[6450-01-P] 

DEPARTMENT OF ENERGY 

10 CFR Part 430 

[Docket Number EERE–2008–BT–STD–0005] 

RIN: 1904–AB57 

Energy Conservation Program: Energy Conservation Standards for Battery Chargers and 

External Power Supplies 

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy. 

ACTION: Notice of proposed rulemaking (NOPR) and public meeting. 

SUMMARY: The Energy Policy and Conservation Act (EPCA) prescribes energy conservation 

standards for various consumer products and commercial and industrial equipment, including 

battery chargers and external power supplies (EPSs). EPCA also requires the U.S. Department of 

Energy (DOE) to determine whether more stringent, amended standards for these products are 

technologically feasible, economically justified, and would save a significant amount of energy. 

In this notice, DOE proposes amended energy conservation standards for Class A EPSs and new 

energy conservation standards for non-Class A EPSs and battery chargers. The notice also 

announces a public meeting to receive comment on these proposed standards and associated 

analyses and results. 

1 
DATES: DOE will hold a public meeting on Wednesday, May 2, 2012 from 9 a.m. to 5 p.m., in 

Washington, DC. The meeting will also be broadcast as a webinar. See section VII, “Public 

Participation,” for webinar registration information, participant instructions, and information 

about the capabilities available to webinar participants. 

DOE will accept comments, data, and information regarding this notice of proposed 

rulemaking (NOPR) before and after the public meeting, but no later than [INSERT DATE 60 

DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]. See section 

VI, “Public Participation,” for details. 

ADDRESSES: The public meeting will be held at the U.S. Department of Energy, Forrestal 

Building, Room 8E-089, 1000 Independence Avenue, SW., Washington, DC 20585. To attend, 

please notify Ms. Brenda Edwards at (202) 586–2945. Please note that foreign nationals visiting 

DOE Headquarters are subject to advance security screening procedures. Any foreign national 

wishing to participate in the meeting should advise DOE as soon as possible by contacting Ms. 

Edwards to initiate the necessary procedures. Please also note that those wishing to bring laptops 

into the Forrestal Building will be required to obtain a property pass. Visitors should avoid 

bringing laptops, or allow an extra 45 minutes. 

Any comments submitted must identify the NOPR for Energy Conservation Standards for 

Battery Chargers and External Power Supplies, and provide docket number EE-2008–BT–STD– 

0005 and/or regulatory information number (RIN) number 1904-AB57. Comments may be 

submitted using any of the following methods: 

2 
1. Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for 

submitting comments. 

2. E-mail: BC&EPS_ECS@ee.doe.gov.Include the docket number and/or RIN in the subject 

line of the message. 

3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Program, 

Mailstop EE-2J, 1000 Independence Avenue, SW., Washington, DC, 20585-0121. If 

possible, please submit all items on a CD. It is not necessary to include printed copies. 

4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of Energy, Building 

Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, Washington, DC, 20024. 

Telephone: (202) 586-2945. If possible, please submit all items on a CD. It is not 

necessary to include printed copies. 

Written comments regarding the burden-hour estimates or other aspects of the collectionof-information requirements contained in this proposed rule may be submitted to Office of 

Energy Efficiency and Renewable Energy through the methods listed above and by e-mail to 

Chad_S_Whiteman@omb.eop.gov. 

For detailed instructions on submitting comments and additional information on the 

rulemaking process, see section VII of this document (Public Participation). 

Docket: The docket is available for review at regulations.gov, including Federal Register 

notices, framework documents, public meeting attendee lists and transcripts, comments, and 

3 
other supporting documents/materials. All documents in the docket are listed in the 

regulations.gov index. However, not all documents listed in the index may be publicly available, 

such as information that is exempt from public disclosure. 

A link to the docket web page can be found at: 

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

This web page will contain a link to the docket for this notice on the regulations.gov site. The 

regulations.gov web page will contain simple instructions on how to access all documents, 

including public comments, in the docket. See section VII for information on how to submit 

comments through regulations.gov. 

For further information on how to submit or review public comments or participate in the 

public meeting, contact Ms. Brenda Edwards at (202) 586-2945 or email: 

Brenda.Edwards@ee.doe.gov. 

FOR FURTHER INFORMATION CONTACT: 

Mr. Victor Petrolati, U.S. Department of Energy, Office of Energy Efficiency and 

Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue, SW., 

Washington, DC, 20585-0121. Telephone: (202) 586-4549. E-mail: Victor.Petrolati@ee.doe.gov. 

Mr. Michael Kido, U.S. Department of Energy, Office of the General Counsel, GC-71, 

1000 Independence Avenue, SW., Washington, DC, 20585-0121. Telephone: (202) 586-8145. Email: michael.kido@hq.doe.gov. 

4 
SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Summary of the Proposed Rule 

A. Benefits and Costs to Consumers 

B. Impact on Manufacturers 

C. National Benefits 

II. Introduction 

A. Authority 

B. Background 

1. Current Standards 

2. History of Standards Rulemaking for Battery Chargers and External Power Supplies 

III. General Discussion 

A. Test Procedures 

1. External Power Supply Test Procedures 

2. Battery Charger Test Procedures 

B. Technological Feasibility 

1. General 

2. Maximum Technologically Feasible Levels 

a. External Power Supply Max-Tech Levels 

b. Battery Charger Max-Tech Levels 

C. Energy Savings 

1. Determination of Savings 

2. Significance of Savings 

D. Economic Justification 

1. Specific Criteria 

a. Economic Impact on Manufacturers and Consumers 

b. Life-Cycle Costs 

c. Energy Savings 

d. Lessening of Utility or Performance of Products 

e. Impact of Any Lessening of Competition 

f. Need for National Energy Conservation 

2. Rebuttable Presumption 

IV. Methodology and Discussion 

A. Market and Technology Assessment 

1. Products Included in this Rulemaking 

a. External Power Supplies 

b. Battery Chargers 

c. Wireless Power 

d. Unique Products 

2. Market Assessment 

a. Market Survey 

b. Non-Class A External Power Supplies 

c. Application Shipments 

d. Efficiency Distributions 

3. Product Classes 

5 
a. External Power Supply Product Classes 

b. Battery Charger Product Classes 

4. Technology Assessment 

a. EPS Efficiency Metrics 

b. EPS Technology Options 

c. High-Power EPSs 

d. Power Factor 

e. Battery Charger Modes of Operation and Performance Parameters 

f. Battery Charger Technology Options 

B. Screening Analysis 

C. Engineering Analysis 

1. Engineering Analysis for External Power Supplies 

a. Representative Product Classes and Representative Units 

b. EPS Candidate Standard Levels (CSLs) 

c. EPS Engineering Analysis Methodology 

d. EPS Engineering Results 

e. EPS Equation Scaling 

2. Engineering Analysis for Battery Chargers 

a. Representative Units 

b. Battery Charger Efficiency Metrics 

c. Calculation of Unit Energy Consumption 

d. Battery Charger Candidate Standard Levels (CSLs) 

e. Test and Teardowns 

f. Manufacturer Interviews 

g. Design Options 

h. Cost Model 

i. Battery Charger Engineering Results 

j. Scaling of Battery Charger Candidate Standard Levels 

D. Markups to Determine Product Price 

E. Energy Use Analysis 

F. Life-Cycle Cost and Payback Period Analyses 

1. Manufacturer Selling Price 

2. Markups 

3. Sales Tax 

4. Installation Cost 

5. Maintenance Cost 

6. Product Price Forecast 

7. Unit Energy Consumption 

8. Electricity Prices 

9. Electricity Price Trends 

10. Lifetime 

11. Discount Rate 

12. Sectors Analyzed 

13. Base Case Market Efficiency Distribution 

14. Compliance Date 

15. Payback Period Inputs 

6 
G. National Impact Analysis 

1. Shipments 

2. Shipment Growth Rate 

3. Product Class Lifetime 

4. Forecasted Efficiency in the Base Case and Standards Cases 

5. Product Price Forecast 

6. Unit Energy Consumption and Savings 

7. Unit Costs 

8. Repair and Maintenance Cost per Unit 

9. Energy Prices 

10. Site-to-Source Energy Conversion 

11. Discount Rates 

12. Benefits from Effects of Standards on Energy Prices 

H. Consumer Subgroup Analysis 

I. Manufacturer Impact Analysis 

1. Overview 

2. EPS MIA 

a. EPS GRIM Key Inputs 

b. Comments from Interested Parties Related to EPSs 

c. High-Power EPS Manufacturer Interviews 

3. Battery Charger MIA 

a. Battery Charger GRIM Key Inputs 

b. Battery Charger Comments from Interested Parties 

4. Comments from Interested Parties Related to EPSs and Battery Chargers 

a. Cumulative Burden 

b. Competition 

5. Manufacturer Interviews 

a. Product Groupings 

b. Competition from Substitutes 

c. Test Procedure Concerns 

d. Multiple Regulation of EPSs and Battery Chargers 

e. Profitability Impacts 

f. Potential Changes to Product Utility 

J. Employment Impact Analysis 

K. Utility Impact Analysis 

L. Emissions Analysis 

M. Monetizing Carbon Dioxide and Other Emissions Impacts 

1. Social Cost of Carbon 

a. Monetizing Carbon Dioxide Emissions 

b. Social Cost of Carbon Values Used in Past Regulatory Analyses 

c. Current Approach and Key Assumptions 

d. Valuation of Other Emissions Reductions 

N. Discussion of Other Comments 

O. Marking Requirements 

P. Reporting Requirements 

V. Analytical Results 

7 
A. Trial Standard Levels 

1. External Power Supply TSLs 

2. Battery Charger TSLs 

B. Economic Justification and Energy Savings 

1. Economic Impacts on Individual Consumers 

a. Life-Cycle Cost and Payback Period 

b. Consumer Subgroup Analysis 

c. Rebuttable Presumption Payback 

2. Economic Impacts on Manufacturers 

a. Cash-Flow Analysis Results 

b. Impacts on Employment 

c. Impacts on Manufacturing Capacity 

d. Impacts on Sub-Group of Manufacturers 

e. Cumulative Regulatory Burden 

3. National Impact Analysis 

a. Significance of Energy Savings 

b. Net Present Value of Consumer Costs and Benefits 

c. Indirect Impacts on Employment 

4. Impact on Utility or Performance of Products 

5. Impact of Any Lessening of Competition 

6. Need of the Nation to Conserve Energy 

7. Other Factors 

C. Proposed Standards 

1. External Power Supplies 

a. Product Class B -- Direct Operation External Power Supplies 

b. Product Class X -- Multiple-Voltage External Power Supplies 

c. Product Class H – High-Power External Power Supplies 

d. Product Class N -- Indirect-Operation External Power Supplies 

2. Battery Chargers 

a. Low-Energy, Inductive Charging Battery Chargers, Product Class 1 

b. Low-Energy, Non-Inductive Charging Battery Chargers, Product Classes 2, 3, and 4 

c. Medium-Energy Battery Chargers, Product Classes 5 and 6 

d. High-Energy Battery Chargers, Product Class 7 

e. Battery Chargers with a DC Input of Less than 9 V, Product Class 8 

f. Battery Chargers with a DC Input Greater than 9 V, Product Class 9 

g. AC Output Battery Chargers, Product Class 10 

3. Summary of Benefits and Costs (Annualized) of Proposed Standards for External Power 

Supplies 

4. Summary of Benefits and Costs (Annualized) of Proposed Standards for Battery 

Chargers 

VI. Procedural Issues and Regulatory Review 

A. Review Under Executive Order 12866 and 13563 

B. Review Under the Regulatory Flexibility Act 

1. Description and Estimated Number of Small Entities Regulated 

a. Methodology for Estimating the Number of Small Entities 

b. Manufacturer Participation 

8 
c. Battery Charger Industry Structure 

d. Comparison Between Large and Small Entities 

2. Description and Estimate of Compliance Requirements 

c. Summary of Compliance Impacts 

3. Duplication, Overlap, and Conflict with Other Rules and Regulations 

4. Significant Alternatives to the Proposed Rule 

C. Review Under the Paperwork Reduction Act 

D. Review Under the National Environmental Policy Act of 1969 

E. Review Under Executive Order 13132 

F. Review Under Executive Order 12988 

G. Review Under the Unfunded Mandates Reform Act of 1995 

H. Review Under the Treasury and General Government Appropriations Act, 1999 446 

I. Review Under Executive Order 12630 

J. Review Under the Treasury and General Government Appropriations Act, 2001 446 

K. Review Under Executive Order 13211 

L. Review Under the Information Quality Bulletin for Peer Review 

VII. Public Participation 

A. Attendance at Public Meeting 

B. Procedure for Submitting Prepared General Statements For Distribution 

C. Conduct of Public Meeting 

D. Submission of Comments 

E. Issues on Which DOE Seeks Comment 

VIII. Approval of the Office of the Secretary 

List of Tables 

Table I-1. Proposed Energy Conservation Standards for Direct Operation External Power 

Supplies 

Table I-2. Proposed Energy Conservation Standards for Battery Chargers 

Table I-3 Impacts of Proposed Standards on Consumers of External Power Supplies 

Table I-4 Impacts of Proposed Standards on Consumers of Battery Chargers 

Table I-5. External Power Supply Product Classes 

Table I-6 Annualized Benefits and Costs of Proposed Standards for External Power Supplies 

Shipped in 2013-2042 

Table I-7. Battery Charger Product Classes 

Table I-8 Annualized Benefits and Costs of Proposed Standards for Battery Chargers Shipped in 

2013-2042 

Table II-1 Federal Active Mode Energy Efficiency Standards for Class A External Power 

Supplies 

Table II-2 Stakeholders Providing Comments on the Preliminary Analysis 

Table III-1. Reduction in Energy Consumption at Max-Tech for Battery Chargers 

Table IV-1 Preliminary Analysis Product Classes 

Table IV-2 External Power Supply Product Classes Used in the NOPR 

Table IV-3 Battery Charger Product Classes 

Table IV-4 Summary of EPS CSLs for Product Classes B, C, D, and E 

Table IV-5 Summary of EPS CSLs for Product Class X 

9 
Table IV-6 Summary of EPS CSLs for Product Class H 

Table IV-7 2.5W EPS Engineering Analysis Results 

Table IV-8 18W EPS Engineering Analysis Results 

Table IV-9 60W EPS Engineering Analysis Results 

Table IV-10 120W EPS Engineering Analysis Results 

Table IV-11 203W EPS Engineering Analysis Results 

Table IV-12 345W EPS Engineering Analysis Results 

Table IV-13 The Battery Charger Representative Units for each Product Class 

Table IV-14 CSLs Equivalent to California Proposed Standards 

Table IV-15 Supplemental Values for Product Classes 10a and 10b 

Table IV-16 Product Class 1 (Inductive Chargers) Engineering Analysis Results 

Table IV-17 Product Class 2 (Low-Energy, Low-Voltage) Engineering Analysis Results . 

Table IV-18 Product Class 3 (Low-Energy, Medium-Voltage) Engineering Analysis Results 

Table IV-19 Product Class 4 (Low-Energy, High-Voltage) Engineering Analysis Results. 

Table IV-20 Product Class 5 (Medium-Energy, Low-Voltage) Engineering Analysis Results 

Table IV-21 Product Class 6 (Medium-Energy, High-Voltage) Engineering Analysis Results 

Table IV-22 Product Class 7 (High-Energy) Engineering Analysis Results 

Table IV-23 Product Class 8 (Low-Voltage DC Input) Engineering Analysis Results 

Table IV-24 Product Class 9 (High-Voltage DC Input) Engineering Analysis Results 

Table IV-25 Product Class 10 (AC Input, AC Output) Engineering Analysis Results 

Table IV-26 Summary of Inputs and Key Assumptions Used in the Preliminary Analysis and 

NOPR LCC Analyses 

Table IV-27 EPS Life-Cycle Cost Savings with 4-Year Lifteime Assumptions 

Table IV-28 EPS Life-Cycle Cost Savings with Alternative (2-year) Lifetime Assumptions 

Table IV-29 Summary of Inputs, Sources and Key Assumptions for the National Impact Analysis 

Table IV-30 Changes to Base Case Efficiency Distributions to Account for CEC Standards 

Table IV-31 Social Cost of CO2, 2010–2050 (in 2007 dollars per metric ton) 

Table IV-32 Proposed Efficiency Marking Protocol for Battery Chargers 

Table IV-33 Proposed Location for Battery Charger Marking 

Table V-1 Trial Standard Levels for External Power Supplies 

Table V-2 Trial Standard Levels for Battery Chargers 

Table V-3 LCC Savings and Payback Period for DC Output, Basic-Voltage External Power 

Supplies 

Table V-4 LCC Savings and Payback Period for Non-Class A External Power Supplies 

Table V-5 LCC Savings and Payback Period for Battery Chargers 

Table V-6 DC Output, Basic-Voltage External Power Supplies: Low-Income Consumer 

Subgroup 

Table V-7 Non-Class A External Power Supplies: Low-Income Consumer Subgroup 

Table V-8 Battery Chargers: Low-Income Consumer Subgroup 

Table V-9 DC Output, Basic-Voltage External Power Supplies: Small Business Consumer 

Subgroup 

Table V-10 Battery Chargers: Small Business Consumer Subgroup 

Table V-11 DC Output, Basic-Voltage External Power Supplies: Top Tier Marginal Electricity 

Price Consumer Subgroup 

Table V-12 Non-Class A External Power Supplies: Top Tier Marginal Electricity Price 

Consumer Subgroup 

10 
Table V-13 Battery Chargers: Top Tier Marginal Electricity Price Consumer Subgroup 

Table V-14 Manufacturer Impact Analysis for Product Classes B, C, D, and E – Flat Markup 

Scenario 

Table V-15 Manufacturer Impact Analysis for Product Classes B, C, D, and E – Preservation of 

Operating Profit Markup Scenario 

Table V-16 Manufacturer Impact Analysis for Product Class X EPS – Flat Markup Scenario 

Table V-17 Manufacturer Impact Analysis for Product Class X EPS – Preservation of Operating 

Scenario 

Table V-18 Manufacturer Impact Analysis for Product Class H EPS – Flat Markup Scenario 

Table V-19 Manufacturer Impact Analysis for Product Class H EPS – Preservation of Operating 

Profit Markup Scenario 

Table V-20 Applications in Product Class 1 

Table V-21 Cash Flow Results – Product Class 1 – Flat Markup Scenario 

Table V-22 Cash Flow Results – Product Class 1 – Pass Through Markup Scenario 

Table V-23 Cash Flow Results – Product Class 1 – Constant Price Markup Scenario 

Table V-24 Applications in Product Classes 2, 3, and 4 

Table V-25 Cash Flow Results – Product Classes 2, 3, and 4 – Flat Markup Scenario 

Table V-26 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup Scenario 

Table V-27 Cash Flow Results – Product Classes 2, 3, and 4 – Constant Price Markup Scenario 

Table V-28 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup Scenario – 

Consumer Electronics 

Table V-29 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup Scenario - 

Power Tools 

Table V-30 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup Scenario – 

Small Appliances 

Table V-31 Applications in Product Classes 5 and 6 

Table V-32 Cash Flow Results – Product Classes 5 and 6 – Flat Markup Scenario 

Table V-33 Cash Flow Results – Product Classes 5 and 6 – Pass Through Markup Scenario 

Table V-34 Cash Flow Results – Product Classes 5 and 6 – Constant Price Markup Scenario 

Table V-35 Applications in Product Class 7 

Table V-36 Cash Flow Results – Product Class 7 – Flat Markup Scenario 

Table V-37 Cash Flow Results – Product Class 7 – Pass Through Markup Scenario 

Table V-38 Cash Flow Results – Product Class 7 – Constant Price Markup Scenario 

Table V-39 Applications in Product Class 8 

Table V-40 Cash Flow Results – Product Class 8 – Flat Markup Scenario 

Table V-41 Cash Flow Results – Product Class 8 – Pass Through Markup Scenario 

Table V-42 Cash Flow Results – Product Class 8 – Constant Price Markup Scenario 

Table V-43 Applications in Product Class 9 

Table V-44 Applications in Product Class 10 

Table V-45 Cash Flow Results – Product Class 10 – Flat Markup Scenario 

Table V-46 Cash Flow Results – Product Class 10 – Pass Through Markup Scenario 

Table V-47 Cash Flow Results – Product Class 10 – Constant Price Markup Scenario 

Table V-48 – Base Case Manufacturer Impact Analysis for All Battery Charger Product Classes 

Due to the CEC Standard 

Table V-49 External Power Supplies: Cumulative National Energy Savings in Quads 

Table V-50 Battery Chargers: Cumulative National Energy Savings in Quads 

11 
Table V-51 Cumulative Net Present Value of Consumer Benefits for External Power Supplies, 3­

Percent Discount Rate (2010$ millions) 

Table V-52 Cumulative Net Present Value of Consumer Benefits for External Power Supplies, 7­

Percent Discount Rate (2010$ millions) 

Table V-53 Cumulative Net Present Value of Consumer Benefits for Battery Chargers, 3-Percent 

Discount Rate (2010$ millions) 

Table V-54 Cumulative Net Present Value of Consumer Benefits for Battery Chargers, 7-Percent 

Discount Rate (2010$ millions) 

Table V-55 Cumulative Emissions Reduction for 2013- 2042 Under External Power Supply 

TSLs 

Table V-56 Cumulative Emissions Reduction for 2013- 2042 Under Battery Charger TSLs 

Table V-57 External Power Supply Product Class B: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-58 External Power Supply Product Classes B, C, D, and E: Estimates of Global Present 

Value of CO2 Emissions Reduction Under TSLs 

Table V-59 External Power Supply Product Class X: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-60 External Power Supply Product Class H: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-61 Battery Charger Product Class 1: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-62 Battery Chargers Product Classes 2, 3, 4: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-63 Battery Chargers Product Classes 5, 6: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-64 Battery Chargers Product Class 7: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-65 Battery Chargers Product Class 8: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-66 Battery Chargers Product Class 10: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-67 External Power Supply Product Class B: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs 

Table V-68 External Power Supply Product Classes B, C, D, E: Estimates of Domestic Present 

Value of CO2 Emissions Reduction Under TSLs 

Table V-69 External Power Supply Product Class X: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs 

Table V-70 External Power Supply Product Class H: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs 

Table V-71 Battery Charger Product Class 1: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-72 Battery Charger Product Classes 2, 3, 4: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs 

Table V-73 Battery Charger Product Classes 5, 6: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

12 
Table V-74 Battery Charger Product Class 7: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-75 Battery Charger Product Class 8: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-76 Battery Charger Product Class 10: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

Table V-77 Estimates of Present Value of NOX Emissions Reduction Under External Power 

Supply TSLs 

Table V-78 Estimates of Present Value of NOX Emissions Reduction Under Battery Charger 

TSLs 

Table V-79 Adding Net Present Value of Consumer Savings to Present Value of Monetized 

Benefits from CO2 and NOX Emissions Reductions Under TSL 1 for Battery Chargers Product 

Classes 2, 3, 4 

Table V-80 Results of Adding Net Present Value of Consumer Savings (at 7% Discount Rate) to 

Net Present Value of Monetized Benefits from CO2 and NOX Emissions Reductions Under 

External Power Supply TSLs 

Table V-81 Results of Adding Net Present Value of Consumer Savings (at 3% Discount Rate) to 

Net Present Value of Monetized Benefits from CO2 and NOX Emissions Reductions External 

Power Supply TSLs 

Table V-82 Results of Adding Net Present Value of Consumer Savings (at 7% Discount Rate) to 

Net Present Value of Monetized Benefits from CO2 and NOX Emissions Reductions Under 

Battery Charger TSLs 

Table V-83 Results of Adding Net Present Value of Consumer Savings (at 3% Discount Rate) to 

Net Present Value of Monetized Benefits from CO2 and NOX Emissions Reductions Under 

Battery Charger TSLs 

Table V-84 Selected National Impacts of Aligning Federal Standards with California Standards 

Table V-85 Summary of Results for Product Class B External Power Supplies 

Table V-86 Proposed Standards for EPSs in Product Classes B, C, D, and E 

Table V-87 Proposed Standards for Product Class X External Power Supplies 

Table V-88 Proposed Standards for Multiple-Voltage External Power Supplies 

Table V-89 Proposed Standards for High-Power External Power Supplies 

Table V-90 Proposed Standards for High-Power External Power Supplies 

Table V-91 Applications of Indirect Operation External Power Supplies 

Table V-92 Summary of Results for Battery Charger Product Class 1 

Table V-93 Proposed Standard for Product Class 1 

Table V-94 Summary of Results for Battery Charger Product Classes 2, 3, and 4 

Table V-95 Proposed Standard for Product Classes 2, 3, and 4 

Table V-96 Summary of Results for Battery Charger Product Classes 5 and 6 

Table V-97 Proposed Standard for Product Classes 5 and 6 

Table V-98 Summary of Results for Battery Charger Product Class 7 

Table V-99 Proposed Standard for Product Class 7 

Table V-100 Summary of Results for Battery Charger Product Class 8 

Table V-101 Proposed Standard for Product Class 8 

Table V-102 Summary of Results for Battery Charger Product Class 10 

Table V-103 Proposed Standard for Product Class 10 

Table V-104 Annualized Benefits and Costs of Proposed Standards for EPSs 

13 
 

Table V-105 Annualized Benefits and Costs of Proposed Standards for Battery Chargers . 

Table VI-1 Estimated Capital Conservation Costs for a Typical Small Business (2010$ million) 

Table VI-2 Estimated Product Conversion Costs for a Typical Small Business (2010$ million) 

Table VI-3 Estimated Total Conversion Costs for a Typical Small Business (2010$ million) 

14 
 

I. Summary of the Proposed Rule 

Title III, Part B1 of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), 

Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified), established the Energy Conservation 

Program for Consumer Products Other Than Automobiles. Pursuant to EPCA, any new or 

amended energy conservation standard that DOE prescribes for certain products, such as battery 

chargers and external power supplies (EPSs), shall be designed to achieve the maximum 

improvement in energy efficiency that is technologically feasible and economically justified. (42 

U.S.C. 6295(o)(2)(A)). Furthermore, the new or amended standard must result in a significant 

conservation of energy. (42 U.S.C. 6295(o)(3)(B)). In accordance with these and other statutory 

provisions discussed in this notice, DOE proposes amended energy conservation standards for 

Class A EPSs and new energy conservation standards for non-Class A EPSs and battery 

chargers. The proposed standards for direct operation EPSs, which are the minimum average 

efficiency in active mode and the maximum power consumption in no-load mode expressed as a 

function of the nameplate output power, are shown in Table I.1. The proposed standards for 

battery chargers, which consist of a set of maximum annual energy consumption levels expressed 

as a function of battery energy, are shown in Table I-2. These proposed standards, if adopted, 

would apply to all products listed in Table I.1 and Table I-2 and manufactured in, or imported 

into, the United States on or after July 1, 2013. In addition to being technologically feasible and 

economically justified, DOE’s proposed standards were also designed to maximize the net 

monetized benefits, as explained further below in this notice. 

Table I-1. Proposed Energy Conservation Standards for Direct Operation External Power 

Supplies 

AC-DC, Basic-Voltage External Power Supply 

1

 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A. 

15 
Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.100 

> 49 watts to ≤ 250 

watts ≥ 0.880 ≤ 0.210 

> 250 watts 0.875 ≤ 0.500 

AC-DC, Low-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.100 

> 49 watts to ≤ 250 

watts ≥ 0.870 ≤ 0.210 

> 250 watts 0.875 ≤ 0.500 

AC-AC, Basic-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.210 

> 49 watts to ≤ 250 

watts ≥ 0.880 ≤ 0.210 

> 250 watts 0.875 ≤ 0.500 

AC-AC, Low-voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.210 

16 
> 49 watts to ≤ 250 

watts ≥ 0.870 ≤ 0.210 

> 250 watts 0.875 ≤ 0.500 

Multiple-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.497 × Pout + 0.067 ≤ 0.300 

> 1 to ≤ 49 watts ≥ 0.075 × ln (Pout) + 0.561 ≤ 0.300 

> 49 watts ≥ 0.860 ≤ 0.300 

17 
 

 

Table I-2. Proposed Energy Conservation Standards for Battery Chargers 

Product 

Class 

Product Class Description Proposed Standard as a 

Function of Battery Energy 

(kWh/yr) 

1 Low-Energy, Inductive 3.04 

2 Low-Energy, Low-Voltage = 0.2095(Ebatt*) + 5.87 

3 Low-Energy, Medium-Voltage 

For Ebatt < 9.74 Wh, 

= 4.68 

For Ebatt ≥ 9.74 Wh, 

= 0.0933(Ebatt) + 3.77 

4 Low-Energy, High-Voltage 

For Ebatt < 9.71 Wh, 

= 9.03 

For Ebatt ≥ 9.71 Wh, 

= 0.2411(Ebatt) + 6.69 

5 Medium-Energy, Low-Voltage 

For Ebatt < 355.18 Wh, 

= 20.06 

For Ebatt ≥ 355.18 Wh, 

= 0.0219(Ebatt) + 12.28 

6 Medium-Energy, High-Voltage 

For Ebatt < 239.48 Wh 

= 30.37 

For Ebatt ≥ 239.48 Wh 

= 0.0495(Ebatt) + 18.51 

7 High-Energy = 0.502(Ebatt) + 4.53 

8 Low-Voltage DC Input 0.66 

9 High-Voltage DC Input No Standard. 

10a AC Output, 

Basic (i.e. no Automatic Voltage Regulation) 

For Ebatt < 37.2 Wh, = 2.54 

For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt) – 

0.18 

10b 

AC Output, 

Contains Automatic Voltage Regulation 

For Ebatt < 37.2 Wh, = 6.18 

For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt) + 

3.45 

A. Benefits and Costs to Consumers 

Table I-3 presents DOE’s evaluation of the economic impacts of the proposed standards 

on consumers of EPSs, as measured by the average life-cycle cost (LCC) savings and the median 

payback period. The projected economic impacts of the proposed standards on individual 

consumers are generally positive. For example, the estimated average life-cycle cost (LCC) 

18 
 

 

 

 

 

 

 

 

savings are from -$0.45 to $0.69 for product class B, depending on the representative unit, $2.07 

for product class X, and $129.08 for product class H.2 

Table I-3 Impacts of Proposed Standards on Consumers of External Power Supplies 

Product Class Rep. Unit Weighted Average LCC Savings 

[2010$] 

Median Payback Period3 

[yrs] 

B 2.5W AC-DC, Basic V 0.04 4.3 

B 18W AC-DC, Basic V 0.69 3.1 

B 60W AC-DC, Basic V (0.45) 5.4 

B 120W AC-DC, Basic V 0.61 1.9 

X 203W Multiple-Voltage 2.07 4.7 

H 345W High-Power 129.08 0.2 

Table I-4 presents DOE’s evaluation of the economic impacts of the proposed standards 

on consumers of battery chargers, as measured by the average life-cycle cost (LCC) savings and 

the median payback period. The projected economic impacts of the proposed standards on 

individual consumers are generally positive. For example, the estimated average life-cycle cost 

(LCC) savings are $1.52 for product class 1, $0.16 for product class 2, $0.35 for product class 3, 

$0.43 for product class 4, $33.79 for product class 5, $40.78 for product class 6, $38.26 for 

product class 7, $3.04 for product class 8, and $8.30 for product class 10.4 

Table I-4 Impacts of Proposed Standards on Consumers of Battery Chargers 

Rep. Unit Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

PC1 - Low E, 

Inductive 1.52 1.7 

PC2 - Low E, LowVoltage 0.16 0.5 

2

 The LCC is the total consumer expense over the life of a product, consisting of purchase and installation costs plus 

operating costs (expenses for energy use, maintenance and repair). To compute the operating costs, DOE discounts 

future operating costs to the time of purchase and sums them over the lifetime of the product. 

3

 As explained in V.B.1.a, DOE uses the median payback period rather than the mean payback period to dampen the 

effect of outliers on the data. 

4

 The LCC is the total consumer expense over the life of a product, consisting of purchase and installation costs plus 

operating costs (expenses for energy use, maintenance and repair). To compute the operating costs, DOE discounts 

future operating costs to the time of purchase and sums them over the lifetime of the product. 

19 
 

 

 

 

PC3 - Low E, 

Medium-Voltage 0.35 3.9 

PC4 - Low E, 

High-Voltage 0.43 3.0 

PC5 - Medium E, 

Low-Voltage 33.79 0.0 

PC6 - Medium E, 

High-Voltage 40.78 0.0 

PC7 - High E 38.26 0.0 

PC8 - DC-DC, <9V 

Input 3.04 0.0 

PC10 - Low E, AC 

Out 8.30 1.5 

B. Impact on Manufacturers 

The industry net present value (INPV) is the sum of the discounted cash flows to the 

industry from the base year through the end of the analysis period (2011 to 2042). Using a real 

discount rate of 7.1 percent, DOE estimates that the INPV for manufacturers of EPSs is $0.276 

billion in 2010$. Under the proposed standards, DOE expects that manufacturers may lose up to 

34.1 percent of their INPV, which is approximately $0.094 billion in 2010$. Based on DOE’s 

interviews with the manufacturers of EPSs and because DOE did not identify any domestic EPS 

production, DOE does not expect any domestic plant closings or any significant change in 

employment, since the vast majority, if not all EPS production occurs abroad. 

For battery chargers, DOE estimates that the INPV for manufacturers of applications that 

include battery chargers is between $53.918 and $53.205 billion in 2010$ using a real discount 

rate of 9.1 percent. Under the proposed standards, DOE expects that manufacturers may lose up 

to 10.2 percent of their INPV, which is approximately $5.428 billion in 2010$. Based on DOE’s 

interviews with the manufacturers of battery chargers, DOE does not expect any domestic plant 

closings or significant change in employment, since DOE only identified one domestic battery 

charger manufacturer. 

20 
C. National Benefits 

External Power Supplies 

DOE’s analyses indicate that the proposed standards would save a significant amount of 

energy over 30 years (2013–2042) ― an estimated 0.99 quads of cumulative energy for EPSs. 

The product classes at issue are comprised of the following groupings of EPS products 

listed below. 

Table I-5. External Power Supply Product Classes 

Product Class Product Class Description 

B DC Output, Basic-Voltage 

2.5 W (0-10.25 W) 

18 W (10.25-39 W) 

60 W (39-90 W) 

120 W (91-250 W) 

C DC Output, Low-Voltage 

D AC Output, Basic-Voltage 

E AC Output, Low-Voltage 

X Multiple-Voltage 

H High-Power 

N Indirect Operation 

21 
 

 

 

The cumulative national net present value (NPV) of total consumer costs and savings of 

the proposed standards in 2010$ ranges from $0.79 billion (at a 7-percent discount rate) to $1.87 

(at a 3-percent discount rate) for EPSs. This NPV expresses the estimated total value of future 

operating-cost savings minus the estimated increased product costs for products purchased in 

2013–2042, discounted to 2011. 

In addition, the proposed standards would have significant environmental benefits. The 

energy saved is in the form of electricity, would result in cumulative greenhouse gas emission 

reductions of 46.5 million metric tons (Mt)5

 of carbon dioxide (CO2) in 2013–2042. During this 

period, the proposed standards would result in emissions reductions of 38 thousand tons of 

nitrogen oxides (NOX) and 0.25 tons (t) of mercury (Hg).6

DOE estimates the net present 

monetary value of the CO2 emissions reduction is between $0.20 and $2.95 billion, expressed in 

2010$ and discounted to 2011. DOE also estimates the net present monetary value of the NOX 

emissions reduction, expressed in 2010$ and discounted to 2011, is between $6.11 and $62.79 

million at a 7-percent discount rate, and between $10.97 and $112.73 million at a 3-percent 

discount rate.7 

5

 A metric ton is equivalent to 1.1 short tons. Results for NOX and Hg are given in short tons. 6

 DOE calculates emissions reductions relative to the most recent version of the Annual Energy Outlook (AEO) 

Reference case forecast. This forecast accounts for regulatory emissions reductions from in-place regulations, 

including the Clean Air Interstate Rule (CAIR, 70 FR 25162 (May 12, 2005)), but not the Clean Air Mercury Rule 

(CAMR, 70 FR 28606 (May 18, 2005)). Subsequent regulations, including the finalized CAIR replacement rule, the 

Cross-State Air Pollution rule issued on July 6, 2011, do not appear in the forecast. On December 30, 2011, the D.C. 

Circuit stayed CSAPR while ordering EPA to continue administering the also remanded 2005 Clean Air Interstate 

Rule (CAIR, which has a similar structure, but with less stringent budgets and less restrictive trading provisions) and 

tentatively set a briefing schedule to allow the case to be heard by April 2012. 

7

 DOE is aware of multiple agency efforts to determine the appropriate range of values used in evaluating the 

potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance regarding 

consistent valuation and reporting of Hg emissions before it once again monetizes Hg in its rulemakings. 

22 
 

 

The benefits and costs of today’s proposed standards, for products sold in 2013-2042, can 

also be expressed in terms of annualized values. The annualized monetary values are the sum of 

(1) the annualized national economic value of the benefits from consumer operation of products 

that meet the proposed standards (consisting primarily of operating cost savings from using less 

energy, minus increases in equipment purchase and installation costs, which is another way of 

representing consumer NPV), and (2) the annualized monetary value of the benefits of emission 

reductions, including CO2 emission reductions.8 The value of the CO2 reductions, otherwise 

known as the Social Cost of Carbon (SCC), is calculated using a range of values per metric ton 

of CO2 developed by a recent interagency process. The derivation of the SCC values is discussed 

in section IV.M. 

Although combining the values of operating savings and CO2 reductions provides a 

useful perspective, two issues should be considered. First, the national operating savings are 

domestic U.S. consumer monetary savings that occur as a result of market transactions while the 

value of CO2 reductions is based on a global value. Second, the assessments of operating cost 

savings and CO2 savings are performed with different methods that use quite different time 

frames for analysis. The national operating cost savings is measured for the lifetime of EPSs 

shipped in 2013 –2042. The SCC values, on the other hand, reflect the present value of all future 

climate-related impacts resulting from the emission of one ton of carbon dioxide in each year. 

These impacts continue well beyond 2100. 

8

 The process that DOE used to convert the time-series of costs and benefits into annualized values is explained in 

section V.C.3 of this notice.” 

23 
Table I-6 shows the annualized values for today’s proposed standards for EPSs. (All 

monetary values below are expressed in 2010$.) The results under the primary estimate are as 

follows. Using a 7-percent discount rate for benefits and costs other than CO2 reduction, for 

which DOE used a 3-percent discount rate along with the SCC series corresponding to a value of 

$22.3/ton in 2010, the cost of the standards proposed in today’s rule is $251.9 million per year in 

increased equipment costs, while the annualized benefits are $325.2 million per year in reduced 

equipment operating costs, $52.3 million in CO2 reductions, and $3.2 million in reduced NOX 

emissions. In this case, the net benefit amounts to $128.7 million per year. Using a 3-percent 

discount rate for all benefits and costs and the SCC series corresponding to a value of $22.3/ton 

in 2010, the cost of the standards proposed in today’s rule is $247.3 million per year in increased 

equipment costs, while the benefits are $348.2 million per year in reduced operating costs, $52.3 

million in CO2 reductions, and $3.3 million in reduced NOX emissions. In this case, the net 

benefit amounts to $156.6 million per year. 

