1 | Energy Efficiency and Renewable Energy eere.energy.gov

[INSERT PICTURE(S) OF PRODUCT(S)]

[INSERT PICTURE(S) OF PRODUCT(S)]

Notice of Proposed Rulemaking Public 

Meeting:

Residential Dehumidifier 

Test Procedures

June 13, 2014

Bryan Berringer

Department of Energy

Building Technologies Program

EERE-2014-BT-TP-0010

Dehumidifier2014TP0010@ee

.doe.gov
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of 

this meeting.

– Be concise – share the ‘air-time’.

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

conversations.

– Webinar participants turn phone on mute; “raise your hand” to be 

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Agenda

1) 9:00 AM Introductions

2) 9:15 AM Stakeholder Opening Statements

3) 9:30 AM Regulatory History

4) 9:45 AM Covered Products

5) 10:00 AM Test Procedure Amendments

6) 11:00 AM Break

7) 11:15 AM Compliance

8) 12:00 PM Closing Remarks
4

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements

3 Regulatory History

4 Covered Products

5 Appendix X Clarifications

6 New Appendix X1

7 Closing Remarks
5

Listening Via the Webcast

• The Department is broadcasting this meeting live over the 

Internet.

• DOE is providing the webcast to accommodate stakeholders 

that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
6

Purpose of the Public Meeting

• Present DOE’s proposed test procedures for Dehumidifiers.

• Invite comment on the notice of proposed rulemaking 

(NOPR) document. 

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or 

statements and raise additional issues for discussion. 
7

Steps in the Test Procedure Rulemaking

• NOPR issued by DOE on May 2, 2014

• NOPR published in the Federal Register on May 21, 2014 (79 

FR 29272)

• NOPR Public Meeting today, June 13, 2014

• Comments on NOPR from interested parties

• Transcript records oral comments from today’s public meeting

• Written comments (comment period closes August 4)

• DOE reviews and considers all comments

• Final Rule Publication

• Final Rule is expected to be issued by January 2015.

Final

Rule NOPR
8

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements

3 Regulatory History

4 Covered Products

5 Appendix X Clarifications

6 New Appendix X1

7 Closing Remarks
9

Opening Remarks

Meeting participants are invited to provide opening remarks or 

statements at this time.
10

Issue boxes correspond to the list of issues published at the end 

of the NOPR document, available at: 

http://www.regulations.gov/#!docketDetail;D=EERE-2014-BTTP-0010.

The deadline for submitting comments is August 4, 2014, 11:59 

PM ET.

Issues for Discussion

Issue Box: DOE welcomes comments, data, and 

information concerning its proposed test procedures 

for dehumidifiers. Whether invited by an issue box or 

not, comments are welcome on any part of DOE’s 

analysis.
11

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements

3 Regulatory History

4 Covered Products

5 Appendix X Clarifications

6 New Appendix X1

7 Closing Remarks
12

Regulatory History: Dehumidifier Test Procedures

Test Procedure Final Rules

Citation Date Description

71 FR 71340 12/08/2006 Test procedure at Appendix X established for 

measuring active mode energy use

77 FR 65942 10/31/2012 Addition of Appendix X1 for measuring 

standby mode and off mode energy use

79 FR 7366 2/7/2014 Removal of obsolete Appendix X and 

redesignation of Appendix X1 as Appendix X

In this NOPR, DOE proposes to amend the redesignated 

Appendix X as well as establish a new Appendix X1.
13

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements

3 Regulatory History

4 Covered Products

5 Appendix X Clarifications

6 New Appendix X1

7 Closing Remarks
14

Product Types

• EPCA defines a dehumidifier as a self-contained, electrically 

operated, and mechanically encased assembly consisting of 

– a refrigerated surface (evaporator) that condenses moisture from the 

atmosphere;

– a refrigerating system, including an electric motor;

– an air-circulating fan; and

– means for collecting or disposing of the condensate. 

• DOE proposes to clarify product types:

Portable dehumidifier – designed to operate within the conditioned 

dehumidified space without the attachment of additional ducting, although 

means may be provided for optional duct attachment.

Whole-home dehumidifier – designed to be installed with ducting to deliver 

return process air to its inlet and to supply conditioned dehumidified process 

air from its outlet to one or more locations in the conditioned dehumidified 

space.

Refrigerant-desiccant dehumidifier – a whole-home dehumidifier that removes 

moisture from the process air by means of a desiccant material in addition to a 

refrigeration system.
15

Convertible Products

A model meeting both the proposed definition of a portable 

and whole-home dehumidifier, with conversion via an optional 

ducting kit, must:

– Be tested as both product categories

– Meet both applicable standards

– Be certified as meeting both standards, if DOE establishes standards for 

whole-home units.
16

Product Type Definitions

DOE seeks comment on the proposed definitions for portable, wholehome, and refrigerant-desiccant dehumidifiers, and whether there are 

additional dehumidifier product categories that should be considered as 

covered products, consistent with the statutory definition of 

dehumidifier.

Issue for Discussion
17

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements

3 Regulatory History

4 Covered Products

5 Appendix X Clarifications

6 New Appendix X1

7 Closing Remarks
18

Current Dehumidifier Test Procedure at Appendix X

• Active mode

– Conducted according to ANSI/AHAM DH-1-2008, “Dehumidifiers”.

– Metrics include:

• Product Capacity [pints/day]

• Energy Factor [L/kWh]

• Standby mode and off mode

– Modes include inactive mode, off mode, off-cycle mode

– Energy use in these modes in aggregate is the Annual Combined 

Low-Power Mode Energy Consumption

• Integrated Energy Factor (IEF)

– Combined metric which incorporates annual combined low-power 

mode energy consumption into EF
19

Clarifications

• DOE proposes a number of amendments to Appendix X, 

which would also be reflected in Appendix X1, to clarify the 

test conduct.

• DOE does not expect these clarifications to change the 

results of Appendix X.
20

Definitions

• Dehumidification mode – an active mode in which a 

dehumidifier:

(1) has activated the main moisture removal function according to the 

humidistat or humidity sensor signal and 

(2) has either activated the refrigeration system or activated the fan or 

blower without activation of the refrigeration system. 

• Product capacity – a measure of the ability of the 

dehumidifier to remove moisture from its surrounding 

atmosphere, measured in pints collected per 24 hours of 

operation under the specified ambient conditions.
21

Definitions

DOE seeks comment on the proposed definitions for dehumidification 

mode and product capacity.

Issue for Discussion
22

Psychrometer Requirements

• The current test procedure does not provide specific 

instructions for psychrometer placement for dehumidifiers 

with multiple intake grilles.

• DOE considered two options:

1. Place a single psychrometer or sampling tree at a location that is 

as close as possible to 1 foot in front of all intake grilles.

2. Place a separate psychrometer or sampling tree 1 foot in front of 

each intake grille.

• Because the second option offered improved reproducibility 

and minimal test burden increases, DOE proposes option 2.

• DOE also proposes to clarify that a psychrometer can only 

be connected to one dehumidifier during testing.
23

Psychrometer Requirements

DOE welcomes comment on the testing burden associated with the 

requirement for multiple psychrometer sampling trees for portable 

dehumidifiers with multiple air inlets, and for connecting only one test 

unit per psychrometer.

Issue for Discussion
24

Condensate Collection

• Dehumidifier buckets may not be large enough to hold all of 

the condensate collected during the 6-hour test.

• When the bucket is full, the unit may turn off the 

compressor or activate an internal pump to empty it.

• Proposed clarifications:

– Dehumidifiers with drains would be connected to a substantially 

closed vessel placed on a scale.

– For dehumidifiers without drains, any auto-shutoff features would 

be disabled and any overflow would be collected in a covered pan 

below the unit, both of which would be on the scale.

– Any internal pump would not be used unless the pump is activated 

by default.
25

Condensation Collection

DOE requests comment on the condensation collection requirements 

for dehumidifiers with and without means for draining the condensate, 

including the use of any internal pump only if it is activated by default in 

dehumidification mode.

Issue for Discussion
26

Control Settings

• Appendix X does not specify the fan speed and RH setting 

during dehumidification mode testing.

• Commenters recommended that:

– Units with a continuous on feature should be tested in 

dehumidification mode using that feature.

– Units without a continuous on feature should be tested at the 

highest fan speed and the lowest humidity setting.

• DOE proposes to adopt these requirements because they:

– Correspond with the highest energy use

– Are consistent with industry practice
27

Control Settings

DOE welcomes comment on the proposed control settings for 

dehumidification mode testing, which would require selecting 

continuous operation for those units with such a function. Otherwise 

the lowest relative humidity setting and, for units with user-adjustable 

fan speed, the highest fan speed would be selected.

Issue for Discussion
28

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements

3 Regulatory History

4 Covered Products

5 Appendix X Clarifications

6 New Appendix X1

7 Closing Remarks
29

New Provisions in Appendix X1

• DOE proposes to incorporate methodology that would 

result in more accurate representation of active mode 

performance.

