1 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

ENERGY CONSERVATION STANDARDS FOR RESIDENTIAL CLOTHES DRYERS AND ROOM AIR CONDITIONERS

Preliminary Activities and Analyses Public Meeting Rulemaking Overview

Stephen WitDepartment of EnergyEnergy Efficiency & REmail.home_appliance2.ru

March 16, 2010

EERE-2007-BT-STD-0010 COMMENT 21.3
2 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

• To present methodologies and characterize re

for analyses to date.

• To discuss specific issues related to each ana• To seek input from attendees on methodologie

assumptions and data sources.

• To describe upcoming analyses and next step

Purpose of the Public Meeting

EERE-2007-BT-STD-0010 COMMENT 21.3
3 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

The Energy Policy and Conservation Act (EPCA) dire

consider seven factors when setting energy conservati

Factor Analysis

1. Economic impact on consumers 

and manufacturers

Life-cycle cost analysisManufacturer impact analysis

2. Lifetime operating cost savings Life-cycle cost analysis3. Total projected energy savings National impact analysis 4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of 

competition

Manufacturer impact analysis

6. Need for national energy 

conservation

National impact analysis

7. Other factors the Secretary 

considers relevant

Environmental assessmentUtility impact analysisEmployment impact analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
4 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

NaImA

Markups to DetermineProductPrice Life-Cycle Cost and

Payback Period Analyses

Steps for the Standards Rulemaking: Prelimin

Activities and Analyses

Market & Technology Assessment

Framework

Document

Preliminary

Activities NOPR Final Rule Effective Date

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
5 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

• Executive Summary includes:

– An overview of the preliminary activities and preliminary technical sup

document (TSD);

– Key results of the analyses; and– Issues on which DOE seeks comment from interested parties.

• Chapter 2 of the preliminary TSD provides a summary of the preli

activities and includes:

– A review of the analyses conducted; and– A discussion of comments on the analytical Framework from intereste

DOE’s responses to those comments.

• Notice of Public Meeting (NOPM) and Availability of the Prelimina

includes:

– Details of the public meeting for the preliminary activities and analyse– A description of the preliminary analyses, results, and documentation 

the website for interested parties to review.

Key Documents Describing the Preliminary Ac

EERE-2007-BT-STD-0010 COMMENT 21.3
6 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Next Steps in the Standards Rulemaking: NO

TrialStandardLevels

Revise Preliminary Analyses

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Environmental Assessment

Employment

Impact 

Analysis

Framework

Document

Preliminary 

Activities NOPR Final Rule Effective Date

EERE-2007-BT-STD-0010 COMMENT 21.3
7 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

• Participants are invited to provide summary comments or stat• Participants are invited to raise additional issues for discussio• Interested parties may provide comments on the preliminary 

analyses through April 26, 2010.

Comments from Participants

EERE-2007-BT-STD-0010 COMMENT 21.3
8 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Preliminary Activities Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

NaImA

Markups to DetermineProductPrice Life-Cycle Cost and

Payback Period Analyses

Market & Technology Assessment

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
9 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Purpose

 Market & Technology Assessment:

• Characterize the markets to determine available product efficiencie

manufacturers, shipments by product class, and technologies avaincreasing efficiencies.

 Screening Analysis:

• Apply screening criteria established by DOE to determine which te

to evaluate and which to screen out.

 Engineering Analysis:

• Evaluate technologies that improve efficiency. • Characterize manufacturer cost-efficiency relationships for higher 

products.

Introduction

EERE-2007-BT-STD-0010 COMMENT 21.3
10 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Market and Technology Assessment

Market Characteristics: Residential Clothes Dry

 DOE identified 14 manufacturers of clothes dryers selling in Market shares for the top three manufacturers have remaine

stable since 2000, considering Whirlpool and Maytag jointly.

 Products are manufactured both in the U.S. and internationa

Market share in 2008. Whirlpool share of market includes Maytag.

EERE-2007-BT-STD-0010 COMMENT 21.3
11 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Market and Technology Assessment

Source: AHAM data submittal in 2008

Market Characteristics: Residential Clothes Dry

EERE-2007-BT-STD-0010 COMMENT 21.3
12 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Residential Clothes Dryer Type Residential Clothes Dryers Product C

Vented Dryers

(existing)

Electric, Standard (4.4 cubic feet (ft3) or greater c

Electric, Compact (120 volts (V)) (less than 4.4 ft

Electric, Compact (240 V) (less than 4.4 ft3 capac

Gas

Vent-less Dryers*

(proposed)

Electric, Compact (240 V) (less than 4.4 ft3 capacElectric, Combination Washer/Dryer

*These product classes will require the adoption of clothes dryer test procedu

measuring energy consumption of vent-less clothes dryers. DOE is consideriamendments to the existing clothes dryer test procedure in a parallel rulemak

Market and Technology Assessment

Residential Clothes Dryers: Proposed Product 

EERE-2007-BT-STD-0010 COMMENT 21.3
13 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Market and Technology Assessment

Vent-less Clothes Dryers

 DOE recognizes the unique utility that vent-less clothes dr

offer to consumers (i.e., no external vent required).

 DOE proposes to consider two product classes for vent-le

clothes dryers.

• Vent-less electric compact (240V) dryers.• Vent-less electric combination washer/dryers.

 Combination washer/dryers provide unique utility, and are 

proposed as a separate product class from other vent-less dryers.

• These machines wash and then dry clothes in the same basket/ca

combined cycle. 

• DOE research suggests all combination washer/dryers are vent-le• Like other vent-less dryers, combination washer/dryers can be ins

locations where venting dryers would be precluded due to ventingrestrictions.

EERE-2007-BT-STD-0010 COMMENT 21.3
14 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Market and Technology Assessment

DOE Clothes Dryer Test Procedure

 DOE has initiated a separate test procedure rulemaking to 

procedures for clothes dryers and room air conditioners. 

 DOE is considering amendments to its clothes dryer test 

procedure to address:

• Active mode energy use issues.• Standby and off mode energy use, as required by the Energy Inde

and Security Act of 2007 (EISA 2007).

 The DOE test procedure does not currently contain provis

testing vent-less clothes dryers.

• DOE believes the test procedure may be used to test vent-less clo

dryers by eliminating the requirement of an exhaust simulator and clarifications. 

EERE-2007-BT-STD-0010 COMMENT 21.3
15 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

The current DOE clothes dryer test procedure does not co

provisions for testing vent-less clothes dryers. DOE invites in

parties to submit inputs on potential clothes dryer test pro

amendments to test vent-less clothes dryers, as well as da

information on the energy efficiency performance of vent-les

dryers. (Issue #2)

Request for Comment:

Residential Clothes-Dryers: Product Classes for Ve

Clothes Dryers

Market and Technology Assessment

EERE-2007-BT-STD-0010 COMMENT 21.3
16 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Market and Technology Assessment

 DOE is also considering potential amendments to the resi

clothes dryer test procedure to address active mode issuethan vent-less clothes dryers:

• Technical changes and procedures for more accurately measuring 

effects of automatic cycle termination.

• Changes to reflect current consumer usage patterns and capabilit

− Changing the number of clothes dryer cycles per year.− Changing the initial remaining moisture content (RMC) in clo

to reflect current clothes washer performance.

− Changing the clothes dryer test load size to reflect current clo

washer capacities.

 Because of the rulemaking schedules, any potential test 

procedure amendments to address these active mode issunot been considered for these preliminary analyses.

DOE Clothes Dryer Test Procedure – Active M

EERE-2007-BT-STD-0010 COMMENT 21.3
17 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Market and Technology Assessment

 EISA 2007 requires DOE to incorporate standby mode and 

mode energy use into the DOE clothes dryer test procedu

• DOE initiated a rulemaking to address standby and off mode ener

its test procedures for clothes dryers and room air conditioners, pu

NOPR on December 9, 2008. (73 FR 74639)

• EISA 2007 requires DOE to consider the most recent version of 

International Electrotechnical Commission (IEC) Standard 62301.

• DOE decided after the December 2008 NOPR to continue the rule

allow for the consideration of a revised version of IEC Standard 62which at that time was expected in July 2009.

• Because the updated version of IEC Standard 62301 has been de

at least the end of 2010, DOE is now continuing the rulemaking, cthe language in the most recent draft version of IEC Standard 623Second Edition.

• The proposed standby and off mode amendments will be conside

same test procedure rulemaking addressing active mode issues.

• Standby and off mode energy consumption is considered in this s

rulemaking.

DOE Clothes Dryer Test Procedure – Standby and O

EERE-2007-BT-STD-0010 COMMENT 21.3
18 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE identified less than ten key manufacturers of room air 

conditioners selling in the U.S. market.

• 70 percent of the 2007 market was controlled by four manufacturer

 DOE did not identify any domestic manufacturing of room a

conditioners.

• Production has moved outside the U.S., mostly to Asia.• Some production may still be occurring in Mexico.

 Significant market changes since 2007.

• Two of the four major manufacturers in 2007 left the market in 200

 Roughly 9.5 million units were shipped in 2007 (2008 Applia

Magazine data).

Market Characteristics: Room Air Condition

Market and Technology Assessment

EERE-2007-BT-STD-0010 COMMENT 21.3
19 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE proposes no new room air conditioner 

product classes.

Product 

Class 

Number Category Description

1

Without Reverse Cycle 

and with Louvered Sides

Less than 6,000 Btu/h

2 6,000 to 7,999 Btu/h3 8,000 to 13,999 Btu/h

14,000 to 19,999 Btu/h

45 20,000 Btu/h or more6

Without Reverse Cycle and 

without Louvered Sides

Less than 6,000 Btu/h6,000 to 7,999 Btu/h

7

8,000 to 13,999 Btu/h

89 14,000 to 19,999 Btu/h

10 20,000 Btu/h or more

11

With Reverse Cycle

With Louvered Sides and less than 20,000 B

12 Without Louvered Sides and less than 14,00

With Louvered Sides and 20,000 Btu/h or m

1314 Without Louvered Sides and 14,000 Btu/h o15

Casement

Casement-Only

16 Casement-Slider

Market and Technology Assessment

EERE-2007-BT-STD-0010 COMMENT 21.3
20 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Standby and off mode test procedures.

