 205.5 167.9 to 222.3 

7% 174.1 165.5 182.4 

3% 206.8 194.9 218.0 

3% plus CO2 range 192.3 to 246.7 180.4 to 234.8 203.5 to 257.9 

Costs 

Incremental Product Costs 

7% 107.7 136.6 105.7 

3% 111.0 146.0 108.0 

Total Net Benefits 

Total† 

7% plus CO2 range 51.9 to 106.3 43.4 to 97.8 62.2 to 116.6 

7% 66.4 28.9 76.7 

3% 95.9 48.9 110.0 

3% plus CO2 range 81.4 to 135.8 34.4 to 88.8 95.5 to 149.9 

* The Primary, Low, and High Estimates utilize forecasts of energy prices and housing starts from the AEO2010 

Reference case, Low Economic Growth case, and Low Economic Growth case, respectively. Low estimate 

corresponds to the low net benefit estimate and uses the zero real price trend sensitivity for equipment prices, and 

the high estimate corresponds to the high net benefit estimate and utilizes the high technological learning rate 

sensitivity for the equipment price trend. 

** The CO2 values represent global values (in 2009$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.9, $22.1, and $36.3 per ton are the averages of SCC distributions calculated using 5­

percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.1 per ton represents the 95th 

percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2009$) is the 

Deleted: 107.7 

Deleted: 107 

Deleted: 111 

Deleted: 111 

Deleted: 60 

Deleted: 114 

Deleted: 57.8 

Deleted: 74 

Deleted: 83 

Deleted: 107 

Deleted: 69 

Deleted: 123 

Deleted: 92 

Deleted: 146 

Comment [A20]: Change recommended by 

OIRA. 

average of the low and high values used in DOE’s analysis. 

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

discount rate, which is $22.1/ton in 2010 (in 2009$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

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range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

VI. Procedural Issues and Regulatory Review 

A. Review Under Executive Orders 12866 and 13563 

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 FR 

51735 (Oct. 4, 1993), requires each agency to identify the problem that it intends to address, 

including, where applicable, the failures of private markets or public institutions that warrant 

new agency action, as well as to assess the significance of that problem. The problems that 

today’s standards address are as follows: 

(1)	 There is a lack of consumer information and/or information processing capability about 

energy efficiency opportunities in clothes dryer and room air conditioner market. 

(2)	 There is asymmetric information (one party to a transaction has more and better 

information than the other) and/or high transactions costs (costs of gathering information 

and effecting exchanges of goods and services). 

(3)	 There are external benefits resulting from improved energy efficiency of clothes dryers 

and room air conditioners that are not captured by the users of such equipment. These 

benefits include externalities related to environmental protection and energy security that 

are not reflected in energy prices, such as reduced emissions of greenhouse gases. 

In addition, DOE has determined that today’s regulatory action is an “economically 

significant regulatory action” under section 3(f)(1) of Executive Order 12866. Accordingly, 

section 6(a)(3) of the Executive Order requires that DOE prepare a regulatory impact analysis 

(RIA) on today’s rule and that the Office of Information and Regulatory Affairs (OIRA) in the 

Deleted: Order 

Comment [A21]: Change recommended by 

OIRA. 

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Office of Management and Budget (OMB) review this rule. DOE presented to OIRA for review 

the draft rule and other documents prepared for this rulemaking, including the RIA, and has 

included these documents in the rulemaking record. The assessments prepared pursuant to 

Executive Order 12866 can be found in the technical support document for this rulemaking. 

They are available for public review in the Resource Room of DOE’s Building Technologies 

Program, 950 L’Enfant Plaza, SW., Suite 600, Washington, DC 20024, (202) 586-2945, between 

9:00 a.m. and 4:00 p.m., Monday through Friday, except Federal holidays. 