– Dehumidification mode testing conditions

– Whole-home dehumidifiers

– Fan-only mode
30

Dehumidification Mode – Ambient Temperature

• Current testing conditions: 80 °F dry-bulb and 69.6 °F wet-bulb 

temperatures (60% relative humidity (RH)).

• Commenters noted:

– Variability in installations (e.g., geographic and installation location 

within living space)

– Higher temperature and humidity levels than in the field

– Frost conditions (i.e., dry bulb temperature < 65°F) typical of basement 

installations

– ANSI/AHAM DH-1-2008 low-temperature test at 65°F dry-bulb 

temperature and 60% RH

• Initial information suggested that basement temperatures range from 

55 °F to 75 °F.

– Oak Ridge National Laboratory’s 1998 Building Foundation Design 

Handbook

– Energy Center of Wisconsin 2010 field study
31

Ambient Temperature

DOE further analyzed typical ambient conditions using climate 

and RECS data.

Usage by Location

Determine regions and 

sub-regions comprising 

states with primary 

dehumidifier use.

Data: RECS 2009

Ambient Conditions

Determine average hourly 

ambient temperature, 

relative humidity, and 

ground temperature by 

state.

Data: NCDC/NOAA 2012

Filter/Analyze Data

Remove hours with relative 

humidity low enough to 

preclude dehumidifier use.

Combine hourly state level 

data to determine average 

monthly sub-region conditions.

Weighted average combination 

to determine regional and 

national average monthly 

conditions.

Overall Average Conditions

Combine monthly overall climate 

data with AHAM monthly usage data 

to result in overall national average 

conditions for regions that represent 

the majority of dehumidifier 

operation.

Data: AHAM Estimates 2006

National Weighted Average Annual Ambient Temperature is 64.06 °F

National Weighted Average Annual Soil Temperature is 65.22 °F 
32

Ambient Temperature

Proposal for Portable Dehumidifiers

• DOE estimates that 65 °F is the most representative drybulb temperature for dehumidification mode testing.

– Is consistent with ANSI/AHAM DH-1-2008 Low Temperature Test 

with conditions of 65 °F dry-bulb temperature and 60% RH.

– More national annual operating hours are estimated at 65 °F test 

conditions than at 80 °F test conditions.

• Alternative combined approach:

– Capacity and IEF from both 65 °F and 80 °F test conditions would be 

combined on a weighted basis to reflect the percentage of annual 

hours for each condition. 

– Other weighting factors could also be considered.

– Would significantly increase test burden because two stabilization 

and two 6-hour test periods would be required.
33

Ambient Temperature

Proposal for Whole-Home Dehumidifiers

• DOE proposes that whole-home dehumidifiers be tested at 

the same conditions as portable dehumidifiers, 65 °F drybulb temperature and 60% RH.

• Alternatively...

– Commenters suggested that the inlet air dry-bulb temperature for 

whole-home dehumidifiers is close to the home’s thermostat 

setting.

– RECS data indicates an average indoor temperature in the Northeast 

and Midwest of 72.7 °F.

– DOE may consider requiring that whole-home dehumidifiers be 

tested with inlet conditions of 73 °F dry-bulb temperature and 60% 

RH.
34

Ambient Temperature

Performance Impacts at Reduced Temperature

Product Class

(pints / day) Test Unit

Percent Change 

from 80 °F to 65 °F (%)

Capacity EF

< 35.00 P1 -35 -26

Class Average -35 -26

35.01 - 45.00

P2 -77 -61

P3 -48 -32

P4 -33 -15

Class Average -53 -36

45.01 - 54.00

P5 -39 -25

P6 -33 -21

P7 -36 -21

Class Average -36 -22

54.01 - 75.00

P8 -61 -39

P9 -39 -32

P10 -65 -36

P11 -59 -35

P12 -36 -14

Class Average -52 -31

> 75.00

P13 -27 -15

W3 -35 -21

W4 -42 -29

W5 -49 -26

W7 -27 -15

W8 -24 5

W9 -49 -33

W10 -20 -4

W12 -42 -35

W13 -45 -35

W14* -39 -25

Class Average -36 -21

* Unducted

Test 

Unit

Dehumidification 

Technology

Percent Change 

from 80 °F to 73 °F (%)

Capacity EF

W3 Refrigerant -15 -6

W4 Refrigerant -18 -9

W5 Refrigerant -21 -8

W7 Refrigerant-Desiccant -12 -5

W8 Refrigerant -10 2

W9 Refrigerant -21 -10

W10 Refrigerant -9 -1

W12 Refrigerant-Desiccant -18 -11

W13 Refrigerant -19 -11

Average -16 -7
35

Ambient Dry-Bulb Temperature

DOE welcomes comment on the revision of the ambient dry-bulb 

temperature for dehumidification mode testing from 80 °F to 65 °F in 

new appendix X1, along with the associated impacts to IEF and 

capacity. 

In addition, DOE welcomes input on the alternate approach in which 

dehumidifiers would be tested under both the 80 °F and 65 °F ambient 

temperature conditions. The IEF and capacity would be calculated as 

weighted averages of these metrics measured at each of the two 

temperatures. More specifically, DOE seeks input on appropriate 

weighting factors. 

DOE also seeks comment on the alternate 73 °F dry-bulb temperature 

test conditions for whole-home dehumidifiers that may be 

representative of average residential thermostat settings during 

dehumidifier use.

Issue for Discussion
36

Dehumidification Mode - Relative Humidity

• Commenters concerned with the current 60% RH test condition:

– Adverse health effects are minimized between 40% and 60% RH.

– People generally do not notice RH fluctuations between 25% and 60%.

– Units in a Cadmus Group study had an average setting of 50% RH

– In the Wisconsin Energy Center study, nearly half maintained an average 

RH less than 50% and only 5 units were operated in more than 60% RH.

• Commenters recommended testing at less than 60% RH.

• Research review:

– ASHRAE 55 - Thermal Environmental Conditions for Human Occupancy

– OSHA Technical Manual

– CADMUS Group Field Study

– DOE Metering Study

– Wisconsin Energy Center Field Study

– Manufacturer Literature
37

Relative Humidity

• Results of additional review and research indicate that 

consumers use dehumidifiers to achieve RH from 50 to 55%. 

• To operate continuously in dehumidification mode, ambient 

relative humidity must be maintained higher than 55%.

• A test with conditions fixed at 60% RH would represent the 

common setpoint, below 60%. 

• This 60% RH specification is consistent with all three ambient 

temperature tests in ANSI/AHAM DH-1-2008.

DOE does not propose any amendments to the relative 

humidity specification.
38

Relative Humidity

DOE seeks comment on the proposal to maintain 60-percent relative 

humidity for the ambient testing conditions for dehumidification mode, 

which would correspond to a 56.6 °F wet-bulb temperature at the 

proposed 65 °F dry-bulb temperature. 

Issue for Discussion
39

Whole-Home Dehumidifiers

Ducted Test Installation

• Whole-home dehumidifiers are intended to be installed and 

operated as part of a ducted air-delivery system.

– Ducts for process inlet and outlet air

– May also have a fresh air inlet duct or multiple supply air outlet 

ducts

– Refrigerant-desiccant units also have reactivation air inlet and outlet 

ducts

• The current test procedure does not account for these field 

conditions that impose an external static pressure, which reduces 

airflow and in turn misrepresents actual capacity and efficiency. 

• DOE tested a sample of 13 whole-home units, including 2 

refrigerant-desiccant units, to investigate test methods that 

would be incorporated in Appendix X1 for ducted installations. 
40

Whole-Home Dehumidifiers

Whole-Home Dehumidifier Configurations

• In addition to using a refrigeration system 

to condense moisture, refrigerantdesiccant dehumidifiers use a desiccant to 

transfer moisture from the process air. 

• Moisture adsorbed by the desiccant is reevaporated and ducted outside by the 

heated reactivation air.

• Refrigeration-only dehumidifiers use a 

refrigeration system to condense moisture 

from the process air.
41

Whole-Home Dehumidifiers

Definitions

Process air – the air supplied to the dehumidifier from the 

dehumidified space and discharged to the dehumidified space 

after moisture has been removed by means of the 

refrigeration system

Reactivation air – the air drawn from unconditioned space to 

remove moisture from the desiccant wheel of a refrigerantdesiccant dehumidifier and discharged to unconditioned 

space
42

Whole-Home Dehumidifiers

Capacity Measurement for Refrigerant-Desiccant Dehumidifiers

• The collected condensate will not represent the total moisture removed 

from the conditioned air because it does not include the moisture 

adsorbed by the desiccant.

• DOE proposes a calculation that determines capacity through 

comparison of the psychrometric conditions of the inlet and outlet 

process airstreams.