24 
 

 

 

 

Table I-6 Annualized Benefits and Costs of Proposed Standards for External Power 

Supplies Shipped in 2013-2042 

Discount Rate 

Primary 

Estimate* 

Low Net 

Benefits 

Estimate* 

High Net 

Benefits 

Estimate* 

Monetized (million 2010$/year) 

Benefits 

Operating Cost Savings 

7% 325.2 309.1 341.1 

3% 348.2 329.5 367.3 

CO2 Reduction at $4.9/t** 5% 14.1 14.1 14.1 

CO2 Reduction at $22.3/t** 3% 52.3 52.3 52.3 

CO2 Reduction at $36.5/t** 2.5% 81.4 81.4 81.4 

CO2 Reduction at $67.6/t** 3% 159.6 159.6 159.6 

NOX Reduction at $2,537/t** 

7% 3.2 3.2 3.2 

3% 3.3 3.3 3.3 

Total† 

7% plus CO2 

range 

342.5 to 488.0 326.4 to 471.9 358.4 to 503.9 

7% 380.7 364.6 396.6 

3% 403.9 385.1 422.9 

3% plus CO2 

range 

365.7 to 511.2 346.9 to 492.5 384.7 to 530.3 

Costs 

Incremental Product Costs 

7% 251.9 251.9 251.9 

3% 247.3 247.3 247.3 

Total Net Benefits 

Total † 

7% plus CO2 

range 

90.5 to 236.1 74.4 to 220.0 106.5 to 252.0 

7% 128.7 112.6 144.7 

3% 156.6 137.9 175.7 

3% plus CO2 

range 

118.4 to 264.0 99.7 to 245.2 137.5 to 283.0 

* The results include benefits to consumers which accrue after 2042 from the products purchased from 2013 through 

2042. Costs incurred by manufacturers, some of which may be incurred prior to 2013 in preparation for the rule, are 

indirectly included as part of incremental equipment costs. The Primary, Low Benefits, and High Benefits Estimates 

utilize forecasts of energy prices from the AEO2010 Reference case, Low Estimate, and High Estimate, 

respectively. 

** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 2010 under 

several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC distributions calculated 

using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.6 per ton represents the 

95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2010$) is 

the average of the low and high values used in DOE’s analysis. 

25 
 

 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent 

discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

DOE has tentatively concluded that the proposed standards represent the maximum 

improvement in energy efficiency that is technologically feasible and economically justified, and 

would result in the significant conservation of energy. DOE further notes that products achieving 

these standard levels are already commercially available for all product classes covered by 

today’s proposal for EPSs, other than product class H (high-power EPSs). Based on the analyses 

described above, DOE has tentatively concluded that the benefits of the proposed standards to 

the Nation (energy savings, positive NPV of consumer benefits, consumer LCC savings, and 

emission reductions) would outweigh the burdens (loss of INPV for manufacturers and LCC 

increases for some consumers). 

DOE also considered more-stringent and less stringent energy use levels as trial standard 

levels, and is still considering them in this rulemaking. However, DOE has tentatively concluded 

that the potential burdens of the more-stringent energy use levels would outweigh the projected 

benefits. Based on consideration of the public comments DOE receives in response to this notice 

and related information collected and analyzed during the course of this rulemaking effort, DOE 

may adopt energy use levels presented in this notice that are either higher or lower than the 

proposed standards, or some combination of level(s) that incorporate the proposed standards in 

part. 

Battery Chargers 

26 
DOE’s analyses for battery chargers indicate that the proposed standards would save a 

significant amount of energy over 30 years (2013–2042) ― an estimated 1.36 quads of 

cumulative energy for battery chargers. 

The product classes at issue are comprised of the groupings of battery chargers listed in 

Table I-7. Each product class grouping was established based on the battery charger’s 

input/output type, and further divided into product classes according to battery energy and 

voltage. 

Table I-7. Battery Charger Product Classes 

Product Class 

# 

Input / Output 

Type 

Battery 

Energy 

(Wh) 

Special 

Characteristic or 

Battery Voltage 

Product Class 

Description 

1 

AC In, 

DC Out 

< 100 

Inductive 

Connection 

Low-Energy, 

Inductive 

2 < 4 V Low-Energy, 

Low-Voltage 

3 4 – 10 V Low-Energy, MediumVoltage 

4 > 10 V Low-Energy, 

High-Voltage 

5 

100–3000 

< 20 V Medium-Energy, LowVoltage 

6 ≥ 20 V Medium-Energy, HighVoltage 

7 > 3000 - High-Energy 

8 DC In, 

DC Out 

- < 9 V Input Low-Voltage 

DC Input 

9 - ≥ 9 V Input High-Voltage 

DC Input 

10a AC In, 

AC Out 

-

Basic (i.e. no 

Automatic Voltage 

Regulation) 

10a 

10b - Contains Automatic 

Voltage Regulation 10b 

27 
The cumulative national net present value (NPV) of total consumer costs and savings of 

the proposed standards in 2010$ ranges from $6.04 billion (at a 7-percent discount rate) to 

$10.96 billion (at a 3-percent discount rate) for battery chargers. This NPV expresses the 

estimated total value of future operating-cost savings minus the estimated increased product 

costs for products purchased in 2013–2042, discounted to 2011. 

In addition, the proposed standards would have significant environmental benefits. The 

savings would result in cumulative greenhouse gas emission reductions of 62.9 Mt of CO2 in 

2013–2042. During this period, the proposed standards would result in emissions reductions of 

52 thousand tons of NOX and 0.35 tons of mercury. DOE estimates the net present monetary 

value of the CO2 emissions reduction is between $0.27 and $4.04 billion, expressed in 2010$ and 

discounted to 2011. DOE also estimates the net present monetary value of the NOX emissions 

reduction, expressed in 2010$ and discounted to 2011, is between $8.19 and $84.14 million at a 

7-percent discount rate, and between $14.88 and $153.05 million at a 3-percent discount rate. 

The benefits and costs of today’s proposed standards, for products sold in 2013-2042, can 

also be expressed in terms of annualized values. The annualized monetary values are the sum of 

(1) the annualized national economic value of the benefits from consumer operation of products 

that meet the proposed standards (consisting primarily of operating cost savings from using less 

energy, minus increases in equipment purchase and installation costs, which is another way of 

representing consumer NPV), and (2) the annualized monetary value of the benefits of emission 

reductions, including CO2 emission reductions. The value of the CO2 reductions is calculated 

28 
using a range of values per metric ton of CO2 developed by a recent interagency process. The 

derivation of the SCC values is discussed in section IV.M. 

Although combining the values of operating savings and CO2 reductions provides a 

useful perspective, two issues should be considered. First, the national operating savings are 

domestic U.S. consumer monetary savings that occur as a result of market transactions while the 

value of CO2 reductions is based on a global value. Second, the assessments of operating cost 

savings and CO2 savings are performed with different methods that use quite different time 

frames for analysis. The national operating cost savings is measured for the lifetime of battery 

chargers shipped in 2013–2042. The SCC values, on the other hand, reflect the present value of 

all future climate-related impacts resulting from the emission of one ton of carbon dioxide in 

each year. These impacts continue well beyond 2100. 

Table I-8 shows the annualized values for today’s proposed standards for battery 

chargers. (All monetary values below are expressed in 2010$.) The results under the primary 

estimate are as follows. Using a 7-percent discount rate for benefits and costs other than CO2 

reduction, for which DOE used a 3-percent discount rate along with the SCC series 

corresponding to a value of $22.3/ton in 2010, the standards proposed in today’s rule result in 

$110.0 million per year in equipment costs savings, and the annualized benefits are 447.2 million 

per year in reduced equipment operating costs, $71.6 million in CO2 reductions, and $4.3 million 

in reduced NOX emissions. In this case, the benefit amounts to $633.0 million per year. Using a 

3-percent discount rate for all benefits and costs and the SCC series corresponding to a value of 

$22.3/ton in 2010, the standards proposed in today’s rule result in $107.9 million per year in 

29 
equipment costs savings, and the benefits are $485.2 million per year in reduced operating costs, 

$71.6 million in CO2 reductions, and $4.5 million in reduced NOX emissions. In this case, the net 

benefit amounts to $669.3 million per year. 

30 
 

 

 

 

Table I-8 Annualized Benefits and Costs of Proposed Standards for Battery Chargers 

Shipped in 2013-2042 

Discount Rate 

Primary 

Estimate* 

Low Net 

Benefits 

Estimate* 

High Net 

Benefits 

Estimate* 

Monetized (million 2010$/year) 

Benefits 

Operating Cost Savings 

7% 447.2 425.6 468.8 

3% 485.2 459.7 511.2 

CO2 Reduction at $4.9/t** 5% 19.3 19.3 19.3 

CO2 Reduction at $22.3/t** 3% 71.6 71.6 71.6 

CO2 Reduction at $36.5/t** 2.5% 111.5 111.5 111.5 

CO2 Reduction at $67.6/t** 3% 218.5 218.5 218.5 

NOX Reduction at $2,537/t** 

7% 4.3 4.3 4.3 

3% 4.5 4.5 4.5 

Total † 

7% plus CO2 

range 

470.7 to 670.0 449.1 to 648.4 492.4 to 691.6 

7% 523.1 501.5 544.7 

3% 561.3 535.8 587.4 

3% plus CO2 

range 

509.0 to 708.2 483.5 to 682.7 535.0 to 734.3 

Costs 

Incremental Product Costs9 7% (110.0) (110.0) (110.0) 

3% (107.9) (107.9) (107.9) 

Total Net Benefits 

Total † 

7% plus CO2 

range 

580.7 to 780.0 559.1 to 758.3 602.3 to 801.6 

7% 633.0 611.4 654.7 

3% 669.3 643.8 695.3 

3% plus CO2 

range 

616.9 to 816.2 591.4 to 790.7 643.0 to 842.2 

* The results include benefits to consumers which accrue after 2042 from the products purchased from 2013 through 

2042. Costs incurred by manufacturers, some of which may be incurred prior to 2013 in preparation for the rule, are 

indirectly included as part of incremental equipment costs. The Primary, Low Benefits, and High Benefits Estimates 

utilize forecasts of energy prices from the AEO2010 Reference case, Low Estimate, and High Estimate, respectively 

9

 The incremental product costs for battery chargers are negative because of a shift in technology from linear power 

supplies to switch mode power for the larger battery chargers in product classes 5, 6, and 7. 

31 
 

 

 

 

** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 2010 under 

several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC distributions calculated 

using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.6 per ton represents the 

95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2010$) is 

the average of the low and high values used in DOE’s analysis. 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent 

discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

DOE has tentatively concluded that the proposed standards represent the maximum 

improvement in energy efficiency that is technologically feasible and economically justified, and 

would result in the significant conservation of energy. DOE further notes that products achieving 

these standard levels are already commercially available for all product classes covered by 

today’s proposal for battery chargers, other than product class 10 (AC output). Based on the 

analyses described above, DOE has tentatively concluded that the benefits of the proposed 

standards to the Nation (energy savings, positive NPV of consumer benefits, consumer LCC 

savings, and emission reductions) would outweigh the burdens (loss of INPV for manufacturers 

and LCC increases for some consumers). 

DOE also considered more-stringent and less-stringent energy use levels as trial standard 

levels, and is still considering them in this rulemaking. However, DOE has tentatively concluded 

that the potential burdens of the more-stringent energy use levels would outweigh the projected 

benefits. Based on consideration of the public comments DOE receives in response to this notice 

and related information collected and analyzed during the course of this rulemaking effort, DOE 

may adopt energy use levels presented in this notice that are either higher or lower than the 

proposed standards, or some combination of level(s) that incorporate the proposed standards in 

part. 

32 
 

II. Introduction 

The following section briefly discusses the statutory authority underlying today’s 

proposal, as well as some of the relevant historical background related to the establishment of 

standards for battery chargers and EPSs. 

A. Authority 

Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), 

Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified) established the Energy Conservation Program 

for Consumer Products Other Than Automobiles,10 a program covering most major household 

appliances (collectively referred to as “covered products”), which includes battery chargers and 

EPSs. (42 U.S.C. 6295(u)) (DOE notes that under 42 U.S.C. 6295(m), the agency must 

periodically review its already established energy conservation standards for a covered product. 

Under this requirement, the next review that DOE would need to conduct must occur no later 

than six years from the issuance of a final rule establishing or amending a standard for a covered 

product.) 

Pursuant to EPCA, DOE’s energy conservation program for covered products consists 

essentially of four parts: (1) testing; (2) labeling; (3) the establishment of Federal energy 

conservation standards; and (4) certification and enforcement procedures. The Federal Trade 

Commission (FTC) is primarily responsible for labeling, and DOE implements the remainder of 

the program. Subject to certain criteria and conditions, DOE is required to develop test 

10 For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A. 

33 
procedures to measure the energy efficiency, energy use, or estimated annual operating cost of 

each covered product. (42 U.S.C. 6293) Manufacturers of covered products must use the 

prescribed DOE test procedure as the basis for certifying to DOE that their products comply with 

the applicable energy conservation standards adopted under EPCA and when making 

representations to the public regarding the energy use or efficiency of those products. (42 U.S.C. 

6293(c)) Similarly, DOE must use these test procedures to determine whether the products 

comply with standards adopted pursuant to EPCA. See 42 U.S.C. 6295(s). As stated below in 

Section II.B.2 the DOE test procedures for battery chargers and EPSs currently appear at title 10, 

Code of Federal Regulations (CFR), part 430, subpart B, appendices Y and Z, respectively. 

DOE must follow specific statutory criteria when prescribing amended standards for 

covered products. As indicated above, any amended standard for a covered product must be 

designed to achieve the maximum improvement in energy efficiency that is technologically 

feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, EPCA precludes 

DOE from adopting any standard that would not result in the significant conservation of energy. 

(42 U.S.C. 6295(o)(3)) Moreover, DOE may not prescribe a standard: (1) for certain products, 

including battery chargers and EPSs, if no test procedure has been established for the product, or 

(2) if DOE determines by rule that the proposed standard is not technologically feasible or 

economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard 

is economically justified, DOE must determine whether the benefits of the standard exceed its 

burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving 

comments on the proposed standard, and by considering, to the greatest extent practicable, the 

following seven factors: 

34 
1. The economic impact of the standard on manufacturers and consumers of the products 

subject to the standard; 

2. The savings in operating costs throughout the estimated average life of the covered 

products in the type (or class) compared to any increase in the price, initial charges, or 

maintenance expenses for the covered products that are likely to result from the imposition of the 

standard; 

3. The total projected amount of energy, or as applicable, water, savings likely to result 

directly from the imposition of the standard; 

4. Any lessening of the utility or the performance of the covered products likely to result 

from the imposition of the standard; 

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

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

6. The need for national energy and water conservation; and 

7. Other factors the Secretary of Energy (Secretary) considers relevant. (42 U.S.C. 

6295(o)(2)(B)(i)(I)–( VII)) 

EPCA, as codified, also contains what is known as an “anti-backsliding” provision, 

which prevents the Secretary from prescribing any amended standard that either increases the 

maximum allowable energy use or decreases the minimum required energy efficiency of a 

covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or 

new standard if interested persons have established by a preponderance of the evidence that the 

standard is likely to result in the unavailability in the United States of any covered product type 

35 
(or class) of performance characteristics (including reliability), features, sizes, capacities, and 

volumes that are substantially the same as those generally available in the United States. (42 

U.S.C. 6295(o)(4)) 

Further, EPCA, as codified, establishes a rebuttable presumption that a standard is 

economically justified if the Secretary finds that the additional cost to the consumer of 

purchasing a product complying with an energy conservation standard level will be less than 

three times the value of the energy savings during the first year that the consumer will receive as 

a result of the standard, as calculated under the applicable test procedure. See 42 U.S.C. 

6295(o)(2)(B)(iii). 

Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating a standard 

for a type or class of covered product that has two or more subcategories. DOE must specify a 

different standard level than that which applies generally to such type or class of products for any 

group of covered products that have the same function or intended use if DOE determines that 

covered products within such group (A) consume a different kind of energy from that consumed 

by other covered products within such type (or class) or (B) have a capacity or other 

performance-related feature which other products within such type (or class) do not have and 

such feature justifies a higher or lower standard . (42 U.S.C. 6294(q)(1)). In determining whether 

a performance-related feature justifies a different standard for a group of products, DOE must 

consider such factors as the utility of the feature to the consumer and other factors DOE deems 

appropriate. Id. Any rule prescribing such a standard must include an explanation of the basis on 

which such higher or lower level was established. (42 U.S.C. 6295(q)(2)) 

36 
Federal energy conservation requirements generally supersede State laws or regulations 

concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)–(c)) DOE 

may, however, grant waivers of Federal preemption for particular State laws or regulations, in 

accordance with the procedures and other provisions set forth under 42 U.S.C. 6297(d). 

Finally, pursuant to the amendments contained in section 310(3) of EISA 2007, any final 

rule for new or amended energy conservation standards promulgated after July 1, 2010, are 

required to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) 

Specifically, when DOE adopts a standard for a covered product after that date, it must, if 

justified by the criteria for adoption of standards in under EPCA (42 U.S.C. 6295(o)), 

incorporate standby mode and off mode energy use into the standard, or, if that is not feasible, 

adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) 

DOE’s current test procedures for battery chargers and EPSs already address standby-mode and 

off-mode energy use. The standards for EPSs also address this energy use; currently there are no 

standards for battery chargers. In this rulemaking, DOE intends to incorporate such energy use 

into any new or amended energy conservation standards it adopts in the final rule. 

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued on 

January 18, 2011 (76 FR 3281 (Jan. 21, 2011)). EO 13563 is supplemental to and explicitly 

reaffirms the principles, structures, and definitions governing regulatory review established in 

Executive Order 12866. To the extent permitted by law, agencies are required by Executive 

Order 13563 to: (1) propose or adopt a regulation only upon a reasoned determination that its 

37 
benefits justify its costs (recognizing that some benefits and costs are difficult to quantify); (2) 

tailor regulations to impose the least burden on society, consistent with obtaining regulatory 

objectives, taking into account, among other things, and to the extent practicable, the costs of 

cumulative regulations; (3) select, in choosing among alternative regulatory approaches, those 

approaches that maximize net benefits (including potential economic, environmental, public 

health and safety, and other advantages; distributive impacts; and equity); (4) to the extent 

feasible, specify performance objectives, rather than specifying the behavior or manner of 

compliance that regulated entities must adopt; and (5) identify and assess available alternatives 

to direct regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can be 

made by the public. 

DOE emphasizes as well that Executive Order 13563 requires agencies “to use the best 

available techniques to quantify anticipated present and future benefits and costs as accurately as 

possible.” In its guidance, the Office of Information and Regulatory Affairs has emphasized that 

such techniques may include “identifying changing future compliance costs that might result 

from technological innovation or anticipated behavioral changes.” For the reasons stated in the 

preamble, DOE believes that today’s NOPR is consistent with these principles, including the 

requirement that, to the extent permitted by law, benefits justify costs and that net benefits are 

maximized. 

Consistent with EO 13563, and the range of impacts analyzed in this rulemaking, the 

energy efficiency standards proposed herein by DOE achieves maximum net benefits. 

38 
B. Background 

1. Current Standards 

Section 301 of EISA 2007 established minimum energy conservation standards for Class 

A EPSs, which became effective on July 1, 2008. (42 U.S.C. 6295(u)(3)(A)) These standards 

provided an active mode efficiency level and a no-load power consumption rate. The current 

standards are set forth in Table II.1 and Table II.2, respectively. 

Table II-1 Federal Active Mode Energy Efficiency Standards for Class A External Power 

Supplies 

Nameplate Output Power Active Mode Minimum Efficiency 

(decimal equivalent of a percentage) 

< 1 Watt 0.5*(nameplate_output) 

1 – 51 Watts 0.5+ 0.09*ln(nameplate_output) 

> 51 Watts 0.85 

Table II-2 Federal No-Load Mode Energy Efficiency Standards for Class A External 

Power Supplies 

Nameplate Output Power No-Load Mode Maximum Power 

Consumption 

≤ 250 Watts 0.5 Watts 

Currently, no Federal energy conservation standards apply to non-Class A EPSs or 

battery chargers. 

2. History of Standards Rulemaking for Battery Chargers and External Power Supplies 

Section 135 of the Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58 (Aug. 8, 

2005), amended sections 321 and 325 of EPCA by defining the terms “battery charger” and 

“external power supply.” That provision also directed DOE to prescribe definitions and test 

procedures related to the energy consumption of battery chargers and external power supplies 

39 
and to issue a final rule that determines whether energy conservation standards shall be issued 

for battery chargers and external power supplies or classes of battery chargers and external 

power supplies. (42 U.S.C. 6295(u)(1)(A) and (E)) 

On December 8, 2006, DOE complied with the first of these requirements by publishing a 

final rule that prescribed test procedures for a variety of products. 71 FR 71340, 71365-71375. 

That rule, which was codified in multiple sections of the Code of Federal Regulations (CFR), 

included definitions and test procedures for battery chargers and EPSs. As stated above, the test 

procedures for these products are found in 10 CFR Part 430, Subpart B, Appendix Y (“Uniform 

Test Method for Measuring the Energy Consumption of Battery Chargers”) and 10 CFR Part 

430, Subpart B, Appendix Z (“Uniform Test Method for Measuring the Energy Consumption of 

External Power Supplies”). 

On December 19, 2007, Congress enacted EISA 2007, which, among other things, 

amended sections 321, 323, and 325 of EPCA. As part of these amendments, EISA 2007 altered 

the EPS definition. Under the definition previously set by EPACT 2005, the statute defined an 

EPS as an external power supply circuit “used to convert household electric current into DC 

current or lower-voltage AC current to operate a consumer product.” (42 U.S.C. 6291(36)(A)) 

Section 301 of EISA 2007 amended that definition by creating a subset of EPSs called “Class A 

External Power Supplies.” This new subset of products consisted of those EPSs that can convert 

to only 1 AC or DC output voltage at a time and have a nameplate output power of no more than 

250 watts (W). The definition excludes any device requiring Federal Food and Drug 

Administration (FDA) listing and approval as a medical device in accordance with section 513 of 

40 
the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c) or one that powers the charger of a 

detachable battery pack or charges the battery of a product that is fully or primarily motor 

operated. (42 U.S.C. 6291(36)(C)) Section 301 of EISA 2007 also established energy 

conservation standards for Class A EPSs that became effective on July 1, 2008, and directed 

DOE to conduct an energy conservation standards rulemaking to review those standards. 

Additionally, section 309 of EISA 2007 amended section 325(u)(1)(E) of EPCA (42 

U.S.C. 6295(u)(1)(E)) by directing DOE to issue a final rule that prescribes energy conservation 

standards for battery chargers or classes of battery chargers or to determine that no energy 

conservation standard is technologically feasible and economically justified. DOE is bundling 

this battery charger rulemaking proceeding with the requirement to review and consider 

amending the energy conservation standards for Class A EPSs. The new rulemaking 

requirements contained in sections 301 and 309 of EISA 2007 effectively superseded the prior 

determination analysis that EPACT 2005 required DOE to conduct. 

Section 309 of EISA 2007 also instructed DOE to issue a final rule to determine whether 

DOE should issue energy conservation standards for external power supplies or classes of 

external power supplies no later than two years after EISA 2007’s enactment. 

(42 U.S.C. 6295(u)(1)(E)(i)(I)) Because Congress already set standards for Class A devices, 

DOE interpreted this determination requirement as applying solely to assessing whether energy 

conservation standards are warranted for EPSs that fall outside of the Class A definition (i.e. 

non-Class A EPSs). Non-Class A EPSs include those devices that have a nameplate output 

power greater than 250 watts, are able to convert to more than one AC or DC output voltage 

41 
 

simultaneously, and are specifically excluded from coverage under the Class A EPS definition in 

EISA 2007 by virtue of their application -- e.g., EPSs used with medical devices.11 DOE 

determined that standards are warranted for non-Class A EPSs. See 75 FR 27170 (May 14, 

2010). Given the similarities between battery chargers and non-Class A and Class A EPSs, DOE 

is handling all three product groups in a single standards rulemaking. 

Finally, section 310 of EISA 2007 established definitions for active, standby, and off 

modes, and directed DOE to amend its existing test procedures for battery chargers and EPSs to 

measure the energy consumed in standby mode and off mode. (42 U.S.C. 6295(gg)(2)(B)(i)) 

Consequently, DOE published a final rule incorporating standby- and off-mode measurements 

into the DOE test procedure. 74 FR 13318, 13334-13336 (March 27, 2009) Additionally, DOE 

amended the test procedure for battery chargers to include an active mode measurement for 

battery chargers and made certain amendments to the test procedure for EPSs. 76 FR 31750 

(June 1, 2011). 

DOE initiated its current rulemaking effort for these products by issuing the Energy 

Conservation Standards Rulemaking Framework Document for Battery Chargers and External 

Power Supplies (the framework document). See 

https://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/bceps_frameworkd 

ocument.pdf. The framework document explained the issues, analyses, and process DOE 

anticipated using to develop energy efficiency standards for those products. DOE also published 

11 To help ensure that the standards Congress set were not applied in an overly broad fashion, DOE applied the 

statutory exclusion not only to those EPSs that require FDA listing and approval but also to any EPS that provides 

power to a medical device. 

42 
a notice announcing the availability of the framework document, announcing a public meeting to 

discuss the proposed analytical framework, and inviting written comments concerning the 

development of standards for battery chargers and EPSs. 74 FR 26816 (June 4, 2009) 

DOE held a public meeting on July 16, 2009, to discuss the analyses and issues identified 

in the framework document. At the meeting, DOE described the different analyses it would 

conduct, the methods proposed for conducting them, and the relationships among the various 

analyses. Manufacturers, trade associations, environmental advocates, regulators, and other 

interested parties attended the meeting. The comments received at the public meeting and during 

the subsequent comment period helped DOE identify and resolve issues involved in this 

rulemaking. 

Following the framework document public meeting, DOE published on November 3, 

2009, a Notice of Proposed Determination to examine the feasibility and related economic costs 

and benefits of setting energy conservation standards for non-Class A EPSs. 74 FR 56928. This 

notice was followed by a final determination published on May 14, 2010, 75 FR 27170, which 

concluded that energy conservation standards for non-Class A EPSs appear to be technologically 

feasible and economically justified, and would be likely to result in significant energy savings. 

Consequently, DOE decided to include non-Class A EPSs in the present energy conservation 

standards rulemaking for battery chargers and EPSs. 

DOE then gathered additional information and performed preliminary analyses for the 

purpose of developing potential amended energy conservation standards for Class A EPSs and 

43 
 

new energy conservation standards for battery chargers and non-Class A EPSs. This process 

culminated in DOE’s announcement in the Federal Register on September 15, 2010, of the 

preliminary analysis public meeting, at which DOE discussed and received comments on the 

following matters: the product classes DOE analyzed; the analytical framework, models, and 

tools that DOE was using to evaluate potential standards; the results of the preliminary analyses 

performed by DOE; and potential standard levels under consideration. 75 FR 56021 (the 

September 2010 notice). DOE also invited written comments on these subjects and announced 

the availability on its website of a preliminary technical support document (preliminary TSD) it 

had prepared to inform interested parties and enable them to provide comments.12 Id. Finally, 

DOE stated its interest in receiving views concerning other relevant issues that participants 

believed would affect energy conservation standards for battery chargers and EPSs, or that DOE 

should address in this NOPR. Id. at 56024. 

The preliminary TSD provides an overview of the activities DOE undertook in 

developing standards for battery chargers and EPSs, and discusses the comments DOE received 

in response to the framework document. It also describes the analytical framework that DOE 

used (and continues to use) in this rulemaking, including a description of the methodology, the 

analytical tools, and the relationships among the various analyses that are part of the rulemaking. 

The preliminary TSD presents and describes in detail each analysis DOE had performed up to 

that point, including descriptions of inputs, sources, methodologies, and results. These analyses 

were as follows: 

12 The preliminary TSD is available at: 

<http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external_preliminaryanalysis_tsd.h 

tml> 

44 
• A market and technology assessment addressed the scope of this rulemaking, identified 

the potential classes for battery chargers and EPSs, characterized the markets for these products, 

and reviewed techniques and approaches for improving their efficiency; 

• A screening analysis reviewed technology options to improve the efficiency of battery 

chargers and EPSs, and weighed these options against DOE’s four prescribed screening criteria: 

(1) technological feasibility, (2) practicability to manufacture, install, and service, (3) impacts on 

equipment utility or equipment availability, (4) adverse impacts on health or safety; 

• An engineering analysis estimated the increases in manufacturer selling prices (MSPs) 

associated with more energy-efficient battery chargers and EPSs; 

• An energy use analysis estimated the annual energy use in the field of battery chargers 

and EPSs as a function of efficiency levels; 

• A markups analysis converted estimated manufacturer selling price (MSP) increases 

derived from the engineering analysis to consumer prices; 

• A life-cycle cost analysis calculated, at the consumer level, the discounted savings in 

operating costs throughout the estimated average life of the product, compared to any increase in 

installed costs likely to result directly from the imposition of a given standard; 

45 
• A payback period (PBP) analysis estimated the amount of time it would take consumers 

to recover the higher expense of purchasing more energy efficient products through lower 

operating costs; 

• A shipments analysis estimated shipments of battery chargers and EPSs over the 30­

year analysis period (2013-2042), which were used in performing the national impact analysis 

(NIA); 

• A national impact analysis assessed the national energy savings (NES), and the national 

net present value of total consumer costs and savings, expected to result from specific, potential 

energy conservation standards for battery chargers and EPSs; and 

• A preliminary manufacturer impact analysis took the initial steps in evaluating the 

effects new or amended efficiency standards may have on manufacturers. 

In the September 2010 notice, DOE summarized the nature and function of the following 

analyses: (1) engineering, (2) energy use analysis, (3) markups to determine installed prices, (4) 

LCC and PBP analyses, and (5) national impact analysis. Id. at 56023-56024. 

DOE held a public meeting on October 13, 2010, to discuss its preliminary analysis. At 

this meeting, DOE presented the methodologies and results of the analyses set forth in the 

preliminary TSD. Major topics discussed at the meeting included, among others, the regulation 

of EPSs for motorized applications and applications with detachable batteries (MADB EPSs), 

46 
 

criteria for establishing separate product classes, and assumptions made by DOE on the usage of 

certain products. The comments received since publication of the September 2010 notice, 

including those received at the preliminary analysis public meeting, have contributed to DOE’s 

proposed resolution of the issues noted by interested parties. This NOPR quotes and summarizes 

many of these comments, and responds to the issues they raised.13 

DOE received written comments on the preliminary analysis from four industry groups 

(the Association of Home Appliance Manufacturers (AHAM, No. 42); the Consumer Electronics 

Association (CEA, No. 46), the Power Tool Institute, Inc. (PTI, No. 45); and the Wireless Power 

Consortium (WPC, No. 40)), six manufacturers (Cobra Electronics Corp. (Cobra, No. 51); Lester 

Electrical of Nebraska, Inc. (Lester) (Lester, No. 50); Motorola, Inc. (Motorola, No. 48); Philips 

Electronics North America Corp. (Philips, No. 41); Stanley Black & Decker (SBD, No. 44); and 

Wahl Clipper Corporation (Wahl, No. 53)), and several energy efficiency advocates, including a 

number of utilities (Pacific Gas and Electric Company, San Diego Gas and Electric Company, 

Southern California Gas Company, and Southern California Edison, collectively organized as the 

California Investor Owned Utilities (California IOUs, No. 43); Northeast Energy Efficiency 

Partnerships (NEEP, No. 49); and a joint comment from Pacific Gas and Electric Company, 

Southern California Gas Company, San Diego Gas and Electric Company, Southern California 

Edison, Appliance Standards Awareness Project, Northeast Energy Efficiency Partnerships, 

Northwest Energy Efficiency Alliance, American Council for an Energy-Efficient Economy, and 

Natural Resources Defense Council (PG&E, et al., No. 47)). These commenters, along with 

13 A parenthetical reference at the end of a quotation or paraphrase provides the location of the item in the public 

record. 

47 
 

 

 

those that provided oral comments at the preliminary analysis public meeting, are summarized in 

Table II-2. 

Table II-2 Stakeholders Providing Comments on the Preliminary Analysis 

Name Abbreviation Type* Oral 

Comments 

Written 

Comments 

Association of Home Appliance 

Manufacturers AHAM IR  

California Investor-Owned Utilities California IOUs U 

Cobra Electronics Corp. Cobra M 

Consumer Electronics Association CEA IR 

Earthjustice EarthJustice EA 

Ecos Consulting on behalf of Pacific Gas 

and Electric ECOS EA 

Fulton Innovation Fulton Innovation M 

Lester Electrical Lester M 

Motorola Motorola M 

Northeast Energy Efficiency 

Partnerships NEEP EA 

Pacific Gas and Electric and others PG&E, et al. U 

Philips Electronics North America Philips M  

Power Tool Institute PTI IR 

Stanley Black & Decker SBD M  

Wahl Clipper Wahl Clipper M 

Wireless Power Consortium WPC IR 

*IR: Industry Representative; M: Manufacturer; EA: Efficiency/Environmental Advocate; CA: Consumer Advocate; 

CS: Component Supplier: TE: Technical Expert: I: Individual; U: Utility; UA: Utility Advocate; FG: Foreign 

Government Agency 

Following the close of the formal public comment period, DOE also received a 

clarification statement regarding an earlier submission to which ASAP joined with other 

commenters (ASAP, No. 55) and a proposal for DOE to adopt an efficiency marking protocol for 

battery chargers from the Natural Resources Defense Council (NRDC, No. 56). 

III. General Discussion 

The following section discusses various technical aspects related to this proposed 

rulemaking. In particular, it addresses aspects involving the test procedures for battery chargers 

and EPSs, the technological feasibility of potential standards to assign to these products, and the 

48 
potential energy savings and economic justification for prescribing the proposed amended 

standards for battery chargers and EPSs. 

A. Test Procedures 

To help analyze the proposal for the products covered under today’s rulemaking, DOE 

applied the recently amended test procedures for EPSs and battery chargers. The following 

sections explain how DOE applied these procedures in evaluating the standards that are being 

proposed. 

1. External Power Supply Test Procedures 

DOE used its recently modified EPS test procedure as the basis for evaluating EPS 

efficiency in the NOPR. This procedure, which was recently codified in appendix Z to subpart B 

of 10 CFR Part 430 (“Uniform Test Method for Measuring the Energy Consumption of EPSs”), 

includes a means to account for the energy consumption from multiple-voltage EPSs and 

clarifies the manner in which to test those devices that communicate with their loads. See 76 FR 

31750, 31782-31783 (June 1, 2011). The term “load communication” refers to the ability of an 

EPS to identify whether a given load is compatible with the product that is being powered. See 

id. at 31752-31753. 

The amended test procedure produces two key outputs relevant to today’s proposal. In 

particular, the procedure provides measurements for active mode efficiency and no-load mode 

power consumption. For single output voltage EPSs, active-mode conversion efficiency is the 

ratio of output power to input power. DOE averages the efficiency at four loading conditions— 

49 
25, 50, 75, and 100 percent of maximum rated output current. For multiple-voltage EPSs, the test 

procedure produces these same four efficiency measurements, but does not average them. For 

both single-voltage and multiple-voltage EPSs, DOE measures the power consumption of the 

EPS when disconnected from the consumer product, which is termed no-load power 

consumption. If the EPS has an on-off switch, the switch is placed in the “on” position when 

making this measurement. 

2. Battery Charger Test Procedures 

The initial battery charger test procedure, 71 FR 71340, 71368 (Dec. 8, 2006), included a 

means to measure battery charger energy consumption in “maintenance” and “no-battery” 

modes. These are non-active modes of operation for a battery charger and neither mode is the 

primary (i.e. active) mode of operation for a battery charger. A battery charger is in maintenance 

mode when the battery it is designed to charge is fully charged, but is still plugged into the 

charger -- i.e. the charger is maintaining the charge in the battery. Standby mode, also known as 

no-battery mode, occurs when a battery charger is plugged into the wall (or power source), but 

the battery has been removed. The test procedure was amended to include measurements (or 

metrics) to account for the energy consumption that takes place in a battery charger during all 

modes of operation -- active (i.e. the energy consumed by a battery charger while charging a 

battery), maintenance (i.e. the energy consumed to maintain the charge of a battery that has 

already been fully charged), standby (the energy consumed when a battery charger is plugged in, 

but the battery is removed from the device), and off (i.e. the energy consumed while a charger is 

plugged in but is switched off) modes. 76 FR 31750. 

50 
In analyzing the various products in preparation of the preliminary analysis, DOE relied 

on a test procedure that was largely based on a procedure that had been developed by the 

California Energy Commission (CEC). That procedure also served as the basis for DOE’s 2010 

proposal to amend the procedure to account for active mode energy consumption during testing. 

75 FR 16958 (April 2, 2010). 

The proposed procedure DOE employed had two key differences from the CEC 

procedure. First, it employed a shortened test procedure for battery chargers whose output power 

to the battery stabilizes within 24 hours. Second, the procedure employed a reversed 

charge/discharge testing order from that specified in the CEC procedure. DOE proposed 

switching the order such that the proposal used a preparatory charge, followed by a measured 

discharge, followed by a measured charge. The final rule dropped this approach in favor of the 

order prescribed in the CEC procedure -- i.e. preparatory discharge, a measured charge, and a 

measured discharge. DOE applied this amended test procedure when analyzing the potential 

energy efficiency levels for battery chargers. 

B. Technological Feasibility 

The following sections address the manner in which DOE assessed the technological 

feasibility of potential standard levels. Energy conservation standards promulgated by DOE must 

be technologically feasible. Separate analyses were conducted for EPSs and battery chargers. 

1. General 

In each standards rulemaking, DOE conducts a screening analysis based on information 

gathered on all current technology options and prototype designs that have the potential to 

51 
improve product or equipment efficiency. To conduct the analysis, DOE develops a list of design 

options for consideration in consultation with manufacturers, design engineers, and other 

interested parties. DOE then determines which of these means for improving efficiency are 

technologically feasible. DOE considers a design option to be technologically feasible if it is 

currently in use by the relevant industry, or if a working prototype exists. See 10 CFR part 430, 

subpart C, appendix A, section 4(a)(4)(i), which provides that “[t]echnologies incorporated in 

commercially available products or in working prototypes will be considered technologically 

feasible.” 

