EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 INTRODUCTION ...............................................................................................................1

ES.2 SUMMARY OF RULEMAKING PROCESS.....................................................................1

ES.3 PRELIMINARY ACTIVITIES ...........................................................................................1

ES.4 KEY ANALYSES AND RESULTS ...................................................................................2

ES.4.1 Market and Technology Assessment ...................................................................................2

ES.4.2 Screening Analysis...............................................................................................................3

ES.4.3 Engineering Analysis...........................................................................................................3

ES.4.3.1 Product Classes Analyzed................................................................................. 4

ES.4.3.2 Efficiency Levels Defined ................................................................................ 4

ES.4.3.3 Manufacturer Costs and Selling Prices............................................................. 5

ES.4.4 Markups to Determine Product Price...................................................................................6

ES.4.5 Energy and Water Use Characterization..............................................................................7

ES.4.6 Life-Cycle Cost and Payback Period Analysis..................................................................11

ES.4.7 Shipments Analysis............................................................................................................16

ES.4.8 National Impact Analysis...................................................................................................17

ES.4.8.1 Efficiency Trend ............................................................................................. 17

ES.4.8.2 National Energy Savings................................................................................. 21

ES.4.8.3 Net Present Value ........................................................................................... 22

ES.4.9 Preliminary Manufacturer Impact Analysis.......................................................................23

ES.5 ISSUES ON WHICH THE DEPARTMENT SEEKS PUBLIC COMMENT ..................24

ES.5.1 Portable Dehumidifier Product Classes.............................................................................24

ES.5.2 Design Options Not Measurable by the Current Dehumidifier Test Procedure ................24

ES.5.3 Energy Use Determination for Portable Dehumidifiers.....................................................24

ES.5.4 Commercial Use of Residential Portable Dehumidifiers...................................................25

ES-i
LIST OF TABLES

Table ES.4.1 Portable Dehumidifier Efficiency Levels at 80 °F....................................................5

Table ES.4.2 Portable Dehumidifier Efficiency Levels at 65 °F....................................................5

Table ES.4.3 Whole-Home Dehumidifier Efficiency Levels at 80 °F and 65 °F............................5

Table ES.4.4 Incremental Dehumidifier Manufacturing Costs .......................................................6

Table ES.4.1 Markups for Determining Dehumidifier Product Price .............................................7

Table ES.4.2 Portable Dehumidifiers ≤20.00 Pints/Day: Annual Energy Use by 

Efficiency Level.......................................................................................................9

Table ES.4.3 Portable Dehumidifiers 20.01–30.00 Pints/Day: Annual Energy Use by 

Efficiency Level.......................................................................................................9

Table ES.4.4 Portable Dehumidifiers 30.01–35.00 Pints/Day: Annual Energy Use by 

Efficiency Level.....................................................................................................10

Table ES.4.5 Portable Dehumidifiers 35.01–45.00 Pints/Day: Annual Energy Use by 

Efficiency Level.....................................................................................................10

Table ES.4.6 Portable Dehumidifiers >45 Pints/Day: Annual Energy Use by Efficiency 

Level ......................................................................................................................10

Table ES.4.7 Whole-Home Dehumidifiers ≤ 8.0 ft3 Case Volume: Annual Energy Use 

by Efficiency Level................................................................................................11

Table ES.4.8 Whole-Home Dehumidifiers >8.0 ft3 Case Volume: Annual Energy Use 

by Efficiency Level................................................................................................11

Table ES.4.9 Dehumidifiers ≤20.00 Pints/Day: LCC and PBP Results......................................13

Table ES.4.10 Dehumidifiers 20.01–30.00 Pints/Day: LCC and PBP Results.............................13

Table ES.4.11 Dehumidifiers 30.01–35.00 Pints/Day: LCC and PBP Results.............................14

Table ES.4.12 Dehumidifiers 35.01–45.00 Pints/Day: LCC and PBP Results.............................14

Table ES.4.13 Dehumidifiers >45.00 Pints/Day: LCC and PBP Results......................................15

Table ES.4.14 Dehumidifiers ≤8.0 ft3 Case Volume (Whole-Home): LCC and PBP 

Results....................................................................................................................15

Table ES.4.15 Dehumidifiers >8.0 ft3 Case Volume (Whole-Home): LCC and PBP 

Results....................................................................................................................16

Table ES.4.16 Portable Dehumidifiers ≤20.00 Pints/Day: Base- and Standards- Case 

Efficiency Distribution in 2019 .............................................................................18

Table ES.4.17 Portable Dehumidifiers 20.01–30.00 Pints/Day: Base- and StandardsCase Efficiency Distribution in 2019.....................................................................19

Table ES.4.18 Portable Dehumidifiers 30.01–35.00 Pints/Day: Base- and Standards-Case 

Efficiency Distribution in 2019 .............................................................................19

Table ES.4.19 Portable Dehumidifiers 35.01–45.00 Pints/Day: Base- and Standards-Case 

Efficiency Distributions in 2019............................................................................19

Table ES.4.20 Portable Dehumidifiers >45.00 Pints/Day: Base- and Standards-Case 

Efficiency Distributions in 2019............................................................................20

Table ES.4.21 Whole-Home Dehumidifiers ≤8.0 ft3 Case Volume: Base- and StandardsCase Efficiency Distributions in 2019 ...................................................................20

Table ES.4.22 Whole-Home Dehumidifiers >8.0 ft3 Case Volume: Base- and StandardsCase Efficiency Distributions in 2019 ...................................................................20

Table ES.4.23 Cumulative Primary National Energy Savings (Quads).......................................21

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Table ES.4.24 Cumulative NPV Results Based on 3-Percent Discount Rate (Billion 

2012$) ....................................................................................................................22

Table ES.4.25 Cumulative NPV Results Based on 7-Percent Discount Rate (Billion 

2012$) ....................................................................................................................23

LIST OF FIGURES

Figure ES.4.1 Dehumidifiers: Historical and Base-Case Shipments Forecast .............................17

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EXECUTIVE SUMMARY

ES.1 INTRODUCTION

This preliminary technical support document (TSD) describes in detail the approaches to 

and results of preliminary activities that DOE performed in investigating amended energy 

conservation standards for residential dehumidifiers. This executive summary summarizes 

DOE’s preliminary activities and results. Additionally, this executive summary delineates issues 

identified during the analyses about which DOE seeks comments from interested parties. Those 

issues are highlighted in the public meeting presentation and are discussed further in chapter 2 of 

the preliminary TSD.