W=� AHI,i × XI,i − AHO,i × XO,i

n

i=1

×

tt

60

W = weight of water removed during the test period

n = number of samples measured during the test period

AH= absolute humidity of the process air

X = volumetric flow rate of the process air, calculated in accordance with Section 7.3 of AMCA 210-07

t = time interval in seconds between samples

60 = conversion from minutes to seconds.
43

Whole-Home Dehumidifiers

Comparison of Condensate Collection and Vapor Calculation 

Capacity Methods

• Sample of whole-home units were tested at 65 °F dry-bulb temperature, 60% 

RH, and 0.5” external static pressure (ESP).*

• Results demonstrate close correlation for 6 of the 7 refrigeration-only units, 

validating the vapor capacity method.

• Results also show that refrigerant-desiccant units removed 1/3 or more of 

moisture by means of the desiccant.

Test Unit Dehumidification 

Technology

Compressor 

Operation

Capacity (pints/day) Energy Factor (L/kWh)

Condensate 

Capacity

Vapor 

Capacity Difference (%) Condensate Capacity

Vapor 

Capacity

Difference 

(%)

W3 Refrigerant Continuous 53 52 -2% 1.59 1.57 -1%

W4 Refrigerant Continuous 53 51 -4% 1.43 1.38 -4%

W5 Refrigerant Cycling 49 68 39% 1.89 2.66 40%

W7 Refrigerant-Desiccant Continuous 42 84 100% 1.08 2.18 101%

W8 Refrigerant Continuous 58 55 -4% 1.44 1.37 -4%

W9 Refrigerant Continuous 71 71 -1% 1.10 1.09 -1%

W10 Refrigerant Continuous 109 113 3% 2.82 2.85 1%

W12 Refrigerant-Desiccant Continuous 70 99 41% 0.75 1.11 48%

W13 Refrigerant Continuous 108 104 -4% 1.68 1.63 -3%

* The selection of this representative ESP value is discussed later.
44

Whole-Home Dehumidifiers

Ducting Configuration

• DOE reviewed the test setup used by the 

National Renewable Energy Laboratory 

in its research on whole-home 

dehumidifiers

• DOE also referred to the Air Movement 

and Control Association International, 

Inc. (AMCA) Standard 210-07 to aid in 

the development of the proposed test 

duct length and sensor placement.
45

• Fresh air from the exterior of a home may be brought into 

the process airstream through an additional inlet port.

• Results for dehumidifiers connected to fresh air with the 

same conditions as the inlet air averaged 3% higher in 

capacity and 4% higher in EF than those without the use of 

fresh air.

• DOE proposes that any fresh air collars be sealed during 

testing.

Whole-Home Dehumidifiers

Fresh Air Inlet
46

Whole-Home Dehumidifiers

Process Air Inlet and Outlet Ducts

• DOE investigated performance impacts of connecting only 

an instrumented outlet test duct versus monitoring 

conditions at both inlet and outlet process air test ducts.

• DOE proposes to require only outlet test ducts.

ESP

at 80°F and 60% RH

(in. w.c.)

Capacity (pints/day) Energy Factor (L/kWh)

Inlet and 

Outlet Ducts

Outlet Duct 

Only

Percent 

Impact (%)

Inlet and 

Outlet 

Ducts

Outlet Duct 

Only

Percent 

Impact 

(%)

0.01 75 77 2.7 2.39 2.40 0.3

0.11 73 74 1.2 2.25 2.31 2.4

0.19 71 73 4.1 2.15 2.26 5.0

0.50 (Extrapolated) 63 66 6.0 1.73 2.01 16.0
47

Whole-Home Dehumidifiers

Test Duct Specifications

• DOE proposes that figures 7A and 16 of AMCA 210-07 

would provide conditions representative of normal 

operation while requiring the fewest components.

– Duct lengths and sensor spacing are specified as a function of duct 

diameter

• Proposed duct specifications:

– 10” diameter

• Majority of units connect to 10” diameter collars

– Galvanized mild steel

• Commonly used in HVAC applications 

• Unaffected by moisture

– Insulation

• Minimum R value of 6

• All seams and edges sealed with tape
48

Whole-Home Dehumidifiers

Transition Sections

• DOE proposes the use of transition sections to allow 

diameters other than 10’’ to be connected to standard-sized 

test ducts.

• DOE referenced section 5.2.1.3 of AMCA 210-07 for a 

maximum 7.5° convergent angle and 3.5° divergent angle. 
49

Whole-Home Dehumidifiers

Flow Straighteners

• Ducts with 10’’ circular diameters require at least 20 feet of 

straight ducting to achieve laminar flow for the typical range 

of whole-home dehumidifier flow rates.

• DOE proposes the use of flow straighteners as specified by 

AMCA 210-07 to reduce duct length to a more manageable 

size.
50

Whole-Home Dehumidifiers

Dry-Bulb Temperature Sensors

• DOE proposes to reference section 5.3.5, Centers of 

Segments-Grids, of ASHRAE Standard 41.1-2013, for drybulb temperature sensors.

• The proposal would require sensors in the center of four or 

more duct cross-sectional sections of equal area.

• DOE further proposes that the temperature be measured 5 

inches upstream of an inlet collar and 95 inches 

downstream of an outlet collar, in accordance with AMCA 

210-07.
51

Whole-Home Dehumidifiers

Relative Humidity Sensors for Refrigerant-Desiccant Units

• RH in these units is measured in both air streams:

– Process air inlet and outlet ducts: used for the vapor capacity calculation

– Reactivation air inlet duct: used to monitor ambient conditions

• DOE considered two sensor options for the duct RH measurement:

• DOE proposes the use of aspirating psychrometers due to lower testing 

burden than chilled mirror hygrometers

Chilled mirror hygrometer Aspirating psychrometer

A cooled surface detects dew point and in 

turn RH.

• Accurate up to 2% RH at 65 °F dry-bulb 

temperature and 60% RH.

• Costly to procure and requires skilled 

operator and frequent cleaning.

Two thermometers detect dry-bulb and wetbulb temperatures.

• Accurate up to 1% RH.

• Commonly used in the industry for 

portable dehumidifier testing.
52

Whole-Home Dehumidifiers

• Pitot-static tube construction in accordance with section 4.2.2, 

Pitot-Static Tube, of AMCA 210-07, 

• The arrangement of pitot-static tubes in each traverse across 

the plane of the duct according to section 4.3.1, Pitot Traverse, 

of AMCA 210-07.

• The measured static pressures at each point in a traverse to be 

averaged to represent the static pressure at that location in the 

test duct.

• Pressure instrumentation accuracy within ±0.01” H2O

Static Pressure Instrumentation
53

Whole-Home Dehumidifiers

Representative External Static Pressure (ESP)

• DOE proposes that the whole-home dehumidifier test be 

conducted at an ESP of 0.5 inches of water column (” H2O) 

to reflect field duct losses.

– Manufacturer literature lists performance at ESPs from 0 to 0.8” H2O.

– The Center for Energy and Environment conducted a study that included 81 

homes in Minnesota, which measured an average ESP of 0.55” H2O.

– DOE’s analysis in the furnace fan test procedure indicated that 0.5” H2O 

would be representative of field duct systems.

• ESP would be calculated as the difference in static pressure 

between the inlet and outlet test ducts.

– Appendix X1 would reference section 7.5.2, Pressure Losses, of AMCA 210-

07 to calculate the losses between the unit under test and the planes of 

static pressure measurement.
54

Whole-Home Dehumidifiers

Impact of ESP on Capacity at 65 °F and 60% RH

Test Unit

Capacity (pints/day) Percent Change in 

Capacity from 0 to 0.5 

in. w.c.

0 in. 

w.c.

0.25 in. 

w.c.

0.5 in. 

w.c.

0.75 in. 

w.c.

1 in. 

w.c.

W3 63 - 53 - - -16%

W4 56 54 53 49 23 -5%

W5 66 - 49 - - -26%

W8 82 73 58 - - -29%

W9 77 75 71 68 68 -8%

W7 107 98 84 - - -21%

W10 120 - 109 - - -9%

W12 112 105 99 - - -12%

W13 125 - 108 - - -14%
55

Whole-Home Dehumidifiers

Impact of ESP on Energy Factor at 65 °F and 60% RH

Test Unit

Energy Factor (L/kWh) Percent Change in 

Energy Factor from 0 to 

0.5 in. w.c.

0 in. 

w.c.

0.25 in. 

w.c.

0.5 in. 

w.c.

0.75 in. 

w.c.

1 in. 

w.c.

W3 1.91 - 1.59 - - -17%

W4 1.5 1.48 1.43 1.31 0.43 -5%

W5 2.31 - 1.89 - - -18%

W8 2.42 2.02 1.44 - - -40%

W9 1.18 1.13 1.1 1.05 1 -7%

W7 2.76 2.55 2.18 - - -21%

W10 3.16 - 2.82 - - -11%

W12 1.28 1.18 1.11 - - -13%

W13 1.94 - 1.68 - - -13%
56

Whole-Home Dehumidifiers

Volumetric Air Flow Rate Instrumentation

• DOE proposes that the volumetric air flow rate be measured 

in the process air for refrigerant-desiccant dehumidifiers to 

allow for use of the vapor capacity calculation method. 