Once DOE has determined that particular design options are technologically feasible, it 

evaluates each of these design options using the following additional screening criteria: (1) 

practicability to manufacture, install, or service; (2) adverse impacts on product utility or 

availability; and (3) adverse impacts on health or safety. (10 CFR part 430, subpart C, appendix 

A, section 4(a)(4)). Section IV.B of this notice discusses the results of the screening analysis for 

battery chargers and EPSs, particularly the designs DOE considered, those it screened out, and 

those that are the basis for the trial standard levels (TSLs) in this rulemaking. 

For further details on the screening analysis for this rulemaking, see chapter 4 of the 

TSD. 

Additionally, DOE notes that it has received no interested party comments regarding 

patented technologies and proprietary designs that would prohibit all manufacturers from 

achieving the energy conservation standards proposed in today’s rule. At this time, DOE believes 

52 
 

 

that the proposed standards for the products covered as part of this rulemaking will not mandate 

the use of any such technologies, but requests additional information regarding proprietary 

designs and patented technologies. 

2. Maximum Technologically Feasible Levels 

When proposing an amended standard for a type or class of covered product, DOE must 

‘‘determine the maximum improvement in energy efficiency or maximum reduction in energy 

use that is technologically feasible’’ for such product. (42 U.S.C. 6295(p)(1)). DOE determined 

the maximum technologically feasible (“max-tech”) efficiency level, as required by section 

325(o) of EPCA, by interviewing manufacturers, vetting their data with subject matter experts, 

and presenting the results for public comment. (42 U.S.C. § 6295(o)). 

a. External Power Supply Max-Tech Levels 

DOE conducted several rounds of interviews with manufacturers of EPSs, integrated 

circuits for EPSs, and applications using EPSs. All of the manufacturers interviewed identified 

ways that EPSs could be modified to achieve efficiencies higher than those available with current 

products. These manufacturers also described the costs of achieving those efficiency 

improvements, which DOE examines in detail in chapter 5 of the TSD. DOE independently 

verified the accuracy of the information described by manufacturers.14 Verifying this information 

required examining and testing products at the best-in-market efficiency level and determining 

14 In confirming this information, DOE obtained technical assistance from two subject matter experts -- Robert 

Gourlay of RDG Engineering in Northridge, CA. and Jon Wexler, an independent and solo consultant in Los 

Angeles, CA. These two experts were selected after having been found through the Institute of Electrical and 

Electronics Engineers (IEEE). Together, they have over 30 years of combined experience with power supply design. 

The experts relied on their years of experience to evaluate the validity of both the design and the general cost of the 

max-tech efficiency levels provided by manufacturers. 

53 
what design options could still be added to improve their efficiency. By comparing the improved 

best-in-market designs (using predicted performance and cost) to the estimates provided by 

manufacturers, DOE was able to assess the reasonableness of the max-tech levels developed. 

DOE solicited comment on its review of the max-tech CSLs prepared for the preliminary 

analysis – particularly with respect to its initial view that 2.5W EPSs may be able to achieve a 

max-tech efficiency of 80% rather than the lower efficiency suggested by manufacturers (See 

Chapter 5 of the TSD for details on how DOE aggregated manufacturer data). During interviews 

conducted in preparation for the NOPR, manufacturers confirmed that an 80% efficiency level is 

achievable for 2.5W EPSs, but not without a decrease in utility. Manufacturers stated that 

reaching that efficiency level would require an increase in the form factor (i.e. the geometry of 

the design), which would make these devices larger. The increased size of the EPS would, in the 

manufacturers’ views, constitute a decreased utility that would be undesirable to consumers 

because of demands for smaller and lighter products. In light of this possibility, DOE used a 

max-tech efficiency value of 74.8%, which represents the average max-tech efficiency level 

predicted by manufacturers, to characterize CSL 4. The aggregated responses from 

manufacturers are discussed in chapter 5 of the TSD. 

DOE created the max-tech (CSL 4) equations for average efficiency and no-load power 

using curve-fits (i.e. creating a continuous mathematical expression to represent the trend of the 

data as accurately as possible) of the aggregated manufacturer data (see chapter 5 of the TSD for 

details on curve fits). DOE created the equations for no-load power based on a curve fit of the 

no-load power among the four representative units. For both the average efficiency and no-load 

54 
power CSL equations, DOE used equations similar to those for CSL 1, involving linear and 

logarithmic terms in the nameplate output power. DOE chose the divisions at 1 watt and 49 watts 

in the CSL 4 equations to ensure consistency with the nameplate output power divisions between 

the equations for CSL 1. 

In the determination for non-Class A EPSs, DOE created CSLs based on test and 

teardown data as well as manufacturer interview data consistent with the Class A EPS 

methodology. See 75 FR 27170, 27174-27175. DOE also stated in Chapter 5 of the preliminary 

analysis TSD that it might further evaluate additional CSLs should that become necessary 

pending later analysis, including revising the max-tech CSLs for all the representative units. 

For the NOPR, DOE has chosen to add a new max-tech CSL for high-power EPSs while 

the max-tech for multiple-voltage EPSs remains unchanged from the preliminary analysis. Based 

on its analysis, DOE ascertained that 345W EPSs are able to achieve comparable efficiencies to 

120W EPSs because efficiency tends to improve with higher nameplate output power before 

leveling off regardless of output power. Because of the diminishing returns of this trend, there 

would be no appreciable difference in the achievable efficiency of a 120W EPS and a 345W 

EPS. Therefore, DOE scaled its 120W EPS cost-efficiency curve using its voltage scaling 

method, outlined in Chapter 5 of the TSD, to generate the max-tech CSL for 345W EPSs. The 

max-tech no-load metric was chosen by assuming that three 120W EPSs could theoretically be 

connected to deliver 345 watts to a load (i.e. three 120W EPSs yield a 360W load). 

Consequently, in analyzing the potential cost-efficiency curves for these products, the no-load 

55 
metric DOE created for CSL 4 is three times greater than the no load used for the 120W 

equivalent CSL. 

b. Battery Charger Max-Tech Levels 

The preliminary analysis did not include max-tech efficiency levels for five of the ten 

product classes that are being addressed today. DOE omitted levels for these product classes 

because manufacturers did not provide information on levels of performance that would be 

technologically feasible and more efficient than the current best-in-market devices. DOE’s 

preliminary analyses typically rely heavily on manufacturer input in framing potential max-tech 

levels for discussion and comment. 

In preparing today’s NOPR, which includes max-tech levels for the ten classes initially 

addressed in DOE’s preliminary analysis, DOE developed a means to create max-tech levels for 

those classes that were previously not assigned max-tech levels. For the product classes that 

DOE was previously unable to generate max-tech efficiency levels, DOE used multiple 

approaches to develop levels for these classes. DOE once again solicited manufacturers for 

information and extrapolated performance parameters from its best-in-market efficiency levels. 

Extrapolating from the best-in-market performance efficiency levels required an examination of 

the devices. From this examination, DOE determined which design options could be applied and 

what affects they would likely have on the various battery charger performance parameters. The 

table below shows the reduction in energy consumption when increasing efficiency from the 

baseline to the max-tech efficiency level. 

56 
 

 

Table III-1. Reduction in Energy Consumption at Max-Tech for Battery Chargers 

Product Class 

Max-Tech Unit Energy 

Consumption 

(kWh/yr) 

Reduction of Energy 

Consumption Relative to 

the Baseline (Percentage) 

1 

(Low-Energy, Inductive) 1.29 85 

2 

(Low-Energy, Low-Voltage) 0.81 91 

3 

(Low-Energy, Medium-Voltage) 0.75 94 

4 

(Low-Energy, High-Voltage) 3.01 92 

5 

(Medium-Energy, Low-Voltage) 15.35 82 

6 

(Medium-Energy, High-Voltage) 16.79 86 

7 

(High-Energy) 131.44 46 

8 

(DC to DC, < 9V Input) 0.19 79 

9 

(DC to DC, ≥ 9V Input) 0.13 83 

10a 

(AC Output, No AVR) 4.95 92 

10b 

(AC Output, AVR) 8.58 92 

Additional discussion of DOE’s max-tech efficiency levels and comments received in 

response to the preliminary analysis can be found in the discussion of candidate standard levels 

in section IV.C.2.d. Specific details regarding which design options were considered for the 

max-tech efficiency levels (and all other CSLs) can be found in Chapter 5 of the accompanying 

TSD. 

C. Energy Savings 

The following discussion addresses the various steps DOE used to assess the potential 

energy savings that DOE projects will likely accrue from the various standard levels that were 

examined. 

57 
 

1. Determination of Savings 

DOE used its NIA spreadsheet model to estimate energy savings from amended standards 

for the battery chargers and EPS products that are the subject of this rulemaking.15 For each TSL, 

DOE forecasted energy savings beginning in 2013, the year that manufacturers would be 

required to comply with amended standards, and ending in the last year products shipped in 2042 

would be retired. DOE quantified the energy savings attributable to each TSL as the difference in 

energy consumption between the standards case and the base case. The base case represents the 

forecast of energy consumption in the absence of amended mandatory efficiency standards and 

considers market demand for more-efficient products. 

The NIA spreadsheet model calculates the electricity savings in “site energy” expressed 

in kilowatt-hours (kWh). Site energy is the energy directly consumed by battery chargers and 

EPSs at the locations where they are used. DOE reports national energy savings on an annual 

basis in terms of the aggregated source (primary) energy savings, which is the savings in the 

energy that is used to generate and transmit the site energy. (See chapter 10 of the TSD.) To 

convert site energy to source energy, DOE derived annual conversion factors from the model 

used to prepare the Energy Information Administration’s (EIA) Annual Energy Outlook 2010 

(AEO2010). 

2. Significance of Savings 

As noted above, 42 U.S.C. 6295(o)(3)(B) any standard that DOE sets must result in 

“significant” energy savings. While the term “significant” is not defined in the Act, the U.S. 

15 The NIA spreadsheet model is described in section IV.G of this notice. 

58 
Court of Appeals, in Natural Resources Defense Council v. Herrington, 768 F.2d 1355, 1373 

(D.C. Cir. 1985), indicated that Congress intended “significant” energy savings in this context to 

be savings that were not “genuinely trivial.” The energy savings for all of the TSLs considered in 

this rulemaking are nontrivial, and, therefore, DOE considers them “significant” within the 

meaning of section 325 of EPCA. 

D. Economic Justification 

This section summarizes the manner in which DOE estimated the economic impacts for 

the various potential standards that it evaluated. Among the aspects considered by DOE were the 

economic impacts on both manufacturers and consumers, life cycle costs, the amount of 

projected energy savings, product utility and performance, impacts on competition, and the 

general need to conserve energy. 

1. Specific Criteria 

As noted in section II.B, EPCA provides seven factors to be evaluated in determining 

whether a potential energy conservation standard is economically justified. (42 U.S.C. 

6295(o)(2)(B)(i)) The following sections discuss how DOE has addressed each of those seven 

factors in this rulemaking. 

a. Economic Impact on Manufacturers and Consumers 

In determining the impacts of new and amended standards on manufacturers, DOE first 

determines the quantitative impacts using an annual cash-flow approach. This step includes both 

a short-term assessment—based on the cost and capital requirements during the period between 

59 
the issuance of a regulation and when entities must comply with the regulation—and a long-term 

assessment over a 30-year analysis period. The industry-wide impacts analyzed include INPV 

(which values the industry on the basis of expected future cash flows), cash flows by year, 

changes in revenue and income, and other measures of impact, as appropriate. Second, DOE 

analyzes and reports the impacts on different types of manufacturers, including impacts on small 

manufacturers. Third, DOE considers the impact of standards on domestic manufacturer 

employment and manufacturing capacity, as well as the potential for standards to result in plant 

closures and loss of capital investment. Finally, DOE takes into account cumulative impacts of 

different DOE regulations and other regulatory requirements on manufacturers. 

For individual consumers, measures of economic impact include the changes in LCC and 

the PBP associated with new or amended standards. The LCC, specified separately in EPCA as 

one of the seven factors to be considered in determining the economic justification for a new or 

amended standard, 42 U.S.C. 6295(o)(2)(B)(i)(II), is discussed in the following section. For 

consumers in the aggregate, DOE also calculates the national net present value of the economic 

impacts on consumers over the forecast period used in a particular rulemaking. 

b. Life-Cycle Costs 

The LCC is the sum of the purchase price of a product (including its installation) and the 

operating expense (including energy and maintenance expenditures) discounted over the lifetime 

of the product. For each battery charger product class and EPS representative unit, DOE 

calculated both LCC and LCC savings for various efficiency levels. The LCC analysis required a 

60 
variety of inputs, such as product prices, electricity prices, product lifetimes, base case efficiency 

distributions, annual unit energy consumption, and discount rates. 

To characterize variability in electricity pricing, DOE established regional differences in 

electricity prices. To account for uncertainty and variability in other inputs, such as discount 

rates, DOE used a distribution of values with probabilities assigned to each value. DOE then 

sampled the values of these inputs from the probability distributions for each consumer. The 

analysis produced a range of LCCs. A distinct advantage of this approach is that DOE can 

identify the percentage of consumers achieving LCC savings due to an increased energy 

conservation standard, in addition to the average LCC savings. DOE presents only average LCC 

savings in this NOPR; however, additional details showing the distribution of results can be 

found in chapter 8 and appendix 8B of the TSD. 

In the LCC analysis, DOE determined the input values for a wide array of end-use 

applications that are powered by battery chargers or EPSs. There are typically multiple 

applications within every representative unit and product class that DOE analyzed. As such, 

DOE considered a wide array of input values for each unit analyzed. The lifetime, markups, base 

case market efficiency distribution, and unit energy consumption all vary based on the 

application. In the analysis, DOE sampled an application based on its shipment-weighting within 

the representative unit or product class. When an application was sampled, its unique inputs were 

selected for calculating the LCC and PBP. For further detail regarding application sampling, see 

appendix 8C of the TSD. 

61 
In its written comments, AHAM stated that the MIA and LCC calculations should be the 

most important considerations when determining where to set the standard level. (AHAM, No. 

42 at p. 15) DOE considered many criteria when selecting the proposed standard level, including 

impacts on manufacturers, consumers, the Nation, and environmental impacts. DOE weighed the 

impacts from each of these analyses in determining the proposed standard level. 

c. Energy Savings 

While significant conservation of energy is a separate statutory requirement for imposing 

an energy conservation standard, EPCA requires DOE, in determining the economic justification 

of a standard, to consider the total projected energy savings that are expected to result directly 

from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) DOE uses the NIA spreadsheet results in its 

consideration of total projected energy savings. 

d. Lessening of Utility or Performance of Products 

In establishing classes of products, and in evaluating design options and the impact of 

potential standard levels, DOE sought to develop standards for EPSs and battery chargers that would 

not lessen the utility or performance of these products. None of the TSLs presented in today’s NOPR 

would substantially reduce the utility or performance of the products under consideration in the 

rulemaking. DOE received no comments that standards for battery chargers and EPSs would increase 

their size and reduce their convenience, increase the length of time to charge a product, shorten the 

intervals between chargers, or any other significant adverse impacts on consumer utility. However, 

based on DOE’s preliminary examination of the information before it, including interviews with 

manufacturers, manufacturers may reduce the availability of features that increase energy use, such 

as LED indicator lights, in an effort to meet any standard levels promulgated as a result of this 

62 
rulemaking. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Manufacturers indicated that these changes would only 

be made if their customers would not be averse to the change in utility. DOE requests interested party 

feedback, including any substantive data, regarding today’s proposed standard levels and the 

potential for lessening of utility or performance related features. 

e. Impact of Any Lessening of Competition 

EPCA directs DOE to consider any lessening of competition that is likely to result from 

standards. It also directs the Attorney General of the United States (Attorney General) to 

determine the impact, if any, of any lessening of competition likely to result from a proposed 

standard and to transmit such determination to the Secretary within 60 days of the publication of 

a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii)) DOE has transmitted a copy of today’s proposed rule to the 

Attorney General and has requested that the Department of Justice (DOJ) provide its 

determination on this issue. DOE will address the Attorney General’s determination, if any, in 

the final rule. 

f. Need for National Energy Conservation 

Certain benefits of the proposed standards are likely to be reflected in improvements to 

the security and reliability of the Nation’s energy system. Reductions in the demand for 

electricity may also result in reduced costs for maintaining the reliability of the Nation’s 

electricity system. DOE conducts a utility impact analysis to estimate how standards may affect 

the Nation’s needed power generation capacity. 

63 
Energy savings from the proposed standards are also likely to result in environmental 

benefits in the form of reduced emissions of air pollutants and greenhouse gases associated with 

energy production. DOE reports the environmental effects from the proposed standards for 

battery chargers and EPSs, and from each TSL it considered, in the environmental assessment 

contained in chapter 15 of the TSD. DOE also reports estimates of the economic value of 

emissions reductions resulting from the considered TSLs in chapter 16 of the TSD. 

2. Rebuttable Presumption 

As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that 

an energy conservation standard is economically justified if the additional cost to the consumer 

of a product that meets the standard is less than three times the value of the first year of energy 

savings resulting from the standard, as calculated under the applicable DOE test procedure. 

DOE’s LCC and PBP analyses generate values used to calculate the payback period of potential 

standards for consumers. These analyses include, but are not limited to, the 3-year payback 

period contemplated under the rebuttable presumption test. However, DOE routinely conducts an 

economic analysis that considers the full range of impacts to the consumer, manufacturer, 

Nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this 

analysis serve as the basis for DOE to definitively evaluate the economic justification for a 

potential standard level, thereby supporting or rebutting the results of any preliminary 

determination of economic justification. The rebuttable presumption payback calculation is 

discussed in section V.B.1.c of this NOPR and chapter 8 of the TSD. 

64 
 

IV. Methodology and Discussion 

DOE used three spreadsheet tools to estimate the impact of today’s proposed standards. 

The first spreadsheet calculates LCCs and payback periods of potential standards. The second 

provides shipments forecasts, and then calculates national energy savings and net present value 

impacts of potential standards. Finally, DOE assessed manufacturer impacts, largely through use 

of the Government Regulatory Impact Model (GRIM). All three spreadsheet tools will be made 

available online at the rulemaking website: 

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

Additionally, DOE estimated the impacts on utilities and the environment that would be 

likely to result from the setting of standards for battery chargers and EPSs. DOE used a version 

of EIA’s National Energy Modeling System (NEMS) for the utility and environmental analyses. 

The NEMS model simulates the energy sector of the U.S. economy. EIA uses NEMS to prepare 

its Annual Energy Outlook, a widely known energy forecast for the United States. The version of 

NEMS used for appliance standards analysis is called NEMS-BT16, and is based on the AEO 

version with minor modifications.17 NEMS-BT offers a sophisticated picture of the effect of 

standards because it accounts for the interactions between the various energy supply and demand 

sectors and the economy as a whole. 

16 BT stands for DOE’s Building Technologies Program. 

17 The EIA allows the use of the name “NEMS” to describe only an AEO version of the model without any 

modification to code or data. Because the present analysis entails some minor code modifications and runs the 

model under various policy scenarios that deviate from AEO assumptions, the name “NEMS-BT” refers to the 

model as used here. For more information on NEMS, refer to The National Energy Modeling System: An Overview, 

DOE/EIA–0581 (98) (Feb.1998), available at: http://tonto.eia.doe.gov/FTPROOT/forecasting/058198.pdf. 

65 
A. Market and Technology Assessment 

When beginning an energy conservation standards rulemaking, DOE develops 

information that provides an overall picture of the market for the products concerned, including 

the purpose of the products, the industry structure, and market characteristics. 

This activity includes both quantitative and qualitative assessments, based primarily on publicly 

available information. The subjects addressed in the market and technology assessment for this 

rulemaking include a determination of the scope of this rulemaking; product classes and 

manufacturers; quantities and types of products sold and offered for sale; retail market trends; 

regulatory and non-regulatory programs; and technologies or design options that could improve 

the energy efficiency of the product(s) under examination. See chapter 3 of the TSD for further 

detail. 

1. Products Included in this Rulemaking 

This section addresses the scope of coverage for today’s proposal, stating which products 

would be subject to new or amended standards. The numerous comments DOE received on the 

scope of today’s proposal are also summarized and addressed in this section. 

a. External Power Supplies 

The term “external power supply” refers to an external power supply circuit that is used 

to convert household electric current into DC current or lower-voltage AC current to operate a 

consumer product. (42 U.S.C. 6291(36)(A)) EPCA, as amended by EISA 2007, also prescribes 

the criteria for a subcategory of EPSs—those classified as Class A EPSs (or in context, “Class 

A”). A Class A EPS is a device that: 

66 
1.	 is designed to convert line voltage AC input into lower voltage AC or DC output; 

2.	 is able to convert to only one AC or DC output voltage at a time; 

3.	 is sold with, or intended to be used with, a separate end-use product that constitutes 

the primary load; 

4.	 is contained in a separate physical enclosure from the end-use product; 

5.	 is connected to the end-use product via a removable or hard-wired male/female 

electrical connection, cable, cord, or other wiring; and 

6. has nameplate output power that is less than or equal to 250 watts. 

See 42 U.S.C. 6291(36)(C)(i). 

The Class A definition excludes any device that either (a) requires Federal Food and 

Drug Administration listing and approval as a medical device in accordance with section 513 of 

the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360c) or (b) powers the charger of a 

detachable battery pack or charges the battery of a product that is fully or primarily motor 

operated. See 42 U.S.C. 6291(36)(C)(ii). 

Based on DOE’s examination of product information, all EPSs appear to share four of the 

six criteria under the Class A definition in that all are: 

 designed to convert line voltage AC input into lower voltage AC or DC output; 

 sold with, or intended to be used with, a separate end-use product that constitutes the 

primary load; 

 contained in a separate physical enclosure from the end-use product; and 

67 
	 connected to the end-use product via a removable or hard-wired male/female 

electrical connection, cable, cord, or other wiring. 

DOE refers to an EPS that falls outside of Class A as a non-Class A EPS (or, in context, 

“non-Class A”). Examples of such devices include EPSs that can convert power to more than one 

output voltage at a time (multiple voltage), EPSs that have nameplate output power exceeding 

250 watts (high-power), EPSs used to power medical devices, and EPSs that provide power to 

the battery chargers of motorized applications and detachable battery packs (MADB). After 

examining the potential for energy savings that could result from standards for non-Class A 

devices, DOE concluded that standards for these devices would be likely to result in significant 

energy savings and be technologically feasible and economically justified. 75 FR 27170 (May 

14, 2010). Thus, DOE is examining the possibility of setting standards for all types of EPSs 

within the scope of today’s notice. 

In the preliminary analysis, DOE treated only those wall adapters that lacked charge 

control as EPSs; those with charge control were not considered to be EPSs. (Charge control 

relates to regulating the amount of current being delivered to a battery.) Under that approach, a 

given wall adapter without charge control capability could be considered both as an EPS and as a 

part of a battery charger. If that approach were adopted, such a wall adapter would be subject to 

whatever EPS standard that DOE may set and would also, indirectly, help the battery charger of 

which it is a part to meet whatever battery charger standard that DOE may set. In essence, the 

EPS would need to satisfy a prescribed level of efficiency, which could create certain design 

restrictions on manufacturers seeking to optimize the overall efficiency of the battery charger. 

68 
In the following paragraphs, DOE summarizes and addresses the comments it received on 

(1) whether to set EPS standards for wall adapters that are part of battery chargers, (2) whether 

the absence of charge control circuitry should be the basis for regulating such wall adapters, and 

(3) if so, appropriate methods for determining whether a given wall adapter contains charge 

control. DOE received a few comments urging DOE to regulate these types of EPSs -- which are 

part of a battery charger system -- as part of the overall battery charger and also as an EPS to 

help ensure that whatever EPS is used in such a charger system meets a minimum level of 

efficiency. Several other parties, however, objected to requiring that these EPSs also meet 

separate EPS standards. Comments focused mainly on MADB EPSs, but some pertained to EPSs 

generally. In response to these comments, DOE is proposing a new approach, namely, to 

evaluate whether an EPS can directly operate an end-use consumer product and to create a new 

product class for those EPSs that cannot directly operate an end-use consumer product. DOE is 

considering this approach in light of the substantial resistance by the industry to the initial 

approach presented during the preliminary analysis phase. 

Energy efficiency advocates favored requiring certain EPSs that are part of battery 

chargers to also meet separate EPS standards—in particular, for those EPSs that do not perform 

charge control functions. PG&E, et al. expressed their strong support for this approach and cited 

research showing that improving the efficiency of a power supply helps improve the efficiency 

of a battery charger. In addition, PG&E commented that a single EPS definition (rather than one 

for Class A and another for non-Class A) would reduce the complexity of compliance and 

enforcement as well as the potential for loopholes. (PG&E, et al., No. 47 at p. 3-4) NEEP also 

69 
expressed its support for this approach and added that DOE's initial research shows that there are 

a limited number of cases where EPSs would be regulated under both standards. (NEEP, No. 49 

at pp. 1-2) The California IOUs and PG&E, et al. expressed their support for using the ENERGY 

STAR EPS definition to determine whether a wall adapter is an EPS. (California IOUs, No. 43 at 

p. 9; PG&E, et al., No. 47 at p. 4) 

AHAM, PTI, and Wahl Clipper agreed with DOE and the efficiency advocates that 

MADB wall adapters should be regulated, but not under multiple efficiency requirements. 

Instead, they urged DOE to regulate these items as battery charger components but not as EPSs. 

(AHAM, No. 42 at pp. 2, 3, 13; PTI, No. 45 at p. 4; Wahl, No. 53 at p. 1) PTI argued that a 

MADB wall adapter cannot be an EPS because it is not used "to operate a consumer product." 

According to PTI, a MADB wall adapter operates a battery charger, but a battery charger is not a 

consumer product because battery chargers are not themselves "distributed in commerce for 

personal use or consumption by individuals." Thus, in its view, MADB wall adapters are not 

EPSs. (PTI, No. 45 at pp. 3-4; Pub. Mtg. Tr., No. 57 at p. 74) AHAM argued that subjecting a 

product to multiple energy efficiency requirements (1) “makes no sense,” (2) could cause 

manufacturers to be in "constant redesign mode" if EPS and battery charger standards change at 

different times, and (3) would be an undue burden. (AHAM, No. 42 at pp. 4-5) AHAM 

contended further that the EPS active mode test is inappropriate and inaccurate for MADB wall 

adapters, as they are never used in the manner tested under that procedure. Consequently, in 

AHAM's view, requiring that these types of wall adapters be tested under the EPS test procedure 

would not enable DOE to meet its obligation to test products in a manner representative of their 

actual use. (AHAM, No. 42 at p. 6) Wahl Clipper echoed AHAM's concerns that the EPS test 

70 
procedure is inappropriate for MADB wall adapters and noted that unsynchronized battery 

charger and EPS standards would force manufacturers to constantly redesign their products. 

Wahl Clipper added that manufacturers "do not know if future standards levels will make it 

impossible to meet both regulations at the same time since there is no correlation between the 

two regulations." (Wahl, No. 53 at p. 1) 

Others had similar concerns about setting standards for Class A devices that are part of 

battery chargers. CEA, Cobra Electronics, and Motorola objected to regulating any wall adapter 

as both an EPS and a component of a battery charger. These parties drew attention to the burden 

that multiple energy efficiency requirements would impose on manufacturers—small businesses 

in particular. CEA commented that its "foremost concern is DOE's contemplation of a 'double 

jeopardy' regulatory situation whereby a single charging device would be subject to two different 

test procedures and two different sets of regulatory requirements," and added that such a 

situation would be "unreasonable and unnecessary—and would be particularly onerous for small 

businesses." (CEA, No. 46 at pp. 1-2) Cobra Electronics, which markets and sells two-way 

radios and mobile navigation devices, commented that “having to be regulated under two 

standards for a product which is infrequently used is an unreasonable burden for small 

companies when added to the burden of other recent regulations." (Cobra, No. 51 at p. 1) 

Motorola also agreed with CEA that the energy efficiency of EPSs should not be regulated in 

two different product categories (battery chargers and EPSs) and added that “given the likely 

high performance standards that will be set for battery chargers, it would be nearly impossible 

for an external power supply to comprise part of a [standards-compliant] battery charger if it 

were not itself highly efficient.” (Motorola, No. 48 at pp. 1-2) 

71 
AHAM also asserted that DOE risks overestimating energy savings if it does not 

determine how to remove the overlap between battery charger and EPS energy savings. AHAM 

emphasized the importance of accurately quantifying the extent to which energy savings from 

battery charger and EPS standards might overlap so that DOE can accurately project the potential 

energy savings from potential standards. (AHAM, Pub. Mtg. Tr., No. 57 at p. 112) 

After carefully considering all of these comments, DOE has tentatively decided to adopt a 

broad scope and to propose an approach in which EPS standards could apply to all devices that 

meet the EPS definition prescribed by EPCA. See 42 U.S.C. 6291(36)(A). Those standards 

prescribed by Congress, namely, those for Class A devices, will remain in effect, and DOE, 

despite the objections raised by CEA and others, has no authority to remove these standards, 

although these standards could be amended to increase their stringency. With regard to non-Class 

A EPSs that are components of battery chargers, DOE has the option to propose new efficiency 

standards for these devices, including those devices that perform charge control functions. 

To help it ascertain whether a given wall adapter performs charge control functions, DOE 

sought comment during the preliminary analysis phase on seven methods it presented to 

determine whether charge control is present in a wall adapter. See Preliminary TSD, appendix 3­

C (detailing the methods DOE considered for determining whether a wall adapter contains 

charge control). In the preliminary analysis, DOE used a method it called "Energy Star 

Inspection," which is based on parts (f) and (g) of the ENERGY STAR program’s definition of 

an EPS. ("ENERGY STAR Program Requirements for Single Voltage External Ac-Dc and Ac72 
 

Ac Power Supplies, Eligibility Criteria (Version 2.0)"18) This method considers certain easily 

observable physical characteristics of the wall adapter. Under this approach, a wall adapter that 

meets either of the following two criteria would be exempt from having to satisfy separate EPS 

standards and would instead be treated simply as a battery charger component: (1) the wall 

adapter has batteries or battery packs that physically attach directly (including those that are 

removable) to the power supply unit; OR (2) the wall adapter has a battery chemistry or type 

selector switch AND an indicator light or state of charge meter. 

As noted above, DOE received comments from the California IOUs and PG&E that 

supported using this method. PTI contended that DOE neglected to include MADB wall adapters 

in its preliminary assessment of the seven methods and requested that DOE include these 

products in any future analysis of possible charge control criteria. (PTI, No. 45 at p. 4) AHAM 

viewed the presence of charge control in a wall adapter as irrelevant. In its view, DOE should 

ask whether a given wall adapter is a MADB device, as all MADB wall adapters should be 

excluded from any EPS standards. (AHAM, No. 42 at p. 12) DOE received no other comments 

on the appropriateness of the Energy Star Inspection method or any of the six other methods it 

considered for identifying charge control in wall adapters. 

At this time, DOE does not believe that such an exclusion from the EPS scope of 

coverage is warranted. It is DOE’s understanding that most, if not all, of the MADB wall 

adapters that DOE proposes to add to the EPS scope of coverage are already subject to, and 

satisfy, the EPS standards currently in place in California. The California standard applies the 

18 http://www.energystar.gov/ia/partners/product_specs/program_reqs/eps_prog_req.pdf 

73 
 

 

 

same efficiency level that already applies to Class A EPSs nationwide. See California Energy 

Commission, "2009 Appliance Efficiency Regulations," August 2009, CEC-400-2009-013, 

Table U-1 on p. 134. This efficiency level is referred to as Level IV in the International 

Efficiency Marking Protocol for External Power Supplies.19 Comments from manufacturers and 

the California IOUs also support this finding. (California IOUs, No. 43 at p. 9) DOE is not aware 

of any products powered by battery chargers and EPSs that are not designed, manufactured, and 

packaged for distribution throughout the country. 

It is DOE’s understanding that products that use EPSs are designed, manufactured and 

packaged for distribution throughout the United States. Assuming that this understanding is 

correct, that fact indicates it is highly unlikely that manufacturers are producing one set of 

products for California and another set for the remaining states. 

Notably, California's EPS standards apply only to devices that meet the ENERGY STAR 

definition of an EPS,20 but do not meet the Class A definition established by EISA 2007. 

(California Energy Commission, "2009 Appliance Efficiency Regulations," August 2009, CEC400-2009-013) This situation stems in large part from California’s adoption of the ENERGY 

19 U.S. EPA, "International Efficiency Marking Protocol for External Power Supplies," October 2008, available at 

Docket No. 62. 

20 For the purposes of EPA's ENERGY STAR specification, an external power supply: (a) is designed to convert line 

voltage ac input into lower voltage ac or dc output; (b) is able to convert to only one output voltage at a time; (c) is 

sold with, or intended to be used with, a separate end-use product that constitutes the primary load; (d) is contained 

in a separate physical enclosure1 from the end-use product; (e) is connected to the end-use product via a removable 

or hard-wired male/female electrical connection, cable, cord or other wiring; (f) does not have batteries or battery 

packs that physically attach directly (including those that are removable) to the power supply unit; (g) does not have 

a battery chemistry or type selector switch AND an indicator light or state of charge meter (e.g., a product with a 

type selector switch AND a state of charge meter is excluded from this specification; a product with only an 

indicator light is still covered by this specification); and (h) has nameplate output power less than or equal to 250 

watts. (See http://www.energystar.gov/ia/partners/product_specs/program_reqs/eps_prog_req.pdf.) 

74 
STAR definition of an EPS when it first established energy conservation standards for these 

devices. Once Congress subsequently established standards for Class A EPSs, these Class A 

devices were removed from the scope of the California standards, leaving behind a set of devices 

California now refers to as "state-regulated EPSs." As a result, these state-regulated EPSs are 

those devices that meet the ENERGY STAR definition of an EPS but do not fall under the Class 

A definition -- specifically medical and MADB EPSs. (Multiple-voltage and high-power EPSs 

do not meet the ENERGY STAR definition but satisfy the Federal definition of an EPS.) 

Due to differences between the ENERGY STAR and Federal statutory definitions of an 

EPS, there could be MADB devices that meet the Federal statutory definition that are not stateregulated. For example, a MADB EPS that has a battery type selector switch and an indicator 

light, and thus does not meet the ENERGY STAR definition of an EPS, would not be covered 

either by the current Federal or California standards. However, as a practical matter, DOE has 

not identified any MADB products that meet the Federal statutory definition of an EPS but do 

not also meet the ENERGY STAR definition. Thus, DOE is unaware of any MADB products 

that are not already subject to California energy efficiency standards that are within the EPS 

scope of coverage being contemplated today. DOE seeks comment on the accuracy of this belief 

and specific examples of such products, if they exist. 

As noted above, some parties commented that requiring wall adapters that are part of 

battery chargers to be tested according to the EPS test procedure would impose an undue burden 

on manufacturers and would be inappropriate and result in inaccurate projections of estimated 

energy savings. In response to these comments, DOE notes that Congress prescribed the 

75 
 

definitions of what constitutes an EPS. It did not provide for any exceptions that would exclude 

those EPSs that are components of another product. Given this situation, DOE must assume that 

Congress was aware of the fact that some battery chargers use EPSs and that it structured these 

statutory provisions to allow for the possibility that all EPSs would be required to meet some 

minimum level of efficiency that would also improve the efficiency of those products that used 

these more efficient devices. 

As to how to measure the energy performance of these devices, DOE believes that these 

wall adapters can be evaluated using the existing EPS test procedure. See 10 CFR part 430, 

subpart B, appendix Z (detailing the procedure to follow when measuring the energy 

consumption of an EPS). In fact, this test procedure already is used to demonstrate compliance 

with existing Federal standards, in the case of Class A EPSs, and California standards, in the 

case of most MADB EPSs.21 The test procedure is designed to assess the energy performance of 

an EPS while in active mode by measuring its active-mode efficiency at 25, 50, 75, and 100 

percent of nameplate output current and then computing the simple arithmetic average of these 

four values. DOE believes that this test procedure yields a meaningful and representative 

measure of an EPS's active-mode efficiency because, along with the no-load mode power 

measurement, it covers the full range of outputs the device may be called on to provide in the 

field. This is true of EPSs that are not part of battery chargers as well as those that are. Thus, the 

EPS test procedure is appropriately applied to all EPSs, including those that are part of battery 

chargers. 

21 California has adopted the Federal EPS test procedure as part of its regulatory requirements. (California Code of 

Regulations, Title 20, Section 1604) 

76 
Regarding PTI's argument that MADB wall adapters cannot, by definition, be EPSs 

because they operate battery chargers (which, in its view, are not consumer products), DOE 

disagrees. First, a battery charger is a consumer product by virtue of its inclusion by Congress 

under Part A of EPCA, 42 U.S.C. 6291(32), which addresses the regulation of consumer 

products. A consumer product is any article of a type that consumes or is designed to consume 

energy and which, to any significant extent, is distributed in commerce for personal use or 

consumption by individuals. See 42 U.S.C. 6291(1). The fact that a battery charger is a device 

that charges batteries for consumer products does not imply that chargers are not themselves 

consumer products, particularly since the definition contemplates the inclusion of those devices 

“in other consumer products, “ which indicates that Congress viewed battery chargers as a 

separate, and individual, consumer product. 

Second, EPSs are also consumer products for similar reasons. 

Third, a MADB wall adapter satisfies the EPS definition since it “convert[s] household 

electric current... to operate a consumer product." See 42 U.S.C. 6291(36)(A) (emphasis added). 

Whether the MADB wall adapter is considered to operate a battery charger, which is a consumer 

product, or is considered to enable the end-use consumer product to operate (by supplying 

energy to the battery, which in turn operates the end-use product), a MADB wall adapter falls 

squarely within the EPS definition because it is taking household electric current to operate a 

consumer product. Accordingly, in DOE’s view, MADB wall adapters are EPSs. 

77 
However, in view of the concerns raised by industry commenters, DOE believes there 

may be merit in distinguishing between a direct operation EPS and an indirect operation EPS. In 

particular, some EPSs are able to directly power an end-use consumer product (e.g., a wireless 

Internet router), while others cannot. This distinction may be necessary because DOE believes 

that less stringent EPS standards may be appropriate for indirect operation EPSs, which cannot 

directly operate an end-use consumer product. As explained later, DOE is proposing a means to 

differentiate between these two types of EPSs and to set different efficiency standards for them. 

DOE's proposed approach to regulating these products is described in more detail in sections 

IV.A.3 and V.C below. 

DOE notes that while Congress amended EPCA to exempt certain EPSs used in security 

and life safety alarms and surveillance systems from the no-load mode power requirements that 

apply generally to Class A EPSs manufactured prior to July 1, 2017, see Pub. L. 111-360 (Jan. 4, 

2011), such systems would be subject to the proposed active mode standards under consideration 

in this NOPR. See 42 U.S.C. 6295(u)(3)(E)(ii) (exempting security and life safety alarms and 

surveillance systems solely from no-load requirements). 