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued on 

January 18, 2011 (76 FR 3281, Jan. 21, 2011). EO 13563 is supplemental to and explicitly 

reaffirms the principles, structures, and definitions governing regulatory review established in 

Executive Order 12866. To the extent permitted by law, agencies are required by Executive 

Order 13563 to: (1) propose or adopt a regulation only upon a reasoned determination that its 

benefits justify its costs (recognizing that some benefits and costs are difficult to quantify); (2) 

tailor regulations to impose the least burden on society, consistent with obtaining regulatory 

objectives, taking into account, among other things, and to the extent practicable, the costs of 

cumulative regulations; (3) select, in choosing among alternative regulatory approaches, those 

approaches that maximize net benefits (including potential economic, environmental, public 

health and safety, and other advantages; distributive impacts; and equity); (4) to the extent 

feasible, specify performance objectives, rather than specifying the behavior or manner of 

compliance that regulated entities must adopt; and (5) identify and assess available alternatives 

to direct regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can be 

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made by the public. 

We emphasize as well that Executive Order 13563 requires agencies “to use the best 

available techniques to quantify anticipated present and future benefits and costs as accurately as 

possible.” In its guidance, the Office of Information and Regulatory Affairs has emphasized that 

such techniques may include “identifying changing future compliance costs that might result 

from technological innovation or anticipated behavioral changes.” For the reasons stated in the 

preamble, DOE believes that today’s direct final rule is consistent with these principles, 

including that, to the extent permitted by law, agencies adopt a regulation only upon a reasoned 

determination that its benefits justify its costs and select, in choosing among alternative 

regulatory approaches, those approaches that maximize net benefits. 

B. Review Under the Regulatory Flexibility Act 

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an final 

regulatory flexibility analysis (FRFA) for any rule that by law must be proposed for public 

comment, unless the agency certifies that the rule, if promulgated, will not have a significant 

economic impact on a substantial number of small entities. As required by Executive Order 

13272, “Proper Consideration of Small Entities in Agency Rulemaking” 67 FR 53461 (Aug. 16, 

2002), DOE published procedures and policies on February 19, 2003, to ensure that the potential 

impacts of its rules on small entities are properly considered during the rulemaking process. 68 

FR 7990. DOE has made its procedures and policies available on the Office of the General 

Counsel’s website (www.gc.doe.gov). 

Comment [A22]: Change recommended by 

OIRA. 

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For the manufacturers of residential clothes dryers and room air conditioners, the Small 

Business Administration (SBA) has set a size threshold, which defines those entities classified as 

“small businesses” for the purposes of the statute. DOE used the SBA’s small business size 

standards to determine whether any small entities would be subject to the requirements of the 

rule. 65 FR 30836, 30850 (May 15, 2000), as amended at 65 FR 53533, 53545 (Sept. 5, 2000) 

and codified at 13 CFR part 121.The size standards are listed by NAICS code and industry 

description and are available at 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. 

Residential clothes dryer manufacturing is classified under NAICS Code 335224, “Household 

Laundry Equipment Manufacturing” and room air conditioner manufacturing is classified under 

NAICS Code 333415, “Air-Conditioning and Warm Air Heating Equipment and Commercial 

and Industrial Refrigeration Equipment Manufacturing.” The SBA sets a threshold of 1,000 

employees or less and 750 employees or less, respectively, for these categories in order for an 

entity to be considered as a small business, as shown in Table VI-1. 

Table VI-1. SBA Classification of Small Businesses Potentially Affected by this Rule 

Industry Description Revenue Limit Employee Limit NAICS 

Household Laundry Equipment Manufacturing N/A 1,000 335224 

Air-Conditioning and Warm Air Heating 

Equipment and Commercial and Industrial 

Refrigeration Equipment Manufacturing 

N/A 750 333415 

DOE reviewed the potential standard levels considered in today’s notice under the 

provisions of the Regulatory Flexibility Act and the procedures and policies published on 

February 19, 2003. To estimate the number of small businesses that could be impacted by the 

amended energy conservation standards, DOE conducted a market survey using all available 

public information to identify potential small manufacturers. DOE’s research included the 