• EISA 2007 directs DOE to incorporate standby mode and off mod

consumption in the DOE room air conditioner test procedure.

• DOE initiated a rulemaking to address standby and off modes, pu

NOPR on December 9, 2008.

• DOE decided to continue the rulemaking to allow for the considera

the expected revisions of IEC Standard 62301.

• Standby and off mode amendments will be incorporated in a comb

procedure rulemaking.

 DOE is considering the following additional issues regard

active mode in the ongoing test procedure rulemaking.

• Annual hours of operation in active mode.• Updated references to commercial test standards AHAM RAC-1-2

ASHRAE 16-1983 (RA 2009). 

 Any potential amendments to the active mode test pro

have not been considered for these preliminary analys

DOE Room Air Conditioner Test Procedure

Market and Technology Assessment

EERE-2007-BT-STD-0010 COMMENT 21.3
21 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 750 annual active mode hours.

• During the framework period, DOE and stakeholders discussed th

possibility of a lower number of hours.

• Work on the LCC analysis suggests that the active mode annual 

actually be higher than 750.

• DOE is proposing an integrated metric (integrated energy efficien

(IEER)) based on 750 active mode hours.

 5,115 annual standby mode hours.

• This is consistent with the alternative approach proposed in the D

2008 room air conditioner test procedure NOPR addressing standmodes. 

Preliminary analysis has been conducted consisten

EISA 2007 requirement for an integrated efficiency 

[ ] 750 [ 

115,5)( 

(

750 )/(

Powerh

W Powerh

Capacityh hrBtu IEER

× Active ×+ Stndby

×

=

Market and Technology Assessment

EERE-2007-BT-STD-0010 COMMENT 21.3
22 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE identified technologies for each product covered in t

rulemaking from the following sources:

• Technical support documents from previous rulemakings;• Literature review;• Product teardowns; and• Input from interested parties.

 The full list of technologies that DOE identified can be fou

Chapter 3, Market and Technology Assessment, of the preTSD.

Technology Assessment

Market and Technology Assessment

EERE-2007-BT-STD-0010 COMMENT 21.3
23 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Technologies were screened using the following criteria:

• Technological feasibility;• Practicability to manufacture, install and service;• Impacts on product utility or product availability; and• Impacts on health or safety.

Screening Analysis

Screening Analysis Methodology

EERE-2007-BT-STD-0010 COMMENT 21.3
24 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE applied the screening criteria to the technologies for ef

improvement identified for residential clothes dryers and roconditioners.

 Residential Clothes Dryers.

• 3 technologies were screened out: Microwave (electric only), Wate

(vent-less electric only), Indirect heating.

• 15 remaining design options.

 Room Air Conditioners.

• No technologies were screened out.• 16 remaining design options.

 Chapter 4, Screening Analysis, of the preliminary TSD provi

additional detail on the screening analysis.

Technologies Screened Out 

Screening Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
25 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE did not consider certain technologies that met the scree

were unable to be evaluated as part of the Engineering Analys

 Residential Clothes Dryers:

• Available data suggest that the efficiency benefits of the technology are negligib• Efficiency cannot be measured according to the conditions and methods specifie

procedure: Improved Termination.

 Room Air Conditioners:

• DOE not aware of any improved designs not currently in use: Improved Fin Des

Design, Improved Indoor Blower and Outdoor Fan Efficiency.

• Available data suggests no improvement because technologies are standard pra

Film Coating on Fins, Spray Condensate onto Condenser Coil.

• No measureable improvement according to the test procedure: Variable Speed 

Thermostatic or Electronic Expansion Valve, Thermostatic Cyclic Controls.

 Chapter 5, Engineering Analysis, of the preliminary TSD inclu

technologies DOE did not consider and the rationale for elimi

Technologies Unable to Be Included

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
26 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Residential Clothes Dryer Design Options

Dryer Control or Drum Upgrades• Increased insulation• Modified operating conditions• Improved air circulation• Improved drum designMethods of Exhaust Heat Recovery (Vented Models Only)• Recycle exhaust heat• Inlet air preheat• Inlet air preheat, condensing modeHeat Generation Options• Heat pump, electric only• Modulating gas, gas onlyComponent Improvements• Improved motor efficiency• Improved fan efficiencyStandby Power Improvements• Switching Power Supply• Transformerless Power Supply with Auto-Powerdown

Clothes Dryer Design Options

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
27 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Increased Heat Transfer Surface Area• Increased frontal coil area• Increased depth of coil (add tube rows)

• Increased fin density• Add subcooler to condenser coil

Increased Heat Transfer Coefficients• Microchannel heat exchangers*Component Improvements• Improved blower/fan motor efficiency• Improved compressor efficiencyStandby Power Improvements• Switching power supply

Room Air Conditioner Design Options

Engineering Analysis

* A heat exchanger design generally made entirely of aluminum consisting of multichannel tubes and fan-fold fins.

EERE-2007-BT-STD-0010 COMMENT 21.3
28 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE requests comment and data regarding additional desig

or variants of the considered design options that can inc

range of considered efficiency improvements for both 

dryers and room air conditioners, including design opti

may not yet be found in the market. (Issue #1)

Request for Comment:

Design Options

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
29 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

• Characterize the relationship between manufacturer cost and 

efficiency.

Downstream Ana

• Life-Cycle Cost an

Payback Period

• National Impacts• Manufacturer Imp

Analysis

Cost – Efficiency 

Relationship

Incremental 

Manufacturing Cost

Efficiency

Purpose of the Engineering Analysis

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
30 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Efficiency-level Appro

Method Residential Clothes Dryers Ro

Con

AHAM Data

√ 

Review of Previous TSD √ Product Teardown and Manufacturer Cost Modeling

√ 

Product Testing √ Manufacturer Interviews √ Component Vendor InterviewsEnergy Modeling

Engineering Analysis Methods, Approach, and Informa

 Analysis was conducted for all residential clothes dryer product cl Analysis was conducted for selected high-volume room air conditi

product classes, with extrapolation to the other product classes.

*AHAM did not receive sufficient data to allow aggregation and reporting to DOE

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
31 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Manufacturing cost models were developed by DOE as pa

efficiency-level approach.

• Material and component costs were generated during product tea

and entered into cost model.

• Cost model generated manufacturing, material, labor, and overhea• Physical teardown analysis conducted with representative product

Manufacturing Costs

 Direct material Direct labor Factory overhead Depreciation

 Sales & marketing Research & development Building Tooling/Equipment

Full 

Production 

Cost

Conversion 

Costs 

(Non-Production Costs)

Manu

+ = C

 Manufacturer interviews were conducted to further refine 

analysis inputs and the results generated by the cost mod

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
32 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Reverse-Engineering Methodology

Raw 

Materials

Finished Materials

Purchased Parts

Selection 

of Units

Physical 

Teardown

Bill of 

Materials

Assembly 

Processes

Manufacturing 

Cost

Fabrication 

Processes

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
33 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Use of Integrated Metrics

 DOE proposes standards to be based on integrated metrics 

incorporating active mode and standby/off mode energy us

• Residential clothes dryers: Integrated Energy Factor (IEF).• Room air conditioners: Integrated Energy Efficiency Ratio (IEER).

 DOE developed cost-efficiency curves based on the integra

efficiency metrics (IEF and IEER).

 The engineering analysis considered design options assoc

both active and standby modes. 

[ ] 750 [ 

115,5)( 

(

750 )/(

Powerh

W Powerh

Capacityh hrBtu IEER

× Active ×+ Stndby

×

=

⎢⎣⎡

×

×

+

=

kWW Dryer an

Powerh

kWhenergycyclePer

lbLoadTest IEF

Stndby

416/1000

620,8 

)(

)(

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
34 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

• Define baseline specifications for each product c• Identify efficiency levels from the baseline to the 

pathway for improving energy efficiency;

• Conduct teardown analysis for representative pro

efficiency levels identified; and

• Generate cost-efficiency curves, which account f

production costs.

Clothes Dryer Cost-Efficiency Curve Developm

Develop 

Baseline

Calculate 

Costs

Develop 

Efficiency 

Pathway

Generate 

CostEfficiency 

Curves

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
35 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Clothes Dryers: Baseline Efficiency Leve

 For vented dryer product classes, DOE determined baseli

efficiency levels for active mode based on the current Fedenergy conservation standards. 

 For vent-less dryer product classes, DOE estimated base

efficiencies for active mode based upon testing.

• Testing conducted by an independent testing lab on representativ

using the DOE test procedure without the exhaust simulator.

 DOE estimated the baseline efficiency level for standby/o

for all product classes based on DOE testing of standby/oenergy use in its sample units.

 Baseline IEF levels were determined by combining the ba

and standby/off energy use. 

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
36 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Clothes Dryers: Baseline Efficiency Leve

Product

Type Product Class

Energy 

Factor 

(EF)

Standby 

Power

(W)

VentedDryers

Electric, Standard (> 4.4 ft3) 3.01 2.0 

Electric, Compact (120 V) (< 4.4 ft3) 3.13 2.0 

Electric, Compact (240 V) (< 4.4 ft3) 2.90 2.0 Gas 2.67 2.0 

Vent-lessDryers

Electric, Compact (240V) (< 4.4 ft3) 2.37 2.0 

Electric, Combination 

Washer/Dryer 1.95 2.0 

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
37 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Clothes Dryers: Active Mode Efficiency Lev

 DOE determined active mode efficiency levels for each pr

class using the following sources: 

• Publicly available market and efficiency data;• Product catalogs;• Technical journals and research;• Prototype technologies; and• Comments from interested parties and manufacturer interviews.

 For the vented electric compact (120V) product class, act

efficiency levels above the baseline were obtained by scaefficiency levels for electric standard dryers by the ratio obaseline efficiencies. 

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
38 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Clothes Dryers: Standby Mode Efficiency Le

 Standby mode efficiency levels were based on DOE testin

reverse engineering analyses. 

• Several different features were observed to be associated with s

lower standby power levels. 

 Only standby power is addressed because no power cons

was observed in off mode for test units capable of such a 

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
39 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Clothes Dryers: Integrated Efficiency Leve

 Integrated efficiency levels based on IEF* were determine

assuming that clothes dryer standby power would remain baseline 2.0 W for active mode levels that do not strictly relectronic controls to achieve.