ES.2 SUMMARY OF RULEMAKING PROCESS

Section 6295(o)(2)(A) of the Energy Policy and Conservation Act (EPCA), Pub. L. 94-

163, 42 U.S.C. 6291 et seq. requires the U.S. Department of Energy (DOE) to establish energy 

conservation standards that achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified. DOE establishes those standards via 

rulemakings for energy-consuming residential and commercial products. For each rulemaking, 

DOE typically first develops a framework document that describes the approaches and methods 

DOE will use in evaluating the need for new or amended standards. DOE then presents the initial 

analytical results in a preliminary technical support document (TSD) such as this one. DOE 

publishes in the Federal Register a notice that announces the date and place of a public meeting, 

as well as the availability of the preliminary TSD and presentation materials that interested 

parties may review before the meeting. The notice also highlights the major analyses DOE 

performed in the preliminary stage of the rulemaking. 

ES.3 PRELIMINARY ACTIVITIES

When evaluating or establishing energy conservation standards, DOE generally divides 

covered products into classes based on the type of energy used, by product capacity, or by 

another performance-related feature that affects efficiency. Different energy conservation 

standards may apply to different product classes. (42 U.S.C. 6295(q)) For residential 

dehumidifiers, EPCA to established the following product classes based on the capacity of the 

unit as measured in pints of water extracted per day, for dehumidifiers manufactured on or after 

October 1, 2012 (42 U.S.C. 6295(cc)(2)):

• Up to 35.00 pints/day;

• 35.01 to 45.00 pints/day;

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• 45.01 to 54.00 pints/day;

• 54.01 to 75.00 pints/day; and

• Greater than 75.00 pints /day.

In the framework document for this rulemaking, published on August 17, 2012, DOE 

identified two general types of residential dehumidifiers differentiated by primary installation 

configuration: portable and whole-home dehumidifiers. 77 FR 49739. Portable dehumidifiers are 

the most commonly sold in the United States and are typically used to reduce the relative 

humidity in one room or area of living space. Whole-home dehumidifiers are designed to be 

attached to ducting that supplies conditioned air to multiple or large living spaces. As a part of 

this standards analysis, DOE analyzed the current dehumidifier market to determine the proper 

product classes for both portable and whole-home dehumidifiers.

The CFR codifies the current procedures for testing the energy consumption of residential 

dehumidifiers. (10 CFR part 430, subpart B, appendix X (hereafter, appendix X)) DOE has 

initiated a separate rulemaking to amend those test procedures, and recently published a test 

procedure notice of proposed rulemaking (NOPR) (XXX Test Procedure NOPR), addressing a 

number of issues that emerged since the last test procedure final rule, published in the Federal 

Register on October 31, 2012. CITE.

Chapter 1 of this preliminary TSD summarizes DOE’s appliance standards program and 

how it applies to this rulemaking, and then outlines the structure of this document. Chapter 2 

summarizes the analytical framework for this rulemaking, the comments received in response to 

the framework document, and DOE’s responses to those comments. Subsequent chapters 

describe in detail the preliminary analyses performed for this stage of the rulemaking. 

Descriptions include inputs, sources, methods, and results. 

ES.4 KEY ANALYSES AND RESULTS 

The following sections summarize the key analyses DOE performed and the results 

obtained in developing this preliminary TSD. 

ES.4.1 Market and Technology Assessment 

When initiating an analysis of potential energy conservation standards for appliances, 

DOE obtains information on the present and past industry structure and market characteristics for 

the products concerned. DOE assesses industries and products both quantitatively and 

qualitatively, based on publicly available information. 

For this rulemaking, DOE addressed (1) manufacturer market share and characteristics, 

(2) existing regulatory and non-regulatory initiatives for improving product efficiency, and (3) 

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trends in product characteristics and retail markets. This data and resource material were used 

throughout the analysis.

DOE reviewed literature and interviewed manufacturers to develop an overall 

understanding of the residential dehumidifier industry in the United States. Industry publications, 

including trade journals, literature from manufacturers, government agencies, and trade 

organizations provided the bulk of the information, including (1) manufacturers and their market 

share; (2) shipments by product type; (3) product information; and (4) industry trends. Chapter 3 

of the preliminary TSD describes the market analysis and resulting information.

DOE typically uses information about existing and past technology options and working 

prototype designs to determine which technologies and combinations of technologies 

manufacturers use to attain higher performance levels. In consultation with interested parties, 

DOE develops a list of technologies to be considered. 

DOE developed a list of technologies for residential dehumidifiers from trade 

publications, technical papers, manufacturer literature, and through consultation with 

manufacturers of components and systems. Because existing products contain many technologies 

for improving product efficiency, product literature and direct examination provided additional 

information. 

ES.4.2 Screening Analysis

The screening analysis (chapter 4) examines whether technologies identified in the 

technology assessment (1) are technologically feasible; (2) are practicable to manufacture, 

install, and service; (3) have an adverse impact on product utility or availability; and/or (4) have 

adverse impacts on health and safety. DOE conducted this screening analysis in consultation 

with interested parties. In the subsequent engineering analysis, DOE further examined the 

technology options that it did not remove from consideration in the screening analysis.

ES.4.3 Engineering Analysis

The engineering analysis (chapter 5) establishes the relationship between the costs of 

manufacturing residential dehumidifiers and their efficiencies. These relationships serve as the 

basis for calculating costs and benefits of modified product designs for consumers, 

manufacturers, and the nation. Chapter 5 describes the product classes DOE analyzed, the 

representative baseline units (which are typically models which just meet existing Federal energy 

conservation standards), the efficiency levels DOE considered, the methodology DOE used to 

develop the manufacturing production cost model, and the cost-efficiency results.

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ES.4.3.1 Product Classes Analyzed

For this rulemaking analysis, DOE used the current product classes established by EISA 

2007 as the basis for the portable dehumidifier analysis, with the capacities adjusted for 

performance at representative ambient conditions under which dehumidifiers are typically 

operated as proposed in the XXX Test Procedure NOPR. CITE. During interviews conducted for 

this preliminary analysis, manufacturers informed DOE that certain installation locations may 

impose size constraints on whole-home dehumidifiers. To address this issue, DOE conducted its 

analysis on two whole-home dehumidifier product classes, separated based on case volume

measured in cubic feet (ft3). In summary, DOE considered the following dehumidifier product 

classes in this preliminary analysis:

• Portable, less than 20.00 pints/day;

• Portable, 20.01 to 30.00 pints/day;

• Portable, 30.01 to 35.00 pints/day;

• Portable, 35.01 to 45.00 pints/day;

• Portable, 45.01 or more pints /day;

• Whole-home, case volume less than 8.0 cubic feet; and

• Whole-home, case volume equal to or greater than 8.0 cubic feet.

ES.4.3.2 Efficiency Levels Defined

DOE based its preliminary analysis for residential dehumidifiers on the integrated energy 

factor (IEF) metric established in appendix X to incorporate standby and off mode energy 

consumption. DOE also considered the impacts to IEF associated with the amendments to 

appendix X proposed in the XXX Test Procedure NOPR. 

