CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DEHUMIDIFIERS ................. 1-1

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS ................... 1-2

1.4 STRUCTURE OF THE DOCUMENT ............................................................................ 1-5

LIST OF TABLES

Table 1.3.1 Analyses Under the Process Rule ........................................................................ 1-4

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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This preliminary technical support document (preliminary TSD) is a stand-alone report 

that provides the technical analyses and results supporting the information presented in the 

preliminary notice of public meeting (NOPM) and executive summary for residential 

dehumidifiers. This preliminary TSD reports on the preliminary activities and analyses

conducted in the period preceding the notice of proposed rulemaking (NOPR) of this rulemaking. 

1.2 OVERVIEW OF STANDARDS FOR RESIDENTIAL DEHUMIDIFIERS

 The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163 (42 United 

States Code (U.S.C.) 6291–6309), established an energy conservation program for major 

household appliances. The National Energy Conservation Policy Act of 1978 (NECPA), Pub. L. 

95-619, amended EPCA to add Part Ca

 of Title III (42 U.S.C. 6311–6317), which established an 

energy conservation program for certain industrial equipment. Additional amendments to EPCA 

give DOE the authority to regulate the energy efficiency of several products, including 

residential dehumidifiers—the products that are the focus of this document. The amendments to 

EPCA in the Energy Policy Act of 2005 (EPACT 2005) (P.L. 109-58), established energy 

conservation standards for residential dehumidifiersb manufactured as of October 1, 2007. 

(Section 135(c)(4)) EPACT 2005 also required that DOE issue a final rule by October 1, 2009, to 

determine whether these standards should be amended. (Id.) Compliance with any amended 

standards would be required for dehumidifiers manufactured as of October 1, 2012. (Id.) In the 

event that DOE did not publish a final rule, EPACT 2005 specified a new set of amended 

standards with a compliance date of October 1, 2012. (Id.) 

 DOE issued an advance notice of proposed rulemaking (ANOPR) to consider energy 

conservation standards for dehumidifiers and other products. 72 FR 64432 (Nov. 15, 2007). The 

Energy Independence and Security Act of 2007 (EISA 2007), Pub. L 110-140 subsequently 

amended EPCA to prescribe new energy conservation standards for dehumidifiers manufactured 

on or after October 1, 2012. DOE codified the EISA 2007 standards at 10 CFR 430.32(v)(2). 74 

FR 12058 (Mar. 23, 2009). 

a Part C has been redesignated Part A-1 in the United States Code for editorial reasons. b Dehumidifiers are defined as self-contained, electrically operated, and mechanically encased assemblies consisting 

of: (1) a refrigerated surface (evaporator) that condenses moisture from the atmosphere; (2) a refrigerating system, 

including an electric motor; (3) an air-circulating fan; and (4) a means for collecting or disposing of the condensate. 

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

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EPCA also requires that, not later than 6 years after the issuance of a final rule 

establishing or amending a standard, DOE publish a NOPR proposing new standards or a notice 

of determination that the existing standards do not need to be amended. (42 U.S.C. 6295(m)(1)) 

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS

 Under EPCA, when DOE is studying new or amended standards, it must consider, to the 

greatest extent practicable, the following seven factors (42 U.S.C. 6295 (o)(2)(B)(i)): 

1) the economic impact of the standard on the manufacturers and consumers of the affected 

products; 

2) the savings in operating costs throughout the estimated average life of the product 

compared to any increases in the initial cost or maintenance expense; 

3) the total projected amount of energy savings likely to result directly from the imposition 

of the standard; 

4) any lessening of the utility or the performance of the products likely to result from the 

imposition of the standard; 

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

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

6) the need for national energy conservation; and 

7) other factors the Secretary considers relevant.

Other statutory requirements are set forth in 42 U.S.C. 6295(o)(1)–(2)(A), (2)(B)(ii)–(iii), 

and (3)–(4).

DOE considers stakeholder participation to be a very important part of the process for 

setting energy conservation standards. Through formal public notifications (i.e., Federal Register

notices), DOE actively encourages the participation and interaction of all stakeholders during the 

comment period in each stage of the rulemaking. Beginning with the framework document and 

during subsequent comment periods, interactions among stakeholders provide a balanced 

discussion of the information that is required for the standards rulemaking. 