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AHAM membership directory, product databases (the AHRI, AHAM, CEC, and ENERGY 

STAR databases), individual company websites, and the SBA dynamic small business search to 

find potential small business manufacturers. DOE also asked stakeholders and industry 

representatives if they were aware of any other small business manufacturers during 

manufacturer interviews and at previous DOE public meetings. DOE reviewed all publicly 

available data and contacted various companies, as necessary, to determine whether they met the 

SBA’s definition of a small business manufacturer of covered residential clothes dryers or room 

air conditioners. DOE screened out companies that did not offer products covered by this 

rulemaking, did not meet the definition of a “small business,” or are foreign owned and operated. 

1. Residential Clothes Dryer Industry 

The majority of residential clothes dryers are currently manufactured in the United States 

by one corporation that accounts for over 70 percent of the market. Two additional large 

manufacturers with foreign and domestic production hold much of the remaining share of the 

market. The small portion of the remaining residential clothes dryer market is supplied by a 

combination of international and domestic companies, all of which have small market shares. 

Based on its review of the dynamic small business search on the SBA website 

(http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm), the Central Contracting Registration 

(https://www.bpn.gov/CCRSearch/Search.aspx), and input from commenters, DOE identified 

only one manufacturer who could potentially be considered a small business under NAICS Code 

335224, “Household Laundry Equipment Manufacturing.” DOE does not believe, however, that 

this company would be directly impacted by the standards established for clothes dryers in 

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today’s final rule. DOE notes that while the potential small business manufacturer has developed 

a highly efficient technology that could be used by other manufacturers to increase the efficiency 

of clothes dryers, the company does not produce clothes dryers and the technology is not yet 

commercially available. DOE acknowledges that the technology developed by this small 

business is a potential design option for clothes dryers, but DOE does not believe this rulemaking 

would in any way affect the ability of this company to commercialize or sell its technology. 

2. Room Air Conditioner Industry 

No room air conditioners are manufactured in the United States. Most manufacturing 

takes place in Asia, primarily China, with limited production in Mexico. In recent years at least 

two major manufacturers have exited the market. At least three major corporations supply a 

majority of the market. The remaining market share is held by several large companies. DOE did 

not identify any small business manufacturers of room air conditioners. 

For room air conditioners, DOE initially identified at least 11 distinct manufacturers of 

room air conditioners sold in the United States. DOE initially determined that 10 of these were 

large or foreign-owned and operated. DOE determined that the one room air conditioner 

manufacturer that was previously designated as a small business manufacturer was acquired by 

another company and now exceeds SBA’s employment threshold for consideration as a small 

business under the appropriate NAICS code. As such, DOE did not identify any small business 

manufacturers of room air conditioners. 

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Based on the discussion above, DOE certifies that the standards for clothes dryers and 

room air conditioners set forth in today’s rule would not have a significant economic impact on a 

substantial number of small entities. Accordingly, DOE has not prepared a regulatory flexibility 

analysis for this rulemaking. DOE will transmit this certification to SBA as required by 5 USC 

605(b). 

C. Review Under the Paperwork Reduction Act 

Manufacturers of clothes dryers and room air conditioners must certify to DOE that their 

products comply with any applicable energy conservation standards. In certifying compliance, 

manufacturers must test their products according to the DOE test procedures for clothes dryers 

and room air conditioners, including any amendments adopted for those test procedures. DOE 

has proposed regulations for the certification and recordkeeping requirements for all covered 

consumer products and commercial equipment, including clothes dryers and room air 

conditioners. 75 FR 56796 (Sept. 16, 2010). The collection-of-information requirement for the 

certification and recordkeeping is subject to review and approval by OMB under the Paperwork 

Reduction Act (PRA). This requirement has been submitted to OMB for approval. Public 

reporting burden for the certification is estimated to average 20 hours per response, including the 

time for reviewing instructions, searching existing data sources, gathering and maintaining the 

data needed, and completing and reviewing the collection of information. 