DOE further notes that it has recently identified an important emerging EPS application: 

solid-state lighting (SSL). SSL technology is used in both the residential and commercial sectors 

for desk lamps, under-cabinet lighting, accent lighting, and many other purposes. Most of the 

SSL luminaires (fixtures) DOE has identified have integral power supplies, but some use power 

supplies that appear to meet the EPS definition. Some of these EPSs plug into an outlet, while 

others are hard wired into the electrical system. DOE has not yet identified any relevant technical 

78 
differences between these EPSs and those for laptops, cell phones, and other electronic 

equipment that it has analyzed in detail as part of today’s notice. DOE did not include SSL 

technology in its NOPR analysis because so few SSL products with EPSs were sold in 2009, the 

base year for shipments. However, because of the rapid proliferation of these products, DOE 

may consider revising its analysis to include SSL products in determining the final standards for 

EPSs. DOE invites comment on SSL EPSs, specifically on whether there are any differences 

between SSL EPSs and other EPSs that might warrant treating them as a separate product class. 

b. Battery Chargers 

A battery charger is a device that charges batteries for consumer products, including 

battery chargers embedded in other consumer products. (42 U.S.C. 6291(32)) All devices that 

meet this definition are within the scope of this rulemaking. 

Like EPSs, battery chargers are used in conjunction with other end-use consumer 

products, such as cell phones and digital cameras. However, unlike EPSs, the battery charger 

definition prescribed by Congress is not limited solely to products powered from AC mains, i.e., 

those products that are plugged into a wall outlet. Further, battery chargers may be wholly 

embedded in another consumer product, wholly separate from another consumer product, or 

partially inside and partially outside another consumer product. 

The California IOUs commented that they "agree with DOE's wide-reaching consumer 

battery charger scope proposed in the preliminary [TSD]," as they believe "it will ultimately 

enable DOE to identify more cost-effective savings opportunities." (California IOUs, No. 43 at 

79 
 

 

p. 2) Several other parties requested that DOE exclude golf car chargers and in-vehicle chargers 

from potential battery charger regulations. 

Lester argued that "golf cars do not meet the definition of a consumer product" because 

they are primarily purchased by businesses rather than individuals, adding that the leading golf 

car manufacturer in the United States sells the vast majority of its golf cars to businesses rather 

than individuals -- specifically 96 percent in 2009 and 97.5 percent in 2010. (Lester, No. 50 at 

p. 1) 

As indicated above, the statutory definition of “consumer product” is a broad one. The 

extent of that breadth indicates that Congress had contemplated that this definition would 

encompass a wide variety of products. DOE’s research indicates that approximately 10.6 percent 

of all new battery-powered golf cars sold each year in the United States are sold to individuals.22 

While DOE has no reason to question Lester's claim that the leading golf car manufacturer sells 

almost all of its golf cars to businesses, there are clearly manufacturers that sell a significant 

number of golf cars to individuals. Further, there is no identifiable difference between battery 

chargers for golf cars sold to individuals and those for golf cars sold to golf courses and other 

businesses. Thus, DOE continues to believe that golf cars are a type of consumer product. The 

distinction between consumer products and industrial equipment has been previously addressed 

by DOE. See http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/cce_faq.pdf 

22 International Market Solutions, Golf Car-Type Vehicles and the Emerging Market for Small, Task-Oriented 

Vehicles in the United States; Trends 2000-2006, Forecasts to 2012, December 2007. For more information about 

this report or to purchase a copy, email icaworld@optonline.net. 

80 
Lester also commented that in certain industrial applications the benefits of less energyefficient, transformer-based battery chargers outweigh those of more energy-efficient, switch 

mode battery chargers and that business managers are skilled in making the proper choice of 

battery charger based on a consideration of all the relevant factors. (Lester, No. 50 at pp. 2-3) In 

this context, Lester argued that businesses that purchase golf cars should be allowed to make 

their own decisions regarding the energy performance of the battery chargers they purchase, 

implying that there is no need for energy conservation standards for this product. 

DOE notes that, in general, the energy conservation standards that it sets must satisfy a 

series of criteria. See generally 42 U.S.C. 6295(o). Among these criteria is the need to ensure the 

continued utility of the regulated product. Consistent with this requirement, DOE will take this 

factor into account when setting standards for battery chargers. 

CEA commented that because in-vehicle chargers do not consume energy from the utility 

grid, they should not be covered by DOE. (CEA, No. 46 at p. 3) Motorola made similar 

statements and concluded that electronics that do not connect to the utility grid should be 

excluded from coverage. Motorola added that since DOE could not demonstrate cost savings 

associated with the potential efficiency standards that were under consideration for these 

products, these devices should not be regulated. (Motorola, No. 48 at pp. 2, 3) Cobra also 

expressed concerns over this product class and stated that quantifying the effect of battery 

chargers that obtain energy from 12V car batteries seems inaccurate and urged DOE to drop this 

product class from consideration. Cobra added that it was too difficult to accurately assess the 

81 
economic impact of standards on 12V in-vehicle chargers because of difficulties inherent in 

accurately estimating gasoline savings. (Cobra, No. 51 at p. 3) 

DOE is aware that consumer products "designed solely for use in recreational vehicles 

and other mobile equipment" are, by law, specifically excluded from coverage as consumer 

products. (42 U.S.C. 6292) Thus, a battery charger designed solely for use in recreational 

vehicles (RVs) and other mobile equipment would not be subject to battery charger standards. 

DOE has identified several consumer products—most prominently portable GPS navigators— 

that are commonly sold with 12V power adapters. However, DOE is not aware of any batteryoperated consumer products that operate within a vehicle that cannot also be charged by alternate 

means, specifically from a 5V USB power source or from mains through a wall adapter. (For 

example, a GPS device may be plugged into a home computer via a USB port to receive power 

and to download data updates to the device’s memory.) In other words, these products are not 

designed solely for use in recreational vehicles and other mobile equipment. DOE seeks 

comment on whether any products exist that can only be operated on 12V. DOE also seeks 

comment on whether a device that can be powered only from a 12V power outlet can be assumed 

to be designed solely for use in recreational vehicles (RVs) and other mobile equipment, or 

whether other 12V power sources exist that could power battery chargers. Lastly, DOE seeks 

comment on whether there are battery chargers with DC inputs other than 5V and 12V. 

DOE also considered whether the above exclusion also applies to battery chargers that 

charge mobile equipment such as golf cars, wheelchairs, and electric scooters. DOE has 

preliminarily determined that this exclusion does not apply to those types of battery chargers, for 

82 
two reasons. First, the statute, by specifying that a device be “designed solely for use in” a 

recreational vehicle or mobile equipment, appears to exclude only those devices that obtain 

power from recreational vehicles and other mobile equipment, not those that provide power to 

recreational vehicles and other mobile equipment. For example, a refrigerator designed solely for 

use in an RV obtains its power from the RV and, thus, is not a covered product, whereas a 

battery charger that is designed solely to charge the batteries of an electric bicycle obtains its 

power from another power source external to the bicycle (e.g., AC mains) and, thus, is a covered 

product. Second, EPCA excludes from coverage those consumer products "designed solely for 

use in recreational vehicles and other mobile equipment." DOE has found that many battery 

chargers that charge mobile equipment are not contained entirely within that equipment, but 

rather operate only partly within, or entirely outside of, that equipment. (Examples of such 

chargers include those for many wheelchairs and lawn mowers.) In DOE’s view, such a device is 

not operated solely in the mobile equipment and, thus, is not excluded from coverage. DOE 

welcomes comment on whether its understanding of how these devices operate is accurate. 

As to the general concern regarding the calculation of potential benefits and savings from 

standards for in-vehicle chargers, DOE notes that it is no longer considering these savings in 

order to avoid any potential conflict with the exclusions set out in EPCA. 

c. Wireless Power 

The Wireless Power Consortium (WPC), which represents companies engaged in the 

emerging technology of wireless transfer of energy to both power and charge consumer products, 

commented that it does not believe that a “wireless power transducer is either an EPS or a battery 

charger” and recommended that a new category of inductive power supply be introduced for 

83 
power supplies having inductive output. WPC explained that it is possible for the various 

components needed for these products, such as the transmitter transducers and receiver 

transducers, to be manufactured by different companies and sold separately. WPC further noted 

that it has not yet been determined how to address the independence of transmitter and receiver 

transducers in regards to overall system efficiency. As a result, “requirements for efficiency 

should be deferred until the technology is better understood and methods for accurately 

measuring the efficiency are developed.” (WPC, No. 42 at p. 2) Similarly, CEA requested that 

DOE categorize wireless power systems independently of battery chargers or EPSs to avoid 

regulatory mandates that could harm innovation in the emerging area of wireless power. CEA 

cited the technology's ability to charge or interact with multiple devices for multiple purposes 

simultaneously and to provide real-time power to appliances without batteries at a variety of 

power levels and transmitting efficiencies. (CEA, No. 46 at pp. 2-3) Philips, in reference to 

wireless power, expressed concern that DOE “might inadvertently take regulatory action that 

could have the unintended effect of stifling this new technology.” (Philips, No. 41 at p. 3) 

DOE has observed that a number of new products have entered the marketplace in recent 

years that use wireless power technology in order to charge small consumer electronics products 

such as digital music players and mobile phones. Some of these products transfer power using 

induction while others use conduction or a galvanic (i.e., current-carrying) connection. Products 

are also sold in a variety of different configurations, as noted in WPC's comment, with some 

transmitters and receivers sold separately, while others are sold together as a system. 

84 
There are a number of different types of products under the broad umbrella of "wireless 

power," including both battery chargers and EPSs. DOE analyzed one type, namely inductive 

battery chargers for wet environments (product class 1), and is proposing standards for these 

products today. In the preliminary analysis, DOE did not differentiate any other wireless power 

battery chargers from their conventional wired counterparts. DOE continues to believe that 

wireless power products that meet the definition of a battery charger, whether inductive or 

galvanic, are covered products. 

However, DOE also agrees with CEA that the ability to charge multiple devices 

simultaneously and wirelessly offers a unique utility to consumers that could adversely and 

inadvertently be affected by standards. Because of this fact, and the immaturity of the 

technology, which collectively explain the absence of energy efficiency performance data on 

these products, DOE is not proposing standards for these types of products. Instead, DOE is 

proposing to create a separate product class for these products and to defer analysis of these 

products to a later standards rulemaking. Therefore, in today’s rulemaking, DOE has reserved a 

section in the CFR for an 11th battery charger product class for products that use wireless power, 

in a dry environment, to charge consumer products. 

With regard to the applicability of EPS standards to wireless power products, DOE 

reiterates that, by definition, an EPS "is used to convert household electric current into DC 

current or lower-voltage AC current to operate a consumer product." (42 U.S.C. 6291(36)(A)) 

Some wireless power transmitter pads are sold by themselves and, thus, are consumer products in 

their own right. Other wireless power transmitter pads are sold along with a power receiver. Such 

85 
a product constitutes a battery charger or a large portion of a battery charger, which also is a 

consumer product. Hence, in both cases, a wall adapter that provides power to the wireless power 

transmitter pad is an EPS. 

d. Unique Products 

Through additional market study of battery chargers and external power supplies since 

the preliminary analysis, DOE has found certain “unique” products that exhibit characteristics 

spanning several of the proposed BCEPS product classes, which make them difficult to classify 

within the scope of this rulemaking. These products possess traits inherent to both battery 

chargers and external power supplies and/or were designed for multiple simultaneous end-use 

consumer applications. In one example, a product DOE examined supplied power to an 

answering machine equipped with two charging stations for a wireless headset and a cordless 

handset. The power converter itself provided two separate outputs at the same nameplate output 

voltage, but with different current limits on each. One output was dedicated to charging the 

wireless headset and one output was used to power the answering machine and charge the 

cordless handset. Under the definitions DOE has used to classify battery chargers and EPSs to 

this point, this product could be considered a multiple-voltage EPS, a multi-port battery charger, 

or even a distinct single-voltage EPS and a battery charger depending on how the terms are 

applied. 

DOE has invested considerable effort in properly analyzing the design tendencies of 

battery chargers and EPSs and believes that the vast majority of these products can be classified 

under the definitions of this proposed rule. DOE also believes that manufacturers, who are most 

86 
familiar with how their products function and their intended use, should be able to appropriately 

determine what type of product they are selling and therefore which standard is appropriate 

based on DOE’s proposed definitions. DOE requests any interested party information regarding 

products that may seem to fall into multiple product classes. 

2. Market Assessment 

a. Market Survey 

To characterize the market for battery chargers and EPSs, DOE gathered information on 

the products that use them. DOE refers to these products as end-use consumer products or battery 

charger and EPS “applications.” This method was chosen for two reasons. First, battery chargers 

and EPSs are nearly always integrated into, bundled with, or otherwise intended to be used with 

a given application; therefore, the demand for applications drives the demand for battery 

chargers and EPSs. Second, because most battery chargers and EPSs are not stand-alone 

products, their usage profiles, energy consumption, and power requirements are all determined 

by the associated application. 

DOE began the development of the preliminary analysis by analyzing online and brickand-mortar retail outlets to determine which applications use battery chargers and EPSs and 

which battery charger and EPS technologies are most prevalent. Because the market for battery 

charger and EPS applications continues evolving, DOE updated the market survey to identify 

new applications and determine whether any relevant attributes of existing applications had 

changed significantly between the preliminary analysis and NOPR phases of the rulemaking. 

87 
In order to more accurately characterize the market for battery chargers and EPSs, DOE 

analyzed the following new applications: media tablets, mobile internet hotspots, smartphones, 

and wireless charging stations. To simplify the analysis, DOE removed external media drives, 

radio-controlled cars (hobby grade), and electronic pest repellents, all of which had low or 

unsupported shipments estimates. Battery chargers and EPSs for such applications and any other 

applications not explicitly analyzed in the market assessment would still be subject to the 

standards proposed in today’s notice as long as they meet the definition of a covered product 

outlined in sections A.1.a and A.1.b, above. DOE also combined Wi-Fi access points with LAN 

equipment and merged weed trimmers and hedge trimmers into a single application 

(rechargeable garden care products). Finally, DOE identified EPS applications that now also 

commonly contain rechargeable batteries and use battery chargers, including LAN equipment 

and video game consoles. Chapter 3 of the TSD discusses all of these market assessment updates 

in further detail. 

As noted in section IV.A.1.a above, DOE is considering including EPSs for SSL 

luminaires when it updates its analysis prior to issuing a final rule. DOE welcomes comment on 

the size of the market for these products, what proportion of SSL luminaires use EPSs, the 

efficiency of those EPSs, and usage patterns. 

The California IOUs suggested that DOE consider two additional products for inclusion 

in battery charger product class 10 (AC output): emergency uninterruptible power supplies 

(UPSs) for cordless phones and emergency backup for security systems. (California IOUs, No. 

43 at p. 7) Battery charger product class 10 is reserved for products that output AC power from 

88 
the battery. UPSs were the only applications that met this criterion. Due to the small number of 

UPSs for cordless phones shipped annually, DOE did not include this application in its 

quantitative analysis for product class 10, despite its inclusion in this class. DOE recognizes that 

many home security systems contain rechargeable emergency backup batteries; however, 

because those backup batteries output DC power in order to operate the electronics in the 

security system, DOE placed these chargers in product class 2. Although DOE recognizes that 

there are battery charger and EPS applications that it did not analyze, it tentatively believes that 

it has included within its analysis all major applications and, thus, has accurately characterized 

battery charger and EPS energy consumption and savings potential for each product class. 

b. Non-Class A External Power Supplies 

In addition, DOE expanded its analysis of applications that use non-Class A EPSs, 

including multiple-voltage and high-power EPSs, those EPSs that are used with medical devices, 

and EPSs used with (1) motor-operated battery charger applications and (2) the chargers of 

detachable batteries (i.e. collectively, MADB devices). In the preliminary analysis, DOE relied 

upon market information it had collected prior to publishing the notice of proposed 

determination for non-Class A EPSs in November 2009. Because updated information was 

available following the preliminary analysis, DOE revisited non-Class A EPSs while conducting 

its NOPR-phase market survey. 

DOE found that multiple-voltage EPSs are used in fewer applications today than they 

were at the time of the first survey. Specifically, DOE removed inkjet imaging equipment from 

89 
the multiple-voltage EPS product class, leaving the Xbox 360 (a video game console) as the only 

application for these devices. 

DOE also reclassified medical EPSs based on the power requirements stated on retailer 

websites and updated lifetime and shipments estimates for medical devices. Philips commented 

that medical devices are expected to last longer than other consumer products and suggested 

using expected lifetimes of six to ten years for these products. (Philips, No. 41 at pp. 2-3) In the 

preliminary analysis, DOE estimated the product lifetimes for all medical devices analyzed to be 

greater than six years based on input from medical EPS manufacturers. Philips’ comment, 

combined with independent market research, helped DOE to confirm its preliminary estimates 

for the NOPR. All of DOE's shipment and lifetime assumptions are documented in the market 

workbook that accompanies chapter 3 of the TSD. 

c. Application Shipments 

DOE relied on published market research to estimate base-year shipments for all 

applications. The base-year was changed from 2008 to 2009 for the NOPR, and application 

shipments were updated wherever supporting data were available. DOE estimated that in 2009 a 

total of 345 million EPSs and 437 million battery chargers shipped for final sale in the United 

States. Philips commented that DOE understated the shipments estimate for products in battery 

charger product class 1—inductive chargers for use in wet environments. In the preliminary 

analysis DOE assumed annual shipments of 5.35 million units, but Philips recommended using 

an estimate that is “closer to 15 million” units. (Philips, No. 41 at p. 2) Philips later explained 

90 
how it derived this estimate from proprietary market data and its knowledge of the toothbrush 

market. In the NOPR-stage analysis, DOE used the shipments estimate recommended by Philips. 

One significant update to the market assessment methodology was to estimate the 

proportion of battery chargers and EPSs used exclusively in the commercial sector. Commercial 

users pay commercial electricity rates, which are lower than residential electricity rates, and, 

therefore, the cost savings they would enjoy from an energy conservation standard would be 

lower. DOE identified applications that were likely to be used in office buildings, restaurants, or 

commercial construction sites, for example, in order to more accurately estimate energy cost 

savings in the life-cycle cost (LCC) analysis and national impact analysis. Data on commercial 

shipments were not readily available for most applications; therefore, DOE assumed similar 

commercial market shares among similar office and telecommunications applications. In the case 

of power tools, DOE assumed that commercial and residential spaces have similar repair and 

maintenance needs and, thus, used the ratio of commercial to residential floor space in the United 

States as a proxy for each sector's share of total power tool shipments. DOE seeks comment on 

which battery charger and EPS applications are used in the commercial sector, what fraction of 

shipments are to the commercial sector, and how product lifetimes and usage may differ between 

residential and commercial settings. (See Issue 2 under “Issues on Which DOE Seeks Comment” 

in section VII.E of this notice.) See chapter 3 of the TSD for more information on DOE’s 

commercial sector market share estimates. 

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d. Efficiency Distributions 

In the preliminary analysis, DOE estimated separate base-case market efficiency 

distributions for each battery charger product class and a single efficiency distribution for all 

Class A EPSs analyzed in the LCC and national impact analyses. AHAM commented that there 

are currently more EPSs in the market with efficiencies at levels higher than the EISA standard 

than what DOE estimated in the preliminary analysis; however, AHAM did not provide any 

specific data to support its claim. (AHAM, Pub. Mtg. Tr., No. 57 at p. 121) On the other hand, 

Cobra Electronics commented that most manufacturers of lower cost products use linear EPSs 

that just meet the current Federal standard rather than more efficient switch mode power supplies 

because of the higher costs involved with using that more efficient technology. (Cobra, No. 51 at 

p. 3) DOE incorporated these stakeholder comments into its updated efficiency distribution 

estimates but largely relied upon product testing and other market research to estimate base-case 

efficiency distributions. Further detail is contained in TSD chapter 3 and the accompanying 

analytical spreadsheet models. 

In preparing today’s NOPR, DOE revised its methodology for calculating efficiency 

distributions from test data. Instead of weighting results for each individual tested unit based on 

the shipments of the associated application, DOE gave equal weight to the results for each unit. 

For battery chargers and EPSs, DOE compared each test result to the proposed compliance 

curves for each candidate standard level (CSL). DOE then divided the number of units at a given 

CSL by the total number of tested units to estimate the percentage of units in the market. For 

select applications, DOE adjusted these distributions to reflect additional data or other market 

research about these applications. For EPSs, DOE also calculated the distribution of tested units 

92 
within the ranges of nameplate output power corresponding to the representative units of 

analysis. Finally, DOE continued to calculate the distribution of tested units within each battery 

charger product class. DOE assigned an efficiency distribution profile to each EPS and battery 

charger application based on application-specific data where possible. For applications that DOE 

did not test, DOE relied on product class (for battery chargers) or representative unit (for EPSs) 

distributions for use in the energy use analysis and LCC analysis. DOE calculated a shipmentweighted average efficiency distribution for each product class for use in the national impact 

analysis. For more detail, see sections IV.E, IV.F, and IV.G below, which discuss the energy use, 

life-cycle cost, and national impact analyses, respectively. 

3. Product Classes 

When necessary, DOE divides covered products into classes by the type of energy used, 

the capacity of the product, and any other performance-related feature that justifies different 

standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE then 

conducts its analysis and considers establishing or amending standards to provide separate 

standard levels for each product class. 

At the preliminary analysis public meeting, DOE presented its rationale for creating 15 

product classes for EPSs and 10 product classes for battery chargers. The product classes 

established for EPSs and battery chargers were based on various electrical characteristics shared 

by particular groups of products. As these electrical characteristics change, so does the utility and 

efficiency of the devices. 

93 
a. External Power Supply Product Classes 

In the preliminary analysis, DOE raised the possibility of creating product classes based 

on nameplate output power and nameplate output voltage. This approach was based on the 

framework set by EISA 2007 and ENERGY STAR 2.0, which, collectively, grouped EPSs in 

this manner. DOE also divided EPS product classes based on whether a device met the Class A 

definition, its application type (motorized or medical), its output power, its output current type, 

its output voltages, and the battery type (detachable) of the associated application. 

For Class A EPSs, the preliminary analysis divided these products into product classes 

A1, A2, A3, and A4 based on ENERGY STAR 2.0 criteria, which classify EPSs based on the 

type of power conversion (i.e., AC to DC or AC to AC) used and nameplate output voltage 

(i.e., low-voltage or basic-voltage). Each of these four product classes (A1-A4) from the 

preliminary analysis was created using these same criteria. The Class A EPS product classes 

were defined using the identical power conversion type and nameplate output voltage 

parameters as the ENERGY STAR program for EPSs. 

Consistent with this initial approach, DOE is proposing to adopt the ENERGY STAR 

definition for low-voltage EPSs. DOE received no comments on these class structures when it 

first raised them during the preliminary analysis phase. As a result, DOE is proposing to adopt 

these class structures as part of today’s proposal. Particularly, if a device has a nameplate 

output voltage of less than 6 volts and its nameplate output current is greater than or equal to 

550 milliamps, DOE is proposing to classify that device as a low-voltage EPS. Additionally, a 

product that does not meet the criteria for being a low-voltage EPS would be classified as a 

basic-voltage EPS. DOE is also proposing definitions for AC to DC and AC to AC EPSs. If an 

94 
EPS converts household electrical current to a lower voltage DC, DOE is proposing to classify 

that product as an AC to DC EPS. Similarly, DOE is proposing to classify a device that 

converts household electrical current to a lower voltage AC output as an AC to AC EPS. 

DOE’s preliminary analysis also explained how DOE was planning to organize nonClass A EPSs, which include medical, MADB, multiple-voltage, and high-power (nameplate 

output power > 250 Watts) EPSs, into product classes. In the preliminary analysis, DOE 

created product classes M1, M2, M3, and M4 for medical EPSs and B1, B2, B3, and B4 for 

MADB EPSs. As with Class A EPSs, DOE considered four product classes for these two 

groups of devices based on combinations of power conversion type and voltage level. 

Additionally, for MADB products, DOE determined whether a wall adapter for a MADB 

application lacked charge control, as defined in appendix 3C of the preliminary TSD, and 

therefore was a MADB EPS. For multiple-voltage EPSs, DOE considered the creation of two 

product classes – X1 and X2 – and for high-power EPSs, it considered only one, H1. In 

response to the preliminary analysis, DOE received comments on the product class definitions 

presented for MADB and multiple-voltage EPSs. The issues raised are discussed below. 

Indirect Versus Direct Operation External Power Supplies 

As noted in section IV.A.1, interested parties raised concerns with DOE’s proposed 

approach in the preliminary analysis regarding MADB EPSs. Based on these comments, DOE 

revised its approach and is no longer using the charge control method it had considered using 

during the preliminary analysis. Instead, DOE is proposing a simpler approach, which would 

require a manufacturer to determine whether an EPS can only “indirectly operate” an application. 

95 
DOE is proposing to define an indirect operation EPS as an EPS that cannot power a 

consumer product (other than a battery charger) without the assistance of a battery. In other 

words, if an end-use product only functions when drawing power from a battery, the EPS 

associated with that product is classified as an indirect operation EPS. Because the EPS must 

first deliver power and charge the battery before the end-use product can function as intended, 

DOE considers this device an indirect operation EPS and has defined a separate product class, N, 

for all such devices. Conversely, if the battery’s charge status does not impact the end-use 

product’s ability to operate as intended and the end-use product can function using only power 

from the EPS, DOE is proposing to treat that wall adapter as a direct operation EPS. 

DOE’s initial approach for determining whether a given EPS has direct operation 

capability involved removing the battery from the application and attempting to operate the 

application using only power from the EPS. While this approach gave the most definitive EPS 

classifications, this procedure had the potential of creating complications during testing since it 

can frequently necessitate the removal of integral batteries prior to testing. The removal of such 

batteries can often require access to internal circuitry via sealed moldings capable of shattering 

and damaging the application. 

DOE then developed a new method of testing to help minimize both the risk of damage to 

the application and the accompanying complexity associated with the removal of the internal 

batteries while ensuring testing accuracy. This approach would require product testers to 

determine whether an EPS can operate an end-use product once the associated battery has been 

96 
fully discharged. Based on product testing results, DOE believes that direct operation EPSs will 

be able to power the application regardless of the state of the battery while indirect-operation 

EPSs will need to charge the battery before the application can be used as intended. Comparing 

the time required for an application to operate once power is applied during fully discharged and 

fully charged battery conditions would provide a reliable indication of whether a given EPS is an 

indirect or direct operation device. Recording the time for the application to reach its intended 

functionality is necessary because certain applications, such as smartphones, contain firmware 

that can delay the EPS from operating the end-use product as expected. If the application takes 

significantly longer to operate once the battery has been fully discharged, DOE would view this 

EPS as one that indirectly operates the end-use consumer product and classify it as part of 

product class N. Using this methodology, DOE was also able to evaluate a given product’s EPS 

as it was intended to be used while limiting the burden of the test. The full procedure is detailed 

in Appendix 3C of the TSD and in the rule language section of today’s notice. 

Product class N that DOE is proposing in today’s notice contains both Class A and nonClass A EPSs. DOE believes that these two groups of devices are technically equivalent, i.e., 

there is no difference in performance-related features between the two groups that would justify 

different standard levels for the two groups. (42 U.S.C. 6295(q)) Because of this technical 

equivalency, DOE grouped these EPSs into one product class for analysis. DOE seeks comment 

on whether there are any performance-related features characteristic of either Class A or nonClass A devices (but not both) in product class N that would help justify analyzing the two 

groups separately. 

97 
If a product is capable of directly operating its end-use consumer product, other 

characteristics must be examined to determine the appropriate product class. In its preliminary 

analysis, DOE separated product classes based on combinations of their power conversion type 

and voltage level. DOE is proposing to use these class definitions based on those combinations 

but with one change. As shown in Table IV-1, DOE used four product classes for each 

combination of power conversion type and voltage level in the preliminary analysis for Class A 

EPSs, MADB EPSs, and medical EPSs. DOE also considered applying the results of the Class A 

engineering analysis directly to medical and MADB EPSs, meaning there would be no difference 

in the cost-efficiency curves or the product class divisions for Class A, medical, or MADB EPSs. 

DOE believed this was a valid approach because the costs associated with improving the 

efficiency of a medical or MADB EPS were identical to those associated with the same 

improvements in a comparable Class A EPS as all three types are technically equivalent. Due to 

these similarities, DOE believed that Class A, medical, and MADB EPSs should be evaluated 

identically. Interested parties did not comment on this simplified approach after it was presented 

during the preliminary analysis public meeting. 

Today’s NOPR proposes eliminating the disaggregation of Class A, medical, and MADB 

EPSs in its product class definitions. This consolidation would reduce the number of product 

classes covering these products from 12 in the preliminary analysis to five (B, C, D, E, and N) in 

the NOPR. Under this consolidated approach, product class B includes direct operation EPSs that 

are AC/DC and basic-voltage (i.e. do not qualify as low-voltage); product class C includes direct 

operation EPSs that are AC/DC and low-voltage (i.e. nameplate output voltage less than 6 volts 

and nameplate output current greater than or equal to 550 milliamps.); product class D includes 

98 
direct operation EPSs that are AC/AC and basic-voltage; product class E includes direct 

operation EPSs that are AC/AC and low-voltage; and product class N includes all indirect 

operation EPSs. 

Table IV-1 Preliminary Analysis Product Classes 

Voltage Level 

Basic (Not LowVoltage) Low (<6V, ≥550mA 

outputs) 

Power 

Conversion 

Type 

AC input, 

DC output A1, B1, M1 (now B) A2, B2, M2 (now C) 

AC input, 

AC output A3, B3, M3 (now D) A4, B4, M4 (now E) 

Multiple-Voltage External Power Supplies 

In the preliminary analysis, DOE considered combining product classes X1 (< 100 

Watts) and X2 (≥ 100 Watts) into one product class for all multiple-voltage EPSs. DOE is 

proposing to define multiple-voltage EPS as devices that convert household electric current 

into multiple simultaneous output currents. The California IOUs were in favor of creating a 

single product class for multiple-voltage EPSs because "the types of products that may occupy 

this category in the future are unknown." (California IOUs, No. 43 at p. 9). DOE’s initial 

approach was based on the view that these product classes corresponded to the two main 

products already in the market in 2008: multi-function devices in X1 and video game consoles 

in X2. As of 2010, multi-function devices no longer use multiple-voltage EPSs, leaving only 

one main product category and the need for only one product class. Therefore, DOE has 

consolidated product classes X1 and X2 into product class X for all multiple-voltage EPSs, 

which are EPSs that can directly operate a consumer product and simultaneously produce 

multiple output voltages. 

99 
 

 

High-Power External Power Supplies 

DOE examined only one product class for high-power EPSs during the preliminary 

analysis because only one relevant consumer application existed at the time the analysis was 

prepared. DOE received no comments on this proposal from interested parties and, therefore, 

maintained one product class for high-power EPSs in the NOPR. This product class includes 

EPSs that can directly operate a consumer product and have a nameplate output power greater 

than 250 watts. To maintain consistency in the naming convention for the NOPR, product class 

H1 is now product class H. All product classes developed for the NOPR are shown in Table 

IV-2. 

. 

Table IV-2 External Power Supply Product Classes Used in the NOPR 

Product Class Description 

Preliminary Analysis 

External Power Supply Product 

Classes 

NOPR 

External Power Supply Product 

Classes 

AC/DC Basic-Voltage A1, M1, B1 (some) B 

AC/DC Low-Voltage A2, M2, B2 (some) C 

AC/AC Basic-Voltage A3, M3, B3 (some) D 

AC/AC Low-Voltage A4, M4, B4 (some) E 

Multiple Voltage X1, X2 X 

High-Power H1 H 

Indirect Operation B1, B2, B3, B4 (most) N 

b. Battery Charger Product Classes 

In the preliminary analysis, DOE used five electrical characteristics to disaggregate 

product classes -- battery voltage, battery energy, input and output characteristics (e.g. inductive 

100 
 

 

charging capabilities),23 input voltage type (line AC or low-voltage DC), and AC output. DOE 

explained its reasoning for using this approach in the preliminary analysis. This reasoning is also 

detailed in chapter 3 of the TSD. 

First, DOE explained that battery voltage greatly affects consumer utility because the 

electronics of a portable consumer product are designed to require a particular battery voltage. If 

a change occurs in battery voltage, it is possible that the end-use application will be rendered 

inoperable. Furthermore, battery chargers that charge lower-voltage (voltage equals the product 

of current (I) and resistance (R)) batteries tend to be less efficient because they use higher 

currents, which increase I2

R losses for the same given output power. (I2R, the product of current 

and voltage, equates to power and refers to losses directly related to current flow.) These devices 

could be disproportionately affected by an equally stringent standard level across all voltages. 

Consequently, DOE opted to use battery voltage as a characteristic for setting product classes. 

See preliminary analysis TSD Chapter 3. 

Second, while battery voltage specifies which consumer product applications can be used 

with a particular battery (and its corresponding battery charger), battery energy describes the 

total amount of work that the battery can perform, regardless of the application, and is also a 

measure of utility. Furthermore, because a battery charger must provide enough output power to 

replenish the energy discharged during use, the capacity and physical size of the battery charger 

23 Inductive charging is a utility-related characteristic designed to promote cleanliness and guarantee uninterrupted 

operation of the battery charger in a wet environment. In wet environments, such as a bathroom where an electric 

toothbrush is used, these chargers ensure that the user is isolated from mains current by transferring power to the 

battery through magnetic induction rather than using a galvanic (i.e. current carrying) connection. 

101 
 

 

 

depend on the amount of battery energy.24 By using battery energy as a proxy for output power, 

only a single criterion, rather than two, is required for classifying battery chargers. This approach 

has the benefit of simplifying any energy conservation standards that DOE may set while 

sufficiently accounting for any differences in battery charger capacity or utility in the standards 

analysis. Additional details on this approach can be found in TSD chapter 3. 

Third, input and output characteristics are important because input voltage can have an 

impact on efficiency and dictate where a battery charger may be used, this impact may affect end 

user utility. With respect to inductive chargers, the utility offered by this characteristic is 

providing reliable and safe electrical power to a device during operation. In wet environments, 

such as a bathroom where an electric toothbrush is used, these chargers ensure that the user is 

isolated from mains current by transferring power to the battery through magnetic induction 

rather than using a galvanic (i.e. current carrying) connection. DOE also identified numerous 

battery chargers that do not include a wall adapter, connecting instead to a personal computer’s 

USB port or a car’s cigarette lighter receptacle. Because input voltage can impact battery charger 

performance and determine where the battery charger can be used, which affects the utility of the 

product, DOE defined product classes using this criterion in the preliminary TSD. In response to 

the preliminary analysis and during manufacturer interviews, DOE received numerous comments 

regarding these product classes, discussed below, and the results of which are summarized in 

Table IV-3. 

24 The minimum output power is a product of battery energy and charge rate. However, while charge rates rarely fall 

outside the range of 1 °C to 10 °C, the battery energy of consumer battery chargers can span over 5 orders of 

magnitude from 1 watt-hour to over 10,000 watt-hours. Therefore, the output power is more dependent on battery 

energy than charge rates. 

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Table IV-3 Battery Charger Product Classes 

Product Class # Input / Output Type Battery Energy 

(Wh) 

Special Characteristic or 

Battery Voltage 

1 

AC In, 

DC Out 

< 100 

Inductive Connection 

2 < 4 V 

3 4 – 10 V 

4 > 10 V 

5 

100–3000 

< 20 V 

6 ≥ 20 V 

7 > 3000 -

8 DC In, 

DC Out 

- < 9 V Input 

9 - ≥ 9 V Input 

10a AC In, 

AC Out 

- Basic (i.e. no Automatic 

Voltage Regulation) 

10b - Contains Automatic 

Voltage Regulation 

During the preliminary analysis public meeting, Philips questioned whether DOE could 

consider product classes based on usage, topology (i.e., the general circuit layout), or price. 

(Philips, Pub. Mtg. Tr., No. 37 at pp. 126-130) Philips and AHAM stated that they believed DOE 

could disaggregate infrequently used products into a separate product class and urged DOE to do 

so. (Philips, No. 43 at p. 3; AHAM, Pub. Mtg. Tr., No. 37 at pp 154-156) AHAM added that, in 

its view, DOE has always established new product classes based on characteristics, designs, or 

functions that affect energy use. (AHAM, No. 44 at p. 6) CEA expressed similar concerns as 

Philips and AHAM, suggesting that DOE did not adequately deal with infrequently charged 

battery chargers. (CEA, No. 48 at p. 2) Earthjustice disagreed with AHAM’s suggestion and 

stated that usage is not a feature of a battery charger, but rather a characteristic of the end user of 

the application that the battery charger accompanies. (Earthjustice, Pub. Mtg. Tr., No. , No. 37 at 

p. 131) Fulton Innovation inquired whether topology is considered as part of the utility of a 

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product and, hence, a factor for setting product classes. (Fulton Innovation, Pub. Mtg. Tr., No., 

37 at pp. 134-135) Finally, Stanley Black and Decker asked whether pricing could be considered 

a utility-related feature to use in defining product classes. (SBD, Pub. Mtg. Tr., No., 37 at pp. 

133-134) 

DOE does not consider usage, topology, and pricing as utility-related features for 

determining separate product classes. These factors were considered separately, however, in 

setting potential energy efficiency levels for these products. Usage defines how a battery charger 

is used, which is inherently tied to the end-use product with which the battery charger is 

packaged. While changes in usage will affect the energy use of a battery charger, they do not 

affect the actual performance of the battery charger, which is the relevant factor DOE must 

consider when establishing a separate class for these products. See 42 U.S.C. 6295(q). Product 

usage is fundamental to the analyses that DOE performs for battery chargers, particularly for the 

LCC and NIA. For each application, DOE estimates the time spent in each mode of operation in 

order to estimate unit energy consumption. Further details on usage and DOE’s assumptions are 

presented in the energy usage section, IV.E, of today’s notice. 

Although DOE does not explicitly define product classes for battery chargers based on 

topology, it considered topologies when it presented its initial product classes. Primarily, DOE 

uses battery energy as a defining characteristic for battery charger product classes. Because of 

the extremely wide range of different battery energies, DOE needed to establish meaningful 

ranges of battery energies for each product class. As outlined in the preliminary analysis TSD 

(Chapter 3), when battery energy changes, the topologies, or general circuit designs that are most 

104 
appropriate also change. Therefore, as part of today’s NOPR, DOE examined the potential 

impacts on topologies when it defined the ranges of battery energies that were considered. 

Finally, price was also not included in the definitions of DOE’s battery charger product 

class because it is not a utility-related feature for the purposes of EPCA. DOE understands 

commenters concerns that some products are marketed at various price points and that energy 

efficiency standards have the potential to raise those price points or eliminate some all together. 

However, price does not directly affect device performance. DOE acknowledges that price is an 

important consideration for consumers and although price is not considered when setting product 

classes, DOE does account for such consumer impacts in the LCC and PBP analyses conducted 

in support of this rulemaking. 