DOE analyzed the baseline units for each product class in the engineering analysis. DOE 

also analyzed several higher efficiency levels, including a maximum technologically feasible 

level, for each portable and whole-home product class, and obtained incremental cost data at 

each of these levels. Capacity and IEF were considered at both the 80 degrees Fahrenheit (°F)

ambient temperature currently specified in appendix X and the 65 °F ambient temperature

proposed in the XXX Test Procedure NOPR. 

Table ES.4.1 and Table ES.4.2 provide the efficiency levels at 80 °F and 65 °F for the portable

product classes under consideration. Table ES.4.3 provides the efficiency levels for the wholehome product classes under consideration. Chapter 5 includes additional details on these product 

classes and efficiency levels. 

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Table ES.4.1 Portable Dehumidifier Efficiency Levels at 80 °F

Efficiency 

Level

Integrated Energy Factor Efficiency Levels (L/kWh)

35.00 

pints/day or 

less

35.01–45.00 

pints/day

45.01–54.00 

pints/day

54.01–75.00 

pints/day

75.01 

pints/day or 

more

Baseline 1.05 1.16 1.29 1.35 2.44

1 1.50 1.50 1.60 1.70 2.80

2 1.70 1.70 1.85 1.85 3.50

3 1.85 1.85 1.95 1.95 4.2

4 1.93 1.93 2.06 2.06 N/A

Table ES.4.2 Portable Dehumidifier Efficiency Levels at 65 °F

Efficiency 

Level

Integrated Energy Factor Efficiency Levels (L/kWh)

20.00 

pints/day or 

less

20.01–30.00 

pints/day

30.01–35.00 

pints/day

35.01–45.00 

pints/day

45.01 

pints/day or 

more

Baseline 0.77 0.80 0.94 1.00 2.07

1 1.10 1.10 1.20 1.30 2.40

2 1.20 1.20 1.40 1.40 2.80

3 1.30 1.30 1.60 1.60 3.52

4 1.42 1.52 1.75 1.75 N/A

Table ES.4.3 Whole-Home Dehumidifier Efficiency Levels at 80 °F and 65 °F

Efficiency 

Level

IEF Efficiency Levels at 80 °F 

(L/kWh)

IEF Efficiency Levels at 65 °F 

(L/kWh)

Less than or 

equal to 8.0 ft3

(Case Volume)

Greater than 

8.0 ft3

(Case Volume)

Less than or 

equal to 8.0 ft3

(Case Volume)

Greater than 

8.0 ft3

(Case Volume)

Baseline 1.90 2.50 1.10 1.68

1 2.20 2.80 1.40 1.90

2 2.50 3.50 1.59 2.80

3 N/A 4.20 N/A 3.41

ES.4.3.3 Manufacturer Costs and Selling Prices

DOE typically uses data submitted by the Association of Home Appliance Manufacturers 

(AHAM) as the primary source of cost information for the engineering analysis. In the absence 

of aggregated incremental manufacturing cost data for dehumidifiers, however, DOE relied 

primarily on its detailed reverse-engineering analysis, consisting of disassembling representative 

units, analyzing the materials and manufacturing processes, analyzing the design approaches 

manufacturers use, and developing a spreadsheet model to ascribe costs to the various designs. 

ES-5
DOE also obtained input from interested parties on the manufacturing cost model inputs and 

results. Chapter 5 of the preliminary TSD includes information on the inputs used to determine 

the manufacturing cost, including material, labor, and overhead prices. Chapter 5 also includes 

information on the various components and features incorporated into designs for residential 

dehumidifiers, as well as certain design options that were retained in the screening analysis but

were not considered in the engineering analysis due to negligible energy savings potential or 

inability to be measured according to the current DOE dehumidifier test procedure.

DOE’s engineering analysis produced cost-efficiency curves for both portable and wholehome product classes. The cost-efficiency curves are described by the efficiency levels DOE 

analyzed and the increase in manufacturer production cost (MPC) required to improve a 

baseline-efficiency product to each of the considered efficiency levels. Table ES.4.4 presents the 

results of the engineering analysis for portable and whole-home residential dehumidifiers.

Table ES.4.4 Incremental Dehumidifier Manufacturing Costs 

ES.4.4 Markups to Determine Product Price

In chapter 6 of the preliminary TSD, DOE calculates the markups to manufacturer selling 

prices that occur throughout the distribution chains for portable and whole-home dehumidifiers, 

converting the estimates of manufacturer costs derived in the engineering analysis to consumer 

prices. In calculating markups, DOE identified the distribution channels for portable and wholehome dehumidifiers and the markup associated with each distribution channel. For portable 

dehumidifiers, DOE estimated markups taken by retailers and also included sales taxes. DOE 

developed separate retailer markups for baseline products (baseline markups) and for the 

incremental cost change due to more expensive, more efficient products (incremental markups). 

Error! Reference source not found. summarizes the markups DOE developed for both portable 

and whole-home dehumidifiers.

Portable Product Class Capacities

(pints/day at 80 °F and 65° F)

Whole-Home Product 

Class Case Volume (ft3)

Efficiency Level ≤ 35 35.01-45 45.01-54 54.01-75 > 75≤ 8.0 > 8.0

≤ 20 20.01-30 30.01-35 35.01-45 > 45

EL1 $- $- $- $- $38.40 $15.22 $6.14

EL2 $1.56 $1.85 $2.94 $1.98 $49.16 $76.18 $37.05

EL3 $4.64 $3.78 $8.72 $7.56 $100.13 $112.01

EL4 $7.77 $10.82 $13.40 $11.24

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Table ES.4.5 Markups for Determining Dehumidifier Product Price

Distribution 

Step

Portable Whole-Home

Replacement First Time Owner

Baseline Incremental Baseline Incremental Baseline Incremental

Manufacturer 1.43 1.43 1.43

Wholesaler -- -- 1.36 1.10 1.36 1.10

Mechanical 

contractor -- -- 1.53 1.22 1.45 1.15

General 

contractor -- -- -- -- 1.47 1.34

Retailer 1.36 1.11 -- -- -- --

Sales Tax 1.071 1.071 -- --

Overall 2.08 1.70 3.19 2.06 4.15 2.42

ES.4.5 Energy and Water Use Characterization

The energy use analysis estimates the energy savings from higher-efficiency appliances 

which are used in the life-cycle cost and subsequent analyses. The DOE test procedure provides 

standardized results that can serve as the basis for comparing the performance of various 

appliances operated under the same conditions. But because the range of energy consumption in 

the field may differ from energy use estimated by the test procedure, DOE also reviewed studies 

that measured the field usage of portable and whole-home dehumidifiers, confirming that field

usage can differ from the rated usage determined by the DOE test procedure.