Public comment is sought regarding: whether this proposed collection of information is 

necessary for the proper performance of the functions of the agency, including whether the 

information shall have practical utility; the accuracy of the burden estimate; ways to enhance the 

368 
 

 

 

 

 

 

 

 

quality, utility, and clarity of the information to be collected; and ways to minimize the burden of 

the collection of information, including through the use of automated collection techniques or 

other forms of information technology. Send comments on these or any other aspects of the 

collection of information to the Office of Management and Budget at the ADDRESSES above, 

and e-mail to Christine_J._Kymn@omb.eop.gov. 

Notwithstanding any other provision of the law, no person is required to respond to, nor 

shall any person be subject to a penalty for failure to comply with, a collection of information 

subject to the requirements of the PRA, unless that collection of information displays a currently 

valid OMB Control Number. 

D. Review Under the National Environmental Policy Act 

DOE has prepared an environmental assessment (EA) of the impacts of the direct final 

rule pursuant to the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.), the 

regulations of the Council on Environmental Quality (40 CFR parts 1500–1508), and DOE’s 

regulations for compliance with the National Environmental Policy Act (10 CFR part 1021). This 

assessment includes an examination of the potential effects of emission reductions likely to result 

from the rule in the context of global climate change, as well as other types of environmental 

impacts. The EA has been incorporated into the direct final rule TSD as chapter 15. DOE found 

that the environmental effects associated with the standards for clothes dryers and room air 

conditioners were not significant. Therefore, DOE is issuing a Finding of No Significant Impact 

(FONSI), pursuant to NEPA, the regulations of the Council on Environmental Quality (40 CFR 

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parts 1500–1508), and DOE’s regulations for compliance with NEPA (10 CFR part 1021). The 

FONSI is available in the docket for this rulemaking. 

E. Review under Executive Order 13132 

Executive Order 13132, "Federalism," 64 FR 43255 (August 4, 1999), imposes certain 

requirements on agencies formulating and implementing policies or regulations that preempt 

State law or that have federalism implications. The Executive Order requires agencies to 

examine the constitutional and statutory authority supporting any action that would limit the 

policymaking discretion of the States and to carefully assess the necessity for such actions. The 

Executive Order also requires agencies to have an accountable process to ensure meaningful and 

timely input by State and local officials in the development of regulatory policies that have 

federalism implications. On March 14, 2000, DOE published a statement of policy describing the 

intergovernmental consultation process it will follow in the development of such regulations. 65 

FR 13735. EPCA governs and prescribes Federal preemption of State regulations as to energy 

conservation for the products that are the subject of today’s direct final rule. States can petition 

DOE for exemption from such preemption to the extent, and based on criteria, set forth in EPCA. 

(42 U.S.C. 6297) No further action is required by Executive Order 13132. 

F. Review Under Executive Order 12988 

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, "Civil Justice Reform" imposes on Federal 

agencies the general duty to adhere to the following requirements: (1) eliminate drafting errors 

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and ambiguity; (2) write regulations to minimize litigation; and (3) provide a clear legal standard 

for affected conduct rather than a general standard and promote simplification and burden 

reduction. 61 FR 4729 (February 7, 1996). Section 3(b) of Executive Order 12988 specifically 

requires that Executive agencies make every reasonable effort to ensure that the regulation: (1) 

clearly specifies the preemptive effect, if any; (2) clearly specifies any effect on existing Federal 

law or regulation; (3) provides a clear legal standard for affected conduct while promoting 

simplification and burden reduction; (4) specifies the retroactive effect, if any; (5) adequately 

defines key terms; and (6) addresses other important issues affecting clarity and general 

draftsmanship under any guidelines issued by the Attorney General. Section 3(c) of Executive 

Order 12988 requires Executive agencies to review regulations in light of applicable standards in 

section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to meet one 

or more of them. DOE has completed the required review and determined that, to the extent 

permitted by law, this direct final rule meets the relevant standards of Executive Order 12988. 