• Section 7.3.1, Velocity Traverse, of AMCA 210-07 measures 

velocity pressure, which would employ the same traverse of 

pitot-static tubes used to measure static pressure.
57

Whole-Home Dehumidifiers

Measurement Frequency

• Appendix X requires psychrometry data to be recorded at 

10-minute intervals or less during dehumidification mode 

testing.

• DOE proposes in Appendix X1 to increase the frequency of 

data acquisition for whole-home dehumidification mode 

testing from 10-minute to 1-minute intervals because the 

conditions of the air in test ducts could vary more quickly 

than in a test chamber.
58

Whole-Home Dehumidifier Testing

DOE seeks comment on the test setup and testing methodology for 

whole-home dehumidifiers in appendix X1, including refrigerantdesiccant dehumidifiers. In particular, DOE welcomes comment on the 

proposed ducting configurations, alternative ambient temperature, and 

ESP, including equipment costs and testing burden.

Issue for Discussion
59

Fan-Only Mode

• Certain dehumidifiers operate the blower when the compressor 

is off after the humidity setpoint has been reached (i.e., fanonly mode) in order to:

– Draw air over the humidistat to monitor ambient conditions

– Defrost and dry the evaporator

– Circulate air in the conditioned space

• The blower may operate continuously or cycle intermittently

• DOE proposes the following mode definition:

Fan-only mode – an active mode in which a dehumidifier

(1) has cycled off its main moisture removal function by humidistat, or 

humidity sensor, or control setting,

(2) has activated its fan or blower to operate either cyclically or continuously, 

and

(3) will may reactivate the main moisture removal function according to the 

humidistat or humidity sensor signal . 
60

Fan-Only Mode

• DOE proposes in Appendix X1 to measure average fan-only mode power 

using:

– Time period

• a 1-hour period for continuous operation, or 

• a period of at least 1 hour including 3 or more full cycles for cyclic operation

– Fan speed

• An adjustable-speed fan would be set at maximum speed because that is the 

setting typically recommended to consumers for maximum moisture removal 

rate.

• To minimize testing burden:

– Testing could be conducted under ambient conditions for either 

dehumidification mode or standby and off mode testing

– No more than one run-in period would be required for all active mode 

testing. Run-in would require the compressor to be operating.

• The off-cycle annual hours in the IEF calculation would instead be 

assigned to fan-only mode for units with fan-only mode. 
61

Fan Mode for Air Circulation

• Certain dehumidifiers provide a consumer-initiated fan mode 

for air circulation that is distinct from the fan-only mode 

discussed previously. 

• DOE is not proposing at this time to measure energy use in this 

air circulation fan mode due to a lack of information on 

consumer usage patterns.
62

Fan-Only Mode

DOE seeks comment on the proposed definition for fan-only mode.

DOE welcomes comment on the proposals for measuring energy 

consumption in fan-only mode in Appendix X1, including the use of the 

maximum speed setting for those units with adjustable fan speed 

settings, the measurement period specifications, and the inclusion of 

fan-only mode energy consumption in the calculation of IEF. DOE also 

seeks comment on whether fan-only mode energy consumption is 

independent of ambient conditions.

DOE welcomes data and input on consumer usage patterns related to 

fan mode for air circulation.

Issue for Discussion
63

Small Business Impacts

• DOE identified five small business manufacturers .

• Impacts of reduced ambient test temperature: 

– AHAM DH-1-2008 includes a test at 65 °F, which suggests that some 

manufacturers already test at the proposed lower temperature.

• DOE estimated the costs associated with the proposal.

– Whole-home test ducts: 

• Refrigeration-only whole-home dehumidifier: $1,500 to $3,000 

• Refrigerant-desiccant dehumidifier: $8,100

– Fan-only mode test can use the same measurement devices as the 

current test procedure.

• Cost of additional meter: $2,000 (if needed)

– Proposed limit of one psychrometer per dehumidifier test could 

require the purchase of additional psychrometers.

• Cost to purchase and calibrate one psychrometer: $1000

• Cost of sampling tree: $300
64

Public Meeting Slides Topics

1 Introductions

2 Stakeholder Opening Statements

3 Regulatory History

4 Covered Products

5 Test Procedure Clarifications

6 New Provisions

7 Closing Remarks
65

How to Submit Comments...

• Public Meeting – oral comments will be captured in the transcript and 

become part of the public record.

• Written comments – NOPR comment period open until August 4, 2014.

Reference docket #: EERE–2014–BT–TP–0010 and/or RIN #: 1904–AC90

Email: Dehumidifier2014TP0010@ee.doe.gov

Mail: Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

1000 Independence Avenue SW., Mailstop EE-2J

Washington, DC 20585-0121

Courier: Mrs. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L'Enfant Plaza, Suite 600

Washington, DC 20024

Telephone: (202) 586-2945
66 | Energy Efficiency and Renewable Energy eere.energy.gov

Energy Conservation Standards:

Preliminary Analysis for

Residential Dehumidifiers

June 13, 2014

Ashley Armstrong

Department of Energy

Building Technologies Program

EERE-2012-BT-STD-0027

ResDehumidifier2012STD0027@ee.

doe.gov
67

Agenda

1:00 – 1:30 pm Introduction

1:30 – 1:45 pm Market and Technology Assessment and Screening

1:45 – 2:00 pm Engineering Analysis

2:00 – 2:30 pm Preliminary Manufacturer Impact Analysis

2:30 – 2:45 pm Markups and Energy Use Analysis

2:45 – 3:00 pm Life-Cycle Cost and Payback Period Analysis

3:00 – 3:15 pm Shipments and National Impact Analysis

3:15 – 3:30 pm Next Steps

3:30 – 3:45 pm Closing Comments from Participants

3:45 – 4:00 pm Closing Remarks
68

Issues for Discussion

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

Department seeks comments.

• The list of issues is in the preliminary analysis notice, available at: 

http://www.regulations.gov/#!documentDetail;D=EERE-2012-BT-STD0027-0016

• The deadline for submitting comments is July 21, 2014.

Request for Comment

DOE welcomes comments, data, and information concerning its 

preliminary analysis for residential dehumidifiers. Issues that 

correspond to those raised in DOE’s published material will be 

numbered in accordance with that material. Whether invited by an 

issue box or not, comments are welcome on any part of DOE’s 

analysis.
69

How to Submit Written Comments

In all correspondence, please refer to this rulemaking by:

– Standards for Residential Dehumidifiers

– Docket Number EERE-2012-BT-STD-0027

– Regulation Identification Number (RIN) 1904-AC81

Email: ResDehumidifier2012STD0027@ee.doe.gov

Postal: Courier

Ms. Brenda Edwards Ms. Brenda Edwards

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

Building Technologies Program, Building Technologies Program, Suite 600

Mailstop EE-5B 950 L’Enfant Plaza, SW

1000 Independence Avenue, SW Washington, DC 20024

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

Comment period closes July 21, 2014, 11:59 PM ET
70

Opening Remarks

Meeting participants are invited to provide opening 

remarks or statements at this time.
71

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

2 Market and Technology Assessment and Screening

3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis

5 Markups and Energy Use Analysis

6 Life-Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis

8 Next Steps
72

Regulatory History

• Energy Policy and Conservation Act of 1975 (EPCA) P.L. 94-163

– Amended by National Energy Conservation Policy Act of 1978, P.L. 95-

619, to establish the “Energy Conservation Program for Certain Industrial 

Equipment.”

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

– Amended EPCA to establish the initial energy conservation standards for 

dehumidifiers.

• Energy Independence and Security Act of 2007 (EISA) P.L. 110-

140

– Further amended EPCA to prescribe new energy conservation standards 

for dehumidifiers manufactured on or after October 1, 2012.

• Notice of Proposed Rulemaking (NOPR) or determination that 

existing standards do not require amendments required by 

March 11, 2015, to meet EPCA’s 6-year look-back provision.