 For higher active mode levels that require electronic cont

added in the standby power design options in order of coeffectiveness. 

* IEF = integrated energy factor

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
40 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Vented Clothes Dryers Integrated Efficiency Level 

Level Efficiency Level Description

Electric 

Standard

Electric 

Compact 

(120V)

Electr

Compa

(240 V

Baseline DOE Standard + 2.0 W Standby 2.96 3.00 2.79 1 Gap Fill + 2.0 W Standby 3.04 3.08 2.86 2 Gap Fill + 2.0 W Standby 3.10 3.15 2.96 3 Gap Fill/Maximum Available + 

2.0 W Standby

3.33 3.37 3.06 

4 Maximum Available + 1.5 W 

Standby

3.35 3.41 3.10 

5 Maximum Available + 0.08 W 

Standby

3.40 3.53 3.19 

6 Heat Pump (Max Tech) + 0.08 W 

Standby

4.52 4.69 4.34 

Engineering Analysis

Integrated Efficiency Levels: Vented Dryer

EERE-2007-BT-STD-0010 COMMENT 21.3
41 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Vent-less Clothes Dryers Integrated Efficiency 

Level Efficiency Level Description Electric Compa

Baseline Baseline + 2.0 W Standby 2.291 Baseline + 1.5 W Standby 2.312 Baseline + 0.08 W Standby 2.373 Gap Fill + 0.08 W Standby 2.394 Gap Fill + 0.08 W Standby 2.595 Heat Pump (Max-Tech) + 0.08 W Standby 3.54

Integrated Efficiency Levels: Vent-less Electric C

(240V) Dryers

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
42 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Vent-less Clothes Dryers Integrated Efficiency 

Level Efficiency Level Description Electric Combinatio

Baseline Baseline + 2.0 W Standby 1.90

1 Gap Fill + 2.0 W Standby 2.15

2 Gap Fill + 2.0 W Standby 2.34

3 Gap Fill + 1.5 W Standby 2.36

4 Gap Fill + 0.08 W Standby 2.425 Heat Pump (Max-Tech) + 0.08 W Standby 3.31

Integrated Efficiency Levels: Vent-less Elec

Combination Washer/Dryers

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
43 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Vented Electric Standard Clothes Dryers Vented Electric Compact 

Efficiency

Level 

IEF 

(lb/kWh)

Incremental 

Manufacturing 

Cost (MPC)

Efficiency

Level 

IEF 

(lb/kWh)

I

Ma

C

Baseline 2.96 $0.00 Baseline 3.00 

1 3.0

4 $11.89 1 3.08 

2 3.10 $63.56 2 3.15 3 3.3

3 $97.48 3 3.37 

4 3.3

5 $98.78 4 3.41 

5 3.4

0 $98.14 5 3.53 

6 4.5

2 $259.13 6 4.69 

Clothes Dryers: Engineering Analysis Resul

The MPC includes the cost of materials, labor, and direct overhead used to manproduct.

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
44 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Vented Electric Compact (240 V) Vented Gas 

Efficiency

Level 

IEF 

(lb/kWh)

Incremental 

Manufacturing 

Cost (MPC)

Efficiency

Level 

IEF 

(lb/kWh)

I

Ma

C

Baseline 2.79 $0.00 Baseline 2.63 

1 2.8

6 $10.95 1 2.71 

2 2.9

6 $63.37 2 2.80 

3 3.0

6 $96.45 3 2.97 

4 3.10 $97.75 4 2.98 

5 3.19 $97.11 5 3.02 6 4.3

4 $246.35

Clothes Dryers: Engineering Analysis Resul

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
45 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Vent-less Electric Compact (240V) Vent-less Electric Combination W

Efficiency

Level 

IEF 

(lb/kWh)

Incremental 

Manufacturing 

Cost (MPC)

Efficiency

Level 

IEF 

(lb/kWh)

In

Ma

C

Baseline 2.29 $0.00 Baseline 1.90 1 2.31 $1.30 1 2.15 

2 2.3

7 $0.66 2 2.34 

3 2.3

9 $13.01 3 2.36 

4 2.5

9 $69.02 4 2.42 

5 3.5

4 $216.37 5 3.31 

Clothes Dryers: Engineering Analysis Resul

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
46 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE AHAM

Efficiency

Level 

EF 

(lb/kWh)

Incremental 

Manufacturing 

Cost (MPC)

Efficiency

Level 

EF 

(lb/kWh)

In

Ma

C

Baseline 3.01 $0.00 Baseline 3.01 

1 3.10 $11.89 1 3.10 2 3.16 $63.56 2 3.16 3 3.4

0 $97.48 3 3.39 

4 4.5

2 $258.47

Comparison of DOE Cost Estimates to AHAM Data Su

Vented Electric Standard Clothes Dryers, Active 

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
47 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE AHAM

Efficiency

Level 

EF 

(lb/kWh)

Incremental 

Manufacturing 

Cost (MPC)

Efficiency

Level 

EF 

(lb/kWh)

In

Ma

C

Baseline 2.67 $0.00 Baseline 2.67 

1 2.7

5 $14.79 1 2.75 

2 2.8

5 $65.36 2 2.77 

3 3.0

2 $156.01 3 3.02 

Engineering Analysis

Comparison of DOE Cost Estimates to AHAM Data Su

Vented Gas Clothes Dryers, Active Mode

EERE-2007-BT-STD-0010 COMMENT 21.3
48 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

• Select representative products spanning the rang

efficiencies for the product classes analyzed;

• Establish baseline specifications and calibrate en• Identify design options for increasing efficiency a

modeling to identify IEER efficiency impact;

• Conduct teardown analysis for the representative 

conduct interviews with manufacturers and compvendors to determine cost impacts of the design 

• Generate cost-efficiency curves by combining en

and cost modeling analysis; and interpolating/ext

product classes not examined.

Room Air Conditioner Cost-Efficiency Curve Deve

Identify 

representative 

products

Conduct costmodeling 

analysis

Identify and 

Model Design 

Options

Generate 

costefficiency 

curves

Develop 

Baseline

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
49 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Representative Product Classes

1 < 6,000 Btu/h, Louvered Sides, No Reverse Cycle3 8,000-13,999 Btu/h, Louvered Sides, No Reverse Cycle5 > 24,000 Btu/h, Louvered Sides, No Reverse Cycle8 8,000-13,999 Btu/h, Non-Louvered Sides, No Reverse Cycle

Room Air Conditioners: Representative Product 

 DOE selected representative product classes for which to c

the full engineering analysis.

 DOE developed cost-efficiency curves for representative pr

each of these product classes.

 DOE then extended this analysis numerically to the remain

product classes.

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
50 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Room Air Conditioners: Representative Product 

Distribution of room air conditioner models in the CEC, AHAM and ENERSTAR Databases

 DOE chose product classes 1, 3, 5, and 8 for full analysis based on 

of the models in multiple product databases.

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
51 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Room Air Conditioners: R-410A Treatment in A

 DOE conducted the energy modeling of design options usi

as the refrigerant.

 DOE sought information on the performance of R-410A rota

compressors of varying efficiency levels for all of the produanalysis.

• The EER ratings of the R-410A compressors are generally lower th

HCFC-22 rotary compressor with a similar capacity.

• The EER ratings for R-410A rotary compressors exhibit a much mo

EER range than HCFC-22 rotary compressors.

 DOE also adjusted the incremental costs to account for the 

cost in converting to R-410A.

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
52 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Room Air Conditioners: R-410A Treatment in A

The figure is based on compressor rating point capacity.

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
53 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Standby

Power 

Efficiency Level

Standby 

Power 

(W)

Incremental 

Manufacturing Cos

Baseline 1.4 $0.00

1 0.7 $1.00

Room Air Conditioners: Standby Power Leve

 DOE measured the standby power consumption of repres

room air conditioners to determine the appropriate energy these modes.

 DOE identified two standby power levels in current room a

conditioners.

• Baseline standby level uses a conventional linear power supply.• Standby level 1 employs a switching power supply. 

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
54 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE set baseline efficiency levels based on current Fede

conservation standards for EER and the baseline standby efficiency level.

 Baseline IEER values were set to the nearest hundredth.

Product

Class

Capacity

(Btu/hr)

EER (Btu/hW) Standby Power (W) 

(B

1 5,000 9.7 1.4 

3 8,000 9.8 1.4 

3 12,000 9.8 1.4 5 24,000 8.5 1.4 8 8,000 8.5 1.4 

8 12,000 8.5 1.4 

Engineering Analysis

Room Air Conditioners: Baseline Efficiency Lev

EERE-2007-BT-STD-0010 COMMENT 21.3
55 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

IEER (Btu/h-W)

Efficiency 

Level

Product Class 1 

<6,000 Btu/h, 

With LS, Without RC

Product Class 

8,000-13,999 Btu

With LS, Without 

Baseline 9.52 9.711 10.1 10.3

2 10.6 10.8

3 11.1 11.3

4 11.6 11.8

5 1

2.0 -

Room Air Conditioners: Incremental Efficiency Le

 DOE established incremental efficiency levels based on rev

market data*, product catalogs, technical journals, prototyptechnologies, comments from interested parties, and manuinterviews.

*Based on ENERGY STAR-qualified room air conditioners as of July 2008 and of availability through retailer website searches.

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
56 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

IEER (Btu/h-W)

Level Product Class 5 

>20,000 Btu/h, 

With LS, Without RC

Product Class 8 

8,000-13,999 Btu/h

Without LS, Without 

Baseline 8.47 8.43

1 9.0 8.92 9.4 9.33 9.8 9.84 1

0.0 -

Room Air Conditioners: Incremental Efficiency Le

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
57 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Engineering Analysis

 DOE used energy modeling for the room air conditioner eng

analysis.

• No data were received from AHAM.• Existing products use HCFC-22, which is banned for new products s

2010.

 DOE updated the energy model used in the previous room a

conditioner rulemaking.

• Update of heat exchanger performance models, including incorpora

microchannel heat exchanger performance;

• Incorporation of additional refrigerants, including R-410A; and• Development of a platform for the Microsoft Windows operating syst

 DOE developed airside models to calculate the impacts on a

fan motor shaft power associated with the incorporation of design options.