G. Review Under the Unfunded Mandates Reform Act of 1995 

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each Federal 

agency to assess the effects of Federal regulatory actions on State, local, and Tribal governments 

and the private sector. Pub. L. No. 104-4, sec. 201 (codified at 2 U.S.C. 1531). For a proposed 

regulatory action likely to result in a rule that may cause the expenditure by State, local, and 

Tribal governments, in the aggregate, or by the private sector of $100 million or more in any one 

year (adjusted annually for inflation), section 202 of UMRA requires a Federal agency to publish 

a written statement that estimates the resulting costs, benefits, and other effects on the national 

economy. (2 U.S.C. 1532(a),(b)) The UMRA also requires a Federal agency to develop an 

371 
 

 

 

 

 

 

 

 

 

 

 

effective process to permit timely input by elected officers of State, local, and Tribal 

governments on a proposed “significant intergovernmental mandate,” and requires an agency 

plan for giving notice and opportunity for timely input to potentially affected small governments 

before establishing any requirements that might significantly or uniquely affect small 

governments. On March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR 12820; also available at 

http://www.gc.doe.gov. 

Although today’s rule does not contain a Federal intergovernmental mandate, it may 

impose expenditures of $100 million or more on the private sector. Specifically, the final rule 

could impose expenditures of $100 million or more. Such expenditures may include (1) 

investment in research and development and in capital expenditures by home appliance 

manufacturers in the years between the final rule and the compliance date for the new standard, 

and (2) incremental additional expenditures by consumers to purchase higher efficiency home 

appliances. 

Section 202 of UMRA authorizes an agency to respond to the content requirements of 

UMRA in any other statement or analysis that accompanies the proposed rule. 2 U.S.C. 1532(c). 

The content requirements of section 202(b) of UMRA relevant to a private sector mandate 

substantially overlap the economic analysis requirements that apply under section 325(o) of 

EPCA and Executive Order 12866. The Supplementary Information section of this notice and the 

“Regulatory Impact Analysis” section of the direct final rule TSD for this rule respond to those 

requirements. 

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Under section 205 of UMRA, the Department is obligated to identify and consider a 

reasonable number of regulatory alternatives before promulgating a rule for which a written 

statement under section 202 is required. 2 U.S.C. 1535(a). DOE is required to select from those 

alternatives the most cost-effective and least burdensome alternative that achieves the objectives 

of the rule unless DOE publishes an explanation for doing otherwise or the selection of such an 

alternative is inconsistent with law. As required by 42 U.S.C. 6295(h) and (o), 6313(e), and 

6316(a), today’s rule would establish energy conservation standards for clothes dryers and room 

air conditioners that are designed to achieve the maximum improvement in energy efficiency that 

DOE has determined to be both technologically feasible and economically justified. A full 

discussion of the alternatives considered by DOE is presented in the “Regulatory Impact 

Analysis” section of the direct final rule TSD. 

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

Section 654 of the Treasury and General Government Appropriations Act, 1999 (Pub. L. 

105-277) requires Federal agencies to issue a Family Policymaking Assessment for any rule that 

may affect family well-being. This rule would not have any impact on the autonomy or integrity 

of the family as an institution. Accordingly, DOE has concluded that it is not necessary to 

prepare a Family Policymaking Assessment. 

I. Review Under Executive Order 12630 

DOE has determined, under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights,” 53 FR 8859 (March 18, 1988), 

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that this regulation would not result in any takings which might require compensation under the 

Fifth Amendment to the U.S. Constitution. 

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

Section 515 of the Treasury and General Government Appropriations Act, 2001 (44 

U.S.C. 3516, note) provides for agencies to review most disseminations of information to the 

public under guidelines established by each agency pursuant to general guidelines issued by 

OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 2002), and DOE’s guidelines 

were published at 67 FR 62446 (Oct. 7, 2002). DOE has reviewed today’s notice under the OMB 

and DOE guidelines and has concluded that it is consistent with applicable policies in those 

guidelines. 