Current rulemaking
73

Definition of Covered Products

• EPACT defines a dehumidifier as follows:

The term “dehumidifier” means a self-contained, electrically operated, 

and mechanically encased assembly consisting of-

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

the atmosphere;

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

• (C) an air-circulating fan; and

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

(42 U.S.C. 6291(34)) 
74

Energy Conservation Standards History

• EISA 2007 established the following (current) energy 

conservation standards for residential dehumidifiers, for 

which compliance is required as of October 1, 2012:

Product Capacity 

(pints/day)

Minimum Energy Factor 

(liters/kWh)

Less than 35.00 1.35

35.01 to 45.00 1.50

45.01 to 54.00 1.60

54.01 to 75.00 1.70

Greater than 75.00 2.5
75

Dehumidifier Standards Rulemaking Timeline

2012 2013 2014 2015 2016 2017 2018

Milestone Date

Preliminary Analysis Publication May 22, 2014

Preliminary Analysis Public Meeting June 13, 2014

Comment Period Ends July 21, 2014

NOPR Publication (projected) March, 2015

Final Rule Publication (projected) March, 2017
76

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

2 Market and Technology Assessment and Screening

3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis

5 Markups and Energy Use Analysis

6 Life-Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis

8 Next Steps
77

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
78

Market and Technology Assessment

Purpose:

• Define product classes

• Characterize the residential dehumidifier industry

• Identify existing regulatory and voluntary efficiency programs

• Gather historical shipments and other relevant market data

• Identify technology options for improving efficiency
79

Product Classes - Portable

• When evaluating and establishing energy conservation 

standards, DOE generally divides covered products into product 

classes by the type of energy used or by capacity or other 

performance-related features that affect efficiency

• DOE conducted its preliminary analysis using the following 

portable product classes:

Portable Product Classes –

Capacity (pints/day)

Appendix X1 (65°F)

Less than 20.00

20.01 to 30.00

30.01 to 35.00

35.01 to 45.00

45.01 or more
80

Product Classes – Whole-Home

• DOE conducted its preliminary analysis using the following 

whole-home product classes:

Whole-Home Product Classes 

Case Volume (cubic feet)

Less than or equal to 8.0

Greater than 8.0
81

Request for Comment

Item 1: DOE invites comments and recommendations from interested 

parties on the proposed product class parameters, which are based on 

capacity for portable dehumidifiers and on case volume for wholehome dehumidifiers.

Product Classes
82

Manufacturers and Market Share

• DOE estimates that there are approximately 25 brands of 

residential dehumidifiers available in the United States

– 17 portable dehumidifier brands 

(market shares estimated 

below).

– 8 whole-home dehumidifier 

brands (and high-capacity 

portable dehumidifiers), with 

Therma-Stor LLC and Aprilaire

(Research Products Corporation) 

making up the majority of the 

market. Other producers 

include Munters, NovelAire, and 

Williams Furnace Company.
83

Efficiency Distribution

• The plot below shows the current availability of residential 

dehumidifiers on the market, based on the current test conditions.

Source: DOE-certified dehumidifiers (http://www.regulations.doe.gov/certification-data/)
84

Technology Assessment

• Dehumidifiers contain a refrigeration system to remove latent 

heat, and therefore moisture, from the air.

• Primary components include:

– Compressor

– Heat Exchangers

• Evaporator

• Condenser

– Expansion Valve or Capillary Tube

– Fan/Blower

– Condensate Collection Bucket or 

Drain
85

Technology Assessment

• DOE identified following initial technology options that could be 

used to improve energy efficiency in dehumidifiers:

Initial Technology Options for Dehumidifiers

• Built-in hygrometer/humidistat • Improved flow-control devices

• Improved compressor efficiency • Low-standby-loss electronic controls

• Improved condenser and evaporator 

performance

• Washable air filters

• Improved controls • Pre-cooling air-to-air heat exchanger

• Improved defrost methods • Heat pipes

• Improved demand-defrost controls

• Improved refrigeration system 

insulation

• Improved fan and fan-motor 

efficiency

• Refrigerant-desiccant systems
86

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
87

Screening Analysis

• Purpose: Identify any technologies to be eliminated from 

further consideration.

• DOE screens out technology options based on four factors:

– Technological feasibility; practicability to manufacture, install, and 

service; impacts on product utility to consumers; and safety of 

technologies.

• DOE screened out pre-cooling air-to-air heat exchangers and 

heat pipes for portable dehumidifiers up to 45 pints/day (based 

on the proposed testing conditions).

– Product case volumes would roughly double with these features, 

resulting in: 

• Adverse impacts on product utility to consumers(e.g., reduced portability, 

increased weight). 

• Unavailability of products with the same sizes and volumes as those 

currently on the market .
88

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

2 Market and Technology Assessment and Screening

3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis

5 Markups and Energy Use Analysis

6 Life-Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis

8 Next Steps
89

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
90

Engineering Analysis

Purpose

• Evaluate design options that improve efficiency

• Characterize manufacturer production cost (MPC) 

versus efficiency for higher-efficiency dehumidifiers.

Downstream Analysis

• Life-Cycle Cost and 

Payback Period Analysis

•National Impact Analysis

• Manufacturer Impact 

Analysis

Manufacturer Production Cost–

Efficiency Relationship

Manufacturer 

Production Cost

Efficiency Level
91

Engineering Analysis Process

The engineering analysis for dehumidifiers was conducted as 

follows:

1. Select Test Sample

Choose market 

representative units 

for testing.

2. Product Testing

Conduct testing at

80 °F and 65 °F 

ambient conditions.

3. Efficiency Levels

Determine appropriate 

baseline and improved 

efficiency levels for the 80 °F

and 65 °F ambient conditions.

4. Teardown

Perform teardowns to 

determine product 

designs and 

manufacturing costs.

5. Numerical Model

Use a numerical model to 

estimate performance and 

associated designs beyond 

the teardown sample.

6. Cost-Efficiency Curves

Determine costefficiency 

relationships.
92

Product Testing

• DOE selected 24 portable units (<45 pints/day) , 13 highcapacity portable(>45 pints/day) and refrigerant-only wholehome units, and 2 refrigerant-desiccant whole-home units for 

testing.

• Selected units covered the range of available capacities and 

efficiencies of products available on the market from multiple 

manufacturers.

• These test units were used in support of both the ongoing test 

procedure rulemaking and this standards analysis, and were 

tested at both 80 °F and 65 °F ambient conditions.
93

Efficiency Levels – Portable

Efficiency

Level Efficiency Level Source

Integrated Energy Factor Efficiency Levels (L/kWh) at 80 °F

35.00 pints/day or 

less

35.01–45.00 

pints/day

45.01–54.00 

pints/day

54.01–75.00 

pints/day

Baseline Baseline with Fan-only Mode 1.05 1.16 1.29 1.35

1 Baseline with no Fan-only 

Mode 1.50 1.50 1.60 1.70

2 Gap Fill or ENERGY STAR 1.70 1.70 1.85 1.85

3 ENERGY STAR or Gap Fill 1.85 1.85 1.95 1.95

4 Maximum Available 1.93 1.93 2.06 2.06

Efficiency

Level Efficiency Level Source

Integrated Energy Factor Efficiency Levels (L/kWh) at 65 °F

20.00 pints/day or 

less

20.01–30.00 

pints/day

30.01–35.00 

pints/day

35.01–45.00 

pints/day

Baseline Baseline with Fan-only Mode 0.77 0.80 0.94 1.00

1 Baseline with no Fan-only 

Mode 1.10 1.10 1.20 1.30

2 Gap Fill 1.20 1.20 1.40 1.40

3 Gap Fill 1.30 1.30 1.60 1.60

4 Maximum Available 1.42 1.52 1.75 1.75
94

Efficiency Levels – High-Capacity Portable and Whole-Home

Efficiency

Level Efficiency Level Source

Integrated Energy Factor Efficiency Levels (L/kWh) at 80 °F

75.01 pints/day or 

more

≤ 8.0 ft3 > 8.0 ft3

Baseline Minimum Available 2.44 1.90 2.50

1 Gap Fill 1 2.80 2.20 2.80

2 Gap Fill 2/Maximum Available 3.50 2.50 3.50

3 Maximum Available 4.2 N/A 4.20

Efficiency

Level Efficiency Level Source

Integrated Energy Factor Efficiency Levels (L/kWh) at 65 °F

45.01 pints/day or 

more

≤ 8.0 ft3 > 8.0 ft3

Baseline Minimum Available 2.07 1.10 1.68

1 Gap Fill 1 2.40 1.40 1.90

2 Gap Fill 2/Maximum Available 2.80 1.59 2.80

3 Maximum Available 3.52 N/A 3.41
95

Product Teardowns

• DOE calculated MPCs by disassembling dehumidifiers from 

multiple manufacturers and creating bills of materials (BOMs).

• BOMs describe the product components in detail and include 

estimates of materials, labor, capital equipment, and overhead 

costs.

• Chapter 5 of the Technical Support Document (TSD) provides 

additional details on DOE’s teardown and cost model 

methodology.
96

Product Teardowns

• Based on teardowns, and confirmed during manufacturer 

interviews, DOE observed that three design options are used to 

increase dehumidifier efficiency in each of the product classes.

– Increasing compressor efficiency

– Improving condenser and evaporator performance

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

• DOE did not specifically consider the remaining design options 

that met the screening criteria for the following reasons: 

– All products already incorporate the design option

– Changes to a specific design option would be captured as observed in the 

teardown sample.

– The current DOE test procedure would not capture the potential 

improvements of the remaining design options.
97

Request for Comment

Item 2: DOE requests comment on whether it should consider design 

options that may improve dehumidifier efficiency under varying 

operating conditions (i.e., improved controls, improved flow-control 

devices, and variable-speed compressors). DOE notes that the current 

and proposed test procedures measure active mode energy use under 

continuous unit operation at constant ambient conditions and may 

not reflect efficiency gains associated with these technologies.