Medical and Single-Cell Battery Chargers 

Interested parties also advocated separating out particular products into their own classes. 

Philips suggested that DOE consider creating a separate product class for medical battery 

chargers, as is done for EPSs. (Philips, No. 43 at p. 2) They mentioned that medical battery 

chargers cannot use off the shelf consumer grade battery chargers and must undergo a special 

regulatory process that adds testing requirements and costs. (Philips, No. 43 at p. 3) At the public 

meeting, Wahl Clipper suggested that DOE should have an additional product class for 

applications that use single-cell batteries. (Wahl Clipper, Pub. Mtg. Tr., No. 37 at p. 158) Neither 

commenter provided any data supporting their views. 

105 
While DOE appreciates the suggestions from Philips and Wahl about segregating out 

additional product classes from DOE’s current definitions, DOE is not inclined to adopt them at 

this time based on the current information before it. As with EPSs, DOE believes that even 

though medical battery chargers must adhere to more stringent requirements than other battery 

chargers, the cost-efficiency relationship will not be appreciably different to merit separate 

standards and product classes. In the preliminary analysis, DOE found that there was virtually no 

difference in the cost effectiveness of improving medical EPS efficiency versus improving Class 

A EPS efficiency. Moreover, DOE is unaware of any capacity or performance-related feature 

present in medical battery chargers that would permit the creation of a special class for these 

devices for purposes of setting separate energy conservation standards. As a result, despite the 

additional safety testing that medical EPSs may have to go through for certification, DOE has 

tentatively consolidated the two groups and no longer distinguishes between them in its product 

class definitions for today’s proposal. Based on the information that DOE receives during the 

course of the comment period, it may reconsider this approach for the final rule. 

As for the single-cell batteries that Wahl Clipper referenced, DOE believes that its 

proposed scaling methodology sufficiently addresses Wahl Clipper’s concerns and allows 

chargers that use single-cell batteries to remain in product class 2 (low-energy, low-voltage). As 

discussed in section IV.C.2.j, when battery energy approaches zero, DOE levels off unit energy 

consumption (UEC) requirements to prevent the adoption of overly stringent requirements that 

could eliminate such products. (UEC is a relevant factor because it is the metric which DOE is 

proposing to regulate for these devices.) 

106 
Motorized Application Detachable Battery (MADB) Battery Chargers 

PTI also submitted comments in which it recommended that DOE revise its 10 battery 

charger product classes presented in the preliminary analysis. PTI stated that because the statute 

provides language for DOE to separate MADB's when referring to EPS’s, DOE should extend 

this distinction to battery chargers and separate MADB battery chargers from consumer 

electronics battery chargers. PTI claimed that even though MADB and consumer electronics 

battery chargers share a common range of battery voltages and energies, the two are vastly 

different in other ways and urged DOE to create different classes for MADB and non-MADB 

products across the same battery voltages and energies. PTI added that part of the problem with 

grouping the two product types together is that consumer electronics promote features such as 

smaller size and weight and longer run-time -- all of which are added benefits related to 

improving a product’s energy efficiency. (PTI, No. 47 at p. 13) In other words, in their view, 

consumer electronics have already begun to move towards more efficient battery chargers and 

manufacturers have been able to pass along the additional costs to consumers because the use of 

more efficient chargers has led to the addition of desirable features, such as reduced notebook 

computer weight. (PTI, No. 47 at pp. 13) 

PTI also disagreed with DOE’s initial plan to group power tools with consumer 

electronics because shipments of consumer electronics, such as laptops, greatly outnumber 

MADB product shipments. Because a shipment-weighted average is employed by DOE in its 

analysis, the calculated effects would be dominated by the effects of the products that have the 

greatest number of shipments. (PTI, No. 47 at p. 6) Since the shipment quantities of consumer 

electronic products far outnumber those for MADB products, PTI asserted that the calculations 

107 
derived by DOE would be dominated by the inclusion of consumer electronics products and 

skew the overall effects projected to occur with a given standard for these products. (PTI, No. 47 

at pp. 6 and 13) 

In addition, in PTI’s view, the incremental cost estimates to achieve higher efficiencies 

which have been included in the life cycle cost analysis, are a much smaller percentage of the 

higher-priced products than they would be for many do-it-yourself power tools. (PTI, No. 47 at 

p. 13) As a result, PTI asserted that do-it-yourself power tool users are likely to be more sensitive 

to price changes even though the incremental change may be similar to higher priced products, 

such as consumer electronics. PTI added that manufacturers, and ultimately consumers, would be 

better served by a class that included only appliances or, alternatively, have appliances more 

fairly represented in the averages. In its view, making this change would generate CSLs that 

more appropriately address the realizable efficiency improvements and strike a better balance 

between the realities of power tool manufacturers and the energy savings gained by the 

consumer. (PTI, No. 47 at p. 13) Therefore, PTI recommended that DOE should calculate CSL 

and LCC information based on sub-classifications of product classes 3 (AC in/DC out, < 100 

Wh, 4-10 V battery chargers) and 4 (AC in/DC out, < 100Wh, > 10V battery chargers) for 

MADB and non-MADB devices. (PTI, No. 47 at p. 7) 

Conversely, the California IOUs supported DOE’s decision to group both power tools 

(i.e. MADB battery chargers) and laptops (i.e. consumer electronics battery chargers) in the same 

product classes for the purposes of this analysis (California IOUs, No. 45 at p. 6) They also 

expressed support for DOE's proposal in the preliminary analysis that usage profiles should not 

108 
be used when creating product classes. (California IOUs, No. 45 at p. 8) In separate comments, 

Pacific Gas and Electric and others urged DOE to reduce the number of product classes from 10 

to 4, and reorganize product classes 2 through 7 (AC in/DC out battery chargers) into one new 

product class. (PG&E, et al., No. 49 at pp. 2-3) 

After considering these comments, DOE re-examined the UEC data from its engineering 

analysis for product classes 3 and 4. DOE found that when MADB applications were removed 

from product classes 3 and 4, the UECs generated for the removed group of MADB applications 

were not significantly different (< 10 percent) than those DOE had presented for the product 

class as a whole. Relative to the reductions in UEC when incrementing CSLs, DOE considered 

these differences much less significant than it initially suspected. Furthermore, for the NOPR 

analysis, DOE altered some of its assumptions for the LCC analysis. In the preliminary analysis, 

DOE assumed the same efficiency distribution for all applications within a product class. For 

example, in product class 4, laptops were assumed to have the same percentage of their 

shipments at CSL 0, 1, and 2 as power tools and all other applications in that product class. As 

mentioned by manufacturers and determined by DOE’s testing program for battery chargers, 

some products, mainly consumer electronics, have already begun increasing the efficiency of 

their products because doing so is desirable to the end user. As a result, DOE has altered its 

assumption that all applications within a product class have the same distribution of efficiency. 

Instead, DOE now makes more tailored assumptions about efficiency distributions for different 

applications based on information provided by manufacturers, publicly available data, and 

DOE’s own test results. 

109 
This new assumption will alter the economics of DOE’s standards analysis and more 

accurately illustrate the effects on consumers for the varying consumer types in each product 

class. Additionally, the individual LCC results for each application are available in appendix 8B 

of the TSD. Similarly, just as DOE is not persuaded to disaggregate certain product classes, DOE 

is also not persuaded to aggregate any additional product classes, as suggested by PG&E. DOE 

initially considered using separate product classes in the preliminary analysis because the 

different battery voltage and energy ratings that define these classes imply a certain utility and 

deviation from those ratings will likely lead to different cost-efficiency relationships and 

efficiency levels. These differences will also lead to different effects on consumers, which will 

likely support different energy conservation standard levels. 

Uninterruptible Power Supply (UPS) Battery Chargers 

Uninterruptible power supplies are used only for emergency situations when power is lost 

and users need time to safely shut down their electronic devices. Consequently, these devices 

generally do not fully charge a completely depleted battery. Additionally, these devices typically 

use integral batteries and generally remain on continuously. Because of its role in providing 

power in emergency situations, the battery chargers within these devices primarily remain in 

maintenance mode, which constitutes the most relevant portion of its energy consumption. 

During manufacturer interviews with UPS producers, DOE discussed additional 

functionality as it pertains to these devices. Manufacturers suggested that DOE classify UPSs 

into three different categories: basic UPSs, UPSs that have automatic voltage regulation (AVR), 

and UPSs that are extended-run capable (i.e., the ability to attach a second battery to increase 

110 
battery capacity within the UPS). After further investigation, DOE decided that two of these 

categories were appropriate and warranted separate standards, but the third category (extendedrun UPSs), as it was simply representative of a change in battery capacity, could be accounted 

for through its scaling methodology. 

AVR UPSs use circuitry that monitors input voltage from the wall and ensures that all 

products plugged into the UPS see a steady flow of voltage despite any fluctuations at the wall. 

This circuitry provides added utility to the consumer by preventing any spikes or dips in voltage, 

but it comes at the expense of additional power consumption by the UPS. This additional power 

consumption of the UPS is always on when the device is plugged in and it is indistinguishable 

from the power consumption due to the battery charger within the UPS. 

To account for these characteristics, DOE is proposing to divide preliminary analysis 

product class 10 into two product classes, one for basic UPSs and one for UPSs that contain 

AVR circuitry. Even though DOE is proposing two product classes for these categories of UPSs, 

DOE believes that the underlying engineering analysis and other downstream analyses for both 

product classes is the same. DOE believes that this is an appropriate assumption because the 

addition of AVR is irrelevant to UPS battery charger power consumption, yet it cannot be 

disaggregated from UPS battery charger power consumption due to the integrated nature of the 

circuitry components within a UPS. In other words, there is no technical reason why the battery 

charger within a basic UPS should be different from the battery charger within a UPS with AVR 

functionality. However, when the latter is tested via DOE’s battery charger test procedure, it will 

demonstrate a higher maintenance mode power consumption and will not be able to meet as 

111 
stringent an energy efficiency standard as a basic UPS. Consequently, for all of DOE’s analyses 

in today’s NOPR, battery chargers for UPSs are examined as an aggregated product class, 

product class 10, rather than separately, however the proposed standard for each product class is 

different. DOE seeks comment on its analytical approach and whether separate classes are 

appropriate in this context. 

4. Technology Assessment 

In the technology assessment, DOE identifies technology options that appear to be 

feasible to improve product efficiency. This assessment provides the technical background and 

structure on which DOE bases its screening and engineering analyses. The following discussion 

provides an overview of the technology assessment for EPSs and battery chargers. Chapter 3 of 

the TSD provides additional detail and descriptions of the basic construction and operation of 

EPSs and battery chargers, followed by a discussion of technology options to improve their 

efficiency and power consumption in various modes. 

a. EPS Efficiency Metrics 

On December 8, 2006, DOE codified a test procedure final rule for single output-voltage 

EPSs in Appendix Z to Subpart B of 10 CFR Part 430 (“Uniform Test Method for Measuring the 

Energy Consumption of External Power Supplies.”) See 71 FR 71340. On June 1, 2011, DOE 

added a test procedure to cover multiple output-voltage EPSs in Appendix Z to Subpart B of 10 

CFR Part 430 (“Uniform Test Method for Measuring the Energy Consumption of External 

Power Supplies.”) 76 FR 31750. DOE’s test procedure, based on the CEC EPS test procedure, 

yields two measurements: active mode efficiency and no-load mode (standby mode) power 

consumption. 

112 
Active-mode efficiency is the ratio of output power to input power. For single-voltage 

EPSs, the DOE test procedure averages the efficiency at four loading conditions—25, 50, 75, and 

100 percent of maximum rated output current—to assess the performance of an EPS when 

powering diverse loads. For multiple-voltage EPSs, the test procedure provides those four 

metrics individually, which DOE is considering averaging when setting the efficiency level 

measurements for these types of devices. The test procedure also specifies how to measure the 

power consumption of the EPS when disconnected from the consumer product, which is termed 

“no-load” power consumption because the EPS outputs zero percent of the maximum rated 

output current to the application. 

To develop the analysis and to help establish a framework for setting EPS standards, 

DOE considered both combining average active-mode efficiency and no-load power into a single 

metric, such as unit energy consumption (i.e. UEC), and maintaining separate metrics for each. 

For the preliminary analysis, DOE chose to evaluate EPSs using the two metrics separately. 

Today’s NOPR proposes continuing to use this method when setting standards for these 

products. Using a single metric that combines active-mode efficiency and no-load power 

consumption to determine the standard may inadvertently permit the “backsliding” of the 

standards established by EISA 2007. Specifically, because a combined metric would regulate the 

overall energy consumption of the EPS as the aggregation of active-mode efficiency and no-load 

power, that approach could permit the performance of one metric to drop below the EISA 2007 

level if it is sufficiently offset by an improvement in the other metric. Such a result would, in 

113 
DOE’s view, constitute a backsliding of the standards and would violate EPCA’s prohibition 

from setting such a level. DOE’s proposed approach seeks to avoid this result. 

The DOE test procedure for multiple-voltage EPSs yields five values: no-load power 

consumption as well as efficiency at 25, 50, 75, and 100 percent of maximum load. See 76 FR 

31750 (June 1, 2011)(noting DOE’s recently added procedures for multiple voltage EPSs 

codified at section 4.2 of appendix Z of subpart B to part 430 of the CFR). In the preliminary 

analysis, DOE examined the possibility of averaging the four efficiency values to create an 

average efficiency metric for multiple-voltage EPSs, similar to the approach followed for singlevoltage EPSs. Alternatively, DOE introduced the idea of averaging the efficiency measurements 

at 50 percent and 75 percent of maximum load because the only known application that currently 

uses a multiple voltage EPS, a video game console, operates most often between those loading 

conditions. DOE sought comment from interested parties on these two approaches. 

The California IOUs commented that the test metric should be an "average of 25%, 50%, 

75%, and 100% of rated output power, similar to the approach taken for single voltage EPSs." 

The California IOUs viewed this approach as best rather than basing the multiple-voltage test 

procedure on the loading profile of a single application which could decrease the applicability of 

any standard since “the types of products that may occupy this category in the future are 

unknown”. (California IOUs, No. 43 at p. 9) 

Though it is aware of only one consumer product using multiple-voltage EPSs, DOE 

believes that evaluating multiple-voltage EPSs using an average-efficiency metric (based on the 

114 
 

efficiencies at 25%, 50%, 75%, and 100% of each output’s normalized maximum nameplate 

output power) would allow a future standard to be applicable to a diverse range of products as it 

would not be based solely on the loading profile of a single EPS application. Therefore, DOE 

evaluated multiple-voltage EPSs using no-load mode power consumption and an average activemode efficiency metric based on the measured efficiencies at 25%, 50%, 75%, and 100% of 

rated output power in developing the proposed energy conservation standards for these products. 

DOE requests feedback on this proposed approach to determining the average efficiency for 

multiple-voltage EPSs. 

b. EPS Technology Options 

DOE considered seven technology options, fully detailed in Chapter 3 of the TSD, which 

may improve the efficiency of EPSs: (1) Improved Transformers, (2) Switched-Mode Power 

Supplies, (3) Low-Power Integrated Circuits, (4) Schottky Diodes and Synchronous 

Rectification, (5) Low-Loss Transistors, (6) Resonant Switching, and (7) Resonant ("Lossless") 

Snubbers. 

AHAM and PTI commented during the preliminary analysis that "[DOE] has not justified 

the value of decreasing the no-load levels at each [initially considered] CSL" (AHAM, No. 42 at 

p. 7; PTI, No. 45 at p. 5). NEEP suggested that DOE should consider whether technology options 

are applicable across product classes (NEEP, No. 49 at 2). 

During its analysis, DOE found that some technology options affect both efficiency and 

no-load performance and that the individual contributions from these options cannot be separated 

from each other in a cost analysis. Given this trend, DOE generated a “matched pairs” approach 

115 
for creating the EPS CSLs where select test units were used in characterizing the relationship of 

average active-mode efficiency and no-load power dissipation. In the matched pairs approach, 

EPS energy consumption improves either through higher active mode efficiency, lower no-load 

mode power consumption, or both. If DOE allowed one metric to decrease in stringency between 

CSLs, then the cost-efficiency results might have shown cost reductions at higher CSLs and 

skew the true costs associated with increasing the efficiency of EPSs. To avoid this result, DOE 

is using an approach that increases the stringency of both metrics for each CSL considered in 

today’s NOPR. 

Regarding NEEP’s suggestion, DOE notes that in developing the engineering analysis, 

DOE considered all technology options when developing CSLs for all four EPS representative 

units. DOE considered the same efficiency improvements during its analysis for non-Class A 

EPSs as it did for Class A EPSs. Where representative units were not explicitly analyzed (i.e. 

product classes C, D, and E), DOE extended its analysis from a directly analyzed class. As a 

result, all design options that could apply to these products were implicitly considered because 

the proposed efficiency levels of the analyzed product class will be scaled to other product 

classes, an approach supported by interested parties. The equations were structured based on the 

relationship of the other Class A product classes to the representative product class such that the 

technology options not implemented by the other classes were accounted for in the proposed 

efficiency equations. For example, AC-AC EPSs (product classes A2 and A4 in the preliminary 

analysis) tend to have higher no load power dissipation because they do not use switched-mode 

methods (see Chapter 3 of the TSD for a full technical description). Therefore, DOE used higher 

no load power metrics when generating CSLs for these product classes than the CSLs from the 

116 
representative product class A1. DOE will continue to examine all technology options and apply 

them wherever possible across all product classes as part of the NOPR analysis. 

c. High-Power EPSs 

In the non-Class A determination analysis TSD, DOE examined the specific design 

options of high-power EPSs as they relate to ham radios, the sole consumer application for these 

EPSs. DOE found that high-power EPSs are unique because both linear and switched-mode 

versions are available as cost-effective options, but the linear EPSs are more expensive and 

inherently limited in their achievable efficiency despite sharing some of the same possible 

efficiency improvements as EPSs in other product classes. Interested parties have expressed 

concern that setting an efficiency standard higher than a linear EPS can achieve would reduce the 

utility of these devices because ham radios are sensitive to the electromagnetic interference 

(EMI) generated by switched-mode EPSs. 

However, DOE believes there is no reduction in utility because EPSs used in 

telecommunication applications are required to meet the EMI regulations of the Federal 

Communications Commission (47 CFR 15, subpart B) regardless of the underlying technology. 

DOE used this assumption when constructing its engineering analysis for the NOPR but seeks 

comment on possible issues with EMI and/or radio frequency interference associated with 

switch-mode power supplies (SMPS) used with amateur radios, including design options for 

reducing or eliminating interference. 

117 
d. Power Factor 

Power factor is a relative measure of transmission losses between the power plant and a 

consumer product. DOE examined the issue of power factor in section 3.6 of the framework 

document for the BCEPS rulemaking and noted that certain ENERGY STAR specifications limit 

power factor. DOE also noted in that same section the role of power factor in higher-power EPSs 

-- namely, that at higher powers, problems associated with power factor (e.g. power dissipation 

in the wiring) become more pronounced. 

PTI commented that DOE should preempt other jurisdictions from regulating power 

factor by addressing power factor as a metric, but not to specify a limit in the energy-efficiency 

standard. (PTI, No. 45 at p. 12) PTI stated that regulating power factor will add cost to the 

product because of the need for additional power factor correction circuitry. It also explained that 

losses due to power factor are a consequence of the power cables used by the local utility, which 

are beyond the control of the manufacturer. (PTI, No. 45 at pp. 10-11) 

DOE notes that regulating power factor includes substantial challenges, such as 

quantifying transmission losses that depend on the length of the transmission wires, which differ 

for each residential consumer. Further, DOE has not yet conclusively analyzed the benefits and 

burdens from regulating power factor. While DOE plans to continue analyzing power factor and 

the merits of its inclusion as part of a future rulemaking, it is DOE’s view that the above factors 

weigh in favor of not setting a power factor-based standard at this time. 

118 
 

 

e. Battery Charger Modes of Operation and Performance Parameters 

For the preliminary analysis, DOE found that there are five modes of operation in which 

a battery charger can operate at any given time. These modes of operation are: active (or charge) 

mode, maintenance mode, no-battery (or standby) mode, off mode, and unplugged mode. These 

five modes are briefly described below25: 

Active (or charge) mode: During active mode, a battery charger is charging a depleted 

battery, equalizing its cells, or performing functions necessary for bringing the battery to the 

fully charged state. 

Maintenance mode: In maintenance mode, the battery is plugged into the charger, has 

reached full charge, and the charger is performing functions intended to keep the battery fully 

charged while protecting it from overcharge. 

No-Battery (or standby) mode: In no-battery mode, the battery is not connected to the 

charger but the battery charger itself is still plugged into mains. 

Off mode: In off mode, the charger remains connected to mains power but the battery is 

removed and all manual on-off switches are turned off. 

Unplugged mode: In unplugged mode, the battery charger is disconnected from mains 

and not consuming any electrical power. 

25 Active mode, maintenance mode, standby mode, and off mode are all explicitly defined by DOE in Appendix Y to 

Subpart B of Part 430 – Uniform Test Method for Measuring the Energy Consumption of Battery Chargers. 

119 
For each battery charger mode of operation, DOE’s battery charger test procedure has a 

corresponding test that is performed that outputs a metric for energy consumption in that mode. 

The tests to obtain these metrics are described in greater detail in DOE’s battery charger test 

procedure. (76 FR 31750) The following items are pertinent performance parameters from those 

tests. 

24-Hour Energy: This quantity is defined as the power consumption integrated with 

respect to time of a full metered charge test that starts with a fully depleted battery. In other 

words, this is the energy consumed to fully charge and maintain at full charge a depleted battery 

over a period that lasts 24 hours or the length of time needed to charge the tested battery plus 5 

hours, whichever is longer. 

Maintenance Mode Power: This is a measurement of the average power consumed while 

a battery charger is known to be in maintenance mode. 

No-Battery (or standby) Mode Power: This is a measurement of the average power 

consumed while a battery charger is in no-battery or standby mode (only if applicable). 

Off-Mode Power: This is a measurement of the average power consumed while an on-off 

switch-equipped battery charger is in off mode (i.e. with the on-off switch set to the “off” 

position). 

120 
Unplugged Mode Power: This quantity is always 0. 

Additional discussion on how these parameters are derived and subsequently combined 

with assumptions about usage in each mode of operation to obtain a value for the UEC is 

discussed below in section IV.C.2.b. 

f. Battery Charger Technology Options 

Since most consumer battery chargers contain an AC to DC power conversion stage, 

similar to that found in an EPS, all of the technology options discussed in section IV.A.4.b also 

apply to battery chargers. The technology options used to decrease EPS no-load power will 

impact battery charger energy consumption in no-battery and maintenance modes (and off mode, 

if applicable), while those options used to increase EPS conversion efficiency will impact energy 

consumption in active and maintenance modes. 

Technology options that DOE considered for battery chargers in the preliminary analysis 

and again for the NOPR include: improved transformer cores, termination, elimination/limitation 

of maintenance mode current, elimination of no-battery mode current, switched-mode power 

supplies, low-power integrated circuits, Schottky diodes and synchronous rectification, phase 

control to limit input power. An in-depth discussion of these technology options can be found in 

TSD chapter 3. 

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B. Screening Analysis 

DOE uses the following four screening criteria to determine which design options are 

suitable for further consideration in a standards rulemaking: 

1. Technological feasibility. DOE considers technologies incorporated in commercial 

products or in working prototypes to be technologically feasible. 

2. Practicability to manufacture, install, and service. If mass production and reliable 

installation and servicing of a technology in commercial products could be achieved on the scale 

necessary to serve the relevant market at the time the standard comes into effect, then DOE 

considers that technology practicable to manufacture, install, and service. 

3. Adverse impacts on product utility or product availability. If DOE determines a 

technology would have significant adverse impact on the utility of the product to significant 

subgroups of consumers, or would result in the unavailability of any covered product type with 

performance characteristics (including reliability), features, sizes, capacities, and volumes that 

are substantially the same as products generally available in the United States at the time, it will 

not consider this technology further. 

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider this technology further. 

See 10 CFR part 430, subpart C, appendix A, (4)(a)(4) and (5)(b). 

122 
For EPSs, DOE did not screen out any technology options after considering the four 

criteria. For battery chargers, DOE screened out: 

1.	 Non-inductive chargers for use in wet environments because of adverse impacts 

on safety; 

2.	 Capacitive reactance because of adverse impacts on safety; and 

3.	 Lowering charging current or increasing battery voltage because of adverse 

impacts on product utility to consumers. 

DOE received no comments in response to its preliminary screening analysis. Therefore, 

DOE is using the same screening analysis for the NOPR. 

For additional details, please see chapter 4 of the TSD. 

C. Engineering Analysis 

In the engineering analysis (detailed in chapter 5 of the TSD), DOE presents a 

relationship between the manufacturer selling price (MSP) and increases in battery charger and 

EPS efficiency. The efficiency values range from that of an inefficient battery charger or EPS 

sold today (i.e., the baseline) to the maximum technologically feasible efficiency level. For each 

efficiency level examined, DOE determines the MSP; this relationship is referred to as a costefficiency curve. 

DOE structured its engineering analysis around two methodologies: (1) test and 

teardowns, which involves testing products for efficiency and determining cost from a detailed 

123 
bill of materials derived from tear-downs and (2) the efficiency-level approach, where the cost of 

achieving increases in energy efficiency at discrete levels of efficiency are estimated using 

information gathered in manufacturer interviews that was supplemented and verified through 

technology reviews and subject matter experts (SMEs). When analyzing the cost of each CSL— 

whether based on existing or theoretical designs—DOE differentiates the cost of the battery 

charger or EPS from the cost of the associated end-use product. 

1. Engineering Analysis for External Power Supplies 

a. Representative Product Classes and Representative Units 

DOE is applying the same methodology in the NOPR as it used in the preliminary 

analysis to identify representative product classes and representative units. In the preliminary 

analysis, DOE selected product class A1 (AC to DC conversion, basic- voltage EPSs) for further 

analysis as the representative product class because it constituted the majority of EPS shipments 

and national energy consumption related to EPSs. Within product class A1, DOE focused on four 

representative units with output power levels at 2.5 watts, 18 watts, 60 watts, and 120 watts 

because most consumer applications use EPSs with these, or similar, nameplate output power 

ratings. In the NOPR, DOE is choosing to focus on representative product class B (AC to DC 

conversion, basic-voltage EPSs), which contains certain product classes from the preliminary 

analysis -- most Class A EPSs from product class A1, most medical EPSs from product class 

M1, and some MADB EPSs from product class B1 (which are EPSs that can directly power an 

application). The NOPR analysis also focuses on the same four representative units as the 

preliminary analysis with output powers at 2.5 watts, 18 watts, 60 watts, and 120 watts in 

124 
 

product class B and scales those results to product classes C, D, and E as suggested by interested 

parties. 

Interested parties supported DOE’s approach in creating and analyzing representative 

product classes and representative units in the preliminary analysis. The California IOUs agreed 

with using product class A1 as the representative product class and scaling to other product 

classes because of the inherent similarities of the A1 devices to those in the other product classes 

(California IOUs, No. 43 at p. 8). Although no specific data were provided, the California IOUs 

also commented in support of the four representative units within the product class noting that 

their own research26 into the power supply market corroborates DOE’s selections (California 

IOUs, No. 43 at p. 8). DOE did not receive comments disputing its selections for the four 

representative units. 

DOE is proposing to continue using the same representative product class and 

representative unit methodology, and will scale results for the other EPS product classes. As 

noted previously, DOE has incorporated EPSs from product class A1 into product class B. 

Within product class B (preliminary analysis product class A1) DOE will focus on the four 

representative units with output powers at 2.5 watts, 18 watts, 60 watts, and 120 watts because 

products with these ratings constitute a significant portion of shipments and energy consumption. 

Interested parties also supported this approach. 

26http://www.energy.ca.gov/appliances/archive/2004rulemaking/documents/case_studies/CASE_Power_Supplies.pd 

f 

125 
b. EPS Candidate Standard Levels (CSLs) 

DOE is applying the same methodology to establish CSLs in the NOPR as it used in the 

preliminary analysis. DOE created CSLs as pairs of EPS efficiency metrics for each 

representative unit with increasingly stringent standards having higher-numbered CSLs. The 

CSLs were generally based on (1) voluntary (e.g. ENERGY STAR) specifications or mandatory 

(i.e. those established by EISA 2007) standards that either require or encourage manufacturers to 

develop products at particular efficiency levels; (2) the most efficient products available in the 

market; and (3) the maximum technologically feasible (“max tech”) level. These CSLs are 

summarized for each representative unit in Table IV-4. In section IV.C.1.e, DOE discusses how 

it developed equations to apply the CSLs from the representative units to all EPSs. 

Table IV-4 Summary of EPS CSLs for Product Classes B, C, D, and E 

CSL Reference Basis 

0 EISA 2007 EISA 2007 equations for efficiency and no-load power 

1 ENERGY STAR 

2.0 

ENERGY STAR 2.0 equations for efficiency and no-load 

power 

2 Intermediate Interpolation between test data points 

3 Best in Market Most efficient test data points 

4 Max Tech Maximum technologically feasible efficiency 

DOE evaluated EPSs using the two EPS efficiency metrics, no-load power consumption 

and active-mode average efficiency, which it grouped into “matched pairs.” Under the matched 

pairs approach, each CSL would increase in stringency in at least one of the metrics and no 

metric would ever be lowered in moving to a higher CSL. DOE’s goal in using this approach was 

to ensure that when it associated costs with the CSLs, that the costs would reflect the complete 

costs of increased efficiency. If DOE followed an approach that permitted a decrease in 

126 
stringency for a given metric, the result might be a projected reduction in EPS cost, which would 

mask the full cost of increasing EPS efficiency. 

DOE received considerable support from interested parties on its matched pairs approach 

for EPS CSLs. However, interested parties, including the California IOUs, also cautioned DOE 

to avoid setting levels for no-load power that were too stringent when compared to active-mode 

efficiency improvements. (California IOUs, No. 43 at p. 8). The California IOUs added that 

“PG&E research suggests that improvements in active mode yield much higher energy savings 

than small, incremental improvements in no-load mode.” Id. PG&E added that DOE should 

verify that the no-load levels for the EPS CSLs are not too stringent, which could lead to higher 

costs since the majority of the projected savings for EPSs would likely come from improving 

active-mode efficiency (PG&E, Pub. Mtg. Tr., No. 57 at pp. 198-199). 

DOE received two additional comments regarding its CSLs. The California IOUs 

supported DOE's CSL selections, particularly those that were developed based on test data. 

(California IOUs, No. 43 at p. 8). Additionally, AHAM stated that DOE should "consider 

whether the CSLs also apply to units that are less than 2.5W," in particular 2.4W and 1.2W EPSs 

because they believe that “the CSL for this class does not apply to these smaller wattage 

products” (AHAM, No. 42 at p. 13). 

DOE considered interested party comments when revising the CSLs for the NOPR. 

DOE’s approach maintains the same efficiency levels for all CSLs but alters the max-tech 

efficiency level based on new data gleaned from manufacturer interviews, which indicated that 

127 
manufacturers could achieve higher max-tech levels than were previously considered during the 

preliminary analysis. No load requirements were carefully considered consistent with commenter 

suggestions to not aggressively increase these levels. 

Further, DOE has tentatively decided to maintain its best-in-market CSL based on test 

data and also considered whether the CSLs for the 2.5W EPS should apply to lower-power EPSs. 

DOE continues to believe that the CSLs apply to these lower power devices because the scaling 

equations developed by DOE incorporate the test results and data of EPSs with nameplate output 

power ratings less than 2.5W. For both metrics and at each CSL, DOE has developed standards 

equations that are functions of nameplate output power. To accommodate the design trend of 

decreasing efficiency with decreasing output power, the 2.5W CSLs are used as lower power 

reference points for the standard equations. All of the direct operation CSLs were created using a 

combination of existing standards and were corroborated with test data. In cases where DOE 

tested EPSs with nameplate output powers less than 2.5 watts, it scaled the results to the 

representative unit (2.5 W) and adjusted the efficiency accordingly. Hence, the 2.5W CSLs are 

supported by data from EPSs with output powers equal to 2.5 watts and scaled EPSs with output 

power ranges below 2.5 watts. DOE used this methodology in generating the CSLs for all of the 

other direct operation representative units where the CSLs were not only based on units tested at 

the nominal output power rating but also on scaled results of EPSs with nameplate output powers 

slightly above and slightly below the representative unit value. For additional detail regarding 

DOE’s scaling methodology see chapter 5 of the TSD. 

128 
 

DOE maintained the same CSLs for multiple-voltage EPSs in product class X as it 

proposed in the preliminary analysis because it received no comments and has no new 

information that would otherwise merit a change in the CSLs for this product class. The CSLs 

are shown in Table IV-5. 

Table IV-5 Summary of EPS CSLs for Product Class X 

CSL Reference Basis 

0 Market Bottom Test data of the least efficient unit in the market 

1 Mid Market Test data of the typical unit in the market 

2 Best-in-Market Manufacturer’s data 

3 Max Tech Maximum technologically feasible efficiency 

DOE structured the CSLs for high-power EPSs based on products available in the market and 

by scaling CSLs for 120-watt EPSs. The two least efficient CSLs are based on units DOE tested 

for the non-Class A EPS determination analysis. CSL 0 corresponds to test results from a linear 

EPS for amateur radio equipment while CSL 1 corresponds to test results from a switched-mode 

EPS for the same application. During interviews for the determination analysis, high-power EPS 

manufacturers indicated that CSL 2 was what they believed to be the max-tech efficiency for 

high-power EPSs. As outlined in section III.B.2.a, DOE believes that the efficiencies of the 

120W EPSs indicate a potential for 345W EPSs to achieve higher efficiencies than CSL 2 since 

achievable efficiency tends to remain the same for EPSs with a nameplate output power above 

49 watts. DOE characterized these higher efficiencies by modeling a 360W EPS composed of 

three 120W EPSs connected in parallel. This theoretical EPS would have the same average 

efficiency as a 120W EPS, scaled for nameplate output voltage, and three times the no-load 

power consumption. DOE developed CSL 3 and CSL 4 for the 345W representative EPSs based 

on the efficiency of the theoretical 360W EPS. DOE received no comments concerning the CSLs 

for high-power EPSs during the preliminary analysis (CSL 0, CSL 1 and CSL 2). DOE seeks 

129 
comment on its proposed methodology for establishing higher-efficiency CSLs (CSL 3 and CSL 

4). The CSLs for product class H are listed in Table IV-6. 

Table IV-6 Summary of EPS CSLs for Product Class H 

CSL Reference Basis 

0 Line Frequency Test data of a low-efficiency unit in the market 

1 Switched-Mode Low 

Level Test data of a high-efficiency unit in the market 

2 Switched-Mode High 

Level Manufacturers’ theoretical maximum efficiency 

3 Scaled Best-in-Market Scaled from 120W EPS CSL 3 

4 Scaled Max Tech Scaled from 120W EPS CSL 4 

c. EPS Engineering Analysis Methodology 

In the preliminary analysis, DOE presented two sets of cost-efficiency curves: one based 

on manufacturer data that showed an increasing trend between cost and efficiency and a second 

set based on test and teardown data that, while inconclusive, generally showed a decreasing 

relationship between cost and efficiency. DOE sought interested party comment on this 

discrepancy. 

Commenters had mixed opinions on which results DOE should use as the basis for its 

analysis. AHAM commented that "based on what was presented that the Department should use 

the manufacturer’s data" rather than the test and teardown data that DOE developed stating that 

“there is no incentive for manufacturers to not give out all necessary information to the 

Department”. (AHAM, No. 42 at p. 13) However, IOUs encouraged DOE to continue to pursue 

teardowns because the test and teardown results in the preliminary analysis, in their view, may 

be as accurate as manufacturer data since "costs are rapidly declining for highly efficient power 

130 
 

supplies." (California IOUs, No. 43 at p. 9). NEEP stated that DOE should "corroborate the costefficiency curve data provided to them by manufacturers." In other words, DOE should reevaluate the manufacturer's results and consider consulting independent sources to establish a 

more direct relationship between efficiency and cost. (NEEP, No. 49 at p. 4). DOE considered 

these opinions and sought additional information. 

In preparing the NOPR analysis, DOE conducted an additional round of manufacturer 

interviews to address the differences between the two cost-efficiency curves in the preliminary 

analysis. Based on the interviews, DOE believes that the discrepancy between the preliminary 

analysis curves was due to an ongoing shift in the market that was not reflected in the data. 

Specifically, the manufacturers stated during these interviews that the EPS market has a trend of 

increasing efficiency and decreasing cost with each design cycle and the DOE-tested units may 

have been from different design cycles.27 By contrast, the manufacturers’ data on which DOE 

had initially relied reflected the cost-efficiency relationship during a single design cycle. In 

general, manufacturers agreed that, in their current design cycle, EPSs are designed to be more 

efficient than the ENERGY STAR level. Thus, DOE’s revised cost-efficiency curves reflect this 

improved understanding across all the representative units using updated data obtained from 

interviews with EPS manufacturers and component suppliers. 

In the preliminary analysis, DOE evaluated switched-mode power supplies (i.e. power 

supplies that use controlled switching of a power source to regulate the flow of current to a load), 

but not linear power supplies. Linear power supplies are power supplies that use a transformer 

27 Original design dates are difficult to determine because the date of release is not often publicized with EPS 

product data. 

131 
 

and a linear regulator to provide power to a load. These devices are typically less cost effective 

as a method to improve energy efficiency and inherently limited in their achievable efficiencies ­

- these limitations stem from the conversion stage delivering current at a higher voltage than 

needed by the consumer product and dropping the excess voltage across the regulator to achieve 

the lower regulated output voltage. The power lost in the regulator is the product of the voltage 

drop and the load current and is dissipated as heat. Switched-mode power supplies do not have 

the same limitations with respect to the level of efficiency they can achieve because the design 

relies on transferring power through the controlled modulation of energy stored in the magnetic 

and electric fields of passive components. As a result, there are fewer resistive losses in the 

conversion stage and the voltage is regulated using controlled switching instead of intentionally 

dissipating excess voltage in the form of heat, Cobra Electronics noted this omission. (Cobra, 

No. 51 at p. 3) DOE has since re-evaluated the analysis and found that linear power supplies are 

a cost-effective option for 2.5 W EPSs at the lower stringency CSLs, but not in meeting other 

CSLs or in satisfying CSLs for other representative units. As a result, the NOPR cost-efficiency 

curves for the 2.5W representative unit include linear supplies as part of the analysis. 

Today’s proposed rule is based on a slightly revised version of the initial methodology 

DOE considered when aggregating manufacturer results for the 2.5W and 18W representative 

units. In the preliminary analysis, DOE used a 3D-aggregation method28 based on cost, 

efficiency, and no-load power to generate cost-efficiency curves for all representative units. The 

same 3D-aggregation methodology was applied to the NOPR analysis with the exception of the 

28 DOE’s 3D-aggregation method is an approach to developing an equation that describes how MSP for an EPS 

changes with respect to both average efficiency and no-load power. That is, MSP is a function of both metrics 

simultaneously. 