K. Review Under Executive Order 13211 

Executive Order 13211, “Actions Concerning Regulations That Significantly Affect 

Energy Supply, Distribution, or Use,” 66 FR 28355 (May 22, 2001), requires Federal agencies to 

prepare and submit to OIRA at OMB, a Statement of Energy Effects for any proposed significant 

energy action. A “significant energy action” is defined as any action by an agency that 

promulgates or is expected to lead to promulgation of a final rule, and that (1) is a significant 

regulatory action under Executive Order 12866, or any successor order; and (2) is likely to have 

a significant adverse effect on the supply, distribution, or use of energy, or (3) is designated by 

the Administrator of OIRA as a significant energy action. For any proposed significant energy 

action, the agency must give a detailed statement of any adverse effects on energy supply, 

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distribution, or use should the proposal be implemented, and of reasonable alternatives to the 

action and their expected benefits on energy supply, distribution, and use. 

DOE has concluded that today’s regulatory action, which sets forth energy conservation 

standards for clothes dryers and room air conditioners, is not a significant energy action because 

the proposed standards are not likely to have a significant adverse effect on the supply, 

distribution, or use of energy, nor has it been designated as such by the Administrator at OIRA. 

Accordingly, DOE has not prepared a Statement of Energy Effects on the direct final rule. 

L. Review Under the Information Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in consultation with the Office of Science and Technology 

(OSTP), issued its Final Information Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 

(Jan. 14, 2005). The Bulletin establishes that certain scientific information shall be peer reviewed 

by qualified specialists before it is disseminated by the Federal Government, including 

influential scientific information related to agency regulatory actions. The purpose of the bulletin 

is to enhance the quality and credibility of the Government’s scientific information. Under the 

Bulletin, the energy conservation standards rulemaking analyses are “influential scientific 

information,” which the Bulletin defines as “scientific information the agency reasonably can 

determine will have, or does have, a clear and substantial impact on important public policies or 

private sector decisions.” 70 FR 2667 

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews of the 

energy conservation standards development process and analyses and has prepared a Peer 

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Review Report pertaining to the energy conservation standards rulemaking analyses. Generation 

of this report involved a rigorous, formal, and documented evaluation using objective criteria and 

qualified and independent reviewers to make a judgment as to the technical/scientific/business 

merit, the actual or anticipated results, and the productivity and management effectiveness of 

programs and/or projects. The “Energy Conservation Standards Rulemaking Peer Review 

Report” dated February 2007 has been disseminated and is available at the following Web site: 

http://www1.eere.energy.gov/buildings/appliance_standards/peer_review.html. 

M. Congressional Notification 

As required by 5 U.S.C. 801, DOE will report to Congress on the promulgation of this 

rule prior to its effective date. The report will state that it has been determined that the rule is not 

a “major rule” as defined by 5 U.S.C. 804(2). 

VII. Public Participation 

A. Submission of Comments 

DOE will accept comments, data, and information regarding this direct final rule no later 

than the date provided in the DATES section at the beginning of this rule. Interested parties may 

submit comments using any of the methods described in the ADDRESSES section at the 

beginning of this notice. 

Submitting comments via regulations.gov. The regulations.gov web page will require you 

to provide your name and contact information. Your contact information will be viewable to 

DOE Building Technologies staff only. Your contact information will not be publicly viewable 

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except for your first and last names, organization name (if any), and submitter representative 

name (if any). If your comment is not processed properly because of technical difficulties, DOE 

will use this information to contact you. If DOE cannot read your comment due to technical 

difficulties and cannot contact you for clarification, DOE may not be able to consider your 

comment. 