Room Air Conditioners: Energy Modeling

EERE-2007-BT-STD-0010 COMMENT 21.3
58 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Modified Engineering Analysis Approach for Roo

Conditioners

In the framework document, DOE proposed the use of an effic

approach for the engineering analysis for room air conditione

this approach was complicated by the lack of aggregated ind

and by the phaseout of HCFC-22 refrigerant. As described in 

DOE adopted an approach relying more on a design-option 

using both energy modeling and manufacturing cost mode

determine the impacts of efficiency improvements for the prod

invites comment on this modified approach for conductin

engineering analysis. (Issue #5)

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
59 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE considered chassis size increases to increase efficie

window units (analyzed product classes 1, 3, and 5). 

• Chassis size increase allows for increased heat exchanger size.

 DOE examined the range of sizes of available room air con

• The data show that baseline efficiency products have a range of s• DOE did not consider chassis size increases beyond the range of 

products.

• DOE’s analysis examined two steps in chassis size growth for mo

product classes.

 Manufacturers have stated that consumer utility is negativ

impacted by such size increases.

 DOE lacks information on whether any size growth is acce

Engineering Analysis

Establishing Appropriate Size Limits for Room 

Conditioners with Louvered Sides

EERE-2007-BT-STD-0010 COMMENT 21.3
60 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Establishing Appropriate Size Limits for Room 

Conditioners with Louvered Sides

A methodology for determining appropriate maximum sizes fo

product classes and capacities has not been established. D

input on this topic, including, if possible, consumer surveys 

data to guide establishing these maximum size limits. (Iss

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
61 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Product Class 1 (<6,000 Btu/h, With Louvers, No Reverse Cyc

Efficiency

Level IEER Incremental MPC Sh

C

Baseline 9.52 $7.65 $1 1

0.1 $12.18 $

2 1

0.6 $18.22 $

3 11.1 $27.19 $

4 11.6 $37.30 $

5 1

2.0 $44.10 $

Room Air Conditioner Engineering Analysis Results

Class 1

 Baseline incremental MPC is non-zero, reflecting the cost of c

to R-410A refrigerant.

 Shipping is often done by retailers, so the manufacturer mark

apply for this part of the cost. Differences in shipping costs p

reflect size increases.

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
62 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Product Class 3 (8,000-13,999 Btu/h, With Louvers, No Reverse 

Efficiency

Level IEER Incremental MPC S

Baseline 9.71 $10.39 

1 1

0.3 $18.11 

2 1

0.8 $25.68 

3 11.3 $40.51 4 11.5 $78.59 

Room Air Conditioner Engineering Analysis: Produ

 DOE consolidated product class 3 results by averaging the 8,

and the 12,000 Btu/h analysis results. 

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
63 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Product Class 5 (>24,000 Btu/h, With Louvers, No Reverse Cy

Efficiency

Level IEER Incremental MPC Sh

Baseline 8.47 $23.78 1 9.0 $37.47 2 9.4 $52.84 3 9.8 $75.30 4 1

0.0 $104.34 

Room Air Conditioner Engineering Analysis: Produ

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
64 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Product Class 8 (8,000-13,999 Btu/h, Without Louvers, No Revers

Efficiency

Level IEER Incremental MPC Sh

C

Baseline 8.44 $7.45 $1 8.9 $10.95 $2 9.3 $15.36 $3 9.8 $28.82 $

Room Air Conditioner Engineering Analysis Results

Class 8

 DOE consolidated product class 8 results by averaging the 8,

and the 12,000 Btu/h analysis results.

 No increase in size, since these products are designed to fit f

wall openings. 

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
65 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE interpolated/extrapolated the incremental costs of the p

classes that were not fully analyzed.

• DOE conducted a full analysis on product classes 1,3,5, and 8.• For the remaining product classes, DOE interpolated or extrapolated 

average capacity of room air conditioners within each product class afactors detailed in the preliminary TSD.

 DOE derived costs using this method for:

• Louvered product classes 2 and 4;• Through-the-wall product classes 6, 7, 9, and 10;• Reverse-cycle product classes 11, 12, 13, and 14; and • Casement and Casement-slider product classes 15 and 16.

Engineering Analysis

Extrapolation for Room Air Conditioner Product Cla

Fully Analyzed

EERE-2007-BT-STD-0010 COMMENT 21.3
66 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE developed estimates of incremental costs for room air c

product classes not fully analyzed by extrapolation methods 

in chapter 5. DOE invites comment on the proposed extrap

approach. (Issue #4)

Engineering Analysis

Request for Comment:

Extrapolation for Room Air Conditioner Product C

Not Fully Analyzed

EERE-2007-BT-STD-0010 COMMENT 21.3
67 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 MSP accounts for the non-production costs and profit (i.e., th

“manufacturer markup”).

 DOE determined appropriate markup factors by using:

• U.S. Securities and Exchange Commission (SEC) 10-K reports

 MPCs are multiplied by the manufacturer markup to determin MSPs are an input to the LCC analysis.

Manufacturer Markup

Clothes Dryers and Room Air Conditioners 1.26

Manufacturer Selling Prices

Engineering Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
68 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE invites comments and recommendations from inter

parties on any other aspects relating to the Market and Tech

Assessment, the Screening Analysis, and the Engineering A

Issues

Request for Comment:

Other Issues

EERE-2007-BT-STD-0010 COMMENT 21.3
69 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Preliminary Activities Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

NaImA

Markups to DetermineProductPrice Life-Cycle Cost and

Payback Period Analyses

Market & Technology Assessment

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
70 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Markups for Product Price Determination:

• To characterize the channels for how products are distributed from 

manufacturer to the consumer.

• To determine prices paid by consumers based on manufacturer se

for baseline and higher efficiency products.

 Energy Use Characterization:

• To develop energy consumption savings estimates for selected pro

efficiency levels. 

 Life-Cycle Cost (LCC) and Payback Period (PBP) Analyses

• To develop the consumer life-cycle cost savings and payback perio

efficiency products.

Purpose

Life-Cycle Cost and Payback Period Analyses

EERE-2007-BT-STD-0010 COMMENT 21.3
71 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

LCC & Payback Period Analyses Flowch

From 

Engineering 

Analysis

From Markups 

to Determine 

Product Price

From Energy Use 

Characterization

Energy

Consumption

Manufacturer

Markup

Sales Tax

Retailer or

Distributor

Markup

Consumer

Price

Baseline

Manufacturer

Cost

Std-Level

Manufacturer

Cost

Energy

Prices

Annual Energy

Cost

Lifetime

Discount Rate

Energy

Price Trend

Installation

Cost

Total Installed 

Cost

Annual 

Operating 

Expense

Lifetime 

Operating 

Expense

Repair Cost

Maintenance 

Cost

Payback 

Period

Life-Cycle Cost and Payback Period Analyses

EERE-2007-BT-STD-0010 COMMENT 21.3
72 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 LCC equals total installed cost plus the sum of operating c

discounted to a particular base year.

 Economic evaluation performed from the consumer perspe Analysis models the uncertainty and variability of inputs us

Carlo approach and probability distributions.

 Analysis implemented in an Excel

® spreadsheet combined 

Ball.

®

First Cost

(Consumer Price +

Installation Cost)

Operating 

Expenses

Combine Change

in Costs

LCC Results

Convert to Present Value

Method

Life-Cycle Cost and Payback Period Analyses

EERE-2007-BT-STD-0010 COMMENT 21.3
73 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Purpose:

• Determine consumer product prices based on manufacturer costs.• Characterize product distribution channels and market segments.

 Inputs:

• Manufacturer Markups.

– Engineering Analysis.

• Retailer Markups.

– U.S. Census Bureau Financial Data for Household Appliance Sto

 Output:

• Baseline and incremental markups.

Purpose, Inputs, and Output of the Markup Ana

Markups Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
74 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Baseline and Incremental Markups

 Markups relate consumer price to cost of goods sold (CGS

 Baseline markups relate price to cost prior to a change in 

• Baseline markups indicate a consumer price that covers all of a ret

distributor’s expenses plus profit.

• Direct labor costs (salaries, payroll, rental and occupancy) are incl

 Incremental markups relate the incremental change in con

price to the incremental change in CGS.

• Some costs remain constant with CGS increases. • Incremental markups cover only expenses that vary with CGS – in 

expenses that increase due to an increase in product efficiency.

– For example, direct labor costs (salaries, payroll, rental and oc

not vary with efficiency-induced changes in CGS.

• DOE assumes other operating costs and profit scale proportionally 

Markups Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
75 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Clothes Dryer and Room Air Conditioner Distrib

Channel

Manufacturer Retailer Consum

Baseline Increment

Clothes Dryers 1.95 1.55Room Air Conditioners 1.95 1.55

Average Overall Markups by Product Cla

Markups Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
76 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Consumer Price

Sales Tax

Retailer Markup

Consumer

Price

Baseline

Manufacturer

Selling Price

Std-Level

Manufacturer

Selling Price

 Consumer Price = Manufacturing Price x Markups

• Manufacturing cost vs. efficiency relationships developed in the E

Analysis

• Markups and Sales Taxes developed in the Markups to Determine 

Consumer Price Determination

EERE-2007-BT-STD-0010 COMMENT 21.3
77 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Installation Costs

• Room Air Conditioners:

– Source: RS Means 2008

Product Class Labor Hours Bare Costs (2008$) Including Overhead a

Labor Material Total Labor Material

Less than 6,000 Btu/h 

with Louvers 1 $38 $0 $38 $59 $0 

8,000-13,999 Btu/h 

with and without Louvers

2 $67 $0 $67 $101 $0 

20,000 Btu/h or more 

with Louvers 4 $134 $0 $134 $202 $0 

Installation costs represent the labor and materials necessary to install the 

DOE found no evidence that installation costs would be impacted with increased e

*Material costs including overhead and profit equal bare costs plus 10 percent profit**Labor costs including overhead and profit equal bare labor costs plus labor markup in RS Means

Installation Cost

EERE-2007-BT-STD-0010 COMMENT 21.3
78 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Installation costs represent the labor and materials necessary to install the 

DOE found no evidence that installation costs would be impacted with increased e

Installation Costs

Installation Cost

• Clothes Dryers:

– Source: RS Means 2008

Product Class Labor Hours Bare Costs (2008$) Including Overhea

Labor Material Total Labor Mate

Electric Vented Clothes Dryers 

(Retrofit) 2.5 $84 $0 $84 $126 $

Electric Vented Clothes Dryers 

(New Owner) 2 $67 $0 $67 $101 $

Electric Vented Clothes Dryers 

(New Construction) 1 $34 $34 $68 $51 $

Gas Clothes Dryers (Retrofit) 2.5 $105 $0 $105 $158 $

Gas Clothes Dryers (New Owner) 2 $84 $0 $84 $126 $

Gas Clothes Vented Dryers (New 

Construction) 1 $42 $34 $76 $63 $

Vent-less Dryers (Retrofit) 2.5 $84 $0 $84 $126 $

Vent-less Dryers (New Owner) 2 $67 $0 $67 $101 $

Vent-less Dryers (New 

Construction) 1 $34 $0 $68 $0 $

*Material costs including overhead and profit equal bare costs plus 10 percent profit**Labor costs including overhead and profit equal bare labor costs plus labor markup in RS Means

EERE-2007-BT-STD-0010 COMMENT 21.3
79 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Selection of Household Samples:

Room Air Conditioners in Residential Buildin

RECS

Households

YES YES Has Room AC?

