1 | Energy Efficiency and Renewable Energy eere.energy.gov [INSERT PICTURE(S) OF PRODUCT(S)]

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## 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.gov2 

# 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 Remarks3 

# 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 A M Test Procedure Amendments 6) 11:00 AM Break 7) 11:15 AM Compliance 8) 12:00 PM Closing Remarks4 

# 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 Remarks5 

# 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 NOPR8 

# 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 Remarks9 

# 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

- BT

TP

- 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 Remarks12 

# 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 Remarks14 

# 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:

– B e tested as both product categories

– M eet both applicable standards

– B e 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, whole

home, 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 Discussion17 

# 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 Remarks18 

# 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 EF19 

# 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 Discussion22 

# 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 Discussion24 

# 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 Discussion26 

# 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 practice27 

### 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 Discussion28 

# 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 Remarks29 

# New Provisions in Appendix X1

• DOE proposes to incorporate methodology that would result in more accurate representation of active mode performance.

– Dehumidification m ode t esting c onditions

– Whole

- home dehumidifiers

– Fan

- only mode30 

# Dehumidification Mode

– Ambient Temperature

• Current testing conditions: 80 ° F dry

- bulb and 69.6 ° F wet

- bulb temperatures (60% relative humidity (RH)).

• Commenters noted:

– V ariability 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 study31 

# 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 ° F32 

# Ambient Temperature
Proposal for Portable Dehumidifiers

• DOE estimates that 65 ° F is the most representative dry

bulb 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 dry

bulb 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

- 735 

### 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 Discussion36 

# 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 Literature37 

# 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 Discussion39 

# 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, refrigerant

desiccant dehumidifiers use a desiccant to transfer moisture from the process air.

• Moisture adsorbed by the desiccant is re

evaporated 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 refrigerant

desiccant dehumidifier and discharged to unconditioned space42 

# 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= � AH I,i × X I,i − AH O,i × X O,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 Inlet46 

# 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 16.047 

# 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 tape48 

# 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 dry

bulb 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 wet

bulb 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” H 2 

## O Static Pressure Instrumentation53 

# 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 (” H 2 

## O) to reflect field duct losses.

– Manufacturer literature lists performance at ESPs from 0 to 0.8” H 2 O.

– The Center for Energy and Environment conducted a study that included 81 homes in Minnesota, which measured an average ESP of 0.55” H 2 O.

– DOE’s analysis in the furnace fan test procedure indicated that 0.5” H 2 O 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.

• S ection 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 refrigerant

desiccant dehumidifiers. In particular, DOE welcomes comment on the proposed ducting configurations, alternative ambient temperature, and ESP, including equipment costs and testing burden. 

# Issue for Discussion59 

# Fan

- Only Mode

• Certain dehumidifiers operate the blower when the compressor is off after the humidity setpoint has been reached ( i.e. , fan

only 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 Discussion63 

# 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: $30064 

# 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 Remarks65 

# 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

- 294566 | 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.gov67 

# 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 Remarks68 

# 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

- STD

0027

- 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 ET70 

# 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 Steps72 

# 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 I ndustrial 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 rulemaking73 

# 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 2.575 

# Dehumidifier Standards Rulemaking Timeline

2012 2015 2013 2014 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, 201776 

# 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 Steps77 

# 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 NOPR78 

# 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 efficiency79 

# 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

– Ca pacity (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 more80 

# 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 8.081 

## 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 whole

home dehumidifiers. 