However, your contact information will be publicly viewable if you include it in the 

comment or in any documents attached to your comment. Any information that you do not want 

to be publicly viewable should not be included in your comment, nor in any document attached 

to your comment. Persons viewing comments will see only first and last names, organization 

names, correspondence containing comments, and any documents submitted with the comments. 

Do not submit to regulations.gov information for which disclosure is restricted by statute, 

such as trade secrets and commercial or financial information (hereinafter referred to as 

Confidential Business Information (CBI)). Comments submitted through regulations.gov cannot 

be claimed as CBI. Comments received through the website will waive any CBI claims for the 

information submitted. For information on submitting CBI, see the Confidential Business 

Information section. 

DOE processes submissions made through regulations.gov before posting. Normally, 

comments will be posted within a few days of being submitted. However, if large volumes of 

comments are being processed simultaneously, your comment may not be viewable for up to 

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several weeks. Please keep the comment tracking number that regulations.gov provides after you 

have successfully uploaded your comment. 

Submitting comments via email, hand delivery, or mail. Comments and documents 

submitted via email, hand delivery, or mail also will be posted to regulations.gov. If you do not 

want your personal contact information to be publicly viewable, do not include it in your 

comment or any accompanying documents. Instead, provide your contact information on a cover 

letter. Include your first and last names, email address, telephone number, and optional mailing 

address. The cover letter will not be publicly viewable as long as it does not include any 

comments 

Include contact information each time you submit comments, data, documents, and other 

information to DOE. Email submissions are preferred. If you submit via mail or hand delivery, 

please provide all items on a CD, if feasible. It is not necessary to submit printed copies. No 

facsimiles (faxes) will be accepted. 

Comments, data, and other information submitted to DOE electronically should be 

provided in PDF (preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format. 

Provide documents that are not secured, written in English and are free of any defects or viruses. 

Documents should not contain special characters or any form of encryption and, if possible, they 

should carry the electronic signature of the author. 

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Campaign form letters. Please submit campaign form letters by the originating 

organization in batches of between 50 to 500 form letters per PDF or as one form letter with a 

list of supporters’ names compiled into one or more PDFs. This reduces comment processing and 

posting time. 

Confidential Business Information. According to 10 CFR 1004.11, any person submitting 

information that he or she believes to be confidential and exempt by law from public disclosure 

should submit via email, postal mail, or hand delivery two well-marked copies: one copy of the 

document marked confidential including all the information believed to be confidential, and one 

copy of the document marked non-confidential with the information believed to be confidential 

deleted. Submit these documents via email or on a CD, if feasible. DOE will make its own 

determination about the confidential status of the information and treat it according to its 

determination. 

Factors of interest to DOE when evaluating requests to treat submitted information as 

confidential include: (1) A description of the items; (2) whether and why such items are 

customarily treated as confidential within the industry; (3) whether the information is generally 

known by or available from other sources; (4) whether the information has previously been made 

available to others without obligation concerning its confidentiality; (5) an explanation of the 

competitive injury to the submitting person which would result from public disclosure; (6) when 

such information might lose its confidential character due to the passage of time; and (7) why 

disclosure of the information would be contrary to the public interest. 

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It is DOE’s policy that all comments may be included in the public docket, without 

change and as received, including any personal information provided in the comments (except 

information deemed to be exempt from public disclosure). 

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________________________________ 

 

 

 

VIII. Approval of the Office of the Secretary 

The Secretary of Energy has approved publication of today’s direct final rule. 

List of Subjects in 10 CFR Part 430 

Administrative practice and procedure, Confidential business information, Energy 

conservation, Household appliances, Reporting and recordkeeping requirements, and Small 

businesses. 

Issued in Washington, DC, on April 8, 2011. 

Kathleen Hogan 

Deputy Assistant Secretary for Energy Efficiency 

Office of Technology Development 

Energy Efficiency and Renewable Energy 

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For the reasons set forth in the preamble, DOE amends chapter II, subchapter D, of title 10 of the 

Code of Federal Regulations, as set forth below: 

PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS 

1. The authority citation for part 430 continues to read as follows: 

Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note. 