132 
 

2.5W and 18W representative units, for which DOE used a 2D aggregation approach.29 DOE 

used a 2D aggregation method because that method more accurately captures the cost-efficiency 

relationship for these EPSs. Generally, DOE believes that 3D aggregation typically yields the 

best curve fit for the dataset, so long as there are sufficient data. However, for the 2.5W and 18W 

EPSs, DOE had less data for which it could generate curve fits. DOE initially ran a 3D 

regression for the 2.5W and 18W representative units, but found that variations in the data for 

no-load power caused the correlation of the resulting curve to be low. Upon further inspection, 

DOE believes that the 2D curve fit more accurately reflects the less-robust underlying dataset for 

these two EPSs because the costs represent incremental improvements to meet specific CSLs 

and, thus, the large variations in the no-load power data provided by manufacturers do not 

degrade the correlation of the curve fit. Therefore, DOE switched to a 2D aggregation that 

described efficiency and cost, which generated a curve with higher correlation and more 

appropriate results for these representative units. For the remaining EPSs, DOE continued to 

apply the 3D-aggregation method because it generated a satisfactory curve fit. For additional 

details, please see chapter 5 of the TSD. 

d. EPS Engineering Results 

DOE characterized the cost-efficiency relationship of the four representative units in 

product class B as shown in Table IV-7, Table IV-8, Table IV-9, and Table IV-10. During 

interviews, manufacturers indicated that their switched-mode EPSs currently meet CSL1, the 

ENERGY STAR 2.0 specification. This factor is reflected in the analysis by setting the 

29 DOE’s 2D-aggregation method is an approach to developing an equation that describes how MSP for an EPS 

changes with respect to average efficiency only. 

133 
 

incremental MSP for the 18W, 60W, and 120W EPSs at $0 at CSL 1, which means that there is 

no incremental cost above the baseline to achieve CSL 1. Costs for the 2.5W EPS, however, are 

estimated at $0.15 for CSL 1. This result occurs because of DOE’s assumption (based on 

available information) that the lowest cost solution for improving the efficiency of the 2.5W EPS 

is through the use of linear EPSs, which are manufactured both at the EISA 2007 level as well as 

at ENERGY STAR 2.0. Specifically, as commenters suggested, DOE examined linear EPSs and 

found that they might be a cost-effective solution at CSL 0 and CSL 1 for 2.5W EPSs. Thus, 

$0.15 indicates the incremental cost for a 2.5W EPS to achieve higher efficiency. For all four 

representative units, the more stringent CSLs, CSL 2, CSL 3, and CSL 4, correspond to 

switched-mode EPSs designed during the same design cycle, which would cause their costs to 

increase with increased efficiency. 

Table IV-7 2.5W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 58.3 67.9 71.0 73.5 74.8 

No-Load Power [W]: 0.500 0.300 0.130 0.100 0.039 

CSL Description: EISA ENERGY 

STAR 2.0 Intermediate Best-inMarket Max Tech 

Incremental MSP[$]: 0.00 0.15 0.33 0.45 0.52 

Table IV-8 18W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 76.0 80.3 83.0 85.4 91.1 

No-Load Power [W]: 0.500 0.300 0.2 0.1 0.039 

CSL Description: EISA ENERGY 

STAR 2.0 Intermediate Best-inMarket Max Tech 

Incremental MSP[$]: 0.00 0.00 0.17 0.64 2.89 

134 
 

 

Table IV-9 60W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 85.0 87.0 87.0 88.0 92.2 

No-Load Power [W]: 0.5 0.5 0.2 0.073 0.05 

CSL Description: EISA ENERGY 

STAR 2.0 Intermediate Best-inMarket Max Tech 

Incremental MSP[$]: 0.00 0.00 0.82 1.29 2.73 

Table IV-10 120W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 85.0 87.0 88.0 88.4 93.5 

No-Load Power [W]: 0.5 0.5 0.23 0.21 0.089 

CSL Description: EISA ENERGY 

STAR 2.0 Intermediate Best-inMarket Max Tech 

Incremental MSP[$]: 0.00 0.00 0.31 0.45 6.41 

Unlike product class B, DOE analyzed a single 203W representative unit for multiplevoltage EPSs. These devices are exclusively used with home video-game consoles, which use 

one output to power the device and another for standby controls. In Chapter 5 of the preliminary 

analysis TSD, DOE indicated that, for the NOPR, it was considering using the cost-efficiency 

relationship for 203W multiple-voltage EPSs that it developed as part of the non-Class A EPS 

determination analysis. In the determination analysis, DOE derived costs for CSL 0 and CSL 1 

from test and teardown data but costs for CSL 2 and CSL 3 came from manufacturer and 

component supplier interviews. DOE received no comments on this approach, which was 

detailed in the preliminary analysis TSD. Hence, DOE is continuing to rely on its determination 

analysis results to help characterize the cost-efficiency relationship for 203W multiple voltage 

EPSs, shown in Table IV-11. 

135 
Table IV-11 203W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

Efficiency [%]: 82.4 86.4 86.4 88.5 

No-Load Power [W]: 12.3 0.4 0.3 0.3 

CSL Description: Market 

Baseline Mid-Market Best-in-Market Max Tech 

Incremental MSP[$]: 0.00 2.45 2.66 7.71 

Similar to the analysis of multiple-voltage EPSs, DOE analyzed one 345W representative 

unit for high-power EPSs. In Chapter 5 of the preliminary analysis TSD, DOE indicated that it 

was considering applying the cost-efficiency relationship for 345W high-power single-voltage 

EPSs that it developed as part of the non-Class A EPS determination analysis to high-power 

EPSs. In the determination analysis, DOE derived costs for CSL 0 and CSL 1 from test and 

teardown data, whereas costs for CSL 2 and CSL 3 came from manufacturer and component 

supplier interviews. DOE did not receive comments on this aspect of its approach in the 

preliminary analysis TSD. Hence, DOE used the results from the determination analysis to 

characterize the costs of the less-efficient CSLs for 345W high-power EPSs in today’s NOPR 

(CSL 0 and CSL 1). 

However, as noted previously in section IV.C.1.b, DOE also believes that a 345W EPS 

could achieve higher efficiencies based on its theoretical model of a 360W EPS that exhibits the 

properties of three 120W EPSs connected in parallel. These higher output devices are typically 

used with amateur radio equipment, which often transmit at power levels between 100 and 200 

watts while simultaneously providing power to other components. DOE developed its costs for 

the higher-efficiency CSLs (CSL 2, CSL 3, and CSL 4) based on 120W EPS analysis. The 

complete cost-efficiency relationship for the 345W EPS is shown in Table IV-12. 

136 
 

Table IV-12 345W EPS Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

Efficiency [%]: 62.4 81.3 84.6 87.5 92.0 

No-Load Power [W]: 15.43 6.01 0.5 0.5 0.266 

CSL Description: Market 

Baseline 

Low 

Market Mid-Market 

Scaled 

Best-inMarket 

Scaled Max 

Tech 

Absolute MSP[$]: 132.68 104.52 104.52 107.30 143.92 

e. EPS Equation Scaling 

During the preliminary analysis phase, DOE presented an approach to derive the average 

efficiency and no-load efficiency requirements for each CSL over the full range of output power 

for Class B EPSs. Mathematical equations define each CSL as a pair of relationships – 1) 

average active-mode efficiency to nameplate output power and 2) no-load mode power 

consumption to nameplate output power. These equations allow DOE to describe a CSL for any 

nameplate output power and are the basis of its proposed standards. A complete description of 

the equations can be found in chapter 5 of the TSD. 

For the baseline CSL and CSL1, DOE relied on equations from EISA 2007 and 

ENERGY STAR 2.0, respectively, rather than developing new equations. Both equations are 

defined over ranges of output power, although the divisions between ranges are slightly different. 

EISA 2007 created divisions by establishing separate efficiency equations at the 1 watt and 51 

watt levels -- ENERGY STAR 2.0 creates a similar dividing line at 1 watt and 49 watts. See 42 

U.S.C. 6295(u)(3)(A) (denoting nameplate output divisions at under 1 watt, 1 watt to not more 

than 51 watts, and over 51 watts) and “ENERGY STAR Program Requirements for Single 

Voltage External Ac-Dc and Ac-Ac Power Supplies” (denoting nameplate output divisions at 

less than or equal to 1 watt, 1 watt to not more than 49 watts, and over 49 watts). DOE developed 

137 
equations for all other CSLs and for consistency and simplicity used the ENERGY STAR 2.0 

divisions at 1 watt and 49 watts for all CSLs. These divisions were created in conjunction with 

the EPS product classes discussed in section IV.A.3.a as part of a complete analysis by the EPA. 

Given that it is considering adopting those product classes for direct operation EPSs, DOE 

believes that utilizing the ENERGY STAR output power divisions for its proposed standards is 

the most appropriate course of action. Consequently, the proposed standards are structured 

around these divisions rather than those created by the EISA 2007 standard or the CEC standards 

for EPSs. 

DOE derived CSL 2, CSL 3, and CSL 4 by fitting equations to the efficiency values of 

their respective data points for each representative unit. DOE used an equation of the form 

Y=a*ln(Pout) + b*Pout+c, for each of the nameplate output power ranges, where Y indicates the 

efficiency requirement; Pout indicates the nameplate output power; and a, b, and c indicate the 

specific parameters defined in the respective CSLs. DOE ensured that the equations met three 

conditions: 

(1) The distance to each point was minimized. 

(2) The equation did not exceed the tested efficiencies. 

(3) DOE further restricted the parameter choice in order to ensure that the CSL 

curves adhered to a matched pairs approach fully detailed in chapter 5 of the TSD. 

Among the CSLs for product class B, DOE only revised the efficiencies of the max-tech 

data points at CSL 4. Thus, the remaining CSL equations, other than max-tech, remain 

unchanged from the equations DOE developed for the preliminary analysis. For the NOPR, DOE 

derived a revised max-tech scaling equation using the new max-tech data points it developed 

138 
after obtaining additional data during manufacturer interviews following the preliminary 

analysis. 

As in the preliminary analysis, DOE scaled the CSL equations from product class B to 

product classes with low-voltage and AC-AC EPSs, which comprise product classes C, D, and E. 

The scaling for these equations was based on ENERGY STAR 2.0, which separates AC-DC 

conversion and AC-AC conversion into “basic-voltage” and “low-voltage” categories. ENERGY 

STAR 2.0 sets less stringent efficiency levels for low-voltage EPSs because they cannot typically 

achieve the same efficiencies as basic-voltage EPSs due to inherent design limitations. Similarly, 

ENERGY STAR 2.0 sets less stringent no-load standards for AC-AC EPSs because they do not 

use the overhead circuitry found in AC-DC EPSs to limit no-load power dissipation. The power 

consumed by the additional AC-AC EPS circuitry would actually increase their no-load power 

metric. DOE used this approach to develop CSLs other than the baseline CSL 0 for product 

classes C, D, and E. Because the baseline is the EISA 2007 standard that applies to all Class A 

EPSs, which comprise most of product classes B, C, D, and E, CSL 0 is the same for all product 

classes. 

As described in the preliminary analysis and continued in today’s proposal, DOE created 

less stringent CSLs for product classes C, D, and E. For CSL 1, the equations come directly from 

the ENERGY STAR 2.0 low-voltage equation. The low-voltage curves for CSL 2, CSL 3, and 

CSL 4 were created by using their respective CSL 2, CSL 3, and CSL 4 basic-voltage efficiency 

curves, and altering all equation parameters by the difference in the coefficients between the 

CSL 1 basic-voltage and low-voltage equations. This approach had the effect of shifting the CSL 

139 
2, CSL 3, and CSL 4 low -voltage curves downward from their corresponding basic-voltage CSL 

2, CSL 3, and CSL 4 curves, by a similar amount as the shift between the CSL basic-voltage and 

low-voltage curves. 

In the executive summary of the preliminary analysis TSD, DOE asked for comment 

regarding the various scaling relationships it developed to analyze EPS representative units and 

generate CSLs for the scaled product classes. The California IOUs commented that they agreed 

"with [scaling EPS] CSLs on the basis of nameplate output power" but added that the standard 

equation should be based on power alone, not on voltage or cord length because this approach 

would allow DOE to create a potential standard more transparently than one based on voltage or 

cord length. In their view, an approach based on either or both of these factors would 

unnecessarily complicate the analysis without yielding an appreciable benefit with respect to 

determining an EPS’s achievable efficiency. (California IOUs, No. 43 at p. 8). 

DOE is proposing to apply the output power scaling method detailed in chapter 5 of the 

TSD to set the standards for the scaled product classes. 

During the preliminary analysis, DOE analyzed the impacts of setting a discrete standard 

for product class X (multiple-voltage EPSs) as there was only one existing product on the market 

at that time. Since then, DOE has re-evaluated its data and now believes that the ENERGY 

STAR 2.0 low-voltage standard equation for AC-DC conversion is a preferable approach to 

setting standards for multiple-voltage EPSs because lower power EPSs tend to be less efficient. 

Under this approach, DOE would take into account that trend and any low-power multiplevoltage EPSs that appear on the market would not be relegated to a single efficiency level that 

140 
was established based on the performance of a 203W unit. As detailed in chapter 5 of the TSD, 

the ENERGY STAR 2.0 low-voltage equation matches the CSL DOE is proposing for the 

standard at the representative unit’s output power of 203 watts, but also sets less stringent 

efficiency standards for lower power EPSs. Therefore, the proposed equation accounts for future 

products requiring multiple-voltage EPSs by setting a continuous standard versus output power 

while also supporting DOE’s analysis of the 203W representative unit in product class X. DOE 

applied the same constraints when fitting the equation to the test data as it did for product classes 

B, C, D, and E. DOE seeks comment on this proposed approach in setting a standard for 

multiple-voltage EPSs. 

For product class H (high-power EPSs), DOE proposes to set a discrete standard for all 

EPSs greater than 250 watts. DOE believes this is appropriate for two main reasons: (1) DOE is 

aware of only one application for high-power EPSs (i.e. amateur radios) and (2) this approach is 

consistent with the standard for product class B, which is a discrete level for all EPSs with 

nameplate output powers greater than 49 watts. In light of these facts, setting a single efficiency 

level as the standard for all EPSs with output powers greater than 250 watts (i.e. high-power 

EPSs) appears to be a reasonable approach to ensure a minimal level of energy efficiency while 

minimizing the overall level of burden on manufacturers. DOE seeks comment on this approach. 

2. Engineering Analysis for Battery Chargers 

When developing the engineering analysis for battery chargers, DOE selected 

representative units for each product class. For each representative unit, DOE tested a number of 

different products. After examining the test results, DOE selected CSLs that set discrete levels of 

improved battery charger performance in terms of energy consumption. Subsequently, for each 

141 
CSL, DOE used either teardown data or information gained from manufacturer interviews to 

generate costs corresponding to each CSL for each representative unit. Finally, for each product 

class, DOE developed scaling relationships using additional test results and generated UEC 

equations based on battery energy. 

a. Representative Units 

For each product class, DOE selected a representative unit upon which it conducted its 

engineering analysis and developed a cost-efficiency curve. The representative unit is meant to 

be an idealized battery charger typical of those used with high-volume applications in its product 

class. Because results from the analysis of these representative units would later be extended to 

additional battery chargers, DOE selected high-volume and/or high-energy-consumption 

applications that use batteries that are typically found across battery chargers in the given 

product class. The analysis of these battery chargers is pertinent to all the applications in the 

product class under the assumption that all battery chargers with the same battery voltage and 

energy provide similar utility to the user, regardless of the actual end-use product with which 

they work. The table below shows the representative units for each product class that DOE 

analyzed. 

142 
Table IV-13 The Battery Charger Representative Units for each Product Class 

Product 

Class # 

Input / 

Output Type 

Battery 

Energy 

(Wh) 

Special 

Characteristic or 

Battery Voltage 

Rep. Unit 

Battery 

Voltage 

(V) 

Rep. Unit 

Battery 

Energy 

(Wh) 

1 

AC In, 

DC Out 

< 100 

Inductive 

Connection 3.6 1.5 

2 < 4 V 3.6 3 

3 4–10 V 7.2 10 

4 > 10 V 12 20 

5 

100–3000 

< 20 V 12 800 

6 ≥ 20 V 24 400 

7 > 3000 - 48 3,750 

8 DC In, 

DC Out 

- < 9 V Input 3.6 2 

9 - ≥ 9 V Input 5 3.6 

10 AC In, 

AC Out - - 12 70 

Additional details on the battery charger representative units can be found in chapter 5 of 

the TSD. 

b. Battery Charger Efficiency Metrics 

In the preliminary analysis, DOE considered using a single metric (i.e. UEC) to illustrate 

the improved performance of battery chargers. DOE designed the calculation of UEC to 

represent an annualized amount of the non-useful energy consumed by a battery charger in all 

modes of operation. Non-useful energy is the total amount of energy consumed by a battery 

charger that is not transferred and stored in a battery as a result of charging (i.e. losses). In order 

to calculate UEC, DOE must have the performance data, which comes directly from its battery 

charger test procedure (see section IV.A.4.e.). DOE must also make assumptions about the 

amount of time spent in each mode of operation. The collective assumption about the amount of 

143 
time spent in each mode of operation is referred to as a usage profile and is addressed in section 

IV.E and further detail in TSD chapter 7. 

The possible use of a UEC metric generated numerous comments. NEEP and PG&E 

stated that they believed UEC to be an inappropriate metric because of the uncertainties around 

the usage profiles. (NEEP, No. 51 at p. 3; PG&E, et al., No. 49 at p. 1) NEEP suggested that 

DOE should regulate 24-hour energy and standby mode power individually rather than use UEC. 

(NEEP, No. 51 at p. 4) For product classes 1 through 9, PG&E proposed that DOE should have 

separate standards for 24-hour charge and maintenance energy and no-battery mode power, 

while for product class 10, DOE should regulate only maintenance mode power. (PG&E, et al., 

No. 49 at p. 2) PG&E also suggested another alternative in which DOE could use UEC, but that 

alternative involved giving equal weight to each mode of operation. (PG&E, et al., No. 49 at p. 

2) While the ENERGY STAR specification for battery chargers (i.e. a nonactive energy ratio) 

does not consider active (or charge) mode, the California IOUs agreed with DOE’s approach to 

consider active mode as a component of UEC. (California IOUs, No. 43 at p. 1) Details on UEC 

are included in the next section of today’s notice (IV.C.2.c). 

DOE recognizes that a wide range of consumers may use the same product in different 

ways, which may cause some uncertainty about usage profiles. Notwithstanding that possibility, 

DOE believes that its assumptions are accurate and appropriate gauges of product use because 

calculated weighted averages of usage profiles based on a distribution of user types were used to 

represent each product class. These assumptions also rely on a variety of sources including 

information from manufacturers and utilities. Details on DOE’s new usage profile assumptions 

144 
 

 

and how they have changed since the preliminary analysis can be found in section IV.E of 

today’s notice and TSD chapter 7. 

DOE also appreciates suggestions to regulate only product class 10 (AC in/AC out) on 

the basis of maintenance mode power. DOE’s proposal follows that suggestion. DOE assumes 

that UPSs, which comprise all of product class 10 units, are always in maintenance mode and 

undergo zero charges per year. By following this approach, the calculated energy per year for 

these devices is simply an allowance of maintenance mode power over a 365-day year. However, 

by converting maintenance mode power to a UEC, DOE can ensure consistency across all 

battery charger classes and avoid any potential confusion.30 

Finally, DOE believes that by aggregating the performance parameters of battery 

chargers into one metric and applying a usage profile, it will allow manufacturers more 

flexibility to improve performance in the modes of operation that will be the most beneficial to 

their consumers rather than being required to improve the performance in each mode of 

operation, some of which may not provide any appreciable benefit. For example, a battery 

charger used with a mobile phone is likely to spend more time per day in no-battery mode than a 

battery charger used for a house phone, which is likely to spend a significant portion of everyday 

in maintenance mode. Consequently, it would be more beneficial to consumers of mobile phones 

if manufacturers improved no-battery mode and house phone battery charger manufacturers 

30 If DOE were to establish an energy conservation standard for UPSs in terms of maintenance mode power, 

manufacturers of other products could be confused and believe that their product is also subject to a maintenance 

mode power standard, when in fact, it is a combination of all of their product’s performance characteristics. 

145 
 

 

improved maintenance mode. Therefore, DOE plans to continue to use UEC as the metric for 

battery chargers. 

c. Calculation of Unit Energy Consumption 

As discussed in IV.C.2.b, UEC is based on a calculation designed to give the total annual 

amount of energy lost by a battery charger from the time spent in each mode of operation. For 

the preliminary analysis, the various performance parameters were combined with the usage 

profile parameters and used to calculate UEC with the following equation: 

Where 

E24 = 24 hour energy 

Ebatt = Measured battery energy 

Pm = Maintenance mode power 

Psb = Standby mode power 

Poff = Off mode power 

tc = Time to completely charge a fully discharged battery 

n = Number of charges per day 

ta&m = Time per day spent in active and maintenance mode 

tsb = Time per day spent in standby mode 

toff = Time per day spent in off mode31 

When separated and examined in segments, it becomes evident how this equation gives a 

value for energy consumed in each mode of operation per day and ultimately, energy 

consumption per year. These segments are discussed individually below. DOE seeks comment 

on all of these equations and its proposed approach. 

31 Those values shown in italics are parameters assumed in the usage profile and change for each product class. 

Further discussion of them and their derivation is found in IV.E. The other values should be determined according to 

section 5 of Appendix Y to Subpart B of Part 430. 

ܷܥܧ ൌ 365 ൬݊ሺܧଶସ െ ܲ௠ሺ24 െ ݐ௖ሻ െ ܧ௔௕௧௧ሻ ൅ ቀܲ௠൫ݐ ௠&௔െ ሺݐ௖݊ሻ൯ቁ ൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯൰

146 
Active (or Charge) Mode Energy per Day 

ሻ െ ܧ௔௕௧௧ሻ ൌ	 ܧ௖஺௧௜௩௘ ெ௢ௗ௘ /݀ܽݕ 	24 െ ݐ ௖െ ܲ௠ሺ ܧଶସ ݊ሺ

In the first portion of the equation, shown above, DOE combines the assumed number of 

charges per day, 24-hour energy, maintenance mode power, charge time, and measured battery 

energy to calculate the active mode energy losses per day. To calculate this value, 24-hour 

energy (E24) is reduced by the measured battery energy (the useful energy inherently included in 

a 24-hour energy measurement) and the product of the value of the maintenance mode power 

multiplied by the quantity of 24 minus charge time. This latter value (24 minus charge time) 

corresponds to the amount of time spent in maintenance mode, which, when multiplied by 

maintenance mode power, yields the amount of maintenance mode energy consumed by the 

tested product. Thus, maintenance mode energy and the value of the energy transferred to the 

battery during charging are both subtracted from 24-hour energy, leaving a quantity theoretically 

equivalent to the amount of energy required to fully charge a depleted battery. This number is 

then multiplied by the assumed number of charges per day (n) resulting in a value for active 

mode energy per day. Details on DOE’s usage profile assumptions can be found in section IV.E 

of today’s notice and TSD chapter 7. 

Maintenance Mode Energy per Day 

ݕ/݀ܽ ݀݁݋ܯ ܽܯݐ݁݊ܿܽ݊݁݅݊ ܧ ൌ ሻ൯ቁܿ݊ݐሺ െ ݉&ܽݐ൫ܲ݉ቀ

In the second segment of DOE’s equation, shown above, maintenance mode power, time 

spent in active and maintenance mode per day, charge time, and the assumed number of charges 

per day are combined to obtain maintenance mode energy per day. Time spent in active and 

maintenance mode is subtracted by the product of the charge time multiplied by the number of 

147 
 

 

charges per day. The resulting quantity is an estimate of time spent in maintenance mode per 

day, which, when multiplied by the measured value of maintenance mode power, yields the 

energy consumed per day in maintenance mode. 

Standby (or No-Battery) Mode Energy per Day 

ݕ/݀ܽ ݀݁݋ܯ ܽ݊ݐܵݕܾ݀ ܧ 	ൌ ሻܾݏݐܾݏܲሺ

In the third part of DOE’s UEC equation, shown above, the measured value of standby 

mode power is multiplied by the estimated time in standby mode per day, which results in a 

value of energy consumed per day in standby mode. 

Off-Mode Energy per Day 

ݕ/݀ܽ ݀݁݋ܯ ܤݐݐ݁ܽݕݎ _݋ܰܧ ൌ ൯݂݂݋ݐ݂݂݋ܲ൫

In the final part of DOE’s UEC equation, shown above, the measured value of off-mode 

power is multiplied by the estimated time in off-mode per day, which results in a value of energy 

consumed per day in off-mode. 

Finally, to obtain UEC, the values found through the above calculations are added 

together. The resulting sum is equivalent to an estimate of the average amount of energy 

consumed by a battery charger per day. That value is then multiplied by 365, the number of days 

in a year, and the end result is a value of energy consumed per year. 

148 
 

 

Modifications to Equation for Unit Energy Consumption 

On April 2, 2010, DOE published its NOPR on active mode test procedures for battery 

chargers and EPSs. 75 FR 16958. In that notice, DOE proposed shortening the active mode test 

procedure in scenarios where a technician could determine that a battery charger had entered 

maintenance mode. 75 FR 16970. However, during its testing of battery chargers, DOE observed 

complications arising when attempting to determine the charge time for some devices, which, in 

turn, could affect the accuracy of the UEC calculation. DOE also received comments opposed to 

the proposed shortened test procedure. DOE ultimately decided that the duration of the charge 

test must not be shortened and be a minimum of 24 hours. See 76 FR 31750 (final rule 

establishing amended test procedure for battery chargers and EPSs). The test that DOE adopted 

is longer if it is known (e.g. because of an indicator light on the battery charger) or it can be 

determined from manufacturer information that fully charging the associated battery will take 

longer than 19 hours.32 

This revision to the test procedure is important because it underscores the potential issues 

with trying to determine exactly when a battery charger has entered maintenance mode, which 

creates difficulty in determining charge time. To address this situation, DOE modified its initial 

UEC equation. The new equation, which was presented to manufacturers during interviews, is 

mathematically equivalent to the equation presented in the preliminary analysis. When the terms 

in the preliminary analysis UEC equation are multiplied, those terms containing a factor of 

charge time cancel each other out and drop out of the equation. What is left can be factored and 

32 The charge mode test must include at least a five-hour period where the unit being tested is known to be in 

maintenance mode. Thus, if a device takes longer than 19 hours to charge, or is expected to take longer than 19 

hours to charge, the entire duration of the charge mode test will exceed 24 hours in total time after the five-hour 

period of maintenance mode time is added. 76 FR 31750, 31766-67, and 31780. 

149 
rewritten as done below. This means that even though the new equation looks different from the 

equation presented for the preliminary analysis, the value that is obtained is exactly the same and 

represents the exact same value of unit energy consumption. 

ܷܥܧ ൌ 365 ൬݊ሺܧଶସ െ ܧ௔௕௧௧ሻ ൅ ቀܲ௠൫ݐ ௠&௔െ ሺ24݊ሻ൯ቁ ൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯൰

In addition to initially considering a shortened battery charger active mode test 

procedure, DOE considered capping the measurement of 24-hour energy at the 24-hour mark of 

the test. However, following this approach could result in inaccuracies because that measurement 

would exclude the full amount of energy used to charge a battery if the charge time is longer than 

24 hours in duration. To account for this possibility, DOE altered this initial approach in the test 

procedure final rule by requiring the measurement of energy for the entire duration of the charge 

and maintenance mode test, which includes a minimum of 5 hours in maintenance mode. 76 FR 

31750, 31780. 

The modifications to the UEC calculation do not alter the value obtained when the charge 

and maintenance mode test is completed within 24 hours. However, if the test exceeds 24 hours, 

the energy lost during charging is scaled back to a 24-hour, or per day, cycle by multiplying that 

energy by the ratio of 24 to the duration of the charge and maintenance mode test. In the 

equation below, tcd, represents the duration of the charge and maintenance mode test and is a 

value that the test procedure requires technicians to determine. DOE also modified the equation 

for the NOPR by inserting a provision to subtract 5 hours of maintenance mode energy from the 

24-hour energy measurement. This change was made because the charge and maintenance mode 

150 
 

 

test includes a minimum of 5 hours of maintenance mode time. Consequently, in the second 

portion of the equation below, DOE would reduce the amount of time subtracted from the 

assumed time in active and maintenance mode time per day. 

In other words, the second portion of the equation, which is an approximation of 

maintenance mode energy, is reduced by 5 hours. This alteration is needed in those instances 

when the charge and maintenance mode test exceeds 24 hours, because the duration of the test 

minus 5 hours is an approximation of charge time. This information, tcd, can then be used to 

approximate the portion of time that a device is assumed to spend in active and maintenance 

mode per day (ta&m) is solely dedicated to maintenance mode.33 The primary equation that 

manufacturers will use to determine their product’s unit energy consumption and whether or not 

their device complies with DOE’s standards is below. 

൅ ൫ܲ௠ሺݐ ௠&௔െ ሺݐ௖ௗ െ 5ሻ݊ሻ൯ ൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯ሻ 24 ሻ ܧଶସ െ 5ܲ௠ െ ܧ௔௕௧௧ ܷܥܧ ൌ 365ሺ݊ሺ ݐ௖ௗ

Secondary Calculation of UEC 

For some battery chargers, the equation described above is not appropriate and an 

alternative calculation is necessary. Specifically, in those cases where the charge test duration (as 

determined according to section 5.2 of Appendix Y to Subpart B of Part 430) minus 5 hours is 

multiplied by the number of charges per day (n) is greater than the time assumed in active and 

33 For a test exceeding 24 hours, the duration of the test less 5 hours is equal to the time it took the battery being 

tested to become fully charged (tcd – 5). That value, multiplied by the assumed number of charges per day, gives an 

estimate of charge (or active) time per day, which can then be subtracted from DOE’s other assumption for ta&m. 

That difference is an approximation for maintenance mode time per day. 

151 
maintenance mode (ta&m), an alternative equation must be used. A different equation must be 

used because if the number of charges per day multiplied by the time it takes to charge (charge 

test duration minus 5 hours -- or the charge time per day) is longer than the assumption for the 

amount of time spent in charge mode and maintenance mode per day, that difference creates an 

inconsistency between the measurements for the test product and DOE’s assumptions. This 

problem can be corrected by using an alternative equation, which is shown below. 

൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯ሻ െ 5ሻ

24

ሺݐ௖ௗ

ሻ ܧଶସ െ 5ܲ௠ െ ܧ௔௕௧௧ ܷܥܧ ൌ 365ሺ݊ሺ

This alternative equation resolves this inconsistency by prorating the energy used for 

charging the battery. 

d. Battery Charger Candidate Standard Levels (CSLs) 

After selecting its representative units for battery chargers, DOE examined the impacts 

on the cost of improving the efficiency of each of the representative units to evaluate the impact 

and assess the viability of potential energy efficiency standards. As described in the technology 

assessment and screening analysis, there are numerous design options available for improving 

efficiency and each incremental technology improvement increases the battery charger efficiency 

along a continuum. The engineering analysis develops cost estimates for several CSLs along that 

continuum. 

152 
 

CSLs are often based on (1) efficiencies available in the market; (2) voluntary 

specifications or mandatory standards that cause manufacturers to develop products at particular 

efficiency levels; and (3) the maximum technologically feasible level.34 

Currently, there are no energy conservation standards for battery chargers. DOE does not 

believe the ENERGY STAR efficiency level to be widely applicable, primarily because these 

levels are limited to chargers used for motor-operated applications and contain no provisions to 

cover active mode energy consumption. Because of this situation, DOE based the CSLs for its 

battery charger engineering analysis on the efficiencies obtainable through the design options 

presented previously (see IV.A.4.f). These options are readily seen in various commercially 

available units. DOE selected commercially available battery chargers at the representative-unit 

battery voltage and energy levels from the high-volume applications identified in the market 

survey. DOE then tested these units in accordance with the DOE battery charger test procedure. 

For each representative unit, DOE then selected CSLs to correspond to the efficiency of battery 

charger models that were comparable to each other in most respects, but differed significantly in 

UEC (i.e. efficiency). 

In general, for each representative unit, DOE chose the baseline (CSL 0) unit to be the 

one with the highest calculated unit energy consumption, and the best-in-market (CSL 2) to be 

the one with the lowest. Where possible, the energy consumption of an intermediate model was 

selected as the basis for CSL 1 to provide additional resolution to the analysis. 

34 The “max-tech” level represents the most efficient design that is commercialized or has been demonstrated in a 

prototype with materials or technologies available today. “Max-tech” is not constrained by economic justification, 

and typically is the most expensive design option considered in the engineering analysis. 

153 
 

Unlike the previous three CSLs, CSL 3 was not based on an evaluation of the efficiency 

of battery charger units in the market, since battery chargers with maximum technologically 

feasible efficiency levels are not commercially available due to their high cost. Where possible, 

DOE analyzed manufacturer estimates of max-tech costs and efficiencies. In some cases, 

manufacturers were unable to offer any insight into efficiencies beyond the best currently 

available in the market. Therefore, DOE projected the efficiency of a max-tech unit by 

estimating through extrapolation from its analysis of the analyzed CSL 2 unit the impacts of 

adding any remaining energy efficiency design options. 

DOE received a number of comments from interested parties regarding the CSLs 

developed for the preliminary analysis. The California IOUs suggested that DOE consider CSLs 

between the best-in-market and max-tech levels. (California IOUs, No. 43 at pp. 3, 5) NEEP 

made a similar suggestion, stating that DOE should have an additional CSL between the 

intermediate and max-tech CSLs. (NEEP, No. 51 at p. 4) The California IOUs added that DOE 

should consider the efficiency levels proposed at a standards-related workshop held in California 

on October 11, 2010.35 (California IOUs, No. 43 at p. 2) 

In response to these suggestions on the preliminary analysis, DOE considered the levels 

proposed at the California workshop. At that workshop, California proposed using separate 

metrics for 24-hour energy, maintenance mode power, and standby mode power. Subsequently, 

35PG&E, Analysis of Standards Options for Battery Charger Systems, October 1, 2010 

(http://www.energy.ca.gov/appliances/battery_chargers/documents/2010-10-11_workshop/2010-10­

11_Battery_Charger_Title_20_CASE_Report_v2-2-2.pdf). 

154 
California modified its approach to battery charger standards and combined the requirements for 

maintenance mode power and standby mode power into one metric. Using its usage profiles to 

translate these standards into a value of UEC, DOE compared its CSLs with the levels adopted 

by California. DOE found that, in most cases, when California’s proposed standard was 

calculated into a value of UEC (using DOE’s usage profile assumptions), it generally 

corresponded closely with one of DOE’s CSLs for each product class. Therefore, in most 

instances, little valuable resolution could be added to DOE’s cost-efficiency curves. 

Although this was the case for most product classes, it was not the case for all of them. 

For product class 2, DOE adopted the suggestion from the California IOUs and added a level 

between CSL 1 and CSL 2 because the magnitude of the gap between UEC values was large 

enough to permit an additional CSL that could provide more cost effective savings. Please see 

TSD chapter 5 for product class 2 test results that illustrate this gap. 

Table IV-14 below shows which CSL aligns most closely with the California proposal for 

each product class. 

155 
Table IV-14 CSLs Equivalent to California Proposed Standards 

Product Class CSL Equivalent to CEC Standard 

1 (Low-Energy, Inductive) CSL 0 

2 (Low-Energy, Low-Voltage) CSL 2 

3 (Low-Energy, Medium-Voltage) CSL 2 

4 (Low-Energy, High-Voltage) CSL 2 

5 (Medium-Energy, Low-Voltage) CSL 3 

6 (Medium-Energy, High-Voltage) CSL 3 

7 (High-Energy) CSL 1 

8 (DC Input < 9 V) CSL 0 

10 (AC Output) CSL 3 

In addition, DOE received comments on specific CSLs for specific product classes. For 

product class 1(low-energy, inductive) in particular, the California IOUs encouraged DOE to 

consider a CSL higher than CSL 3 because, in their view, CSL 3 was shown to be cost effective, 

leaving a possibility of additional cost-effective savings at higher efficiencies. (California IOUs, 

No. 43 at p. 5) For product class 2 (low-energy, low-voltage), the California IOUs asserted that 

DOE’s baseline CSL should be lower because the test results presented in the preliminary 

analysis TSD showed products with UEC levels higher than the baseline value selected by DOE. 

(California IOUs, No. 43 at p. 6) PTI expressed concern over the max-tech level for product 

class 4, stating that it would be achievable only by using a lithium-based (i.e. Lithium-ion or “Liion”) battery technology, which is currently used in laptop computer applications. (PTI, No. 47 at 

p. 8) Finally, when developing a max-tech level for product classes 2, 3 (low-energy, medium 

voltage), 4 (low-energy, high-voltage), 8 (low-energy, low DC input), and 9(low-energy, high 

DC input), the California IOUs suggested that DOE speak to integrated circuit component 

suppliers. (California IOUs, No. 43 at p. 5) 

156 
Based on all of these comments, DOE conducted further analysis and review. For product 

class 1, DOE conducted additional interviews with manufacturers of these products and has 

revised its engineering analysis accordingly. DOE believes that the new MSPs, which are shown 

in section IV.C.2.i, more accurately depict the relationship between cost and efficiency for 

electric toothbrushes, which is the predominant application in that class. 

For product class 2, DOE understands the concerns about creating an accurate baseline 

UEC for these devices. However, the baseline level that DOE has developed for today’s NOPR 

is representative of the worst performing products tested by DOE. All of the units that showed 

higher values of energy consumption were products that Ecos, an independent consulting firm 

and test lab that assisted the CEC when developing a battery charger test procedure, tested and 

provided to DOE. DOE believes that this factor may be partially explained by timing. Since 

many of the units tested by Ecos that performed poorly were older test units, it is likely that these 

devices did not incorporate EPSs that meet the EISA 2007 regulations that went into effect in 

2008. Therefore, DOE believes that its current CSL 0 for product class 2 is appropriate and 

provides a reasonable picture of the current battery charger market. 

In response to PTI’s comment, DOE clarifies that its preliminary analysis did not include 

an analysis for CSL 3 in product class 4. DOE obtained results only up to CSL 2 for product 

class 4. DOE notes that one of the units tested and torn down for that CSL was a power tool. For 

the NOPR, DOE has developed an analysis for CSL 3 in product class 4, which corresponds to 

that class’s maximum technology level. 