# Product Classes82 

# 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 Drain85 

# 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 systems86 

# 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 NOPR87 

# 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 Steps89 

# 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 NOPR90 

# 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 RelationshipManufacturerProduction Cost

Efficiency Level91 

# Engineering Analysis Process

T he 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 cost

efficiency relationships.92 

# Product Testing

• DOE selected 24 portable units (< 45 pints/day) , 13 high

capacity portable(>45 pints/day) and refrigerant

- only whole

home 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 1.7594 

## 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 ft 3 > 8.0 ft 3

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 ft 3 > 8.0 ft 3

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 3.4195 

# 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 Teardowns98 

# 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. #3100 

## • $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 $11.24101 

## • 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 (ft 3 )
> 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 $112.01102 

# 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 Steps103 

# 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 NOPR104 • 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 burden s Phase 2 Phase 3 Phase 1105 • 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 Issues106 

# 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 Steps108 

# 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 NOPR109 

# 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 Analysis110 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 Analysis 

# Markups Analysis

Overview111 

## 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 Types112 

# 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 NOPR113 

# 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 Analysis114 

## 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

Overview115 

## Calculation Flow 

# Energy Use Analysis

( ) 

# ( )      
× + × +        

× × × ×      

= Stby Stby Fan Fan Dehum ENERGY kW X kW X Eff X CAP Year ofUse TotalHours DEH 24 473

. 0 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 Use116 

# Energy Use AnalysisPortable 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 1,785Whole-Home Willem, 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 Steps118 

# 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 NOPR119 

# 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 

## Overview120 

## 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 Analysis121 

## 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 Analysis122 

## 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 Analysis123 

## 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 Analysis124 

## 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 Analysis125 

## 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 Analysis126 

## 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 Analysis127 

## 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 Analysis128 

## 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 Analysis129 

## LCC Savings Results: Example from the LCC Analysis for PC1 

# Life

- Cycle Cost and Payback Period Analysis130 

# 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 Steps131 

# 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 NOPR132 

## 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 Analysis133 

## Shipments Model

Historical Shipments & Market Share by Class Appliance Lifetime

Total Shipments Replacement

Shipments

Shipments by Product Class

First

- Time Owners 

# Shipments Analysis134 

## 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 rulemaking135 

## 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 Analysis136 

## Shipments Analysis 

# Shipments Analysis

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50Shipments (Millions)

Year Modelled Replacement Shipments Modelled First-time Owners Historical Shipments Modelled Total Shipments137 

## 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 Analysis138 

## Standards Impacts on Shipments 

# Shipments Analysis

0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50Shipments (million)

Base Case CSL 1 CSL 2 CSL 3 CSL 4139 

# 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 NOPR140 

## 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 Analysis141 

## 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 Analysis142 

## National Energy Savings Flow Diagram 

# National Impact Analysis143 

## National Consumer Net Present Value Flow Diagram 

# National Impact Analysis144 

## Shipment

- Weighted and Market Share Efficiency Data

• Shipment

- weighted efficiency (SWEF) data :

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

weighted 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 Analysis145 

### • 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 Cycle146 

## 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 Analysis147 

## National Energy Savings Results 

# National Impact Analysis

0.000 0.005 0.010 0.015 0.020 0.025Quads

Year National FFC Energy Savings, Proposed Trial Standard Level 3148 

## Net Present Value Savings Results, Product Class 1, EL3 

# National Impact Analysis149 

# 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 Steps150 

# 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 Analysis151 

## • 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 Levels152 

# 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 Analysis154 

## 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 Analysis155 

# 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 Analysis157 

## 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 (CO 2 )

• Sulfur dioxide (SO 2 )

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

• Nitrogen oxides (NO x )

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

• Methane (CH 4 )

• Nitrous Oxide (N 2 O)

• Mercury (Hg) 

# Emissions Analysis158 

# 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 CO 2 

### 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 NO x 

### , methane, Hg, SO 2 

### , and NO 2 

### 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 Analysis161 

## 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 Analysis162 

# Utility Impact Analysis

Request for Comment

Item 10: DOE seeks input from stakeholders on its plans to use NEMS

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

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

— and if not, what would be a more appropriate model to use?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 Analysis164 

## 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 Analysis165 

# 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 analysis166 

# 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 Analysis167 

## 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 Analysis168 

# 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