2. Revise §430.32 paragraphs (b), and (h) to read as follows: 

§ 430.32 Energy and water conservation standards and effective dates. 

* * * * * 

(b) Room air conditioners. 

Product class 

Energy 

efficiency ratio, 

effective as of 

Oct. 1, 2000 

Combined 

energy efficiency 

ratio, effective as 

of [INSERT 

DATE] 

1. Without reverse cycle, with louvered sides, 

and less than 6,000 Btu/h 9.7 11.0 

2. Without reverse cycle, with louvered sides, 

and 6,000 to 7,999 Btu/h 9.7 11.0 

3. Without reverse cycle, with louvered sides, 

and 8,000 to 13,999 Btu/h 9.8 10.9 

4. Without reverse cycle, with louvered sides, 

and 14,000 to 19,999 Btu/h 9.7 10.7 

5a. Without reverse cycle, with louvered 

sides, and 20,000 to 24,999 Btu/h 8.5 9.4 

5b. Without reverse cycle, with louvered 9.0 

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sides, and 25,000 Btu/h or more 

6. Without reverse cycle, without louvered 

sides, and less than 6,000 Btu/h 9.0 10.0 

7. Without reverse cycle, without louvered 

sides, and 6,000 to 7,999 Btu/h 9.0 10.0 

8a. Without reverse cycle, without louvered 

sides, and 8,000 to 10,999 Btu/h 9.6 

8b. Without reverse cycle, without louvered 

sides, and 11,000 to 13,999 Btu/h 

8.5 

9.5 

9. Without reverse cycle, without louvered 

sides, and 14,000 to 19,999 Btu/h 8.5 9.3 

10. Without reverse cycle, without louvered 

sides, and 20,000 Btu/h or more 8.5 9.4 

11. With reverse cycle, with louvered sides, 

and less than 20,000 Btu/h 9.0 9.8 

12. With reverse cycle, without louvered 

sides, and less than 14,000 Btu/h 8.5 9.3 

13. With reverse cycle, with louvered sides, 

and 20,000 Btu/h or more 8.5 9.3 

14. With reverse cycle, without louvered 

sides, and 14,000 Btu/h or more 8.0 8.7 

15. Casement-Only 8.7 9.5 

16. Casement-Slider 9.5 10.4 

* * * * * 

(h) Clothes dryers. (1) Gas clothes dryers manufactured after January 1, 1988 shall not be 

equipped with a constant burning pilot. 

(2) Clothes dryers manufactured on or after May 14, 1994 and before [INSERT DATE 3 

YEARS AFTER DATE OF PUBLICATION IN THEFEDERAL REGISTER], shall have an 

energy factor no less than: 

Product Class 

Energy Factor 

(lbs/kWh) 

i. Electric, Standard (4.4 ft3 or greater capacity) 3.01 

ii. Electric, Compact (120V) (less than 4.4 ft3 capacity) 3.13 

iii. Electric, Compact (240V) (less than 4.4 ft3 capacity) 2.90 

383 
 

 

 

iv. Gas 2.67 

(2) Clothes dryers manufactured on or after [INSERT DATE 3 YEARS AFTER DATE 

OF PUBLICATION IN THE FEDERAL REGISTER], shall have a combined energy factor 

no less than: 

Product Class 

Combined Energy 

Factor (lbs/kWh) 

i. Vented Electric, Standard (4.4 ft3 or greater 

capacity) 3.73 

ii. Vented Electric, Compact (120V) (less than 4.4 ft3 

capacity) 3.61 

iii. Vented Electric, Compact (240V) (less than 4.4 ft3 

capacity) 3.27 

iv. Vented Gas 3.30 

v. Ventless Electric, Compact (240V) (less than 4.4 ft3 

capacity) 2.55 

vi. Ventless Electric, Combination Washer-Dryer 2.08 

* * * * * 

384