DOE calculated the annual energy use for the seven product classes of dehumidifiers 

based on the mode of dehumidifier operation (e.g. dehumidification mode, fan-only mode, or 

standby mode), method of condensate removal, and space conditioning parameters. To calculate 

annual energy use, DOE used data from the Energy Information Administration (EIA) 2009 

Residential Energy Consumption Survey (RECS). DOE assumed an average of 5.2 months of 

annual usage for portable dehumidifiers and 5.6 months of annual usage for whole-home 

dehumidifiers. Efficiencies are given in terms of IEF, which divides the amount of condensate 

removed by the sum of energy use in dehumidification, fan-only, and combined low-power

(standby/off) modes.

To determine the variability of energy use by products that would meet possible energy 

efficiency standards, DOE used data from RECS, which is a nationwide survey of a sample of 

housing units that collects statistical information related to each household’s consumption of and 

expenditures for energy, including dehumidifier presence and the frequency with which it is 

used. RECS also collects data on the climate-related characteristics of the housing units, enabling 

DOE to estimate a household’s energy consumption attributable to the dehumidifier. RECS does 

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not, however, collect data regarding whether the dehumidifier is a portable or whole-home 

model. DOE separated the two dehumidifier types, portable and whole home, based on the 

presence of an air conditioner and an air handling duct system. More specifically, DOE assumed 

that households use whole-home dehumidifiers if they:

• are located in the Northeast, Midwest, or South Census regions;

• are located in the Building America Climate region categorized as “mixed humid”;

• are single-family homes, either attached or detached;

• have a central air conditioner; and

• have duct work.

Table ES.4.1 through Table ES.4.7 present the energy use estimated for each product 

class of dehumidifier at each efficiency level that DOE is considering. The portable product class 

capacities and IEF’s are based on the 65 °F ambient temperature proposed in the XXX Test 

Procedure NOPR. The tables show the energy consumption calculated based on the equation 

shown below.

( ) ( )



 





+ × + × 















×

× × ×



 



 = Fan Fan Stby Stby

Dehum

ENERGY X kW X kW

Eff

CAP X

Year

TotalHoursofUse DEH

24

0.473

Eq. 1

Where:

DEHENERGY = annual energy consumption of dehumidifier (kWh/year),

Year

TotalHoursofUse = number of hours the dehumidifier is used per year (at >0 W),

CAP = dehumidifier capacity (pints of condensate removed/day),

0.473 = conversion factor for liters in a pint,

24 = number of hours in a day

Eff = dehumidifier efficiency (liters of condensate removed/kWhdehum),

XDehum = fraction of time in dehumidification mode,

XFan = fraction of time in fan-only mode,

XStby = fraction of time in standby/off mode,

kWDehum= kW of dehumidification mode,

kWFan = kW of fan-only mode, and

kWStby = kW of standby/off mode.

Note:

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24

0.473

×

× ×

Eff

Cap X Dehum = XDehum × kWDehum Eq. 2

Table ES.4.6 Portable Dehumidifiers ≤20.00 Pints/Day: Annual Energy Use by Efficiency 

Level

Level Integrated Energy Factor 

(L/kWh)

Annual Energy Use* 

(kWh/year)

Baseline 0.77 632.9

1 1.10 448.5

2 1.20 412.6

3 1.30 382.3

4 1.42 351.5

* Capacity = 17.9 pints/day; annual usage = 3,799 hours; XDehum = 35.3%; XFan

= 6.5%; XStby = 58.2%, WFan = 65 W; WStby = 1 W.

Table ES.4.7 Portable Dehumidifiers 20.01–30.00 Pints/Day: Annual Energy Use by 

Efficiency Level

Level Integrated Energy Factor

(L/kWh)

Annual Energy Use*

(kWh/year)

Baseline 0.80 844.5

1 1.10 619.2

2 1.20 569.1

3 1.30 526.7

4 1.52 453.1

* Capacity = 25 pints/day; annual usage = 3,799 hours; XDehum = 35.3%; XFan = 

6.5%; XStby = 58.2%, WFan = 65 W; WStby = 1 W.

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Table ES.4.8 Portable Dehumidifiers 30.01–35.00 Pints/Day: Annual Energy Use by 

Efficiency Level

Level Integrated Energy Factor

(L/kWh)

Annual Energy Use*

(kWh/year)

Baseline 0.94 932.5

1 1.20 734.4

2 1.40 632.1

3 1.60 555.3

4 1.75 509.3

* Capacity = 32.5 pints/day; annual usage = 3,799 hours; XDehum = 35.3%; XFan = 

6.5%; XStby = 58.2%, WFan = 65 W; WStby = 1 W.

Table ES.4.9 Portable Dehumidifiers 35.01–45.00 Pints/Day: Annual Energy Use by 

Efficiency Level

Level Integrated Energy Factor

(L/kWh)

Annual Energy Use*

(kWh/year)

Baseline 1.00 1075.9

1 1.30 831.8

2 1.40 773.7

3 1.60 679.3

4 1.75 622.6

* Capacity = 40 pints/day; annual usage = 3,799 hours; XDehum = 35.3%; XFan = 

6.5%; XStby = 58.2%, WFan = 65 W; WStby = 1 W.

Table ES.4.10Portable Dehumidifiers >45 Pints/Day: Annual Energy Use by Efficiency 

Level

Level Integrated Energy Factor

(L/kWh)

Annual Energy Use*

(kWh/year)

Baseline 2.07 944.3

1 2.40 817.0

2 2.80 702.9

3 3.52 562.8

* Capacity = 72.5 pints/day; annual usage = 3,799 hours; XDehum = 35.3%; XFan = 

6.5%; XStby = 58.2%, WFan = 65 W; Wstby = 1 W.

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Table ES.4.11Whole-Home Dehumidifiers ≤ 8.0 ft3 Case Volume: Annual Energy Use by 

Efficiency Level

Level Integrated Energy Factor

(L/kWh)

Annual Energy Use*

(kWh/year)

Baseline 1.10 1250.3

1 1.40 994.3

2 1.59 882.1

* Capacity = 56.2 pints/day; annual usage = 4,091 hours; XDehum = 29%; XFan

=8%; XStby = 63%; WFan = 146 W; WStby = 3.08 W.

Table ES.4.12Whole-Home Dehumidifiers >8.0 ft3 Case Volume: Annual Energy Use by 

Efficiency Level

Level Integrated Energy Factor

(L/kWh)

Annual Energy Use*

(kWh/year)

Baseline 1.68 1331.9

1 1.90 1184.1

2 2.80 821.4

3 3.41 684.5

* Capacity = 91.7 pints/day; annual usage = 4,091 hours; XDehum = 29%; XFan

=8%; XStby = 63%; WFan = 146 W; WStby = 3.08 W.