Product Teardowns
98

Numerical Model

• DOE’s teardown sample did not cover the entire range of 

capacities and efficiency levels that DOE is proposing to analyze 

for potential standards.

• To fill gaps in the teardown sample, DOE used a numerical 

model to estimate the design changes and associated costs 

necessary to reach different efficiency levels and capacities.

– The numerical model is based on the MarkN program developed for use 

in the most recent room air conditioners direct final rule (April 21, 2011).

– DOE modified the room air conditioner program to set the condenser 

inlet air conditions (typically outdoor air for room air conditioners) equal 

to the evaporator outlet air conditions (typically the indoor return air for 

air conditioners).

– DOE first increased compressor efficiencies, then increased heat 

exchanger sizes to estimate the changes necessary to reach higher IEFs.
99

Cost-Efficiency Relationships

• Using actual teardowns and estimated manufacturing costs for 

modeled units, DOE created cost-efficiency curves for each 

major manufacturer.

• DOE combined manufacturer curves based on estimated market 

share to develop a weighted-average cost-efficiency curve for 

each product class.

Weighted Average

$MPC

Efficiency Level

Manufacturer Curves

$MPC

Efficiency Level

Manuf. #1

Manuf. #2

Manuf. #3
100

• $0 incremental cost from baseline to EL1 represents the 

elimination of fan-only mode.

Cost-Efficiency Relationships

Efficiency

Level

Pints/day at 80 °F and 65° F

≤ 35 35.01-45 45.01-54 54.01-75

≤ 20 20.01-30 30.01-35 35.01-45

BL 0 0 0 0

EL1 $- $- $- $-

EL2 $1.56 $1.85 $2.94 $1.98 

EL3 $4.64 $3.78 $8.72 $7.56 

EL4 $7.77 $10.82 $13.40 $11.24 
101

• Incremental costs for high-capacity portable and whole-home 

units are higher than for portable units due to the higher overall 

MPCs of these products.

Cost-Efficiency Relationships

Efficiency

Level

Pints/day at 

80 °F and 65° F

Whole-Home 

Case Volume (ft3)

> 75

≤ 8.0 > 8.0

> 45

BL 0 0 0

EL1 $38.40 $15.22 $6.14 

EL2 $49.16 $76.18 $37.05 

EL3 $100.13 $112.01 
102

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

2 Market and Technology Assessment and Screening

3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis

5 Markups and Energy Use Analysis

6 Life-Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis

8 Next Steps
103

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
104

• Purpose

– To identify the impacts of energy conservation standards on manufacturers.

• Phase 1

– DOE creates an industry profile to characterize the industry and identify 

important issues that require consideration.

• Phase 2

– DOE prepares an industry cash-flow model and an interview questionnaire 

to guide subsequent discussions with manufacturers.

• Phase 3

– DOE interviews manufacturers, and assesses the impacts of standards both 

quantitatively (using the Government Regulatory Impact Model) and 

qualitatively (impacts on competition, manufacturing capacity, employment, 

and regulatory burden).

Manufacturer Impact Analysis - Overview

Industry 

profile

Develop 

preliminary 

GRIM

Develop 

interview 

guide

Interviews

& industry

subgroup

analyses

Assess 

employment, 

competition, 

capacity, & 

regulatory

burdens

Phase 1 Phase 2 Phase 3
105

• Impacts of Higher Selling Prices

– Higher selling prices could price-out a segment of residential dehumidifier 

consumers. Such impacts could be particularly severe in the whole-home 

segment due to the two-tier distribution structure.

• Application Constraints for Whole-Home Manufacturers

– Size constraints for certain whole-home dehumidifier applications place limits 

on manufacturers’ ability to make higher efficiency products.

• Impacts on Consumer Utility

– Increased product efficiency may come at a cost to other product features, 

such as size, noise level, and performance at low temperatures. 

• Conversion Costs

– Conversion costs could be significant if amended standards require new 

product platforms in the form of increased product envelope size.

• Small Business Impacts

– Amended standards could place a disproportionate burden on small 

businesses.

Preliminary MIA Key Issues
106

Issues for Comment

Request for Comment

Item 3: DOE requests comment on its identification of key issues and 

requests data and information from interested parties that can assist 

in evaluating the potential impact on manufacturers.

Item 4: DOE considers the impacts on certain manufacturer subgroups, 

including small business manufacturers, that have different cost 

structures or operate within different regulatory frameworks in the 

NOPR stage. DOE requests feedback on subgroups to analyze and/or 

characteristics appropriate for subgroup analysis.
107

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

2 Market and Technology Assessment and Screening

3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis

5 Markups and Energy Use Analysis

6 Life-Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis

8 Next Steps
108

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
109

Markups Analysis

Total Installed Cost

Payback Period

Lifetime Operating 

Expense

Life-Cycle Cost

Energy Consumption

Electricity Prices

Annual Energy 

Expense

Repair Costs

Maintenance Costs

Electricity Price 

Trend

Annual Operating 

Expense

Lifetime

Discount Rates

Customer Price

Installation Cost

Data Inputs

Intermediate Analysis

Output Results

From Engineering 

Analysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups 

Analysis

Baseline MSP

Std-level MSP

From Engineering 

Analysis

Price is a function 

of efficiency

From Energy Use 

Analysis
110 110

• Purpose

– Determine customer prices under a standards scenario based on 

manufacturer costs.

– Characterize product distribution channels and market segments.

– Describe dehumidifier retailer direct costs, expenses, and profits

• Output

– Manufacturer markups and baseline and incremental markups for 

both portable and whole-home dehumidifiers.

Markups Markups Analysis Analysis

Overview
111

Markups Analysis Markups Analysis

• Baseline Markups

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

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

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

distributor’s or contractor’s expenses plus profit.

• Incremental Markups

– Incremental markups relate the incremental change in consumer price 

to the incremental change in CGS.

– Certain costs, such as direct labor costs (salaries, payroll, rental and 

occupancy), do not vary with efficiency induced changes in CGS and 

remain constant in the calculation of incremental markups.

– Incremental markups cover only expenses that vary with CGS in this 

case, expenses that increase due to an increase in equipment 

efficiency.

Markup Types
112

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
113

Energy Use Analysis

Total Installed Cost

Payback Period

Lifetime Operating 

Expense

Life-Cycle Cost

Energy Consumption

Electricity Prices

Annual Energy 

Expense

Repair Costs

Maintenance Costs

Electricity Price 

Trend

Annual Operating 

Expense

Lifetime

Discount Rates

Customer Price

Installation Cost

Data Inputs

Intermediate Analysis

Output Results

From Engineering 

Analysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups 

Analysis

Baseline MSP

Std-level MSP

From Engineering 

Analysis

Price is a function 

of efficiency

From Energy Use 

Analysis
114

Purpose

• Develop annual energy use data for the life-cycle cost and payback period 

analyses to calculate annual operating costs.

Method

• Develop household samples from DOE-EIA’s Residential Energy 

Consumption Survey (RECS) for the two product class to be analyzed.

• Use research studies, RECS data along with Engineering Analysis data to 

develop annual energy use on a per-household basis.

Energy Use Analysis

Overview
115

Calculation Flow

Energy Use Analysis

( ) ( )



 





+ × + × 





 







×

× ×  ×



 



 = Fan Fan Stby Stby

Dehum

ENERGY X kW X kW

Eff

CAP X

Year

TotalHoursofUse DEH

24

0.473

X

Annual Operating Hours

(hours/year)

Dehum

Power (kW)

X 

Dehum

Mode (%)

Fan Power 

(kW)

X 

Fan Mode 

(%)

SB Power 

(kW) 

X 

SB Mode 

(%)

+ +

Annual 

Energy Use
116

Energy Use Analysis Portable 

Study / Source Dehumidification Mode Operating Hours

Average Hours / Year

ADL (1998)

AHAM (2005)

ENERGY STAR (2006)

ENERGY STAR calculator

The Cadmus Group (2012)

1,620

1,095

1,620

2,851

2,160

Willem, et al. (2013a) CCB*

CCDD**

NCCB†

NCCDD‡

1,136

1,078

1,267

1,785

Whole-HomeWillem, et al. (2013b) Whole-home 2,542

*CCB = Climate controlled space, bucket for 

condensate

**CCDD = Climate controlled space, direct drain for 

condensate

†NCCB = Non-climate controlled space, bucket for 

condensate

‡NCCDD = Non-climate controlled space, direct drain 

for condensate

Energy Use Inputs: Literature Review of Operating Hours

DOE augmented RECS household data with data from the research studies and compared the research findings 

with estimates used in the previous standards rulemaking in 2006 to estimate annual hours and a range of annual 

energy use values.