 Before DOE determines whether or not to adopt a proposed energy conservation 

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6295(m)(2)(B))

Any new or amended standard must be designed to achieve significant additional conservation of 

energy and be technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) To 

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determine whether economic justification exists, DOE must review comments on the proposal 

and determine that the benefits of the proposed standard exceed its burdens to the greatest extent 

practicable, weighing the seven factors listed above. (42 U.S.C. 6295 (o)(2)(B)(i)) 

After the publication of the framework document, the energy conservation standards 

rulemaking process involves three additional, formal public notices, which DOE publishes in the 

Federal Register. The first of the rulemaking notices is a NOPM, which is designed to publicly 

vet the models and tools used in the preliminary rulemaking and to facilitate public participation 

before the NOPR stage. The second notice is the NOPR, which presents a discussion of

comments received in response to the NOPM and the preliminary analyses and analytical tools; 

analyses of the impacts of potential amended energy conservation standards on consumers, 

manufacturers, and the Nation; DOE’s weighting of these impacts of amended energy 

conservation standards; and the proposed energy conservation standards for the product. The 

third notice is the final rule, which presents a discussion of the comments received in response to 

the NOPR; the revised analyses; DOE’s weighting of these impacts; the amended energy 

conservation standards DOE is adopting for the product; and the compliance dates of the 

amended energy conservation standards. 

 In August 2012, DOE published a notice of public meeting and availability of the 

framework document. 77 FR 49739 (Aug. 17, 2009) The framework document, Energy 

Conservation Standards Rulemaking Framework Document for Residential Dehumidifiers, 

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

establishment of amended energy conservation standards for these products. This document is 

available at: http://www.regulations.gov/#!documentDetail;D=EERE-2012-BT-STD-0027-0003.

 Subsequently, DOE held a public meeting on September 24, 2012, (“September 2012 

public meeting”) to discuss procedural and analytical approaches to the rulemaking. In addition, 

DOE used the public meeting to inform and facilitate involvement of interested parties in the 

rulemaking process. The analytical framework presented at the public meeting described the 

different analyses, such as the engineering analysis and the consumer economic analyses (i.e., 

the life-cycle cost (LCC) and payback period (PBB) analyses), the methods proposed for 

conducting them, and the relationships among the various analyses.

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Table 1.3.1 Analyses Under the Process Rule

Preliminary Analyses NOPR Final Rule

Market and technology assessment Revised preliminary analyses Revised NOPR analyses

Screening analysis Life-cycle cost sub-group 

analysis

Engineering analysis Manufacturer impact analysis

Energy use determination Utility impact analysis

Markups for equipment price 

determination

Environmental assessment

Life-cycle cost and payback period 

analysis

Employment impact analysis

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact analysis

 During the September 2012 public meeting, interested parties commented about 

numerous issues relating to each one of the analyses listed in Table 1.3.1. Comments from 

interested parties submitted during the framework document comment period elaborated on the 

issues raised during the public meeting. DOE attempted to address these issues during its 

preliminary analyses and summarized the comments and DOE’s responses in chapter 2 of the 

preliminary TSD.

 As part of the information gathering and sharing process, DOE organized and held 

interviews with manufacturers of the residential dehumidifiers considered in this rulemaking as 

part of the engineering analysis. DOE selected companies that represented production of all types 

of products, ranging from small to large manufacturers, and included the Association of Home 

Appliance Manufacturers (AHAM) member companies. DOE had four objectives for these 

interviews: (1) solicit manufacturer feedback on the draft inputs to the engineering analysis; (2) 

solicit feedback on topics related to the preliminary manufacturer impact analysis; (3) provide an 

opportunity, early in the rulemaking process, to express manufacturers’ concerns to DOE; and 

(4) foster cooperation between manufacturers and DOE.

 DOE incorporated the information gathered during the engineering interviews with 

manufacturers into its engineering analysis (chapter 5) and the preliminary manufacturer impact 

analysis (chapter 12). Following the publication of the preliminary analyses and the NOPM 

public meeting, DOE intends to hold additional meetings with manufacturers as part of the 

consultative process for the manufacturer impact analysis conducted during the NOPR phase of 

the rulemaking. 