ES.4.6 Life-Cycle Cost and Payback Period Analysis

Energy conservation standards produce a change in consumer operating costs—usually a 

decrease—and a change in product purchase price—usually an increase. DOE analyzed the net 

financial effect on consumers of amended standards for dehumidifiers by evaluating the LCC of 

the products (chapter 8). In performing this analysis, DOE used the cost-efficiency relationship 

derived from the engineering analysis, along with the energy costs derived from the energy use 

characterization. Because the operating costs of a more expensive, higher-efficiency product 

decrease in response to new standards, at some time in the life of that product the net savings in 

operating costs since the time of purchase equal the increase in the purchase price of the product. 

The time required for a product to reach that cost-equivalency point is known as the payback 

period (PBP).

DOE identified several inputs for estimating the LCC and PBP, including retail prices 

and installed costs, energy prices, discount rates, and product lifetimes. For dehumidifiers, there 

was no information that indicated that more efficient dehumidifiers would have greater repair or 

maintenance costs, so DOE did not assume additional costs would occur. The LCC and PBP 

analysis utilized values that reflect unit energy consumption in the field. DOE used EIA’s energy 

price data to determine the range and variability of prices for electricity in 2012, then used 

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projections of the prices from EIA’s Annual Energy Outlook 2013 to estimate future electricity 

prices. DOE developed discount rates by estimating the finance cost for consumers to purchase 

major appliances.

For portable dehumidifiers, DOE considered multiple sources to estimate product 

lifetime: Appliance Magazine, American Council for an Energy-Efficient Economy, and the 

Northeast Energy Star Lighting and Appliance. Because of the similarity in operation and based 

on available data, DOE assumed whole-home dehumidifiers have the same life span as 

residential room air conditioner and applied the lifetime parameters derived for room air 

conditioners to whole-home dehumidifiers. 

To estimate accurately the percentage of consumers who would be affected by a standard 

at each candidate standard level (CSL) of efficiency, the LCC analysis considered the projected 

distribution of efficiencies for the product classes of dehumidifiers purchased under the base case 

(the case without new energy efficiency standards). Lacking industry-supplied data, the 

distributions were developed from models and efficiencies listed in publically available 

databases. DOE projected the base-case distributions to the year that compliance with any 

amended standards would be required (2019). Using the projected distribution of efficiencies for 

each product class, DOE assigned a specific product efficiency to each sample household. If a 

household was assigned a product efficiency that equaled or exceeded the efficiency of the CSL 

under consideration, the LCC calculation shows that the household would be unaffected by that 

standard level. 

Error! Reference source not found. through Error! Reference source not found.

show the LCC and PBP results by efficiency level for each dehumidifier product class. The 

portable product class capacities and IEF’s are based on the 65 °F ambient temperature proposed 

in the XXX Test Procedure NOPR. DOE determined the median values for the PBPs by 

excluding those users not affected by the standard. Figures presented in chapter 8 show the range 

of LCC savings and PBPs for all of the efficiency levels considered for each product class.

ES-12
Table ES.4.13Dehumidifiers ≤20.00 Pints/Day: LCC and PBP Results

EL IEF* 

(L/kWh)

Life-Cycle Cost (2012$) Life-Cycle Cost Savings Median 

Payback 

Period 

(Years)

Average 

Installed 

Cost

Average 

Lifetime 

Operating 

Cost†

Average 

LCC

Average 

Savings 

(2012$)

% Users Having

Net

Cost

No 

Impact

Net 

Benefit

Baseline 0.77 $219 $698 $917

1 1.10 $219 $490 $709 $129 0% 38% 62% 0.0

2 1.20 $221 $450 $671 $167 0% 32% 68% 0.1

3 1.30 $227 $415 $642 $186 0% 32% 68% 0.3

4 1.42 $232 $381 $612 $294 0% 3% 97% 0.4

* IEF = Integrated energy factor.

† Discounted.

Table ES.4.14Dehumidifiers 20.01–30.00 Pints/Day: LCC and PBP Results

EL IEF* 

(L/kWh)

Life-Cycle Cost (2012$) Life-Cycle Cost Savings Median 

Payback 

Period 

(Years)

Average 

Installed 

Cost

Average

Lifetime 

Operating 

Cost†

Average 

LCC

Average 

Savings 

(2012$)

% Users Having

Net

Cost

No 

Impact

Net 

Benefit

Baseline 0.80 $231 $937 $1,168

1 1.10 $231 $683 $914 $0.00 0% 100% 0% NA

2 1.20 $234 $626 $860 $145 0% 53% 47% 0.1

3 1.30 $237 $578 $816 $235 0% 33% 67% 0.2

4 1.52 $249 $495 $744 $398 0% 6% 94% 0.4

* IEF = Integrated energy factor.

† Discounted.

ES-13
Table ES.4.15Dehumidifiers 30.01–35.00 Pints/Day: LCC and PBP Results

EL IEF* 

(L/kWh)

Life-Cycle Cost (2012$) Life-Cycle Cost Savings Median 

Payback 

Period 

(Years)

Average 

Installed 

Cost

Average

Lifetime 

Operating 

Cost†

Average 

LCC

Average 

Savings 

(2012$)

% Users Having

Net

Cost

No 

Impact

Net 

Benefit

Baseline 0.94 $260 $1,037 $1,297

1 1.20 $260 $813 $1,073 $0.00 0% 100% 0% NA

2 1.40 $265 $697 $963 $164 0% 51% 49% 0.2

3 1.60 $275 $611 $886 $399 0% 3% 97% 0.4

4 1.75 $283 $559 $841 $441 0% 3% 97% 0.5

* IEF = Integrated energy factor.

† Discounted.

Table ES.4.16Dehumidifiers 35.01–45.00 Pints/Day: LCC and PBP Results

EL IEF* 

(L/kWh)

Life-Cycle Cost (2012$) Life-Cycle Cost Savings Median 

Payback 

Period 

(Years)

Average 

Installed 

Cost

Average

Lifetime 

Operating 

Cost†

Average 

LCC

Average 

Savings 

(2012$)

% Users Having

Net

Cost

No 

Impact

Net 

Benefit

Baseline 1.00 $281 $1,199 $1,480

1 1.30 $281 $923 $1,204 $0.00 0% 100% 0% NA

2 1.40 $284 $857 $1,142 $119 0% 66% 34% 0.1

3 1.60 $294 $751 $1,044 $412 0% 5% 95% 0.3

4 1.75 $300 $687 $987 $472 0% 4% 96% 0.4

* IEF = Integrated energy factor.

† Discounted.