Source: AHAM 2006, ENERGY STAR 2006, The Cadmus Group 2012, Willem et al., 2013a, 2013b.
117

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

2 Market and Technology Assessment and Screening

3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis

5 Markups and Energy Use Analysis

6 Life-Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis

8 Next Steps
118

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
119

Life-Cycle Cost and Payback Period Analysis

Total Installed Cost

Payback Period

Lifetime Operating 

Expense

Life-Cycle Cost

Energy Consumption

Electricity Prices

Annual Energy 

Expense

Repair Costs

Maintenance Costs

Electricity Price 

Trend

Annual Operating 

Expense

Lifetime

Discount Rates

Customer Price

Installation Cost

Data Inputs

Intermediate Analysis

Output Results

From Engineering 

Analysis

Distributor Markup

Contractor Markup

Sales Tax Markup

From Markups 

Analysis

Baseline MSP

Std-level MSP

From Engineering 

Analysis

Price is a function 

of efficiency

From Energy Use 

Analysis

Overview
120

Life-Cycle Cost (LCC) and 

Payback Period (PBP) Analysis Purpose

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

• LCC equals consumer price plus the sum of annual operating costs discounted to a 

particular base year.

• Economic evaluation performed from the consumer perspective.

• Results expressed as LCC difference (baseline minus efficiency standard level).

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

savings for 1 year.

Life-Cycle Cost and Payback Period Analysis
121

Method

• Monte Carlo simulation analysis used.

‒ Characterize the variability and uncertainty associated with the inputs 

using probability distributions.

‒ RECS household samples used to characterize the variability in annual 

energy use and energy prices.

‒ Probability distributions used to characterize the uncertainty in other 

operating cost inputs (e.g., discount rates, product lifetimes) and 

manufacturing costs.

• One LCC and PBP analysis result per product class.

‒ Analysis conducted for each proposed product class analyzed in detail 

in the Engineering Analysis.

• Base case efficiency distributions developed to avoid overstating the 

benefits from increasing product efficiency.

Life-Cycle Cost and Payback Period Analysis
122

Total Installed Cost

• Total Installed Cost = Retail Price + Installation Cost

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

‒ Manufacturing cost vs. efficiency relationships developed in the 

Engineering Analysis

‒ Markups and Sales Taxes developed in the Markups to Determine 

Equipment Price analysis

• Installation costs represent the labor and materials necessary to install the 

appliance

‒ DOE did not consider or calculate installation costs for portable 

dehumidifiers

‒ Whole-home dehumidifier installation costs are based on cooling and 

heating system installation but DOE assumed that costs do not vary with 

efficiency

Life-Cycle Cost and Payback Period Analysis
123

Lifetime Operating Cost

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

electricity price trend)

• Annual Operating Cost = Annual Energy Cost + Repair Cost + Maint. Cost

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

‒ Energy use by mode developed in the Energy Use Analysis

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

‒ Electricity prices developed from DOE Energy Information Administration 

(EIA) Form 861

Life-Cycle Cost and Payback Period Analysis
124

Operating Cost Inputs: Electricity Prices and Price Trends

• Electricity prices are used to convert energy use to energy costs. 

• DOE developed electricity prices from EIA Form 861 data. 

• DOE used the DOE-EIA Annual Energy Outlook (AEO) for projections of 

future average energy prices (reference, high, and low scenarios). 

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

(reference, high, and low scenarios). 

Life-Cycle Cost and Payback Period Analysis
125

Operating Cost Inputs: Maintenance and Repair Costs

• DOE bases repair costs on annualized costs of key components and 

frequency of replacement in the field.

• Typically, small incremental changes in product efficiency incur little or no 

changes in repair and maintenance costs over baseline products. 

• DOE did not include maintenance and repair costs differences based on 

efficiency level.

Life-Cycle Cost and Payback Period Analysis
126

Operating Cost Inputs: Product Lifetimes

• DOE used information from available literature sources to establish 

specific residential dehumidifier lifetimes.

• Average lifetime for portable dehumidifiers: 11 years

• Average lifetime for whole-home dehumidifiers: 19 years

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Lifetime Dist. for Portable Dehumidifiers

% of Retiring

% of Surviving

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Lifetime Dist. for Whole-home Dehumidifiers

% of Retiring

% of Surviving

Life-Cycle Cost and Payback Period Analysis
127

Operating Cost Inputs: Discount Rates

• Discount rates are used to convert streams of annual operating expenses 

to present value in the LCC analysis. 

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

rulemakings.

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

products.

‒ Finance cost based on:

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

cards, home equity loans)

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

savings accounts)

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

much of the equity and debt data.

Life-Cycle Cost and Payback Period Analysis
128

Operating Cost Inputs: Energy Efficiency in the Base Case

• Share of consumers affected by particular efficiency level captured by 

projected distributions of product efficiencies in first compliance year 

under base case. 

Life-Cycle Cost and Payback Period Analysis
129

LCC Savings Results: Example from the LCC Analysis for PC1

Life-Cycle Cost and Payback Period Analysis
130

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

2 Market and Technology Assessment and Screening

3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis

5 Markups and Energy Use Analysis

6 Life-Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis

8 Next Steps
131

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
132

Overview

• Purpose

‒ Quantify changes over time in product shipments due to potential 

new energy efficiency standards.

‒ Estimate the disaggregation of shipments into product classes, and 

how the shipments by product class change over time.

• Method

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

‒ The model accounts for replacements and first time owners.

Shipments Analysis
133

Shipments Model

Historical Shipments & 

Market Share by Class Appliance Lifetime

Total Shipments

Replacement 

Shipments

Shipments by 

Product Class

First-Time Owners

Shipments Analysis
134

Shipments Analysis Inputs

Shipments Analysis

Input Data Source / Description

Replacement Appliance Lifetime from Life-Cycle Cost Analysis

Historical Shipments All portable dehumidifier product classes: AHAM Data 

Submittal, previous rulemaking

Shipments by Product Class All dehumidifier product classes: AHAM Data Submittal, 

Market and Technology Analysis, previous rulemaking
135

Base-Case Shipments Projection Approach

• Base-case shipments projection depicts the situation where new 

standards are not adopted.

• Shipment projection accounts for: 

‒ First-time owners product sales

‒ Replacements

• Base-case projections developed for product classes

Shipments Analysis
136

Shipments Analysis

Shipments Analysis

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

Shipments (Millions)

Year

Modelled Replacement Shipments

Modelled First-time Owners

Historical Shipments

Modelled Total Shipments
137

Standards Impacts on Shipments

• DOE developed Standards-Case Projections from the same data it used to 

develop the Base-Case Projection.

• Standards-Case Projections also use purchase price increases and 

operating cost savings to estimate shipments impacts.

• Market impact analysis shows sensitivity of shipments to purchase price 

and operating costs.

Shipments Analysis
138

Standards Impacts on Shipments

Shipments Analysis

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

Shipments (million)

Base Case CSL 1 CSL 2 CSL 3 CSL 4
139

Preliminary Analysis Rulemaking Stage

Energy Use 

Analysis

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Markups 

Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Framework 

Document

Final 

Rule

Preliminary

Analysis NOPR
140

Overview

• Purpose

‒ Determine the projected national energy savings and consumer 

national net present value.

• Method

‒ Develop annual series of national energy and economic impacts.

‒ Use the shipments model to estimate the total stock of residential

dehumidifiers in service each year. 

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

‒ Report estimates for economic impact as change in consumer National 

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

‒ Account for the time-value of money through defined discount rates.

National Impact Analysis
141

National Impact Analysis Process

Shipments 

Model

National 

Energy 

Savings

National

Economic

Impacts

LCC 

Analysis 

Results and 

Other Inputs

National 

Energy Savings 

(Quads)

National 

Net Present Value 

(NPV)

(2012 US $, billion)

• National energy savings calculated for period from 2019 - 2048 (30 years of 

shipments)

• NPV calculated for products shipped over the period from 2019 - 2048 (30 

years of shipments)

National Impact Analysis
142

National Energy Savings Flow Diagram

National Impact Analysis
143

National Consumer Net Present Value Flow Diagram

National Impact Analysis
144

Shipment-Weighted and Market Share Efficiency Data

• Shipment-weighted efficiency (SWEF) data:

‒ Key components of the national impact analysis are dependent on shipmentweighted efficiencies.

• Per-unit annual energy consumption—needed to determine NES.

• Retail price and per-unit annual operating costs—needed to determine NPV.

• Market share efficiency data:

‒ Historical market share efficiency data help estimate how standards will 

impact base-case efficiencies and reveals the distribution of product 

efficiencies for a given year by product class.

‒ Market share data (or base-case efficiency distributions) are requested in the 

LCC and PBP analysis and will also be used in the national impact analysis.

‒ DOE has assumed a “roll up” scenario to project standards impacts in past 

standards rulemakings.

National Impact Analysis
145

• Full fuel cycle (FFC) measure of energy and greenhouse gas and other 

emissions is accounted for in this standards rulemakings.

‒ DOE has published a Notice of Policy (NOP) stating its intention to 

incorporate FFC metrics into the cost-benefit analysis. 76 FR 51282 

(Aug. 18, 2011). 