NO

Reject

NO

250 - 650

NO

Reject Reject

Room AC

Used?

3 or Less

RAC Units

Household

Sq. ft.

=< 250

YES

>= 650

Note: Square footage designation based on Energy Star sizing guidelines. Additional adju

to account for number of household members.

Energy Use Characterization

EERE-2007-BT-STD-0010 COMMENT 21.3
80 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Selection of Building Samples:

Room Air Conditioners in Commercial Buildin

* RAC as primary cooling equipment for at least a portion of the building?

Energy Use Characterization

YES

CBECS 

Buildings

Has 

room 

AC?

Building 

not 

vacant?

RAC 

primary?*

Building 

Sq. ft YES YES

>300

<300

>900

NO

Reject

NO

Reject

NO

Reject

EERE-2007-BT-STD-0010 COMMENT 21.3
81 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Selection of Household Samples:

Clothes Dryers

* Vented Dryer Criteria:

• Manufactured Home• Multifamily Home• Single family home with < 1,000 sq. ft. and no garage or basement

Energy Use Characterization

EERE-2007-BT-STD-0010 COMMENT 21.3
82 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Base case product efficiency assignment accounts for the projected market 

products at different efficiency levels.

• Not all consumers purchase products at current minimum standard.• LCC analysis recognizes that consumers already purchasing products at efficiencie

equal to a prospective standard level are not impacted by the standard.

Example: Room Air Conditioners Base Case Market Shares

Efficiency Level

< 6,000 Btu/h with 

Louvers

8,000 – 13,999 Btu/h with 

Louvers

> 20,000 Btu/h with 

Louvers

8,00

wi

IEER Market Share IEER Market Share IEER Market Share IEER 

Baseline 9.5 96.0% 9.7 51.4% 8.5 37.0% 8.4 

1 10.1 0.0% 10.3 1.5% 9.0 6.1% 8.9 

2 10.6 4.0% 10.8 44.3% 9.4 56.2% 9.3 3 11.1 0.0% 11.3 1.7% 9.8 0.7% 9.8 

4 11.6 0.0% 11.5 1.1% 10.0 0.0%

5 12.0 0.0%

Source: AHAM shipment data by efficiency level, ENERGY STAR fractions by state. 

Product Assignment in the Base Case

EERE-2007-BT-STD-0010 COMMENT 21.3
83 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Product Assignment in the Base Case

Example: Clothes Dryers Base Case Market Shares

Efficiency 

Level

Vented Electric 

Standard

Vented Electric 

Compact (120V)

Vented Electric 

Compact (240V) Vented Gas 

Vent-less 

Electric Compa

(240V)

IEF

Market 

Share IEF

Market 

Share IEF

Market 

Share IEF

Market 

Share

IEF Mark

Sha

Baseline 2.96 29.5% 2.79 38.9% 3.00 100.0% 2.63 26.8% 2.29 100% 

1 3.04 49.9% 2.86 38.9% 3.08 0.0% 2.71 43.4% 2.31 0.0% 2 3.10 20.6% 2.96 0.0% 3.15 0.0% 2.80 28.9% 2.37 0.0% 3 3.33 0.0% 3.06 22.2% 3.38 0.0% 2.97 0.9% 2.39 0.0% 4 3.35 0.0% 3.10 0.0% 3.41 0.0% 2.98 0.0% 2.59 0.0% 5 3.40 0.0% 3.19 0.0% 3.53 0.0% 3.02 0.0% 3.54 0.0% 6 4.52 0.0% 4.34 0.0% 4.69 0.0%

Source: CEC directory

EERE-2007-BT-STD-0010 COMMENT 21.3
84 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Base-Case Efficiency Distributions

Issues

To estimate the share of consumers that would be affec

standard at a particular efficiency level, DOE’s LCC an

analyses considered the projected distribution of pro

efficiencies that consumers would purchase in the base 

the case without amended energy efficiency standards). D

that the data on recent trends in shipment-weighted a

efficiency of room air conditioners and shares of ENERG

products are inconclusive. Therefore, DOE assumed that t

shares of the efficiency levels in 2014 will be roughly the s

shares in 2007. DOE also believes that there is little evid

expect much change in the energy efficiency of clothes dr

base case. DOE invites comment on the approach used t

base-case market shares of the considered efficiency leve

#13)

EERE-2007-BT-STD-0010 COMMENT 21.3
85 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Energy Use Parameters

Example: Residential Room Air Conditioner

RECS

EER by

efficiency

level

AHAM

Data

Existing

EER

RAC

Capacity

Unit Energy

Consumption

(UEC)

Household

Sq. ft.

RAC Age

# of RAC

Units

Reported

Energy

Use*

Energy

Use

Operating

Hours

CDD Weather

Station

Data

Monthly

CDD Data

* Climate data from 2005 RECS

Energy Use Determination

EERE-2007-BT-STD-0010 COMMENT 21.3
86 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Active Mode Energy Use:

– Load weight distributions based on CEC data and DOE test proced– Remaining Moisture Content (RMC) distributions based on CEC da– Clothes dryer cycles calculated from RECS

 Standby Power Use:

– 1 cycle = 60 minutes– Standby power level from test lab measurements

Energy Use Parameters

Example: Clothes Dryers

Energy Use Determination

EERE-2007-BT-STD-0010 COMMENT 21.3
87 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

The DOE test procedure uses weights of 7 lb for standard

units and 3 lb for compact-size units. For its LCC ana

DOE developed a distribution of weights by matching th

tub sizes for models in the CEC directory with the corre

between tub size and average pounds specified in the 

procedure. DOE invites comment on this approach. (Iss

Issues

Request for Comment:

Load Sizes for Clothes Dryers

EERE-2007-BT-STD-0010 COMMENT 21.3
88 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE is currently considering amendments to its clothes dr

procedure to revise the initial RMC to reflect the perfor

of residential clothes washers currently on the mar

However, DOE has not yet published a NOPR for poten

procedure amendments. Therefore, for this prelimin

analysis, DOE did not analyze energy conservation sta

based on initial RMCs lower than the existing 70 percen

may consider revising the IEF efficiency levels in later 

of this rulemaking as warranted by further research 

comments from interested parties. (Issue #9)

Issues

Request for Comment:

Clothes Dryer Remaining Moisture Conten

EERE-2007-BT-STD-0010 COMMENT 21.3
89 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

For the LCC analysis, DOE estimated the number of clothe

cycles per year for each sample home using data giv

RECS on the number of laundry loads (clothes washer 

washed per week and the frequency of clothes dryer us

invites comment on this approach. (Issue #8)

Issues

Request for Comment:

Number of Annual Cycles for Clothes Drye

EERE-2007-BT-STD-0010 COMMENT 21.3
90 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Annual Operating Hours for Room Air Conditio

For each considered room air conditioner capacity, D

calculated the number of operating hours for each roo

conditioner in the residential sample using the reported 

use for room air conditioning in the 2005 RECS along 

estimates of the EER of the room air conditioner(s) in 

sample home. DOE based the latter on the reported age 

unit and historical data on shipment-weighted average 

DOE invites comment on this approach. (Issue #7

Issues

EERE-2007-BT-STD-0010 COMMENT 21.3
91 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Baseline Average Annual Energy Use Resul

Energy Use Results

Room Air Conditioners

Electricity Use

Baseline Efficiency 

Level

Residential 

(kWh/year)

C

(

Room Air Conditioners <6000 Btu/h, with Louvers 9.52 688 Room Air Conditioners 8000-13,999 Btu/h, with Louvers 9.71 672 Room Air Conditioners 

≥ 20,000 Btu/h, with Louvers 8.47 1118 

Room Air Conditioners 8000-13,999 Btu/h, without Louvers 8.43 712 

Clothes Dryers Baseline Efficiency Level Energy Vented Electric Standard 2.96 519 kWh/Vented Electric Compact (120V) 3.00 270 kWh/Vented Electric Compact (240V) 2.79 290 kWh/Vented Gas 2.63

1.65 MMBt

71.4 kWh/

Vent-less Electric Compact (240V) 2.29 351 kWh/Vent-less Electric Combination Washer/Dryer 1.90 424 kWh/

EERE-2007-BT-STD-0010 COMMENT 21.3
92 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Electricity:

• Based on EIA Form 861 Data.

 Natural Gas:

• Based on data from EIA’s Natural Gas Navigator.

 Liquefied Petroleum Gas (LPG):

• Based on data from EIA’s State Energy Consumption, Price, and Ex

Estimates.

Historical Energy Prices:

Clothes Dryers

Note: Energy prices developed for 13 Regions: 9 Census Divisions and 4 Large States

Energy Prices

EERE-2007-BT-STD-0010 COMMENT 21.3
93 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Electricity Prices

 Electricity prices are used to convert electricity use to electricity co

 For the LCC, electricity prices are defined for each household or bu DOE uses an average price to define the LCC baseline, and margin

determine LCC cost savings; the marginal price is the price paid foincrement of consumption.