ES-14
Table ES.4.17Dehumidifiers >45.00 Pints/Day: LCC and PBP Results

EL IEF* 

(L/kWh)

Life-Cycle Cost (2012$) Life-Cycle Cost Savings Median 

Payback 

Period 

(Years)

Average 

Installed 

Cost

Average

Lifetime 

Operating 

Cost†

Average 

LCC

Average 

Savings 

(2012$)

% Users Having

Net

Cost

No 

Impact

Net 

Benefit

Baseline 2.07 $874 $1,050 $1,924

1 2.40 $939 $906 $1,845 $31 12% 61% 27% 4.6

2 2.80 $957 $777 $1,734 $128 12% 32% 56% 3.2

3 3.52 $1,043 $619 $1,662 $218 22% 16% 62% 4.1

* IEF = Integrated energy factor.

† Discounted.

Table ES.4.18Dehumidifiers ≤8.0 ft3 Case Volume (Whole-Home): LCC and PBP Results

EL IEF* 

(L/kWh)

Life-Cycle Cost (2012$) Life-Cycle Cost Savings Median 

Payback 

Period 

(Years)

Average 

Installed 

Cost

Average

Lifetime 

Operating 

Cost†

Average 

LCC

Average 

Savings 

(2012$)

% Users Having

Net

Cost

No 

Impact

Net 

Benefit

Baseline 1.00 $1,614 $1,988 $3,602

1 1.40 $1,640 $1,586 $3,226 $192 2% 75% 23% 1.2

2 1.59 $1,747 $1,409 $3,156 $192 10% 56% 34% 4.2

* IEF = Integrated energy factor.

† Discounted.

ES-15
Table ES.4.19Dehumidifiers >8.0 ft3 Case Volume (Whole-Home): LCC and PBP Results

EL IEF* 

(L/kWh)

Life-Cycle Cost (2012$) Life-Cycle Cost Savings Median 

Payback 

Period 

(Years)

Average 

Installed 

Cost

Average

Lifetime 

Operating 

Cost†

Average 

LCC

Average 

Savings 

(2012$)

% Users Having

Net

Cost

No 

Impact

Net 

Benefit

Baseline 1.68 $1,988 $2,117 $4,105

1 1.90 $1,999 $1,884 $3,883 $56 1% 74% 24% 0.8

2 2.80 $2,052 $1,314 $3,366 $602 7% 19% 73% 1.4

3 3.41 $2,183 $1,099 $3,282 $823 20% 0% 80% 3.4

* IEF = Integrated energy factor.

† Discounted.

ES.4.7 Shipments Analysis

DOE requires shipment forecasts to calculate the national impacts of potential standards 

on energy use, net present value (NPV) of costs and savings, as well as to the manufacturer 

impact analysis. DOE’s shipments model for dehumidifiers considers shipments to replace 

existing units and to first time owners (FTO). DOE used an accounting method that tracks the 

total stock of units by vintage to determine shipments to the replacement market. DOE estimated 

a stock of dehumidifiers by vintage by integrating historical shipments starting from 1972. To 

calibrate the estimated shipments with the historical data, DOE introduced into the model a 

market segment identified as existing households without dehumidifiers, also referred to as 

FTOs. DOE estimated that 0.34 percent of existing households without a dehumidifier would 

annually purchase this product over the period 2019─2048. Chapter 9 of this preliminary TSD 

provides additional details on the shipments analysis.

Error! Reference source not found.shows the forecasted shipments in the base case 

(i.e., the case without new energy efficiency standards) and the historical shipments DOE used to 

calibrate the forecast. 

ES-16
Figure ES.4.1 Dehumidifiers: Historical and Base-Case Shipments Forecast

ES.4.8 National Impact Analysis

The national impact analysis (NIA) estimates impacts on the nation of potential new 

energy efficiency standards for dehumidifiers. Those impacts encompass: 

1. national energy savings (NES) attributable to standards for the considered product 

classes;

2. the monetary value of energy savings attributable to standards for the considered 

product classes;

3. the increased total installed costs attributable to standards for the considered product 

classes; and 

4. the NPV of the energy savings attributable to standards for the considered product 

classes (the difference between the value of the energy savings and the total installed 

costs). 

ES.4.8.1 Efficiency Trend

A key component of DOE’s NIA is the equipment energy efficiencies forecasted over 

time for the base case and for each of the standards cases. For the base case, DOE assumed an 

annual growth rate of 0.25 percent between 2019 and 2048.

0.0000

0.5000

1.0000

1.5000

2.0000

2.5000

3.0000

3.5000

Shipments (million)

Year

Shipment - Historical and Projected

Historical

Projected

ES-17
For its projected efficiencies of CSLs, in addition to a “roll-up” scenario, DOE developed 

a shift scenario. In the shift scenario DOE applies an annual growth rate in average energy 

efficiency to the shipment-weighted integrated energy factors (SWIEF), as it is done in the base 

case. To develop standards case forecasted SWIEFs, DOE developed growth trends for each 

candidate standard level that maintained the same per-unit average total installed cost difference for 

the year 2019 between the base case and each standards case over the entire forecast period (2019–

2048). DOE’s approach for developing standards case SWIEFs in this manner assumes that the rate 

of adoption of more efficient products under the standards case can occur only at a rate which 

ensures that the average total installed cost difference between the standards case and base case over 

the entire forecast period is held constant. Because the total installed cost versus efficiency 

relationship for each product class demonstrates an increasing cost rate for more efficient products, 

the SWIEF growth rate for each standards case is lower than the SWIEF growth rate for the base 

case.

Error! Reference source not found. through Error! Reference source not found.

show the base-case and CSL product efficiency distributions in 2019, based on the IEF for each 

of the seven product classes that DOE is considering. The portable product class capacities and 

IEF’s are based on the 65 °F ambient temperature proposed in the XXX Test Procedure NOPR. 

The CSLs are composed of efficiency levels analyzed in the life-cycle cost and payback period 

analysis (chapter 8). Also included in the tables are the weighted integrated energy factors 

(SWIEFs) and weighted annual energy use (SWAEU) associated with the base case and each 

CSL.

Table ES.4.20 Portable Dehumidifiers ≤20.00 Pints/Day: Base- and Standards- Case 

Efficiency Distribution in 2019

EL CSL

IEF

Market Shares (%)

Base 

Case

Candidate Standard Level

(L/kWh) 1 2 3 4

Baseline - 0.77 62% 0% 0% 0% 0%

1 1 1.10 6% 68% 0% 0% 0%

2 2 1.20 0% 0% 68% 0% 0%

3 3 1.30 29% 29% 29% 97% 0%

4 4 1.42 3% 3% 3% 3% 100%

SWIEF (L/kWh) 0.96 1.17 1.24 1.30 1.42

SWAEU (kWh/yr) 517 405 381 360 331

ES-18
Table ES.4.21 Portable Dehumidifiers 20.01–30.00 Pints/Day: Base- and Standards- Case 

Efficiency Distribution in 2019

EL CSL IEF

(L/kWh)

Market Share (%)