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 DOE developed spreadsheets for the engineering, LCC, PBP, and national impact 

analyses for each product. For each product, DOE developed an LCC spreadsheet that calculates 

the LCC and PBP at various energy efficiency levels. DOE also developed a national impact 

analysis spreadsheet that calculates the national energy savings (NES) and national net present 

values (NPVs) at various energy efficiency levels. This spreadsheet includes a model that 

forecasts the impacts of amended energy conservation standards at various levels on product 

shipments. All of these spreadsheets are available on the DOE website for residential 

dehumidifiers at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/dehumidifiers.html.. 

1.4 STRUCTURE OF THE DOCUMENT

This preliminary TSD outlines the analytical approaches used in this rulemaking. The

TSD consists of fourteen chapters, an environmental assessment, a regulatory impact analysis, 

and appendices. 

Chapter 1 Introduction: provides an overview of the appliance standards program 

and how it applies to this rulemaking, and outlines the structure of the 

document. 

Chapter 2 Analytical Framework: describes the rulemaking process. 

Chapter 3 Market and Technology Assessment: characterizes the market for the 

considered products and the technologies available for increasing 

product efficiency.

Chapter 4 Screening Analysis: identifies all the design options that improve 

efficiency of the considered products, and determines which technology 

options are viable for consideration in the engineering analysis. 

Chapter 5 Engineering Analysis: discusses the methods used for developing the 

relationship between increased manufacturer price and increased 

efficiency.

Chapter 6 Markups to Determine Product Cost: discusses the methods used for 

establishing markups for converting manufacturer prices to customer 

product costs. 

Chapter 7 Energy Use Determination: discusses the process used for generating 

energy-use estimates for the considered products as a function of 

standard levels.

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Chapter 8 Life-Cycle Cost and Payback Period Analysis: discusses the effects of 

standards on individual customers and users of the products and 

compares the LCC and PBP of products with and without higher 

efficiency standards.

Chapter 9 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher efficiency standards, including how 

product purchase decisions are economically influenced and how DOE 

models this relationship with econometric equations. 

Chapter 10 National Impact Analysis: Discusses the methods used for forecasting 

national energy consumption and national economic impacts based on 

annual product shipments and estimates of future product energy 

efficiency distributions in the absence and presence of amended energy 

conservation standards.

Chapter 11 Life-Cycle Cost Subgroup Analysis: discusses the effects of standards 

on different subgroups of consumers and compares the LCC and PBP of 

products with and without higher efficiency standards for these 

consumers.

Chapter 12 Manufacturer Impact Analysis: discusses the effects of standards on the 

finances and profitability of product manufacturers.

Chapter 13 Utility Impact Analysis: discusses the effects of standards on electric 

and gas utilities.

Chapter 14 Employment Impact Analysis: discusses the effects of standards on 

national employment. 

Environmental Assessment for Residential Dehumidifiers: discusses the effects of 

standards on three pollutants—sulfur dioxide (SO2), nitrogen oxides 

(NOx), and mercury—as well as carbon emissions.

Regulatory Impact Analysis for Residential Dehumidifiers: discusses the impact of nonregulatory alternatives to efficiency standards.

Appendix 3A AHAM Data Submittal

Appendix 5A AHAM Engineering Analysis Questionnaire 

Appendix 6A Detailed Data for Equipment Price Markups

Appendix 7A Housing Variables 

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Appendix 7B Weather Station Data Mapping to RECS Households 

Appendix 8A User Instructions for Life-Cycle Cost and Payback Period Spreadsheets

Appendix 8B Uncertainty and Variability in LCC Analysis for Dehumidifiers

Appendix 8C Lifetime Distributions

Appendix 8D Distributions Used for Discount Rates 

Appendix 9A Relative Price Elasticity of Demand for Appliances 

Appendix 10A User Instructions for National Impact Analysis Spreadsheets 

Appendix 10B Full Fuel Cycle Multipliers

Appendix 10C National Net Present Value of Consumer Benefits Using Alternative 

Product Price Forecasts

Appendix 10D National Energy Savings and Net Present Value Using Alternative 

Growth Scenarios 

Appendix 12A Manufacturer Impact Analysis Interview Guide

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