 Residential

• Input data are the LBNL-TAP tariff sample for 90 utilities (updated in 2008) an

consumption data from RECS 2005.

• The marginal price is defined by decrementing the energy use and calculating 

the consumer electricity bill.

 Commercial

• For commercial electricity consumers demand charges are significant.• Prices are calculated based on previous analysis (CUAC and DT).• The tariff-based bill calculations are summarized in an electricity cost function• This cost function provides the price as a function of the energy and demand 

EERE-2007-BT-STD-0010 COMMENT 21.3
94 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

AEO 2009 Energy Price Forecasts

• Energy price projections to 2030 based on EIA’s Annual Energy Ou

Residential Natural Gas Residential Electric

Prices

Energy Prices

EERE-2007-BT-STD-0010 COMMENT 21.3
95 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Issues

Request for Comment:

Repair and Maintenance CostsRepair and Maintenance Costs

DOE did not find any evidence that repair and maintenan

change as product efficiency increases for room air condit

clothes dryers. DOE requests any specific information sh

extent to which repair and maintenance costs change as 

efficiency increases beyond the baseline levels used in 

analysis. 

DOE invites comment on the extent repair and maintenan

change as product efficiency increases. (Issue #1

EERE-2007-BT-STD-0010 COMMENT 21.3
96 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Other Inputs for LCC

 Discount Rates (Primary data source: Federal Reserve Board’s Survey of Cons

the years 1989, 1992, 1995, 1998, 2001, 2004, and 2007).

Product Class Minimum Average MaxRoom Air Conditioners 3.0 10.5 Clothes Dryers 5.0 16.0 

Housing Type Finance Cost Based on: New Construction* Mortgage Replacements Home equity loans, Credit card, Other loans, Checking & savings 

accounts, Certificates of deposit, Bonds, Stocks

 Equipment Lifetime (DOE used RECS equipment age data, AHS equipment stoc

data to derive lifetime distributions using a Weibull function.)

* Clothes Dryers only

Other Inputs for LCC

EERE-2007-BT-STD-0010 COMMENT 21.3
97 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Lifetime

DOE conducted an analysis of actual lifetime in the field 

combination of shipments data, the stock of the consi

appliances, and responses in RECS on the age of the app

the homes. The data allowed DOE to estimate a survival 

which provides an average and a median appliance lifeti

analysis yielded an average lifetime for room air conditio

approximately 10.5 years and for clothes dryers of approx

years. 

DOE invites comment on its approach for estimating the l

clothes dryers and room air conditioners. (Issue #

Issues

EERE-2007-BT-STD-0010 COMMENT 21.3
98 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

LCC Savings and PBP Results

Example: Room Air Conditioners, 8000-13,999 Btu/h, wit

Preliminary Results

Efficiency 

Level

IEER

Btu/hr

Life-Cycle Cost (2008$) Life-Cycle Cost Savings 

Average 

Installed 

Price

Average 

Operating 

Cost

Average 

LCC

Average 

Savings 

(2008$)

Households with

Net

Cost

No 

Impact

Net 

Benefit

Baseline 9.7 $489 $655 $1,144

1 10.3 $502 $614 $1,117 $14 14% 49% 37% 

2 10.8 $517 $584 $1,100 $23 17% 47% 36% 3 11.3 $543 $556 $1,099 $24 53% 3% 44% 4 11.5 $602 $546 $1,148 -$24 69% 1% 30% 

EERE-2007-BT-STD-0010 COMMENT 21.3
99 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

LCC Savings and PBP Results

Example: Electric Standard Clothes Dryer

Preliminary Results

Efficiency 

Level

IEF

lb/kWh

Life-Cycle Cost (2008$) Life-Cycle Cost Savings 

Average 

Installed 

Price

Average 

Operating 

Cost

Average 

LCC

Average 

Savings 

(2008$)

Households with

Net

Cost

No 

Impact

Net 

Benefit

Baseline 2.96 $552 $657 $1,209

1 3.04 $571 $638 $1,209 $0 19% 70% 10% 2 3.10 $651 $627 $1,277 -$54 78% 21% 1% 

3 3.33 $703 $584 $1,287 -$64 87% 0% 13% 4 3.35 $705 $578 $1,284 -$60 86% 0% 14% 5 3.40 $704 $563 $1,267 -$44 79% 0% 21% 6 4.52 $953 $424 $1,377 -$154 85% 0% 15% 

EERE-2007-BT-STD-0010 COMMENT 21.3
100 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Issues

Request for Comment:

Other Issues

Repair and Maintenance Costs

DOE invites comment and recommendations from interest

on any other aspects related to the Life-Cycle Cost Ana

EERE-2007-BT-STD-0010 COMMENT 21.3
101 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Framework

Document

Preliminary 

Activities NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

NaImA

Markups to DetermineProductPrice Life-Cycle Cost and

Payback Period Analyses

Market & Technology Assessment

Preliminary Manufacturer Impact Analysis

Preliminary Activities Flow Diagram

EERE-2007-BT-STD-0010 COMMENT 21.3
102 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Purpose

 Shipments Analysis:

• To estimate room air conditioner and clothes dryer shipments over 

 National Impact Analysis:

• To estimate the National Energy Savings (NES) from room air con

clothes dryer energy conservation standards at different efficiency 

• To estimate the national economic impact on room air conditioner 

dryer consumers (or the Net Present Value (NPV)) from energy costandards at different efficiency levels.

National Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
103 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

National Impact Analysis Process

Shipments Model

National Energy Savings

NationalConsumer EconomicImpacts

LCC Analysis Results and Other Inputs

Nation

Energy Sa

(Quad

Nation

Net Presen

(2008$, b

• National energy savings calculated for period from 2014-2044.• NPV calculated for products shipped over the same period.

National Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
104 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Shipments Analysis Flowchart

Example: Room Air Conditioners

Historical Shipments

Room Air 

Conditioner Lifetime

Replacement

Shipments

Total 

Shipmen

Existing Households 

without any air 

conditioning

Average Room Air 

Conditioner 

Saturation

Shipments to existing 

households adding a 

new room air 

conditioner

Total

Shipments

Shipments Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
105 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Shipments Model Inputs

Input Data Source/Description

New Constructions & ReplacementsLifetime From Life-Cycle Cost AnalysisNew Construction ShipmentsClothes DryersForecasted New Housing Annual Energy Outlook 2009New Housing Saturations Residential Energy Consumption Survey 2005Historical ShipmentsRoom Air Conditioners, Clothes Dryers AHAM Data Submittal; AHAM Factbooks; Appliance MagaShipment Distribution by Product ClassRoom Air Conditioners, Clothes Dryers AHAM Data Submittal

Shipments Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
106 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Room Air Conditioner Historical & Modeled Ship

Shipments Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
107 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Clothes Dryers Historical & Modeled Shipme

Shipments Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
108 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

National Impact Analysis Inputs

Total Installed Cost Annual weighted-average per unit values as a function of efficiency le

LCC analysis.

Repair and Maintenance Costs

Annual values are a function of efficiency level (from LCC analysis).

Annual Energy Use Annual weighted-average per unit values as a function of efficiency le

LCC analysis.

Base-Case Efficiencies

Shipments-weighted efficiencies determined for the effective year. Baefficiency distributions from LCC analysis.

Standards-Case Forecasted Efficiencies

Roll-up scenario assumed for determining shipment-weighted efficienstandards case.Both Base- and Standards-Case efficiencies: Frozen at the effective y

Energy Prices Average prices and forecasted energy prices from EIA AEO2009 forec

and extrapolation to 2044. 

Electricity Site-toSource Conversion Factors

Conversion factors based on marginal heat rates from NEMS correspo2007AEO. Factors vary annually and account for generation, distributtransmission losses.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis GuidelinPresent Year Future expenses are discounted to the year 2011.Rebound Effect Room Air Conditioners – 15 percent

National Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
109 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Forecasted Efficiencies

Example: Room Air Conditioners: 8,000-13,999 Btu/h, Wi

 Base-Case efficiency distribution from LCC analysis.

• Based on AHAM data submittal and for room air conditioners, also incorporated reg

distributions based on ENERGY STAR market shares.

 Standards-Case efficiency distributions based on “Roll-up” scenario.

• Efficiencies below the standard level “roll-up” to the standard level.• Efficiencies above the standard level are unaffected.

 Forecasted efficiencies assumed to remain constant at effective date level.

Efficiency 

Level EER

Market Shares

Base Case

Efficiency Levels (analyz

1 2 3 

Baseline 9.7 51%

1 10.3 2% 53%

2 10.8 44% 44% 97%

3 11.3 2% 2% 2% 99%

4 11.5 1% 1% 1% 1% 

Shipments-Weighted EER 10.24 10.55 10.82 11.30 

National Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
110 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

National Energy Savings Results

Example: Room Air Conditioners, 8,000-13,999 Btu/h, wi

Efficiency Level 2 - 10.8 Btu/hr

0

0.0010.0020.0030.0040.0050.0060.007

2014 2019 2024 2029 2034 2039

National Savings, Quads

National Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
111 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Net Present Value Results

Example: Room Air Conditioners, 8,000-13,999 Btu/h, wit

Annual Values Efficiency Level 2 – 10.8 Btu/hr

National Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
112 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Natural Gas Price Impacts Methodology and Re

DOE conducted an analysis of the potential impacts of room air conditioneclothes dryer energy conservation standards on natural gas prices on all s

the economy (this analysis is presented to provide a base for input from inparties on an analysis DOE plans to include in the NOPR stage of the rulem

 Methodology:

• DOE’s analysis used NEMS, which utilizes energy price elasticities to estima

prices that would result from a change in energy demand. 

• Two scenarios were analyzed for room air conditioners and clothes dryers: a

first efficiency level for all product classes, and b) all max-tech options.

 Results:

• The estimated natural gas price reduction averages 0.2 cents per MMBtu (sc

cents per MMBtu (scenario 2).

 National Benefits:

• The estimated economy-wide savings over the period 2014–2044 has an NP

discount rate) of $0.22 billion (scenario 1) and 3.25 billion (scenario 2).