Base 

Case

Candidate Standard Level

1 2 3 4

Baseline - 0.80 0% 0% 0% 0% 0%

1 1 1.10 47% 47% 0% 0% 0%

2 2 1.20 21% 21% 68% 0% 0%

3 3 1.30 27% 27% 27% 94% 0%

4 4 1.52 6% 6% 6% 6% 100%

SWIEF (L/kWh) 1.20 1.20 1.24 1.31 1.52

SWAEU (kWh/yr) 550 550 527 499 431

Table ES.4.22 Portable Dehumidifiers 30.01–35.00 Pints/Day: Base- and Standards-Case 

Efficiency Distribution in 2019

EL CSL IEF

(L/kWh)

Market Share (%)

Base 

Case

Candidate Standard Level

1 2 3 4

Baseline - 0.94 0% 0% 0% 0% 0%

1 1 1.20 49% 49% 0% 0% 0%

2 2 1.40 48% 48% 97% 0% 0%

3 3 1.60 0% 0% 0% 97% 0%

4 4 1.75 3% 3% 3% 3% 100%

SWIEF (L/kWh) 1.31 1.31 1.41 1.60 1.75

SWAEU (kWh/yr) 653 653 603 530 486

Table ES.4.23 Portable Dehumidifiers 35.01–45.00 Pints/Day: Base- and Standards-Case 

Efficiency Distributions in 2019

EL CSL IEF

(L/kWh)

Market Share (%)

Base 

Case

Candidate l Standard Level

1 2 3 4

Baseline - 1.00 0% 0% 0% 0% 0%

1 1 1.30 34% 34% 0% 0% 0%

2 2 1.40 61% 61% 95% 0% 0%

3 3 1.60 1% 1% 1% 96% 0%

4 4 1.75 4% 4% 4% 4% 100%

SWIEF (L/kWh) 1.38 1.38 1.42 1.61 1.75

SWAEU (kWh/yr) 758 758 739 651 597

ES-19
Table ES.4.24 Portable Dehumidifiers >45.00 Pints/Day: Base- and Standards-Case 

Efficiency Distributions in 2019

EL CSL IEF

(L/kWh)

Market Share (%)

Base 

Case

Candidate Standard Level

1 2 3 4

Baseline - 2.07 39% 0% 0% 0% 0%

1 1 2.40 29% 68% 0% 0% 0%

2 2, 3 2.80 16% 16% 84% 84% 0%

3 4 3.52 16% 16% 16% 16% 100%

SWIEF (L/kWh) 2.52 2.64 2.92 2.92 3.52

SWAEU (kWh/yr) 933 958 971 971 1,043

Table ES.4.25 Whole-Home Dehumidifiers ≤8.0 ft3 Case Volume: Base- and StandardsCase Efficiency Distributions in 2019

EL CSL IEF

(L/kWh)

Market Share (%)

Base Case

Candidate Standard Level

1 2 3 4

Baseline - 1.10 25% 0% 0% 0% 0%

1 1, 2, 

3 1.40 19% 44% 44% 44% 0%

2 4 1.59 56% 56% 56% 56% 100%

SWIEF (L/kWh) 1.43 1.51 1.51 1.51 1.59

SWAEU (kWh/yr) 1,131 1,137 1,137 1,137 1,185

Table ES.4.26 Whole-Home Dehumidifiers >8.0 ft3 Case Volume: Base- and StandardsCase Efficiency Distributions in 2019

EL CSL IEF

(L/kWh)

Market Share (%)

Base 

Case

Candidate Standard Level

1 2 3 4

Baseline - 1.68 22% 0% 0% 0% 0%

1 1 1.90 46% 68% 0% 0% 0%

2 2, 3 2.80 16% 16% 84% 84% 0%

3 4 3.41 16% 16% 16% 16% 100%

SWIEF (L/kWh) 2.24 2.29 2.90 2.90 3.41

SWAEU (kWh/yr) 1,472 1,475 1,511 1,511 1,621

ES-20
Based on the assumption of a zero-percent growth rate in the efficiencies for the base 

case and all potential standards cases, DOE maintained the SWIEFs shown in Error! Reference 

source not found. through Error! Reference source not found.throughout the projection 

period, from 2019 to 2048. 

ES.4.8.2 National Energy Savings 

DOE calculated annual national energy savings as the difference between national energy 

consumption in the base case (without new efficiency standards) and under each CSL. DOE 

estimated energy consumption and savings based on site energy, which is the energy consumed 

by a household. DOE then converted site energy consumption and savings to the primary energy 

consumed at power stations to provide the site electricity. Cumulative energy savings are the 

sum of the annual NES. 

The NES results, shown in Error! Reference source not found., are cumulative over the 

period in which units shipped in 2019-2048 are operating. The energy savings are given in 

quadrillion British thermal units (quads) and are shown as primary energy savings. The portable 

product class capacities are based on the 65 °F ambient temperature proposed in the XXX Test 

Procedure NOPR.

Table ES.4.27 Cumulative Primary National Energy Savings (Quads)

CSL ≤20.00 

Pints/Day

20.01-

30.00 

Pints/Day

30.01-

35.00 

Pints/Day

35.01-

45.00

Pints/Day

>45.00 

Pints/Day

≤8.0 ft3

Case 

Volume 

(WholeHome)

>8.0 ft3

Case 

Volume 

(Wholehome)

All

1 0.20 0.01 0.01 0.00 0.02 0.00 0.00 0.23

2 0.22 0.03 0.04 0.02 0.03 0.00 0.00 0.34

3 0.26 0.06 0.14 0.14 0.03 0.00 0.00 0.63

4 0.32 0.15 0.19 0.19 0.04 0.00 0.01 0.89

On August 18, 2011, DOE published a statement of policy in the Federal Register 

announcing its intention to use full-fuel-cycle (FFC) measures of energy use and greenhouse gas 

and other emissions in the national impact analyses and emissions analyses included in future 

energy conservation standards rulemakings. 76 FR 51281; amended by 77 FR 49701 (August 17, 

2012). Table ES.4.24 summarizes the full-fuel cycle national energy savings..

ES-21
Tale ES.4.24 Full-Fuel-Cycle National Energy Savings (Unit: Quads)

CSL ≤20.00 

Pints/Day

20.01-

30.00 

Pints/Day

30.01-

35.00 

Pints/Day

35.01-

45.00 

Pints/Day

>45.00 

Pints/Day

≤8.0 ft3

Case 

Volume 

(WholeHome)

>8.0 ft3

Case 

Volume 

(Wholehome)

All

1 0.20 0.01 0.01 0.00 0.02 0.00 0.00 0.23

2 0.22 0.03 0.05 0.02 0.03 0.00 0.00 0.35

3 0.26 0.06 0.14 0.14 0.03 0.00 0.00 0.64

4 0.32 0.15 0.19 0.19 0.04 0.00 0.01 0.91

ES.4.8.3 Net Present Value 

DOE calculated net monetary savings for consumers in each year after amended

standards would take effect for the base case and each standards case as the difference between 

total savings in operating costs and increases in total installed cost. DOE calculated savings 

throughout the lifetime of products shipped in 2019-2048. DOE used discount rates of 7 percent 

and 3 percent, respectively, to discount future costs and savings to the present. DOE calculated 

the NPV as the difference between the present value of operating cost savings and the present 

value of total installed costs. The NPV results for the seven product classes of dehumidifiers are 

shown in Error! Reference source not found. and Error! Reference source not found.. As 

with the NES results, NPV results are presented as a function of the CSL combination. The 

portable product class capacities are based on the 65 °F ambient temperature proposed in the 

XXX Test Procedure NOPR.