157 
Finally, in developing the max-tech levels in the NOPR engineering analysis, DOE relied 

on input from manufacturers of battery chargers and original equipment manufacturers (OEMs) 

of products that use battery chargers. Manufacturers were able to provide DOE with sufficient 

information to enable the agency to ascertain what level of technology is feasible and is capable 

of surpassing the efficiency levels of incumbent technology currently available at the high end of 

the market today. Based on this information, DOE tentatively concluded that based on these 

discussions with manufacturers and OEMs there was sufficient information to define max-tech 

levels without interviewing integrated circuit suppliers. 

e. Test and Teardowns 

As mentioned above, the CSLs used in the battery charger engineering analysis were 

based on the efficiencies of battery chargers available in the market. Following testing, the units 

corresponding to each commercially available CSL were disassembled to (1) evaluate the 

presence of energy efficiency design options and (2) estimate the materials cost. The 

disassemblies included an examination of the general design of the battery charger and helped 

confirm the presence of any of the technology options discussed in section IV.A.4.f. 

After the battery charger units corresponding to the CSLs were evaluated, they were torn 

down by iSuppli, a DOE contractor and industry expert. An in-depth teardown and cost analysis 

was performed for each of these units. For some products, like camcorders and notebook 

computers, the battery charger constitutes a small portion of the circuitry. In evaluating the 

related costs, iSuppli identified the subset of components in each product enclosure responsible 

158 
for battery charging. The results of these teardowns were then used as the primary source for the 

MSPs. 

Interested parties offered some feedback regarding DOE’s test and teardowns after the 

preliminary analysis. Stanley Black and Decker suggested that DOE should validate iSuppli’s 

results by having them teardown products whose true costs are known -- i.e. those instances 

where a manufacturer may have supplied data under a non-disclosure agreement. (B&D, Pub. 

Mtg. Tr., No. 37 at p. 234) AHAM recommended that DOE look at low cost products in product 

class 4 (e.g. notebook computers and large power tools). Wahl Clipper recommended that DOE 

estimate costs at lower volume levels than those used in the preliminary analysis -- it offered 

20,000 units per year as one alternative -- because the effects on cost might be greater when 

components are purchased in lower volumes. (Wahl Clipper, Pub. Mtg. Tr., No. 37 at p. 206) 

The California IOUs made a number of recommendations to DOE. First, they suggested that 

DOE use PG&E’s battery charger test data and that DOE gather more teardown data. (California 

IOUs, No. 43 at p. 2) Second, they supported DOE’s decision to leave out packaging costs from 

the teardown results. In particular, for product class 2 (e.g. mobile and cordless phones), they 

recommended that DOE conduct teardown analyses of units with slightly higher and lower 

battery energies. Third, the California IOUs urged DOE to test and tear down a wider array of 

battery chargers from product classes 5 (e.g. marine chargers) and 7 (e.g. golf cars). They 

suggested this approach because they claimed that their own test data showed a wider range of 

efficiencies among battery chargers belonging to these classes. (California IOUs, No. 43 at pp. 4, 

6) 

159 
For the NOPR, DOE has adopted most of the recommendations raised by commenters 

and has expanded its test program. DOE has performed additional tests using a variety of 

products from a number of product classes, including product classes 2, 4, 5, and 7. Further, 

DOE has performed additional teardown analyses on products from all ten proposed product 

classes. In total, over 100 new test results have been incorporated into the NOPR analysis. 

Packaging costs have continued to be excluded because they do not represent costs associated 

with improving the efficiency of a product. Regarding Wahl Clipper’s suggestion to modify the 

volume assumption to 20,000 in order to determine how costs may change for a lower volume 

manufacturer, DOE believes that the large number of applications in each product class make it 

too difficult to select an appropriate low volume level. Additionally, DOE believes that the 

change in volume that results in higher costs for a manufacturer is likely to have little effect on 

consumers because the incremental costs from CSL to CSL are likely to be the same regardless 

of volume. 

Finally, DOE verified the accuracy of the iSuppli results by confirming those results with 

individual manufacturers during interviews. As will be discussed in the following section, DOE 

performed additional manufacturer interviews for the NOPR and during these interviews, the 

initial iSuppli results were vetted with manufacturers. DOE believes that it has sufficiently 

verified the accuracy of its teardown results and believes that all of the engineering costs gleaned 

from iSuppli are appropriate. 

160 
f. Manufacturer Interviews 

The preliminary analysis had, in part, relied on information obtained through interviews 

with several battery charger manufacturers. These manufacturers consisted of companies that 

manufacture battery chargers and OEMs of battery-operated products who package battery 

chargers with their end-use products. DOE followed this approach to obtain data on the possible 

efficiencies and resultant costs of consumer battery chargers. 

DOE received two comments regarding manufacturer interviews. First, PTI 

recommended that DOE speak with power tool manufacturers individually to obtain detailed 

information that would otherwise be unavailable through PTI as a trade association. (PTI, No. 47 

at p. 12) Second, AHAM requested that the manufacturer interviews also involve discussions 

about testing costs and non-recurring capital expenditures. (AHAM, No. 44 at p. 13) 

In preparing the NOPR, additional interviews were conducted, including those with 

manufacturers who were previously interviewed and new ones who were not. These interviews 

served two purposes. First, it gave manufacturers the opportunity to provide feedback on the 

preliminary analysis engineering analysis results. Aggregated information from these results is 

provided in TSD chapter 5. Second, these interviews also provided manufacturer inputs and 

comments in preparing the manufacturer impact analysis, which is discussed in detail in section 

IV.I. 

DOE attempted to obtain teardown results for all of its product classes but encountered 

difficulties in obtaining useful and accurate teardown results for two of its products classes -- 

161 
namely, product class 1 (e.g. electric toothbrushes) and product class 10 (e.g. uninterruptible 

power supplies). For these two classes, DOE relied heavily on information obtained from 

manufacturer interviews. DOE found that when it attempted to teardown product class 1 devices, 

most contained potting (i.e. material used to waterproof internal electronics). Removal of the 

potting also removed the identifying markings that iSuppli needed to estimate a cost for the 

components. As a result, manufacturer interview data helped furnish the necessary information to 

assist DOE in estimating these costs. 

In the case of UPSs, DOE found that it was difficult to accurately compare product costs 

because of the varying functionality of these devices. For example, DOE examined multiple 

UPSs, some of which provided additional utility to end users, such as AVR. As discussed earlier, 

AVR involves circuitry that monitors input voltage from the wall and ensures that all products 

plugged into the UPS see a steady flow of voltage despite any fluctuations. This added circuitry 

was impossible to distinguish from the standard UPS battery charging circuitry, which made it 

difficult to compare the costs of products that did not provide the same level of utility to the enduser. Furthermore, because the cost versus efficiency data provided by manufacturers showed 

economically justifiable levels through the max-tech level developed in the preliminary analysis, 

DOE believed that these data were sufficient to set out the proposed levels without resorting to a 

more time-consuming tear-down analysis. However, after a second round of interviews with UPS 

manufacturers for the NOPR and conducting additional analysis (including testing), DOE found 

that it needed to make a modification to its approach for dealing with battery chargers within 

UPSs. 

162 
When DOE tested UPSs according to the battery charger test procedure, it was unable to 

obtain maintenance mode power measurements as low (i.e. as good in terms of energy 

consumption) as those that manufacturers indicated were possible. DOE believes that the 

discrepancies between its test measurements and the data provided by manufacturers stems from 

the manner in which the test procedure measures energy consumption. TP measures consumption 

of unit as a whole -- the entire UPS. BC only is using from mfr data. In particular, the DOE test 

procedure measures the energy consumption of the unit -- in this case, the UPS -- as a whole. 

Measuring the energy consumption of the battery charger alone in this instance would involve 

destructive testing. As a result, the data that DOE derived following its current test procedure for 

battery chargers includes the energy consumption from other UPS components other than the 

battery charger itself. For this reason, in this instance, DOE believes that the manufacturersupplied data is more likely to accurately reflect the actual energy consumption of the battery 

charger alone. Because manufacturers would be unlikely to over-estimate the potential energy 

consumption of their products, DOE believes that their estimates of power consumption from the 

UPS’s battery charger are still appropriate estimates. However, DOE still needs to account for 

the discrepancies between the manufacturer data and the measurements from its test procedure. 

For the NOPR, DOE conducted additional testing of UPSs in which it attempted to 

describe the differences between its test procedure measurement and the values provided by 

manufacturers. During this round of testing, DOE performed the DOE test procedure, but added 

another measurement. As mentioned previously, while it is extremely difficult to isolate the 

power consumption due to battery charging from any other UPS functionality, the input power to 

the battery itself can be measured. With this measurement, DOE obtained two useful pieces of 

163 
information. First, it allowed DOE to isolate a portion of battery charging power consumption 

from all other functions within a UPS and develop a trend line that describes how maintenance 

mode power will vary as battery energy changes. Second, this measurement, combined with the 

data from the tested units that corresponded to DOE’s best-in-market test results (in terms of 

maintenance mode power as measured in the DOE test procedure), allowed DOE to develop 

supplemental values that it could use to increment the data provided by manufacturer such that it 

correlated to DOE test results. These values essentially operate as a means to account for the 

additional energy consumption used by a device when providing additional functionality. DOE 

developed two values, shown in Table IV-15 below, one for basic UPSs and one for UPSs that 

incorporate AVR. See TSD Chapter 5 for additional details. DOE is proposing to use these two 

values to develop an appropriate standard for basic UPSs and UPSs with AVR, after DOE 

proposes selecting an appropriate TSL for product 10. 

Table IV-15 Supplemental Values for Product Classes 10a and 10b 

Product Class 

Maintenance Mode 

Supplemental Value for 

Proposed Standard (W) 

UEC Supplemental Value 

for Proposed Standard 

(kWh/yr) 

10a (UPSs without AVR) 0.4 3.45 

10b (UPSs with AVR) 0.8 7.08 

g. Design Options 

Design options are technology options that remain viable for use in the engineering 

analysis after applying the screening analysis as discussed above in section IV.B. 

In response to the preliminary analysis, DOE received comments regarding design 

options and their application to the overall analysis. The California IOUs indicated that, with 

164 
respect to the larger battery charger product classes where lead-acid batteries are most common, 

DOE should apply technologies more common in smaller units, such as switch-mode power 

supplies, to these devices in the analysis. (California IOUs, No. 43 at p. 5) NEEP made similar 

suggestions and stated that DOE should examine whether technologies can be applied across 

multiple product classes. (NEEP, No. 51 at p. 2) However, CEA urged DOE to account for the 

differences in battery chemistries and determine the appropriateness of given technologies for 

certain applications. CEA added that DOE must consider how battery technologies could be 

impacted by new efficiency requirements. (CEA, No. 48 at p. 2) Motorola expressed similar 

concerns and noted that although certain battery chemistries are less efficient, those chemistries 

may have other inherently important features like wider temperature range operations and 

improved cycle-life. Motorola insisted that these things should be considered when DOE 

conducts its technical and economic analyses. (Motorola, No. 50 at p. 2) Stanley Black and 

Decker added that DOE should not assume that additional utility is desirable as it will likely 

cause an increase in cost to the consumer. (SBD, Pub. Mtg. Tr., No, 37 at pp. 147-148) Finally, 

Lester commented that transformer-based chargers are more reliable, durable and provide 

batteries with a much longer life expectancy. Lester added that these chargers are often 

preferable to more efficient switch-mode chargers in industrial applications. (Lester, No. 52 at p. 

2) Lester did not include any additional data to corroborate their statements regarding increased 

durability for battery chargers that are transformer-based and the life expectancy for batteries 

that use such chargers. 

DOE clarifies that all technology options that are not eliminated in the screening analysis 

(section IV.B) become design options that are considered in the engineering analysis. As most 

165 
CSLs are based on actual teardowns of units manufactured and sold in today’s battery charger 

market, DOE did not control which design options were used at each CSL. No technology 

options were preemptively eliminated from use with a particular product class. Similarly, if 

products are being manufactured and sold, DOE believes that fact indicates the absence of any 

significant loss in utility, such as an extremely limited operating temperature range or shortened 

cycle-life. Therefore, DOE believes that all CSLs can be met with technologies that are feasible 

and that fit the intended application. 

For the max-tech designs, which are not commercially available, DOE developed these 

levels in part with a focus on maintaining product utility as projected energy efficiency 

improved. Although some features, such as decreased charge time, were considered as added 

utilities, DOE did not assign any monetary value to such features. Additionally, DOE did not 

assume that such features were undesirable, particularly if the incremental improvement in 

performance causes a significant savings in energy costs. Finally, DOE appreciates the need to 

consider durability, reliability, and other performance and utility related features that affect 

consumer behavior. On these issues, DOE seeks information, including substantive data, to help 

it assess these factors in consumer products. 

h. Cost Model 

Today’s NOPR continues to apply the same approach used in the preliminary analysis to 

generate the manufacturer selling prices (MSPs) for the engineering analysis. For those product 

classes other than product classes 1 and 10, DOE’s MSPs rely on the teardown results obtained 

from iSuppli. The bills of materials provided by iSuppli were multiplied by a markup that 

166 
 

depended on product class. For those product classes for which DOE could not estimate MSPs 

using the iSuppli teardowns -- product classes 1 and 10 -- DOE relied on aggregate manufacturer 

interview data, which projected that economic savings would accrue through the max-tech level 

in the preliminary analysis. 

Additional details regarding the cost model and the markups assumed for each product 

class are presented in TSD chapter 5. 

i. Battery Charger Engineering Results 

The results of the engineering analysis are reported as cost-efficiency data (or “curves”) 

in the form of MSP (in dollars) versus unit energy consumption (in kWh/yr). These data form the 

basis for the NOPR analyses. This section illustrates the results that DOE obtained for all 10 

product classes in its NOPR engineering analysis. 

Table IV-16 Product Class 1 (Inductive Chargers) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy 

(Wh) 26.7 19.3 10.8 5.9 

Maintenance Mode 

Power (W) 1.2 0.8 0.4 0.2 

No-Battery Mode 

Power (W) 0.5 0.4 0.2 0.1 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy 

Consumption 

(kWh/yr) 

8.73 6.10 3.04 1.29 

MSP [$] $2.05 $2.30 $2.80 $6.80 

In response to the engineering results that DOE provided in the preliminary analysis for 

product class 1, DOE received one comment from Philips. Philips publicly submitted estimates 

167 
 

 

 

 

 

of “what the consumer pays,” for CSLs 0, 1, 2, and 3 for product class 1. Philips suggested that 

those values would be $8, $10, $15, and $24, respectively. (Philips, No. 43 at p. 2) In its 

preliminary analysis, DOE proposed MSPs for product class 1 to be: $2.05, $2.22, $2.45, $2.60, 

for CSLs 0 through 3 respectively. Although DOE appreciates the feedback provided by Philips, 

it is vastly different from the information gathered on manufacturer interviews. DOE believes 

this discrepancy is partially due to a misinterpretation of the term MSP. The values that Philips 

provided, as it has described them, would correspond to what DOE considers a retail price and 

not an MSP. DOE has revised its MSPs for product class 1 according to the data obtained from 

manufacturers on interviews for the NOPR. 

Table IV-17 Product Class 2 (Low-Energy, Low-Voltage) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 

CSL Description Baseline Intermediate 2nd Intermediate Best in Market Max Tech 

24 Hour Energy 

(Wh) 46.5 36.9 19.7 8.2 6.9 

Maintenance 

Mode Power 

(W) 

1.8 1.4 0.5 0.1 0.04 

No-Battery 

Mode Power 

(W) 

0.70 0.30 0.08 0.08 0.05 

Off-Mode Power 

(W) 0.0 0.0 0.0 0.0 0.0 

Unit Energy 

Consumption 

(kWh/yr) 

8.66 6.47 2.86 1.03 0.81 

MSP [$] $0.62 $0.71 $2.13 $3.84 $5.72 

DOE did not receive any specific comments on its product class 2 engineering results in 

the preliminary analysis, but its revised results are presented in Table IV-17. 

168 
 

 

 

 

 

 

 

 

 

 

 

Table IV-18 Product Class 3 (Low-Energy, Medium-Voltage) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 123.0 53.6 17.0 15.9 

Maintenance Mode 

Power (W) 4.5 1.8 0.3 0.3 

No-Battery Mode Power 

(W) 3.5 1.0 0.2 0.2 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy 

Consumption (kWh/yr) 11.90 4.68 0.79 0.75 

MSP [$] $0.77 $1.98 $5.47 $5.51 

DOE did not receive any specific comments on its product class 3 engineering results in 

the preliminary analysis, but its revised results are presented in Table IV-18. 

Table IV-19 Product Class 4 (Low-Energy, High-Voltage) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 167.5 52.6 39.1 27.2 

Maintenance Mode Power 

(W) 5.9 1.4 0.5 0.4 

No-Battery Mode Power (W) 2.2 1.4 0.3 0.3 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 37.73 9.91 4.57 3.01 

MSP [$] $3.79 $6.76 $12.71 $18.34 

DOE did not receive any specific comments on its product class 4 engineering results in 

the preliminary analysis, but its revised results are presented in Table IV-19. 

169 
 

 

 

 

 

 

 

Table IV-20 Product Class 5 (Medium-Energy, Low-Voltage) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 2036.9 1647.3 1195.5 1180.0 

Maintenance Mode Power (W) 21.2 11.9 8.0 0.0 

No-Battery Mode Power (W) 20.1 11.6 4.2 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 84.60 56.09 29.26 15.35 

Incremental MSP [$] $18.48 $21.71 $15.69 $127.00 

DOE did not receive any specific comments on its product class 5 engineering results in 

the preliminary analysis, but its revised results are presented in Table IV-20. 

Table IV-21 Product Class 6 (Medium-Energy, High-Voltage) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 891.6 786.1 561.0 536.4 

Maintenance Mode Power (W) 10.6 6.0 4.0 0.0 

No-Battery Mode Power (W) 10.0 5.8 2.1 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 120.60 81.72 38.33 16.79 

Incremental MSP [$] $18.48 $21.71 $15.69 $127.00 

For product class 6, DOE performed additional product testing for the NOPR, but did not 

obtain a complete data set upon which to base its engineering analysis. This situation was due in 

170 
 

large part to DOE’s inability to locate products with sufficiently similar battery energies and the 

fact that the products tested did not span a significant range of performance. DOE’s test data for 

this product class are available in chapter 5 of the accompanying TSD. In order to develop an 

engineering analysis for this product class, DOE relied on, among other things, the results 

gleaned from product class 5, interviews with manufacturers, and its limited test data from 

product class 6. 

The difference between product class 5 and product class 6 is the range of voltages that 

are covered. Product class 5 covers low-voltage (less than 20 V) and medium energy (100 Wh to 

3,000 Wh) products, while product class 6 covers high-voltage (greater than or equal to 20 V) 

and medium energy (100 Wh to 3,000 Wh) products. The representative unit examined for 

product class 5 is a 12 V, 800 Wh battery charger, while the representative unit analyzed for 

product class 6 is a 24 V, 400 Wh battery charger. Despite the change in voltage, DOE believes 

that similar technology options and battery charging strategies are available in both classes. Both 

chargers are used with relatively large sealed-lead acid batteries in products like wheelchairs, 

electric scooters, and electric lawn mowers. However, since the battery chargers in product class 

6 work with higher voltages, current can be reduced for the same output power, which creates the 

potential for making these devices slightly more efficient because I2

R losses36 will be reduced. 

For the NOPR, DOE examined its product class 5 results and analyzed how the 

performance may be impacted if similar technologies are used. The resulting performance 

parameters are shown in Table IV-21. To account for the projected variation in energy 

36 In electrical circuits, I2

R losses manifests themselves as heat and are the result of high levels of current flow 

through a device. 

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consumption, DOE used information on charge time and maintenance mode power to adjust the 

corresponding values for 24-hour energy. Additionally, DOE discussed with manufacturers about 

how costs may differ in manufacturing a 12 V (product class 5) charger versus a 24 V (product 

class 6) charger. Manufacturers indicated that, holding constant all other factors, there would 

likely be minimal change, if any, in the cost. Therefore, because DOE scaled performance 

assuming that the designs for corresponding CSLs in each product class used the same design 

options and only differed in voltage, DOE did not scale costs from product class 5. Rather than 

scaling the product class 5 costs, DOE used the same MSP’s for product class 6 that were 

developed from iSuppli tear down data for product class 5. DOE believes these costs are an 

accurate representation of the MSPs and seeks comment on its methodology in scaling the results 

of product class 5 to product class 6, including the decision to hold MSPs constant. 

Table IV-22 Product Class 7 (High-Energy) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 

CSL Description Baseline Intermediate Max Tech 

24 Hour Energy (Wh) 5884.2 5311.1 4860.0 

Maintenance Mode Power 

(W) 10.0 3.3 2.6 

No-Battery Mode Power 

(W) 0.0 1.5 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 255.05 191.74 131.44 

Incremental MSP [$] $88.07 $60.86 $164.14 

DOE did not receive any specific comments on its product class 7 results in the 

preliminary analysis, but its revised results are presented in Table IV-22. 

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Table IV-23 Product Class 8 (Low-Voltage DC Input) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy (Wh) 10.4 8.4 3.7 3.1 

Maintenance Mode Power 

(W) 0.3 0.2 0.1 0.04 

No-Battery Mode Power (W) 0.0 0.0 0.0 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 0.90 0.66 0.24 0.19 

MSP [$] $5.90 $3.26 $5.77 $5.95 

Product class 8 (e.g. MP3 players and smartphones) consists of devices that charge with a 

DC input of less than 9 V, which is mostly those products that charge via USB connections. 

When DOE analyzed this product class it tested and tore down 3 devices, one for CSL 0, 1, and 

2; and all of which were MP3 players. 

DOE’s analysis projects a significant drop in MSP from CSL 0 to CSL 1. See Table 

IV-23. Because of this drop, DOE tentatively believes that at least one of its trial standard levels 

for this product class meets DOE’s criteria for being economically justified and technologically 

feasible. However, the baseline unit MSP for this analysis may be inflated due to the cost of the 

particular integrated circuit used in that unit. The integrated circuit used in this device performs 

additional functions besides battery charging and constitutes a significant portion of the bill of 

materials generated by iSuppli. DOE was unable to determine what portion of the integrated 

circuit was dedicated to battery charging and therefore, kept the entire cost of the component in 

its bill of materials. Because of this factor and the minimal differences in energy consumption 

between each CSL for product class 8, DOE is considering an alternative approach in addition to 

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its proposed standard. Both the proposed standard and the alternative approach are outlined in 0 

and, as with all other product class data, DOE seeks comment on its MSP projections for product 

class data. 

Table IV-24 Product Class 9 (High-Voltage DC Input) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 

CSL Description Baseline Intermediate Best in Market 

24 Hour Energy (Wh) 48.1 13.5 8.1 

Maintenance Mode Power 

(W) 1.8 0.2 0.2 

No-Battery Mode Power 

(W) 0.0 0.1 0.1 

Off-Mode Power (W) 0.0 0.0 0.0 

Unit Energy Consumption 

(kWh/yr) 0.79 0.26 0.13 

MSP [$] $1.94 $2.77 $3.02 

For the preliminary analysis, DOE scaled the results of other product classes to obtain 

results for product class 9. The results of DOE’s revised analysis, based on test and teardown 

results, are shown in Table IV-24. 

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Table IV-25 Product Class 10 (AC Input, AC Output) Engineering Analysis Results 

CSL 0 CSL 1 CSL 2 CSL 3 

CSL Description Baseline Intermediate Best in Market Max Tech 

24 Hour Energy 

(Wh) - - - -

Maintenance Mode 

Power (W) 2.2 0.7 0.5 0.2 

No-Battery Mode 

Power (W) 0.0 0.0 0.0 0.0 

Off-Mode Power (W) 0.0 0.0 0.0 0.0 

Unit Energy 

Consumption 

(kWh/yr) 

19.27 6.13 4.00 1.50 

Incremental Unit 

Energy Consumption 

(kWh/yr) 

- 13.14 2.13 2.50 

MSP [$] $2.76 $3.93 $4.25 $4.64 

As discussed previously, DOE believes that the engineering analysis results it developed 

in the preliminary analysis using manufacturer-supplied data provide an appropriate estimate of 

the cost-versus-UEC (or maintenance mode power) relationship for the battery charger 

embedded within a UPS. Also as discussed previously, DOE believes that this relationship is 

appropriate for UPSs, regardless of whether they have AVR. Consequently, DOE has used one 

set of engineering data, presented in Table IV-25 above, in all of the subsequent analyses (e.g. 

the LCC and NIA). DOE contends that this is an accurate approach because the technologies 

available in designing a battery charger used within a UPS are the same whether or not that UPS 

has AVR. The corresponding costs for these technologies would also result in the same MSP for 

the battery charger as a component of the UPS. 

Finally, in the preliminary analysis, DOE developed cost-efficiency curves based on both 

manufacturer interviews and when possible, test and teardown results. As a result of some 

differences in these curves, NEEP suggested that DOE should reconcile differences in the results 

obtained from manufacturer data and from teardowns. (NEEP, No. 51 at p. 4) 

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The data obtained from teardowns that was available at the time of manufacturer 

interviews was included in the interview guide and discussed at those meetings. DOE continued 

to conduct teardowns after those meetings and has added data that will be available for public 

comment. Through that process, DOE seeks to continue to refine its analysis and to mitigate any 

differences between the teardown and manufacturer data. 

j. Scaling of Battery Charger Candidate Standard Levels 

To establish its proposed energy conservation standards for products with all battery 

energies and battery voltages within a product class, DOE developed a UEC scaling approach. 

After developing the engineering analysis results for the representative units, DOE had to 

determine a methodology for extending the UEC at each CSL to all other ratings not directly 

analyzed for a given product class. DOE had initially raised the possibility of using UEC as a 

function of battery energy. DOE also indicated that it might base this UEC function on the test 

data that had been obtained up through the preliminary analysis.37 

Numerous interested parties submitted comments regarding the potential scaling 

methodology. AHAM generally supported DOE’s proposed approach in which the UEC was 

scaled with regards to battery energy but suggested that DOE hold UEC constant below a certain 

value of battery energy because the fixed losses in these low-energy, lower power units begin to 

dominate and more stringent standards risk becoming overly restrictive on the ability of 

37 At the preliminary analysis public meeting, DOE handed out a supplemental slide deck, which outlined 

preliminary ideas to scaling UEC based on test data and with respect to battery energy. See these slides available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external_preliminaryanalysis_public 

_mtg.html 

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manufacturers to design useful products for consumers. AHAM also suggested that DOE 

consider UEC as a function of battery voltage. (AHAM, No. 44 at p. 9) PTI made similar 

suggestions and commented that it may be appropriate for UEC to remain constant for battery 

energies below the representative unit value. (PTI, No. 47 at p. 9) 

The California IOUs suggested applying a single scaling relationship for active mode 

energy for product classes 2 through 7. For battery chargers with very high battery energies, such 

as those used in golf cars, the California IOUs believed that a flat or constant standard might be 

appropriate. (California IOUs, No. 43 at pp. 3-4) The California IOUs also argued that a 

potential scaling approach based on the test results of multi-capacity battery chargers would be 

inaccurate and argued that it should be dropped. They indicated that a scaling relationship based 

on such products would be demonstrative of products that are capable of using multiple batteries 

rather than products representative of the bulk of battery chargers, which are designed for a 

single specific battery. (California IOUs, No. 43 at p. 6) Finally, these commenters asserted that 

maintenance mode power and no-battery mode power should be regulated independently of 

battery energy, as many of the same design options are applicable to small and large energy 

battery chargers. Because of these similarities, the California IOUs asserted that all battery 

chargers, regardless of battery size, should be capable of the same level of performance in those 

modes of operation and DOE should assume this value is constant irrespective of battery energy. 

(California IOUs, No. 43, at p. 7) 

DOE considered the comments it received and refined its scaling approach for the NOPR. 

In particular, DOE evaluated scaling approaches based on the battery voltage and the battery 

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energy and found that the latter is a more appropriate way to model its scaling methodology. 

When DOE examined its test results, it noted a much weaker correlation between battery voltage 

and UEC than between battery energy and UEC. See TSD, appendix 5C. DOE also noticed from 

its test results that the individual performance parameters, such as maintenance mode power, nobattery mode power, and 24-hour energy, could be formulated as functions of battery energy. See 

TSD, Chapter 5. For this reason, DOE did not follow the recommendation of the California IOUs 

to leave some performance parameters constant. 

Additionally, DOE is proposing to scale UEC as a function of battery energy for golf 

cars. The TSD shows that, as battery energy increases, so too does the UEC because more energy 

is needed to charge the larger battery. See TSD, chapter 5 (discussing test results related to 

product classes 5, 6, and 7 that demonstrate the linear relationship between increasing battery 

energy and UEC). DOE also found that this trend was true for product class 10 devices (UPSs), 

which incorporate lead-acid batteries. The details on the scaling methodology for these products 

are also available in TSD chapter 5. 

In contrast, for product classes 1 and 8 DOE is proposing that all devices within those 

product classes be required to meet one nominal standard. For these product classes, battery 

energy appeared to have little impact on the UEC’s that were calculated. Accordingly, to account 

for these differences, DOE is tentatively proposing two separate approaches for scaling UEC 

based on these test results -- i.e. one that scales with battery energy and another that remains at a 

single, nominal level. 

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DOE’s scaling approach for the NOPR relies heavily on the test data that it has gathered 

throughout the rulemaking process. DOE examined each performance parameter individually 

and, when possible, looked at groups of product class test results. For example, product classes 2, 

3, and 4 are similar products that use similar technologies and span the same battery energy 

ratings. In these cases, DOE examined all of these test results together. DOE also developed 

regression equations for each of the performance parameters needed to calculate UEC and 

ultimately, aggregated those equations with assumptions about usage profiles for each product 

class. That is, DOE examined test results for maintenance mode power, no-battery mode power, 

and 24-hour energy individually and relative to battery energy. From these data, DOE derived 

equations for each parameter as it relates to battery energy. Because each equation was a 

function of the same parameter, battery energy, each one could be combined with assumptions 

about product usage to develop a single UEC equation that was also a function of battery energy. 

For product classes other than product classes 1, 8, and 10, DOE developed equations 

that use different slopes for different CSLs. For higher CSL equations in a given product class, 

the slope of the UEC line becomes smaller, which means that the line describing UEC versus 

battery energy becomes flatter. DOE found that when it filtered its test results and examined 

products with similar technologies (e.g. lithium-ion chemistry batteries) spanning a range of 

battery energy levels, the slope of the line generated for 24-hour energy correlated to the inverse 

of 24-hour efficiency, which is the ratio of measured battery energy to 24-hour energy, expressed 

as a percentage. Thus, as products became more efficient, the slope of the equation used to 

describe UEC versus battery energy became flatter. 

179 
Finally, DOE adopted the suggestions offered by AHAM and PTI regarding the treatment 

of small battery energies. When DOE was developing its CSL equations for UEC, it found 

during testing that the correlation between points at low battery energies was much worse than 

for the rest of the range of battery energy, which indicated that the initial equations DOE had 

initially planned to use did not match the test results. To address this situation, DOE generated a 

boundary condition for its CSL equations, which essentially flattens the UEC below a certain 

threshold of battery energy to recognize that below certain values, fixed power components of 

UEC, such as maintenance mode power, dominate UEC. Making this change helped DOE to 

create a better-fitting equation to account for these types of conditions to ensure that any 

standards that are set better reflect the particular characteristics of a given product. 

For additional details and the exact CSL equations developed for each product class, 

please see TSD chapter 5. 

D. Markups to Determine Product Price 

The markups analysis develops appropriate markups in the distribution chain to convert 

the MSP estimates derived in the engineering analysis to consumer prices. At each step in the 

distribution chain, companies mark up the price of the product to cover business costs and profit 

margin. Given the variety of products that use battery chargers and EPSs, distribution varies 

depending on the product class and application. As such, DOE assumed that the dominant path to 

market establishes the retail price and, thus, the composite markup for a given application. The 

markups applied to end-use products that use battery chargers and EPSs are approximations of 

the battery charger and EPS markups. 

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In the case of battery chargers and EPSs, the dominant path to market typically involves 

an end-use product manufacturer (i.e. OEM) and retailer. DOE developed OEM and retailer 

markups by examining annual financial filings, such as Securities and Exchange Commission 

(SEC) 10-K reports, from more than 80 publicly traded OEMs, retailers, and distributors engaged 

in the manufacturing and/or sales of consumer applications that use battery chargers or EPSs. 

Retail prices for EPSs in product class H (e.g. EPSs for amateur radios) were readily 

available, as these devices are not typically bundled with a consumer application. Thus, using 

these retail prices and the component costs determined in its teardown analysis, DOE was able to 

derive markups for EPSs in product class H. 

DOE typically calculates two markups for each product in the markups analysis. These 

are: a markup applied to the baseline component of a product’s cost (referred to as a baseline 

markup) and a markup applied to the incremental cost increase that results from standards 

(referred to as an incremental markup). The incremental markup relates the change in the MSP of 

higher-efficiency models (the incremental cost increase) to the change in the retailer’s selling 

price. 

In the preliminary analysis public meeting, PTI commented that DOE neglected to take 

into account situations in which an EPS is purchased by a battery charger manufacturer to be 

integrated into a battery charger. In these cases, the completed battery charger (with integrated 

EPS) is sold to an OEM to be packaged with an end-use application. Philips explained that three 

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markups would be applied to the MSP of these EPSs: one by the battery charger manufacturer, 

one by the OEM, and one by the retailer. (PTI, Pub. Mtg. Tr., No. 57 at p. 316) 

DOE agrees that, for situations in which this additional step occurs, the battery charger 

manufacturer would need to cover its costs and profit margin with a markup. However, given 

DOE’s assumption that the dominant path to market sets the final product price, it is only for 

those classes of EPS for which this is the most common path to market that the final product 

price would be affected. DOE believes that this situation would primarily apply to EPSs that 

exclusively provide power to a stand-alone battery charger, such as EPSs for power tools, 

garden-care equipment, and other applications with detachable batteries. As explained in section 

IV.A.1 above, DOE did not quantify savings for EPSs that cannot directly power an end-use 

consumer product (i.e., EPSs that only provide power to a battery charger), and, therefore, DOE 

did not quantify markups for these "indirect operation" EPSs. The remaining EPSs that power 

battery chargers can also power an application directly, meaning that the EPS is not exclusively a 

component of the battery charger. Instead, it is a component of the application itself, e.g., a 

notebook computer. In those cases, DOE assumes that it is more common that the OEM, rather 

than the battery charger manufacturer, sources the EPS, making a third markup unnecessary. 

AHAM commented that engineering costs to integrate a battery charger into an end-use 

consumer product are typically higher than those for an EPS, and it may be inappropriate to 

apply an incremental markup to battery chargers at the OEM stage that is lower than the baseline 

markup. (AHAM, Pub. Mtg. Tr., No. 57 at p. 325) 

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To calculate incremental markups, DOE subtracted “selling, general, and administrative 

expenses” (SG&A) from net profit to yield operating profit. Dividing this amount by the revenue 

value yields an incremental markup. By subtracting SG&A from net profit, DOE assumes that 

indirect costs (such as indirect labor and overhead) remain constant when a product becomes 

more efficient and, therefore, do not need to be accounted for in the incremental markup. Given 

that SG&A does not include research and development (R&D) or engineering costs, any direct 

labor, R&D, engineering, and other direct expenses that OEMs incur when integrating a more 

efficient battery charger into an application are assumed to be recovered through the incremental 

markup. 

Chapter 6 of the TSD provides additional detail on the markups analysis. 

E. Energy Use Analysis 

DOE estimated the annual energy use of products in the field as they are used by 

consumers. The energy use analysis provides the basis for other analyses, particularly 

assessments of the energy savings and the savings in consumer operating costs that could result 

from DOE’s adoption of new or amended standards. While the DOE test procedure provides 

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

products used under the same conditions, the energy use analysis seeks to capture the range of 

operating conditions for battery chargers and EPSs in the United States. 

Battery chargers and EPSs are power conversion devices that transform input voltage to a 

suitable voltage for the end-use application or battery they are powering. A portion of the energy 

that flows into a battery charger or EPS flows out to a battery or end-use product and, thus, 

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cannot be considered to be consumed by the battery charger or EPS. However, to provide the 

necessary output power, other factors contribute to battery charger and EPS energy consumption 

-- e.g. internal losses and overhead circuitry.38 Therefore, the traditional method for calculating 

energy consumption -- by measuring the energy a product draws from mains while performing 

its intended function(s) -- is not appropriate for battery chargers and EPSs. Instead, DOE 

considered energy consumption to be the energy dissipated by the battery charger or EPS (losses) 

and not delivered to the end-use product or battery as a more accurate means to determine the 

energy consumption of these products. Once the energy and power requirements of those end-use 

products and batteries were determined, DOE considered them fixed, and DOE analyzed only 

how standards would affect the energy consumption of the battery chargers and EPSs 

themselves. 

DOE applied a single usage profile for each application to calculate the unit energy 

consumption for battery chargers and EPSs. However, usage varies by application and among 

users. DOE examined the usage profiles of multiple user types for applications where usage 

varies widely (for example, a light user and a heavy user or an amateur user and professional 

user). AHAM suggested that DOE revisit, and possibly revise, its usage profile assumptions for 

the NOPR stage analyses. (AHAM, No. 42 at p. 8) As new information became available and 

analytical methodologies were altered, DOE revisited its usage profile assumptions to ensure the 

accuracy of its NOPR analyses. As part of its NOPR analysis, DOE re-examined its initial usage 

profiles in the following ways: 

38 Internal losses are energy losses that occur during the power conversion process. Overhead circuitry refers to 

circuits and other components of the EPS, such as monitoring circuits, logic circuits, and LED indicator lights, that 

consume power but do not directly contribute power to the end-use application. 

184 
 New applications were added or existing applications were combined; 

 Existing applications were divided into applications used in a commercial setting and 

applications used in a residential setting; 

 New sources (such as published studies or data from stakeholders) were made 

available or new data were provided to DOE; and/or 

 Tested charge times indicated that DOE’s usage profiles were in need of revision. 

DOE also explored high- and low-savings scenarios in an LCC sensitivity analysis. 

Values that varied in this sensitivity analysis included battery charger and EPS usage profiles and 

EPS loading points. Varying these values allowed DOE to account for uncertainty in the average 

usage profiles and explore the effect that usage variations might have on energy consumption, 

life-cycle cost, and payback. Additional information on this sensitivity analysis is contained in 

appendix 8B to the TSD. 

DOE does not assume the existence of a rebound effect, in which consumers would 

increase use in response to an increase in energy efficiency and resulting decrease in operating 

costs. For BCs and EPSs, DOE expects that, in light of the small amount of savings expected 

over the course of the year, the rebound effect is likely to be negligible because consumers are 

unlikely to notice the decrease in operating costs that would result from new standards for these 

products. 

At the preliminary analysis public meeting, PG&E, through its consultant Ecos, 

commented that DOE should adopt the simplified approach to battery charger usage profiles 

185 
being pursued by California. It claimed that the wide variety of end-use applications and end 

users makes it infeasible to accurately characterize usage for battery chargers. It recommended 

instead that DOE assign all applications to one of two categories: those that are charged rarely 

(such as battery chargers for uninterruptible power supplies and other backup batteries) and those 

that are charged sometimes (all other battery chargers). (Ecos/PG&E, Pub. Mtg. Tr., No. 57 at p. 