Natural Gas Price Impacts

EERE-2007-BT-STD-0010 COMMENT 21.3
113 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Issues

Request for Comment:

Other Issues

DOE invites comment and recommendations from interest

on any other aspects related to the National Impact An

EERE-2007-BT-STD-0010 COMMENT 21.3
114 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Preliminary Activities Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

NaImA

Markups to DetermineProductPrice Life-Cycle Cost and

Payback Period Analyses

Market & Technology Assessment

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
115 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE conducted on-site and telephone interviews with 

manufacturers of:

• Residential clothes dryers; and• Room air conditioners.

 Topics included:

• Engineering analysis overview, methodology, and results;• Key issues (as defined by manufacturer);• Current market conditions (shipments, market share, product mix

profitability);

• Manufacturer subgroup analysis;• Product utility and innovation (performance vs. efficiency, design • Potential impacts of amended energy conservation standards (es

conversion costs); and

• Cumulative regulatory burdens (state, federal, international).

Preliminary Manufacturer Impact Analysis (MIA) O

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
116 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE interviewed manufacturers representing almost 90 p

the U.S. residential clothes dryer market.

Residential Clothes Dryer Preliminary MIA

Manufacturer

Sub-Group 

Analysis

Product Utility and Innovation

Impacts of Efficiency Standards

Current 

Market 

Conditions

KeyIssues

CuReBu

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
117 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Cumulative Regulatory Burden

• Concern regarding the proposed UL Safety Requirement - Fire Containmen

Resistant Standard, which would increase material costs and require develoexpenditures.

• Current and new DOE energy conservation standards rulemakings for othe

regulated equipment (e.g., residential and commercial clothes washers).

• Potential Reduction of Hazardous Substances (RoHS) requirements.

 Impact on Product Mix

• According to manufacturers, amended energy conservation standards could 

longer drying times for clothes dryers, especially at higher efficiency levels.

• All manufacturers stated that dryers requiring much over one hour to dry on

load would not currently be accepted by the majority of consumers.

Residential Clothes Dryer Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
118 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 ENERGY STAR Program:

• Multiple manufacturers indicated that an ENERGY STAR program would h

programs for higher efficiency research.

• Consumers are becoming more educated on clothes dryers and would like 

products follow clothes washers in improving efficiency.

• ENERGY STAR could be the differentiator needed to ensure sales, particu

high-end products.

 Economic Impacts:

• Manufacturers expressed concern regarding the current economic conditio

impacts it has had on their operations and workforce.

• Customers that purchase high-end products are only buying clothes dryers 

necessary; lower-end product customers are still buying washers and dryer

and middle-end product customers are not making new purchases at all. R

increase as customers try to maintain their current products longer.

• Reductions in workforces make it difficult to justify new product developme

support product rulemakings.

• Capital expenditures are extremely controlled, with strict limitations on how 

be allocated for design improvements. 

Residential Clothes Dryer Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
119 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Impact on Profitability:

• Profit margins are likely to be affected if new or more costly known technolo

be introduced into the market to meet amended standards.

• For some manufacturers, especially those with low market share, stringent 

could reduce their profit margin to a point where the U.S. market is no long

• Several manufacturers also mentioned that if they were forced to redesign 

due to amended standards, costs would increase and they would reduce ththeir products and even cut entire product platforms to remain profitable.

 Product Conversion Costs:

• For lower-volume manufacturers, high capital costs for new tooling and equ

not be justifiable given their production volume, and they would resort to us

purchased parts at a higher per-unit cost to minimize capital investments.

• Multiple lower-volume manufacturers stated that amended standards set at 

Level 2 and above would most likely force them to exit the residential markinvestment requirements and the resultant market outlook.

• Multiple manufacturers also expressed concern over how the implementatio

design changes for clothes dryers would affect their standardization of com

Residential Clothes Dryer Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
120 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Product Innovation:

• Some manufacturers indicated that the implementation of amended standa

force a choice of technologies too quickly to meet a standard.

• All manufacturers are concerned that new or amended standards would ta

from investments in possible innovations that would take place without sta

Residential Clothes Dryer Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
121 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Residential Clothes Dryer Manufacturer Subgrou

DOE research suggests that there are no residential clothes 

manufacturers in the United States that are designated as 

businesses by the U.S. Small Business Administration. 

invites comment on whether a manufacturer subgroup an

is appropriate for the NOPR stage. (Issue #14)

Preliminary Manufacturer Impact Analysis

Request for Comment:

Residential Clothes Dryer Manufacturer Subgro

EERE-2007-BT-STD-0010 COMMENT 21.3
122 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Residential clothes dryer manufacturers must also comply w

Underwriters Laboratory (UL) fire containment regulatio

clothes dryers. DOE seeks information from interested pa

further evaluate this issue in the NOPR analyses. (Issu

Preliminary Manufacturer Impact Analysis

Request for Comment:

Underwriters Laboratory Fire Safety Regulation for 

Dryers

EERE-2007-BT-STD-0010 COMMENT 21.3
123 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE interviewed manufacturers representing nearly 30 pe

the U.S. room air conditioner market..

Room Air Conditioner Preliminary MIA

Manufacturer

Sub-Group 

Analysis

Product Utility and Innovation

Impacts of Efficiency Standards

Current 

Market 

Conditions

KeyIssues

CuReBu

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
124 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Cumulative Regulatory Burden:

• All manufacturers reported challenges regarding the 2010 EPA ph

the use of HCFC-22 refrigerant in new equipment.

• Issues included concern about reliability and performance of R-41

compressors, and size constraints of room air conditioners whilemaintaining current efficiency levels.

• Potential changes to electrical codes for fire safety could add furth

and manufacturing complexity.

• Multiple manufacturers also mentioned possible carbon-penalties 

associated with future greenhouse gas regulations, RoHS requireand Canadian product safety registration payments.

Room Air Conditioner Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
125 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 The Environmental Protection Agency (EPA) banned prod

and import of HCFC-22 for newly manufactured equipmenU.S., starting on January 1, 2010.

 Manufacturers reported many challenges with addressing 

regulation.

• Higher manufacturing costs• Reliability of R-410A compressors• Maintaining size constraints while meeting existing efficiency leve

 R-410A compressors do not extend over the full range of 

capacities and EERs of HCFC-22 compressors, especially high-capacity room air conditioner compressors (> 1.5 To

 R-410A operates at higher pressures and thus requires th

tubing.

Conversion from HCFC-22 to R-410A

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
126 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Impact on Product Mix/ENERGY STAR Program:

• Manufacturers reported lower efficiencies with R-410A refrigerant 

versus HCFC-22 units for a given cabinet size.

• Required changes may result in a decrease in total shipments, du

constraints in the efficiency levels that can be reached within the 

chassis sizes.

• Size limitations are especially relevant in the through-the-wall ma• Increases in product size could have a significant impact on cons

utility.

Room Air Conditioner Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
127 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Industry Consolidation:

• Multiple manufacturers stated that the number of factories supply

U.S. market has shrunk from 20 to 30 factories to less than 10, evproduction volumes have increased.

• Amended standards could accelerate this consolidation.• No major manufacturing facilities remain in the U.S. – most produ

Asia (particularly China), with some in Mexico.

 Impact on Profitability:

• Some manufacturers believe they would experience a reduction i

ENERGY STAR-qualified product sales with changes in efficiency standards.

• Room air conditioner units bought by lower-income consumers ar

sensitive.

• Industry profit margins have continually decreased and could con

decrease with amended energy conservation standards.

Room Air Conditioner Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
128 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Product Conversion Costs:

• Manufacturers commented that the availability of technology optio

efficiency improvement and the cost of bringing them to market is concern.

• Low margins of the room air conditioner business make it difficult 

any product development, conversion, etc. costs.

• Amended energy conservation standards could exacerbate some 

manufacturers’ disadvantage of not controlling component develo

 Product Innovation:

• Some manufacturers believe that product innovation would be sty• Resources would be focused on redesigning for efficiency improve

rather than on the development of new products.

• In contrast, other manufacturers believe product innovation would 

from amended standards as the potential for compressor and mottechnology evaluation would increase.

Room Air Conditioner Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
129 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Impact on Consumer Subgroups:

• Multiple manufacturers expressed concern regarding the impacts 

income and elderly subgroups.

• Higher cost necessitated from amended energy conservation stan

may cause these individuals to choose not to buy such units.

• This would put those consumers at risk of heat stroke and other h

related medical issues.

Room Air Conditioner Key Issues

Preliminary Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
130 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE research suggests that there is at least one room a

conditioner manufacturer that is a small business. DOE i

comment on whether a manufacturer subgroup analys

appropriate for the NOPR stage. (Issue #14)

Preliminary Manufacturer Impact Analysis

Request for Comment:

Room Air Conditioner Manufacturer Subgroup

EERE-2007-BT-STD-0010 COMMENT 21.3
131 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE welcomes comments and recommendations fro

interested parties on any aspects related to the Prelimin

Manufacturer Impact Analysis.

Preliminary Manufacturer Impact Analysis

Request for Comment:

Other Issues

EERE-2007-BT-STD-0010 COMMENT 21.3
132 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

NOPR Analyses Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

TrialStandardLevels

Revise Preliminary Analyses

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Environmental Assessment

Employment

Impact 

Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
133 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Purpose:

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

proposed standard level is selected.

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

and may vary between product classes.

– NOPR analyses assess impacts for trial standard levels (not efficiency le

product class).

 Method:

• Trial standard levels are assembled from the product classes and efficiency le

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.

Selection of Trial Standard Levels

Trial Standard Levels

EERE-2007-BT-STD-0010 COMMENT 21.3
134 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Criteria for the Selection of Trial Standard Lev

DOE requests feedback on the criteria it should use f

basing the selection of Trial Standard Levels.

 A critical part of the NOPR analysis on which DOE is seek

guidance is the criteria used in selecting trial standard lev

 Trial standard levels are created from combinations of effi

levels at the product class level.

Issues

EERE-2007-BT-STD-0010 COMMENT 21.3
135 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

NOPR Analyses Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

TrialStandardLevels

Revise Preliminary Analyses

Utility

Impact 

Analysis

Environmental Assessment

Employment

Impact 

Analysis

Manufacturer

Impact 

Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
136 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Manufacturer Impact Analysis

 Purpose:

• To assess the impacts of standards on residential clothes dryer and room air c

manufacturers.