Table ES.4.28 Cumulative NPV Results Based on 3-Percent Discount Rate (Billion 2012$)

CSL ≤20.00 

Pints/Day

20.01-30.00 

Pints/Day

30.01-

35.00 

Pints/Day

35.01-

45.00

Pints/Day

>45.00 

Pints/Day

≤8.0 ft3

Case 

Volume 

(WholeHome)

>8.0 ft3

Case 

Volume 

(WholeHome)

All

1 1.42 0.04 0.04 0.00 0.12 0.01 0.01 1.64

2 1.59 0.22 0.32 0.12 0.14 0.01 0.02 2.43

3 1.84 0.40 0.96 0.94 0.14 0.01 0.02 4.31

4 2.20 0.98 1.29 1.27 0.23 0.01 0.03 6.01

ES-22
Table ES.4.29 Cumulative NPV Results Based on 7-Percent Discount Rate (Billion 2012$)

CSL ≤20.00 

Pints/Day

20.01-30.00 

Pints/Day

30.01-

35.00 

Pints/Day

35.01-

45.00

Pints/Day

>45.00 

Pints/Day

≤8.0 ft3

Case 

Volume 

(WholeHome)

>8.0 ft3

Case 

Volume 

(WholeHome)

All

1 0.61 0.02 0.02 0.00 0.05 0.00 0.00 0.70

2 0.68 0.09 0.14 0.05 0.06 0.00 0.01 1.04

3 0.78 0.17 0.40 0.38 0.06 0.00 0.01 1.80

4 0.92 0.41 0.54 0.54 0.09 0.00 0.01 2.51

ES.4.9 Preliminary Manufacturer Impact Analysis

The preliminary manufacturer impact analysis (MIA) focuses on manufacturers of 

residential dehumidifiers. Potential impacts include financial effects, both quantitative and 

qualitative, that might result from new energy conservation standards and consequently lead to 

changes in manufacturing practices for residential dehumidifiers. DOE identified potential 

impacts through interviews with manufacturers and other interested parties. Chapter 12 of the 

preliminary TSD includes details on the key issues DOE identified during the preliminary MIA.

DOE identified the following key issues for residential dehumidifiers:

• Impact on profitability, product mix, and shipments

• Market share and industry consolidation

• Conversion costs, manufacturing capacity, and employment levels

• Impact on innovation and product utility

• Cumulative regulatory burden

• Impact on small manufacturers

• Impact on product mix

During the preliminary analysis stage, DOE conducted the preliminary MIA by first 

identifying products, methods, and practices used in the residential dehumidifier industry. Next, 

DOE determined how energy efficiency improvements affect cost, production, and various other 

manufacturing metrics. Finally, DOE interviewed manufacturers for feedback. At the beginning 

of the interview process, DOE interviewed manufacturers and adjusted the analysis as 

appropriate, based on the feedback. In the interviews, DOE also examined any additional effects 

on competition, manufacturing capacity, direct employment, and the cumulative burden of other 

regulations affecting manufacturers, as well as several issues raised by individual manufacturers.

ES-23
ES.5 ISSUES ON WHICH THE DEPARTMENT SEEKS PUBLIC COMMENT 

DOE is interested in receiving comments from interested parties on all aspects of this 

preliminary TSD, especially comments or data that might improve DOE’s analyses. DOE 

welcomes data or information that will help resolve the following specific issues, which were 

raised in response to the framework document and during preparation of this preliminary TSD.

ES.5.1 Portable Dehumidifier Product Classes

Several interested parties recommended that DOE consolidate portable dehumidifiers into 

fewer product classes, potentially as few as a single product class. Interested parties also 

recommended that DOE consider an equation-based energy conservation standard for 

dehumidifiers. In this preliminary analysis, DOE maintained the existing portable dehumidifier 

product classes and adjusted the capacities to reflect the proposed lower ambient temperature for 

testing because it did not find an inherent single relationship between product capacity and 

energy efficiency. DOE observed that chassis size availability, among other features, impacts the 

ability of different manufacturers to achieve certain energy efficiencies for their products at 

different capacities. DOE welcomes comment on this decision, and seeks further information on 

portable dehumidifier product classes.

ES.5.2 Design Options Not Measurable by the Current Dehumidifier Test Procedure

As discussed further in chapter 5 of the preliminary TSD, the current DOE dehumidifier 

test procedure measures active mode energy use under continuous unit operation at constant 

ambient conditions. Therefore, it does not capture energy savings that may be achieved using 

design options that improve efficiency in varying conditions (i.e., electronic humidistats, 

improved controls, improved flow-control devices, and variable speed compressors). DOE also 

concluded that the ambient conditions in the test procedure preclude heat exchanger coil frosting 

that would be necessary to realize the benefits of improved defrost methods and improved 

demand-defrost controls. DOE requests comment on whether these design options should be 

considered further, and if so, how the test procedure should account for them.

ES.5.3 Energy Use Determination for Portable Dehumidifiers

DOE reviewed existing and new literature, including the two studies mentioned by the 

Joint Commenters, to establish a range of energy use for dehumidifiers. A newly published field 

metering study for portable dehumidifiers linked outdoor absolute humidity to indoor air 

conditions and dehumidifier compressor use.a The study found that dehumidifier use was 

influenced by whether the basement was finished and the type of dehumidifier condensate 

removal. DOE based its energy use analysis on the equations used to model the relationship 

a Willem, Henry, et al. 2013. Using Field-Metered Data to Quantify Annual Energy Use of Residential Portable Unit 

Dehumidifier. Lawrence Berkeley National Laboratory. LBNL-6975E. 

ES-24

 
between vapor density and compressor use developed from the field metering study. It found that 

the energy use values were within the range of the values used in the 2007 rulemaking. DOE 

requests input on its proposed method for energy use determination.

ES.5.4 Commercial Use of Residential Portable Dehumidifiers

DOE reviewed existing data and literature and found no information on shipments to or 

energy use of residential portable dehumidifiers in commercial enterprises. DOE requests 

stakeholder data and literature to characterize saturation of and energy use by residential portable 

dehumidifiers in commercial settings.

ES-25