• Methodology is based on the calculation of a FFC multiplier, or conversion 

factor, for each of the primary fuels used by the product.

National Impact Analysis

Full Fuel Cycle
146

National Impact Analysis Inputs

Input Description

Total Installed Cost Annual weighted-average per unit values as a function of efficiency level taken from the LCC 

analysis.

Repair and 

Maintenance Costs

Repair and maintenance costs are constant across efficiency level.

Annual Energy Use Annual weighted-average per unit values as a function of efficiency level taken from LCC 

analysis.

Base-Case Efficiencies Shipments-weighted efficiencies determined for the effective year. Based on base-case 

efficiency distribution from LCC analysis. Assumes 0.25% efficiency improvement without 

standards.

Standards-Case 

Forecasted Efficiencies

Roll-up scenario assumed for determining shipment-weighted efficiency for each standards

case.

Energy Prices Average prices and forecasted energy prices from EIA AEO 2012 forecasts (to 2035) and 

extrapolation to 2048.

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

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Guideline A-4.

Present Year Future expenses are discounted to the year 2013.

National Impact Analysis
147

National Energy Savings Results

National Impact Analysis

0.000

0.005

0.010

0.015

0.020

0.025

Quads

Year

National FFC Energy Savings, Proposed Trial Standard Level 3 
148

Net Present Value Savings Results, Product Class 1, EL3

National Impact Analysis
149

Public Meeting Topics

1 Regulatory History, Test Procedures, and Overview

2 Market and Technology Assessment and Screening

3 Engineering Analysis

4 Preliminary Manufacturer Impact Analysis

5 Markups and Energy Use Analysis

6 Life-Cycle Cost and Payback Period Analysis

7 Shipments and National Impact Analysis

8 Next Steps
150

NOPR Stage

Framework 

Document

Final 

Rule

Preliminary

Analysis

NOPR

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Consumer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions 

Analysis

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis
151

• Purpose

– To develop a list of potential amended standard levels from which impacts are 

weighed and a proposed standard level is selected.

• Each trial standard level consists of a set of efficiency levels covering all product 

classes, and may vary between product classes.

• NOPR analyses assess impacts for trial standard levels (not efficiency levels for each 

product class).

• Method

– Trial standard levels are assembled from the product classes and efficiency 

levels identified in the preliminary analyses.

• Trial standard levels cover a range of efficiencies and can include:

– Most energy efficient level (max-tech);

– Efficiency level with the lowest life-cycle cost;

– Efficiency level with a payback period of three years or less;

– Efficiency levels with noteworthy technologies; and

– Efficiency levels that fill in large gaps.

Trial Standard Levels

Selection of Trial Standard Levels
152

Trial Standard Levels

Request for Comment

Item 5: DOE requests feedback on the criteria it should use for basing 

the selection of Trial Standard Levels.

• A critical part of the NOPR analysis on which DOE is seeking early guidance 

is the criteria used in selecting trial standard levels.

• Trial standard levels are created from combinations of efficiency levels at 

the product class level.
153

NOPR Stage

Framework 

Document

Final 

Rule

Preliminary

Analysis

NOPR

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Consumer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions 

Analysis

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis
154

Overview

• Purpose

‒ Analyze the economic impacts of standards on consumers, including 

subgroups who may be disproportionately impacted compared with 

the general user population.

• Method

‒ Refine the LCC analysis to examine the impacts for defined subgroups.

Consumer Subgroup Analysis
155

Consumer Subgroup Analysis

Request for Comment

Item 6: DOE requests input as to which consumer subgroups, if any, it 

should consider when developing standards for residential 

dehumidifiers.
156

NOPR Stage

Framework 

Document

Final 

Rule

Preliminary

Analysis

NOPR

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Consumer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions 

Analysis

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis
157

Overview

• Purpose

–Estimate emissions impacts from amended energy conservation 

standards for dehumidifiers including changes in FFC emissions

• Method

–DOE will base the emission factors for FFC on EIA’s AEO, supplemented 

by data from other sources. The following emissions are assessed: 

• Carbon dioxide (CO2)

• Sulfur dioxide (SO2) 

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

regional emissions cap and trading programs

• Nitrogen oxides (NOx)

– Clean Air Interstate Rule (CAIR) permanently caps NOx emissions in 28 eastern 

States and DC

• Methane (CH4)

• Nitrous Oxide (N2O)

• Mercury (Hg)

Emissions Analysis
158

Monetization of Emission Reductions

• DOE intends to use the most current Social Cost of Carbon (SCC) values 

developed by interagency reviews.

– SCC is intended to be a monetary measure of the incremental damage resulting from 

greenhouse gas (GHG) emissions, including but not limited to agricultural productivity 

loss, human health effects, property damage from rising sea level, and changes in the 

ecosystem.

• At present, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2019, expressed in 

2013$, were $12.0, $40.5, $62.4, and $119 per metric ton avoided. 

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

time.

• DOE will also estimate the potential monetary benefit of reduced NOx, 

methane, Hg, SO2, and NO2 emissions resulting from the considered 

standard levels.
159

Emissions Analysis and Emissions Monetization

Request for Comment

Item 7: DOE seeks input on its plans to use NEMS-BT to conduct the 

emissions analysis for the products covered by this rulemaking.

Item 8: Are there any other emissions factors the Department should 

consider in this rulemaking?

Item 9: Are there other approaches to the emissions analysis that the 

Department should consider?
160

NOPR Stage

Framework 

Document

Final 

Rule

Preliminary

Analysis

NOPR

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Consumer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions 

Analysis

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis
161

Overview

• Purpose

‒ Assess the overall impacts on domestic energy supplies that would 

result from the imposition of standards. 

• Method

‒ DOE proposes to use NEMS-BT, a variant of the NEMS (National Energy 

Modeling System) developed and used by DOE/EIA for their AEO 

report, as the basis of the Utility Impact Analysis.

‒ Outputs of the utility impact analysis include projections of electricity 

sales, price, and avoided capacity resulting from a comparison of base 

and standards cases.

‒ DOE will model the energy savings impacts from amended energy 

conservation standards using NEMS-BT to generate projections that 

deviate from the AEO reference case.

Utility Impact Analysis
162

Utility Impact Analysis

Request for Comment

Item 10: DOE seeks input from stakeholders on its plans to use NEMSBT to conduct the utility impact analysis. Examples of the type of input 

sought by DOE include, but are not limited to, whether the NEMS-BT 

model is appropriate for assessing the utility impacts of efficiency 

standards — and if not, what would be a more appropriate model to 

use?
163

NOPR Stage

Framework 

Document

Final 

Rule

Preliminary

Analysis

NOPR

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Consumer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions 

Analysis

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis
164

Overview

• Purpose

‒ Assess the overall impact on national employment from the 

imposition of efficiency standards at differing levels.

‒ Include both direct and indirect employment impacts.

• Direct employment impacts are estimated in the manufacturer impact 

analysis.

• Indirect employment impacts result from shifting consumer expenditures 

among goods and services ( “substitution effect”) and changing 

equipment and energy costs (“income effect”).

• Method

‒ DOE intends to use the ImSET (Impact of Sector Energy Technologies) 

model for the evaluation of indirect employment impacts.

Employment Impact Analysis
165

Employment Impact Analysis

Request for Comment

Item 11: DOE welcomes feedback on its planned approach for 

assessing national employment impacts, both direct and indirect, and 

it is interested in whether other tools or factors should be considered 

as part of its analysis. If other tools or factors should be considered, 

please identify them and explain why, and how, they should be 

integrated into DOE's analysis
166

NOPR Stage

Framework 

Document

Final 

Rule

Preliminary

Analysis

NOPR

Manufacturer

 Impact 

 Analysis

Utility

 Impact 

Analysis

Employment

 Impact

 Analysis

Consumer 

Subgroup 

Analysis

Revise

Preliminary 

Analysis

Emissions 

Analysis

Regulatory

 Impact 

Analysis

Engineering

Analysis

Life-Cycle

Cost &

Payback 

Period

Analysis

National

 Impact

Analysis
167

Overview

• Purpose

‒ Explore the potential for non-regulatory alternatives to new energy 

efficiency standards.

• Method

‒ Base the assessment on the actual impacts of any such initiatives to 

date, but consider information presented regarding the impacts that 

any existing initiative might have in the future.

Regulatory Impact Analysis
168

How to Submit Written Comments

In all correspondence, please refer to this rulemaking by:

– Standards for Residential Dehumidifiers

– Docket Number EERE-2012-BT-STD-0027

– Regulation Identification Number (RIN) 1904-AC81

Email: ResDehumidifier2012STD0027@ee.doe.gov

Postal: Courier

Ms. Brenda Edwards Ms. Brenda Edwards

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

Building Technologies Program, Building Technologies Program, Suite 600

Mailstop EE-5B 950 L’Enfant Plaza, SW

1000 Independence Avenue, SW Washington, DC 20024

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

Comment period closes July 21, 2014, 11:59 PM ET