• To identify and estimate impacts on manufacturer sub-groups that may be mor

impacted than the industry as a whole.

• To examine the impact of cumulative regulatory burdens on the industry.

 Method:

• Analyze industry cash flow and net present value through use of the Governme

Impact Model (GRIM).

• Interview manufacturers to refine inputs to the GRIM, develop sub-group analy

qualitative issues.

 Output:

• Industry Net Present Value impacts;• Sub-group Net Present Value impacts; and• Other impacts.

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
137 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

• The MIA consists of three phases:

Manufacturer Impact Analysis Process

Industry profile

Develop straw-man GRIM*

Develop interview guide

Interviews

& industrywide / 

subgroup

analyses

Assess direct employment, competition, cumulative burden

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 1 Phase 3

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
138 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

The MIA is both concurrent and coordinated with a

throughout the rulemaking process.

Phase I

Industry Profile

Phase III

Manufacturer Interviews

Revised Industry Cash Flow

Manufacturer Subgroup Analysis

Qualitative Assessment

Phase II

“Strawman” GRIM

Manufacturer Impact Analysis

Screening A

Screening An

Engineering A

Engineering A

LCC Anal

LCC Analy

National En

Savings An

National Ene

Savings Ana

Consumer Su

Consumer Su

Utility Imp

Utility Impa

Environmenta

Environmental 

Other Rulemaking A

Indirect Emp

Impac

Indirect Emplo

Impacts

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
139 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Phase I: Industry Profile

 Collect financial and market information:

• Industry reports;• Company annual reports and websites;• Trade journals;• U.S. Census Bureau;• SEC 10-K form filings;• Information from the preliminary activities preceding the NOPR

manufacturer production costs, markups; and manufacturer seprices, shipments.

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
140 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Manufacturer Prices

Shipments

Manufacturing 

Financial Infor

Cash Flow Impacts, 

Changes in Industry NPV

GRIM

Phase II: Develop Straw-man GRIM

 The Government Regulatory Impact Model (GRIM) is an i

cash flow analysis that estimates the change in industry due to the introduction of new efficiency standards.

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
141 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 A critical aspect of the MIA involves interviews with manuf

interview guide is sent to manufacturers in preparation for 

 Interview topics will include:

• Engineering analysis;• Shipments model;• Cost structure and financial parameters;• Conversion costs (capital expenditures, tooling, R&D, testing);• Impact of other regulations / cumulative burden;• Direct employment impacts;• Import / Export issues;• Consolidation / competitive impacts;• Replacement parts or refurbishments;• Impact of the standard’s effective date; and• Other topics important to manufacturers.

Phase II: Develop Interview Guide

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
142 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Interviews are expected to be conducted early in the NOP DOE encourages all interested manufacturers to provide i

the MIA in support of the:

• Industry-wide GRIM;• GRIM assumptions; and• Manufacturer subgroup analysis.

 Proprietary information is protected.

• Confidentiality agreements are executed.• Quantitative information is aggregated.

Phase III: Manufacturer Interviews

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
143 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 The subgroup analysis is a more focused version of 

industry-wide analysis.

• Work with subgroup representatives to better understand a

qualify the differential impacts of potential amended energy conservation standards on these groups.

• Consider and focus on issues of importance to the subgrou

including employment, capacity utilization and cumulative burden.

• Review draft findings with subgroup members during 

development.

Phase III: Manufacturer Subgroup Analysi

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
144 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Cumulative Regulatory Burden

 DOE seeks to mitigate the overlapping effects on manufactu

amended energy conservation standards and other regulatoaffecting the same products.

 While any one regulation may not impose a significant burd

manufacturers, the combined effects of several impending rmay have serious consequences for some manufacturers, gmanufacturers, or an entire industry. 

 As part of the MIA, DOE will assess the potential cumulative 

regulatory burden on manufacturers of residential clothes droom air conditioners.

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
145 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Residential Clothes Dryers: Cumulative Regulatory 

DOE requests comment on the potential regulations 

facing the residential clothes dryer industry.

 DOE identified the following regulations that could impac

manufacturers of residential clothes dryers:

• UL Safety Requirement - Fire Containment/Burn Resistant Sta• DOE’s amended energy conservation standards for other prod• RoHS requirements.

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
146 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Request for Comment:

Room Air Conditioners: Cumulative Regulatory 

DOE requests comment on the potential regulation

facing the room air conditioner industry.

 DOE identified the following regulations that could impa

manufacturers of room air conditioner products:

• Environmental Protection Agency’s (EPA) ban on HCFC refrig

new products;

• DOE’s amended energy conservation standards for other prod• Potential greenhouse gas regulations;• RoHS requirements;• Electrical codes for fire safety;

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
147 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 DOE identified small businesses and is interested in the p

impacts as a result of amended energy conservation stand

 DOE defines small businesses using the Small Business 

Administration (SBA) definitions. 

• Residential clothes dryers and room air conditioners are matched 

North American Industry Classification System (NAICS) code 335Household Laundry Equipment Manufacturing, or NAICS code 33Ventilation, Heating, Air-Conditioning, and Commercial RefrigeratiEquipment Manufacturing.

• Small businesses under these codes are defined as 500 employe

fewer.

 Residential Clothes Dryers:

• DOE identified no small businesses.

 Room Air Conditioners:

• DOE identified at least one small business.

Request for Comment:

Small Business Impacts

Manufacturer Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
148 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE invites comments on the identification of any sm

businesses within the residential clothes dryer or room 

conditioner industries. (Issue #14)

Manufacturer Impact Analysis

Request for Comment:

Small Business Impacts

EERE-2007-BT-STD-0010 COMMENT 21.3
149 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

NOPR Analyses Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

TrialStandardLevels

Revise Preliminary Analyses

Utility

Impact 

Analysis

Environmental Assessment

Employment

Impact 

Analysis

Manufacturer

Impact 

Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
150 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Purpose:

• To investigate the effects on utilities from reduced energy sales and 

demand due to potential standards.

 Method:

• Uses national energy savings results.• Uses the Energy Information Administration’s National Energy Mode

(NEMS) tailored for DOE’s Building Technologies Program (NEMS-B

 Output:

• Change in energy sales and price by region.• Change in the mix of electricity generation.• Change in new capacity construction.

Utility Impact Analysis

Utility Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
151 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

NOPR Analyses Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

TrialStandardLevels

Revise Preliminary Analyses

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Environmental Assessment

Employment

Impact 

Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
152 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

Employment Impact Analysis

 Purpose:

• To report net jobs created or eliminated nationally as a consequence 

energy conservation standards.

 Method:

• Uses the ImSET tool, a spreadsheet model of the U.S. economy that 

188 sectors most relevant to industrial, commercial, and residential benergy use.

• Changes in product and energy expenditures taken from the Nationa

Analysis.

• Estimates the national employment and income effects of energy sav

appliances.

• Direct employment impacts taken from the Manufacturer Impact Ana

 Output:

• Change in employment by sector as a consequence of new standard

Employment Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
153 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

NOPR Analyses Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

TrialStandardLevels

Revise Preliminary Analyses

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Environmental Assessment

Employment

Impact 

Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
154 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Purpose:

• To report environmental impacts as a consequence of new energy co

standards, including changes in power plant emissions as well as emhouseholds due to the use of gas appliances. 

 Method:

• Energy savings results taken from the National Impact Analysis.• Energy Information Administration’s National Energy Modeling Syste

provides power-plant emissions.

• ‘In-Building’ emissions due to fossil-fuel fired appliances to be determ

emission factors.

• Economic benefits resulting from emissions reductions based on a ra

monetary values.

 Output:

• Estimate of national emission reductions of SO2, NOx, mercury and C

– Power plant SO2, NOx, and mercury are effectively capped throu

Congressional legislation resulting in little to no emission reducti

standards.

– In-building SO2 and NOx still emitted by fossil-fuel fired applianc

Environmental Assessment

Environmental Assessment

EERE-2007-BT-STD-0010 COMMENT 21.3
155 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

NOPR Analyses Flow Diagram

Framework

Document

Preliminary 

Activities NOPR Final Rule

TrialStandardLevels

Revise Preliminary Analyses

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Environmental Assessment

Employment

Impact 

Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
156 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

 Purpose:

• To investigate the national impacts due to non-regulatory alternati

with mandatory energy conservation standards.

• The non-regulatory alternatives that may be considered: 

– No new regulatory action; early replacement; prescriptive stan

consumer tax credits; manufacturer tax credits; consumer rebefficiency targets; bulk government procurement.

 Method:

• Modify NES spreadsheet model to consider non-regulatory scenar

– Non-regulatory scenarios increase overall appliance efficiency 

modeled by modifying the base case efficiency trend.

– NPV calculated for non-regulatory alternatives in the same wa

adopted standard.

 Each non-regulatory scenario will decrease national app

operating costs and increase appliance equipment prices

 Output:

• National Energy Savings and Net Present Value of the non-regula

alternatives.

Regulatory Impact Analysis

Regulatory Impact Analysis

EERE-2007-BT-STD-0010 COMMENT 21.3
157 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

DOE requests comments and invites questions from 

interested parties regarding the Department of Energy

Residential Clothes Dryer and Room Air Conditione

Energy Conservation Standards Rulemaking.

Final Comments and Questions

EERE-2007-BT-STD-0010 COMMENT 21.3
158 | Residential Clothes Dryer and Room Air Conditioner Energy Conservation Standards 

• Public Meeting – Oral comments will be captured in the transcript an

become part of the public record.

• Written comments – Preliminary Activities and Analyses comment p

open until April 26, 2010. Reference docket #: EERE-2007-BT-STDand/or RIN #: 1904–AA89.

Email: home_appliance2.rulemaking@ee.doe.govMail: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program, Mail stop EE-2JPublic Meeting for Residential Clothes Dryers and RConditionersEE-2007-STD-00101000 Independence Avenue, SW.Washington DC, 20585-0121

Courier: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L’Enfant Plaza, SW., Suite 600Washington, DC, 20024

How to Submit Comments...

EERE-2007-BT-STD-0010 COMMENT 21.3