30) In a joint letter submitted to DOE, energy efficiency advocates echoed these sentiments and 

suggested that DOE group products into one of two possible general duty cycles: ‘charged some 

of the time’ and ‘almost always in maintenance mode.’” (PG&E, et al., No. 47 at p. 2) In the 

preliminary analysis public meeting, PTI commented that taking into account usage profiles to 

analyze annual energy consumption is the correct approach because it is the only way to express 

meaningful savings to the public. PTI reiterated its support for DOE’s proposed approach in its 

written comments, claiming that increased detail allows for a more accurate understanding of 

variations in use and a basis for estimating actual energy consumption. PTI also stated that it 

“believe[s] that the subsequent UEC calculation based upon usage patterns provides a 

meaningful measure of energy use.” (PTI, Pub. Mtg. Tr., No. 57 at p. 378 and No. 45 at pp. 7-8) 

AHAM supported the continued use of usage profiles in estimating unit energy consumption and 

emphasized that, because of their critical nature, usage profiles should be more exact, not 

simplified. (AHAM, Pub. Mtg. Tr., No. 57 at p. 376 and No. 42 at p. 8) 

In developing its usage profiles, DOE relied on empirical data for more than 40 

applications. These data primarily consisted of user surveys, metering studies, and stakeholder 

input. Collectively, the analyzed applications for which DOE has empirical usage data accounted 

for more than 80 percent of annual aggregate battery charger energy use, because the available 

186 
data focused mainly on the more common, high-powered, and high-use applications. Usage 

profiles for the remaining applications were derived from these known usage profiles. DOE 

recognizes that the calculation of usage profiles is not an exact science, but is confident that 

energy use and potential savings can be more accurately estimated if application-specific use is 

taken into account. Therefore, based on data and arguments presented to DOE to date, DOE is 

proposing to continue to use the same basic approach to battery charger usage profiles that it 

used in the preliminary analysis. 

Philips questioned DOE’s initial assumption during the preliminary analysis phase that 

seldom-used applications, such as beard and mustache trimmers, are plugged in, on average, one 

hour per day. Instead, Philips stated that such products are rarely charged and the potential 

energy savings from regulating battery chargers and EPSs that power these products would be 

very small. (Philips, Pub. Mtg. Tr., No. 57 at pp. 130-131) AHAM commented that many of the 

products that DOE assumes to be charged for one hour per week, such as personal care products 

and other portable appliances, are typically charged less frequently. (AHAM, No. 42 at p. 6) 

DOE’s usage profiles are intended to represent an average usage scenario across all users, 

rather than any particular type of user. DOE recognizes that while many users likely have these 

products plugged in for less than one hour per day, others (specifically those with cradle 

chargers) tend to leave these products plugged in for more than one hour per day. Some users 

may rarely, if ever, unplug their chargers. Given these possible variations in usage, DOE 

revisited its assumed usage profiles for personal care products and other infrequently charged 

products. DOE opted to leave its usage profiles for beard and mustache trimmers and hair 

187 
clippers unchanged in the reference case, but also to explore high- and low-use scenarios in the 

LCC sensitivity analyses. Upon further analysis, DOE agrees with AHAM and Philips that some 

small, portable applications are charged, on average, less frequently than indicated in the 

preliminary analysis (1 hour per week). Thus, DOE reduced the amount of time in active and 

maintenance modes to 0.5 hours per week for air mattress pumps, mixers, blenders, handheld 

GPSs, and residential portable printers. DOE also explored the effects of lower use for other 

applications in the LCC sensitivity analysis. 

Philips also suggested the following usage profile for battery chargers in product class 1 

(inductive chargers for use in wet environments): 

1. Active + Maintenance = 17.25 hr/day 

2. Unplugged = 6.48 hr/day 

3. No Battery = 0.11 hr/day 

4. Off = 0 hr day 

5. Charges per day = 0.048 (Philips, No. 41 at p. 2) 

DOE’s usage profile from its preliminary analysis, which was provided by PG&E (Ecos 

Consulting, No. 30), assumed that all products in product class 1 are cradle-charged and, thus, 

are never unplugged. While DOE tentatively agrees with Philips that some users unplug their 

chargers once the product is charged, PG&E’s research suggests that Philips overestimated the 

number of users who unplug between charges (and by extension, the amount of time the average 

unit spends unplugged). Thus, for the NOPR, DOE used an average of the usage profiles 

provided by PG&E and Philips for its reference case usage profile. This resulted in a usage 

188 
profile that assumed those products spend some time in unplugged mode, but less than the time 

suggested by Philips. High- and low-use scenarios for the applications in product class 1 were 

explored in the LCC sensitivity analysis. 

Stanley Black & Decker commented that outdoor gardening appliances are typically used 

seasonally, and that the initial unit energy consumption values for these products that DOE had 

considered during the preliminary analysis phase should be reduced by half. It added, though, 

that DOE should maintain its lifetime assumptions from the preliminary analysis. (SBD, No. 44 

at p. 1) DOE agrees that these products are typically used seasonally and notes that it had already 

accounted for seasonal use, as suggested by Stanley Black & Decker, when it created the usage 

profiles in the preliminary analysis. The usage profile that DOE used in the NOPR-stage analysis 

continues to apply a seasonal use assumption for these products. 

Cobra Electronics claimed that the typical residential two-way radio is charged less than 

once per week, since residential consumers tend to use these products a few times per year. 

(Cobra, No. 51 at p. 2) DOE agrees that residential use of two-way radios is likely to be 

infrequent, but also recognizes that many of the two-way radios used by residential users are also 

available to commercial users, who charge these products far more frequently. In preparation of 

the NOPR analysis, DOE analyzed the energy use of the two-way radio application separately 

for those products charged in a residential setting and those products charged in a commercial 

setting. DOE assumed that two-way radios charged in a residential setting are charged 

infrequently, as was suggested by Cobra, while those charged in a commercial setting are 

charged more frequently. 

189 
Lester commented that “the reduction in energy loss as estimated is overstated for golf 

cars due to mistaken assumptions about the duty cycle and corresponding energy use.” (Lester, 

No. 53 at p. 2) DOE remains confident in its assumptions for golf car use, which are derived 

from manufacturer input. As it did for two-way radios, DOE divided the golf car application into 

two distinct applications: golf cars charged in the residential sector, and golf cars charged in the 

commercial sector. DOE’s residential usage profile assumes less time in active use and, 

therefore, fewer charges per day, while DOE’s commercial usage profile assumes heavier use. 

Given this heavier use, DOE assumed that commercial golf cars spend less time in maintenance 

mode, as they are typically used more frequently, and for longer durations, than are residential 

golf cars. 

In response to comments from manufacturers that battery chargers in product class 2 that 

meet the baseline efficiency level may be slow chargers and designed for less frequent use or 

increased time in maintenance mode, the California IOUs commented that these products may 

not always be used infrequently, but rather can be used by some segments of the population on a 

daily basis. (California IOUs, No. 43 at p. 6) 

DOE’s usage profiles are designed to take into account the average use of all users, 

subject to the constraints of a given battery charger, such as a slow charge rate or quick discharge 

rate. DOE believes that it has accurately estimated the usage profiles of handheld vacuum 

cleaners (which are in no battery mode, on average, six minutes per day), cordless phones (which 

are in no battery mode, on average, more than two hours per day), and the usage profiles for the 

190 
remaining applications in its analysis. These usage profiles reflect average use, and, therefore, 

account for infrequent and frequent users of these applications. 

DOE recognizes that there is considerable variation in how individual consumers use 

battery chargers and EPSs for specific applications. This leads to some uncertainty and 

disagreement over what an appropriate usage profile is for specific applications, such as power 

tools, personal care products, and other applications. In all cases, DOE used the best available 

data to derive reference case usage profiles for each application. For applications with highly 

variable use, DOE explored high- and low-use scenarios in an LCC sensitivity analysis. DOE 

continues to seek data and substantiated recommendations that will allow it to further refine its 

reference case usage profiles. (See Issue 12 under “Issues on Which DOE Seeks Comment” in 

section VII.E of this notice.) 

Chapter 7 of the TSD provides additional detail on the energy use analysis. 

F. Life-Cycle Cost and Payback Period Analyses 

This section describes the LCC and payback period analyses and the spreadsheet model 

DOE used for analyzing the economic impacts of possible standards on individual consumers. 

Details of the spreadsheet model, and of all the inputs to the LCC and PBP analyses, are 

contained in chapter 8 and appendix 8A of the TSD. DOE conducted the LCC and PBP analyses 

using a spreadsheet model developed in Microsoft Excel. When combined with Crystal Ball (a 

191 
 

commercially-available software program), the LCC and PBP model generates a Monte Carlo 

simulation39 to perform the analysis by incorporating uncertainty and variability considerations. 

The LCC analysis estimates the impact of a standard on consumers by calculating the net 

cost of a battery charger or EPS under a base-case scenario (in which no new energy 

conservation standard is in effect) and under a standards-case scenario (in which the proposed 

energy conservation standard is applied). The base-case scenario is determined by the efficiency 

level that a sampled consumer currently purchases, which may be above the baseline efficiency 

level. The life-cycle cost of a particular battery charger or EPS is composed of the total installed 

cost (which includes manufacturer selling price, distribution chain markups, sales taxes, and any 

installation cost), operating expenses (energy and any maintenance costs), product lifetime, and 

discount rate. As noted in the preliminary analysis, DOE considers installation costs to be zero 

for battery chargers and EPSs. 

The payback period is the change in purchase expense due to a more stringent energy 

conservation standard, divided by the change in annual operating cost that results from the 

standard. Stated more simply, the payback period is the time period it takes to recoup the 

increased purchase cost of a more-efficient product through energy savings. DOE expresses this 

period in years. 

Table IV-26 summarizes the approach and data that DOE used to derive the inputs to the 

LCC and PBP calculations for the preliminary analysis and the changes made for today’s 

39 Monte Carlo simulations model uncertainty by utilizing probability distributions instead of single values for 

certain inputs and variables. 

192 
 

 

 

 

 

 

 

proposed rule. The following sections discuss these inputs and comments DOE received 

regarding its presentation of the LCC and PBP analyses in the preliminary analysis, as well as 

DOE’s responses thereto. 

Table IV-26 Summary of Inputs and Key Assumptions Used in the Preliminary Analysis 

and NOPR LCC Analyses 

Inputs September 2010 Preliminary Analysis Changes for the Proposed Rule 

Manufacturer 

Selling Price 

Derived from the Engineering Analysis through 

manufacturer interviews (battery chargers and 

EPSs) and test/teardown results (battery chargers 

only). 

Used same methodology, but 

conducted additional test/teardowns 

and interviews. 

Markups Considered various distribution channel pathways 

for different applications. Applied a reduced 

“incremental” markup to the portion of the 

product price exceeding the baseline price. 

Used same methodology with 

additional data sources. See chapter 6 

of the TSD for details. 

Sales Tax Derived weighted-average tax values for each 

Census division and large State from data 

provided by the Sales Tax Clearinghouse.1 

Updated the sales tax using the latest 

information from the Sales Tax 

Clearinghouse.2 

Installation Cost Assumed to be zero. No change. 

Maintenance Cost Assumed to be zero. Included the cost of repurchasing a 

battery that fails within the application 

lifetime. Accounted for the incremental 

cost of a lithium ion battery over a 

nickel chemistry battery, only for CSL 

2 or higher. 

Unit Energy 

Consumption 

Determined for each application based on 

estimated loading points and usage profiles (for 

EPSs), and battery characteristics and usage 

profiles (for battery chargers). 

Used same methodology with 

additional data sources. See chapter 7 

of the TSD for details. 

Electricity Prices Price: Based on EIA’s 2008 Form EIA-861 data.3 

Variability: Regional energy prices determined 

for 13 regions. 

Price: No change. The 2008 Form EIA861 is the most current source 

available. DOE also considered 

subgroup analyses using electricity 

prices for low-income consumers and 

top tier marginal price consumers. 

Variability: No change. 

Electricity Price 

Trends 

Forecasted with EIA’s Annual Energy Outlook 

Early Release 2010.4 

Updated with EIA’s Annual Energy 

Outlook 2010.5 

Lifetime Determined for each application based on 

multiple data sources. 

Used same methodology with 

additional data sources. See chapter 3 

of the TSD for details. 

Discount Rate Residential: Approach based on the finance cost 

of raising funds to purchase and operate battery 

chargers or EPSs either through the financial cost 

of any debt incurred (based on the Federal 

Reserve’s Survey of Consumer Finances data6

 for 

1989, 1992, 1995, 1998, 2001, 2004, and 2007) 

or the opportunity cost of any equity used. Timeseries data was based on arithmetic means from 

1979-2009. 

Commercial: Derived discount rates using the 

cost of capital of publicly-traded firms based on 

Residential: DOE updated the 

calculations to consider the geometric 

means for all time-series data from 

1980-2009. 

Commercial: DOE updated the riskfree rate to use a 40-year average return 

on 10-year treasury notes, as reported 

by the U.S. Federal Reserve.10 DOE 

updated the equity risk premium to use 

the geometric average return on the 

S&P 500 over a 40-year time period. 

193 
 

 

 

 

 

data from Damodaran Online,7 the Value Line 

Investment survey,8

 and the Office of 

Management and Budget (OMB) Circular No. A94.9 

Sectors Analyzed All reference case results used the residential 

sector inputs. Commercial sector results were 

presented in Appendix 8B as a sensitivity 

analysis. 

All reference case results represent a 

weighted average of the residential and 

commercial sectors. 

Base Case Market 

Efficiency 

Distribution 

All market efficiency distributions were constant 

across representative units and product classes. 

Distributions were derived from test results. 

Where possible, DOE derived market 

efficiency distributions for specific 

applications within a representative unit 

or product class. 1

 The four large States are New York, California, Texas, and Florida. 2

 Sales Tax Clearinghouse, Aggregate State Tax Rates. Available at: https://thestc.com/STRates.stm. 3

 U.S. Department of Energy. Energy Information Administration. Form EIA-861 Final Data File for 2008. 

November, 2010. Washington, D.C. Available at: http://www.eia.doe.gov/cneaf/electricity/page/eia861.html. 4 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2010 Early Release. 

March, 2010. Washington, D.C. Available at: http://www.eia.doe.gov/oiaf/aeo/. 5 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2010. November, 

2010. Washington, D.C. Available at: http://www.eia.doe.gov/oiaf/aeo/. 6

 The Federal Reserve Board, Survey of Consumer Finances 1989, 1992, 1995, 1998, 2001, 2004, 2007. Available 

at: http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html. 7 Damodaran Online Data Page, Historical Returns on Stocks, Bonds and Bills-United States, 2010. Damodaran. 

Available at: http://pages.stern.nyu.edu/~adamodar. 8

 Value Line. Value Line Investment Survey. 2010. Available at: http://www.valueline.com. 9

 U.S. Office of Management and Budget. Circular No. A-94. Appendix C. 2009. Available at: 

http://www.whitehouse.gov/omb/circulars_a094_a94_appx-c/. 10 The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, Historical Data, 

Instrument: Treasury Constant Maturities, Maturity: 10-year, Frequency: Annual, Description: Market yield on 

U.S. Treasury securities at 10-year constant maturity, quoted on investment basis. Available at: 

http://www.federalreserve.gov/releases/H15/data.htm. 

1. Manufacturer Selling Price 

As in the preliminary analysis, DOE used a combination of test and teardown results and 

manufacturer interview results to develop manufacturer selling prices. DOE conducted tests and 

teardowns on a large number of additional units and applications for the NOPR, and incorporated 

these findings into the MSP. Further detail on the MSPs can be found in chapter 5 of the TSD. 

Examination of historical price data for a number of appliances that have been subject to 

energy conservation standards indicates that an assumption of constant real prices and costs may 

overestimate long-term trends in appliance prices. Economic literature and historical data suggest 

194 
 

 

that the real costs of these products may in fact trend downward over time according to 

“learning” or “experience” curves. On February 22, 2011, DOE published a Notice of Data 

Availability (NODA, 76 FR 9696) stating that DOE may consider improving regulatory analysis 

by addressing equipment price trends. In the NODA, DOE proposed that when sufficiently longterm data are available on the cost or price trends for a given product, it would analyze the 

available data to forecast future trends. 

To forecast a price trend for the NOPR, DOE considered the experience curve approach, 

in which an experience rate parameter is derived using two historical data series on price and 

cumulative production, but in the absence of historical shipments of battery chargers and EPSs 

and of sufficient historical Producer Price Index (PPI) data for small electrical appliance 

manufacturing from the Bureau of Labor Statistics’ (BLS)40, DOE could not use this approach. 

This situation is partially due to the nature of EPS and battery charger design. EPSs and battery 

chargers are made up of many electrical components whose size, cost, and performance rapidly 

change, which leads to relatively short design lifetimes. DOE also considered performing an 

exponential fit on the deflated AEO’s Projected Price Indexes that most narrowly include battery 

chargers and EPSs. However, DOE believes that these indexes are sufficiently broad that they 

may not accurately capture the trend for battery chargers and EPSs. Furthermore, battery 

chargers and EPSs are not typical consumer products; they are more like a commodity that 

OEMs purchase. 

Given the uncertainty, DOE is not incorporating product price changes into today’s 

NOPR. For the NIA, DOE also analyzed the sensitivity of results to three alternative battery 

40 Series ID PCU33521-33521; http://www.bls.gov/ppi/ 

195 
 

chargers and EPSs price forecasts. Appendix 10-B of the NOPR TSD describes the derivation of 

alternative price forecasts. 

DOE requests comments on the most appropriate trend to use for real battery charger and 

EPS prices, both in the short run (to 2013) and the long run (2013-2042). 

2. Markups 

DOE applies a series of markups to the MSP to account for the various distribution chain 

markups applied to the analyzed product. These markups are evaluated for each application 

individually, depending on its path to market. Additionally, DOE splits its markups into 

“baseline” and “incremental” markups. The baseline markup is applied to the entire MSP of the 

baseline product. The incremental markups are then applied to the marginal increase in MSP 

over the baseline’s MSP. Further detail on the markups can be found in chapter 6 of the TSD. 

3. Sales Tax 

As in the preliminary analysis, DOE obtained State and local sales tax data from the Sales 

Tax Clearinghouse. The data represented weighted averages that include county and city rates. 

DOE used the data to compute population-weighted average tax values for each Census division 

and four large States (New York, California, Texas, and Florida). For the NOPR, DOE retained 

this methodology and used updated sales tax data from the Sales Tax Clearinghouse.41 The U.S. 

41 Sales Tax Clearinghouse, Aggregate State Tax Rates. https://thestc.com/STRates.stm. 

196 
 

Census Bureau population estimates used in the preliminary analysis are the most current data 

available.42 

4. Installation Cost 

As detailed in the preliminary analysis, DOE considered installation costs to be zero for 

battery chargers and EPSs because installation would typically entail a consumer simply 

unpacking the battery charger or EPS from the box in which it was sold and connecting the 

device to mains power and its associated product or battery. Because the cost of this 

“installation” (which may be considered temporary, as intermittently used devices might be 

unplugged for storage) is not quantifiable in dollar terms, DOE considered the installation cost to 

be zero. 

5. Maintenance Cost 

In the preliminary analysis, DOE did not consider repair or maintenance costs for battery 

chargers or EPSs. In making this decision, DOE recognized that the service life of a battery 

charger or EPS typically exceeds that of the consumer product with which it is designed to 

operate. Thus, a consumer would not incur repair or maintenance costs for a battery charger or 

EPS. Also, if a battery charger or EPS failed, DOE expects that consumers would typically 

discard the battery charger or EPS and purchase a replacement. DOE received no comments 

challenging this assumption and has continued relying on this assumption for purposes of 

calculating the NOPR’s potential costs and benefits. 

42 The U.S. Census Bureau. Annual Estimates of the Population for the United States, Regions, States, and Puerto 

Rico: April 1, 2000 to July 1, 2009. http://www.census.gov/popest/states/tables/NST-EST2009-01.xls. 

197 
Although DOE did not assume any repair or maintenance costs would apply generally to 

battery chargers or EPSs, DOE has considered including a maintenance cost for the replacement 

of lithium ion batteries in certain battery charger applications. Through conversations with 

manufacturers, DOE learned that such batteries would need replacing within the service life of 

the battery charger for certain applications based on the battery lifetime and the usage profile 

assigned to the application. Lithium ion batteries are marginally more expensive than batteries 

with nickel chemistries (e.g. nickel metal-hydride or “Ni-MH”), as explained in chapter 5 of the 

TSD. DOE accounted for this marginal cost increase in these applications at CSLs that use 

lithium batteries. This maintenance cost only applied to applications where DOE believed the 

lifetime of the application would surpass the lifetime of the battery. DOE estimated the battery 

lifetime based on the total number of charges the battery could handle divided by the number of 

charges per year projected for the application. DOE relied on data provided by manufacturers to 

estimate the total number of charges the battery could undergo before expiring. Further detail on 

maintenance costs can be found in chapter 8 of the TSD. 

6. Product Price Forecast 

As noted in section IV.F., to derive its central estimates DOE assumed no change in 

battery charger and EPS prices over the 2013-2042 period. In addition, DOE conducted a 

sensitivity analysis using three alternative price trends based on AEO indexes. These price 

trends, and the NPV results from the associated sensitivity cases, are described in appendix 10-B 

of the NOPR TSD. 

198 
7. Unit Energy Consumption 

The NOPR analysis uses the same approach for determining UECs as the one used in the 

preliminary analysis. The UEC was determined for each application based on estimated loading 

points and usage profiles (for EPSs), and battery characteristics and usage profiles (for battery 

chargers). DOE refined the usage profiles, battery characteristics, and usage profiles for the 

NOPR. Further detail on the UEC calculations can be found in chapter 7 of the TSD. 

8. Electricity Prices 

DOE determined energy prices by deriving regional average prices for 13 geographic 

areas consisting of the nine U.S. Census divisions, with four large states (New York, Florida, 

Texas, and California) treated separately. The derivation of prices was based on data in EIA’s 

Form EIA-861. 

In its written comments, NEEP stated that the high electricity prices in the Northeast 

region of the United States would likely make the LCC and PBP results more attractive for 

customers in this region. (NEEP, No. 49 at p. 2) Typically, higher energy costs increase a 

consumer’s operating cost savings. As in the preliminary analysis, DOE sampled a regional 

electricity price for each trial of the Monte Carlo simulation. Additionally, the electricity price 

for the Northeast region used by DOE’s analysis is greater than the national average. DOE 

estimates a residential electricity price of $0.166/kWh for the New England region and 

$0.181/kWh for the state of New York, which exceeds the national average of $0.112/kWh. 

Further detail on regional electricity price sampling is available in chapter 8 of the TSD. 

199 
 

 

 

9. Electricity Price Trends 

To project electricity prices to the end of the product lifetime in the preliminary analysis, 

DOE used data from EIA’s Annual Energy Outlook (AEO) 2010 Early Release.

43 This data 

source only contained a reference case scenario, which required DOE to separately project the 

high- and low-economic-growth scenarios using the relationship between the scenarios in the 

AEO 2009 data.44 For the NOPR, DOE used the final release of the AEO 2010,45 which 

contained reference, high- and low-economic-growth scenarios. 

10. Lifetime 

DOE considers the lifetime of a battery charger or EPS to be from the moment it is 

purchased for end-use up until the time when it is permanently retired from service. Because the 

typical battery charger or EPS is purchased for use with a single associated application, DOE 

assumed that it will remain in service for as long as the application does. Even though many of 

the technology options to improve battery charger and EPS efficiencies may result in an 

increased useful life for the battery charger or EPS, the lifetime of the battery charger or EPS is 

still directly tied to the lifetime of its associated application. With the exception of EPSs for 

mobile phones and smartphones (see below), the typical consumer will not continue to use an 

EPS or battery charger once its application has been discarded. For this reason, DOE used the 

same lifetime estimate for the baseline and standard level designs of each application for the 

43 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2010 Early Release. 

March, 2010. Washington, D.C. Available at: http://www.eia.doe.gov/oiaf/aeo/. 44 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2009 with Projections to 

2030. March, 2009. Washington, D.C. Available at: http://www.eia.doe.gov/oiaf/aeo/. 45 U.S. Department of Energy. Energy Information Administration. Annual Energy Outlook 2010. November, 2010. 

Washington, D.C. http://www.eia.doe.gov/oiaf/aeo/. 

200 
 

LCC and PBP analyses. Further detail on product lifetimes and how they relate to applications 

can be found in chapter 3 of the TSD. 

The one exception to the rule that EPSs do not exceed the lifetime of their associated enduse products is the lifetime of EPSs for mobile phones and smartphones. While the typical length 

of a mobile phone contract is 2 years, and thus many phones are replaced and no longer used 

after 2 years, DOE assumed that the EPSs for these products will remain in use for an average of 

4 years. This assumption is based on an expected standardization of the market around microUSB plug technology, driven largely by the GSMA Universal Charging Solution.46 To verify 

that this evolution towards micro-USB plug technology is in fact taking place, DOE examined 

more than 30 top-selling basic mobile phone and smartphone models offered online by 

Amazon.com, Sprint, Verizon Wireless, T-Mobile, and AT&T. DOE found that all of the newest 

smartphone models other than the Apple iPhone use micro-USB plug technology. While some 

basic mobile phones continue to use mini-USB or other connector technologies, DOE found 

more than 15 basic mobile phone models that have adopted the micro-USB technology. 

If new EPSs are compatible with a wide range of mobile phone and smartphone models, a 

consumer may continue to use the EPS from their old phone after upgrading to a new phone. 

Even though it is currently standard practice to receive a new EPS with a phone upgrade, DOE 

assumes that in the near future consumers will no longer expect manufacturers to include an EPS 

with each new phone. DOE requests comment from stakeholders on the reasonableness of this 

46 The GSMA Universal Charging Solution is an agreement between 17 mobile operators and manufacturers to have 

the majority of all new mobile phones support a universal charging connector by January 1, 2012. The press release 

for the agreement can be accessed here: <http://www.gsma.com/articles/mobile-industry-unites-to-drive-universalcharging-solution-for-mobile-phones/17752/> 

201 
 

 

 

 

 

 

assumption. Tables IV-27 and IV-28 show that assuming a lifetime of 2 years (rather than 4 

years) for mobile phone and smartphone EPSs results in lower life-cycle cost savings (or greater 

net costs) for consumers of those products. However, the net effect on Product Class B as a 

whole is negligible due to the fact that mobile phones and smartphones together comprise only 7 

percent of shipments in Product Class B. LCC results for all other applications in Product Class 

B are shown in chapter 11 of the TSD. 

Table IV-27 EPS Life-Cycle Cost Savings with 4-Year Lifteime Assumptions 

Weighted Average LCC Savings for a 

Standard at the Given CSL [2010$] 

CSL 1 CSL 2 CSL 3 CSL 4 

Mobile Phones 0.06 (0.01) (0.12) (0.15) 

Smartphones 0.05 (0.02) (0.13) (0.16) 

Product Class B 

Shipment-Weighted Average 

0.18 0.21 0.16 (0.99) 

Table 28 EPS Life-Cycle Cost Savings with Alternative (2-year) Lifetime Assumptions 

Weighted Average LCC Savings for a 

Standard at the Given CSL [2010$] 

CSL 1 CSL 2 CSL 3 CSL 4 

Mobile Phones (0.02) (0.19) (0.34) (0.40) 

Smartphones (0.02) (0.18) (0.31) (0.38) 

Product Class B 

Shipment-Weighted Average 

0.18 0.20 0.15 (1.01) 

11. Discount Rate 

In the preliminary analysis, DOE derived residential discount rates by identifying all 

possible debt or asset classes that might be used to purchase and operate products, including 

household assets that might be affected indirectly. DOE estimated the average shares of the 

various debt and equity classes in the average U.S. household equity and debt portfolios using 

data from the Survey of Consumer Finances (SCF) from 1989 to 2007. DOE used the mean share 

of each class across the seven sample years as a basis for estimating the effective financing rate 

202 
 

 

 

for products. DOE estimated interest or return rates associated with each type of equity and debt 

using SCF data and other sources. The mean real effective rate across the classes of household 

debt and equity, weighted by the shares of each class, is 5.6 percent. 

For the commercial sector, DOE derived the discount rate from the cost of capital of 

publicly-traded firms falling in the categories of products that involve the purchase of battery 

chargers or EPSs. To obtain an average discount rate value for the commercial sector, DOE used 

the share of each category in total paid employees provided by the U.S. Census Bureau47 and 

Federal,48 State, and local49 governments. By multiplying the discount rate for each category by 

its share of paid employees, DOE derived a commercial discount rate of 7.0 percent. 

For the NOPR analysis, DOE uses the same methodology employed in the preliminary 

analysis but has changed the calculations to account for the geometric means for all time-series 

data. Additionally, the analysis now includes updates to the risk-free rate to use a 40-year 

average return on 10-year U.S. Treasury notes, as reported by the U.S. Federal Reserve,50 and the 

equity risk premium -- which now uses the geometric average return on the S&P 500 over a 40­

year timer period. The new discount rates are estimated to be 5.1 percent and 7.1 percent in the 

47 U.S. Census Bureau. The 2010 Statistical Abstract. Table 607 – Employment by Industry. 

http://www.census.gov/compendia/statab/2010/tables/10s0607.xls. 48 U.S. Census Bureau. The 2010 Statistical Abstract. Table 484 – Federal Civilian Employment and Annual Payroll 

by Branch. http://www.census.gov/compendia/statab/2010/tables/10s0484.xls. 49 U.S. Census Bureau. Government Employment and Payroll. 2008 State and Local Government. 

http://www2.census.gov/govs/apes/08stlall.xls. 50 The Federal Reserve Board, Federal Reserve Statistical Release, Selected Interest Rates, Historical Data, 

Instrument: Treasury Constant Maturities, Maturity: 10-year, Frequency: Annual, Description: Market yield on U.S. 

Treasury securities at 10-year constant maturity, quoted on investment basis. Available at: 

http://www.federalfederalreserve.gov/releases/H15/data.htm. 

203 
residential and commercial sectors, respectively. For further details on discount rates, see chapter 

8 and appendix 8D of the TSD. 

12. Sectors Analyzed 

In the preliminary analysis, DOE analyzed battery chargers and EPSs in the residential 

sector for the reference case scenario and presented commercial sector results in appendix 8B. 

DOE developed several inputs specifically for the commercial sector, such as energy prices, 

energy price trends, and discount rates. Other application-specific inputs -- e.g. UEC, markups, 

and market distribution -- were not altered between the residential sector and commercial sector 

analyses. 

The NOPR analysis includes an examination of a weighted average of the residential and 

commercial sectors as the reference case scenario. Additionally, all application inputs are 

specified as either residential or commercial sector data. Using these inputs, DOE then sampled 

each application based on its shipment weighting and used the appropriate residential or 

commercial inputs based on the sector of the sampled application. This approach provides more 

specificity as to the appropriate input values for each sector, and permits an examination of the 

LCC results for a given representative unit or product class in total. For further details on sectors 

analyzed, see chapter 8 of the TSD. 

13. Base Case Market Efficiency Distribution 

For purposes of conducting the LCC analysis, DOE analyzed candidate standard levels 

relative to a base case (i.e., a case without new federal energy conservation standards). This 

204 
analysis required an estimate of the distribution of product efficiencies in the base case (i.e., what 

consumers would have purchased in 2013 in the absence of new federal standards). Rather than 

analyzing the impacts of a particular standard level assuming that all consumers will purchase 

products at the baseline efficiency level, DOE conducted the analysis by taking into account the 

breadth of product energy efficiencies that consumers are expected to purchase under the base 

case. 

The preliminary analysis contained base case market efficiency distributions for each 

representative unit or product class. The distributions were based on test results, shipmentweighting of applications, and trends in efficiency that DOE identified. Under this approach, the 

resulting efficiency distribution could be heavily influenced by one or two very common 

applications associated with a particular product class or representative unit. 

In preparing the NOPR analysis, DOE derived base case market efficiency distributions 

that are specific to each application where it had sufficient data to do so. This approach helped to 

ensure that the market distribution for applications with fewer shipments was not 

disproportionately skewed by the market distribution of the applications with the majority of 

shipments. For battery chargers, DOE also adjusted its efficiency distributions for pending 

efficiency regulations in California (for more information please see IV.G.4). As a result, the 

updated analysis more accurately accounts for LCC and PBP impacts. 

205 
14. Compliance Date 

The compliance date is the date when a new standard becomes operative, i.e., the date by 

which battery charger and EPS manufacturers must manufacture products that comply with the 

standard. DOE’s publication of a final rule in this standards rulemaking is scheduled for 

completion by 2013. EPCA had prescribed that DOE complete a rulemaking to amend the Class 

A EPS standards by July 2011 and had given manufacturers a two-year lead time to satisfy those 

standards – i.e. July 2013. (42 U.S.C. 6295(u)(3)(D)(i)(II)(bb) Given the timing in issuing this 

rule, DOE may choose to retain this prescribed two-year lead time for EPS manufacturers in 

spite of the compliance date currently provided in EPCA. There are no similar requirements for 

the compliance date for battery charger and new (non-Class A) EPS standards, but DOE is also 

targeting a two-year time period between publication and compliance. DOE calculated the LCCs 

for all consumers as if each would purchase a new product in the year that manufacturers would 

be required to meet the new standard (2013). However, DOE bases the cost of the equipment on 

the most recent available data; all dollar values are expressed in 2010$. DOE invites comment on 

the compliance date it should provide manufacturers in light of the current set of circumstances. 

15. Payback Period Inputs 

The PBP is the amount of time a consumer needs to recover the assumed additional costs 

of a more-efficient product through lower operating costs. As in the preliminary analysis, DOE 

used a “simple” PBP for the NOPR, because the PBP does not take into account other changes in 

operating expenses over time or the time value of money. As inputs to the PBP analysis, DOE 

used the total installed cost of the product to the consumer for each efficiency level, as well as 

the first-year annual operating costs for each efficiency level. The calculation requires the same 

206 
inputs as the LCC, except for energy price trends and discount rates; only energy prices for the 

year the standard becomes required for compliance (2013 in this case) are needed. 

DOE received a single comment addressing its initial PBP analysis. In particular, Philips 

commented that DOE had underestimated the projected PBP for inductively charged 

toothbrushes (i.e., battery charger product class 1). (Philips, No. 43 at p. 2) DOE notes that 

payback periods comprise a metric demonstrating the underlying cost-effectiveness of a standard 

level. An underestimated PBP could result from an underestimated incremental consumer 

purchase price or an overestimated amount of operating cost savings. Philips suggested an 

alternate usage profile for battery charger product class 1 that included time spent in unplugged 

mode. (Philips, No. 41 at p. 2) In its view, the use of such an adjusted profile would provide a 

more accurate picture of the projected savings. 

DOE agrees with Philips that battery chargers in product class 1 likely spend some time 

in unplugged mode and adjusted its usage profile accordingly. The usage profile for these 

products now includes time in unplugged mode, which resulted in a reduction in operating cost 

savings. In the NOPR, DOE refined many of its estimates for the inputs contributing to purchase 

price and operating costs. While DOE is confident in the accuracy of these inputs and the 

accompanying PBP calculations presented in this NOPR, DOE continues to seek comment to 

help refine its approach as needed. 

G. National Impact Analysis 

The National Impact Analysis (NIA) assesses the national energy savings (NES) and the 

net present value (NPV) of total consumer costs and savings that would be expected to result 

207 
from new or amended standards at specific efficiency levels. (“Consumer” in this context refers 

to consumers of the product being regulated.) DOE calculates the NES and NPV based on 

projections of annual unit shipments, along with the annual energy consumption and total 

installed cost data from the energy use and LCC analyses. For the NOPR analysis, DOE 

forecasted the energy savings, operating cost savings, product costs, and NPV of consumer 

benefits for products sold from 2013 through 2042. 

DOE evaluates the impacts of new and amended standards by comparing base-case 

projections with standards-case projections. The base-case projections characterize energy use 

and consumer costs for each product class in the absence of new or amended energy 

conservation standards. DOE compares these projections with projections characterizing the 

market for each product class if DOE adopted new or amended standards at specific energy 

efficiency levels (i.e., the TSLs or standards cases) for that class. For the base case forecast, 

DOE considers historical trends in efficiency and various forces that are likely to affect the mix 

of efficiencies over time. For the standards cases, DOE also considers how a given standard 

would likely affect the market shares of efficiencies greater than the standard. 

To make the analysis more accessible and transparent to all interested parties, DOE used 

an MS Excel spreadsheet model to calculate the energy savings and the national consumer costs 

and savings from each TSL. MS Excel is the most widely used spreadsheet calculation tool in the 

United States and there is general familiarity with its basic features. Thus, DOE’s use of MS 

Excel as the basis for the spreadsheet models provides interested parties with access to the 

models within a familiar context. The TSD and other documentation that DOE provides during 

208 
the rulemaking help explain the models and how to use them, and interested parties can review 

DOE’s analyses by changing various input quantities within the spreadsheet. The NIA 

spreadsheet model uses average values as inputs (as opposed to probability distributions). 

For the current analysis, the NIA used projections of energy prices from the AEO2010 

Reference case. In addition, DOE analyzed scenarios that used inputs from the AEO2010 High 

Economic Growth, Low Economic Growth, and Carbon Cap and Trade cases. These cases have 

higher or lower energy price trends compared to the Reference case. NIA results based on these 

cases are presented in appendix 10A to the TSD. 

Table IV-29 summarizes the inputs and key assumptions DOE used in its preliminary 

NIA and the changes to the analysis for the NOPR. Discussion of these inputs and changes 

follows the table. See chapter 10 of the TSD for further details. 

209 
Table IV-29 Summary of Inputs, Sources and Key Assumptions for the National Impact 

Analysis 

Inputs Source Key Assumptions 

Base Year 

Shipments 

Market Assessment [Refer to the Market Assessment] 

Shipment 

Growth Rate 

Shipment Analysis 0.75 percent annually, equal to population growth 

Lifetimes Market Assessment Battery charger and EPS lifetime is equal to the 

lifetime of the end-use product it powers. 

Base Year 

Efficiencies 

Market Assessment [Refer to the Market Assessment] 

Base-Case 

Forecasted 

Efficiencies 

Shipments Analysis Efficiency distributions remain unchanged 

throughout the forecast period 

Standards-Case 

Forecasted 

Efficiencies 

Shipments Analysis ”Roll-up” scenario 

Annual Energy 

Consumption 

per Unit 

Energy Use Analysis Annual shipment weighted-average marginal 

energy consumption values for each product class 

Improvement 

Cost per Unit 

Engineering Analysis Annual shipment weighted-average marginal cost 

values for each product class 

Markups Markups Analysis [Refer to the Markups Analysis] 

Repair and 

Maintenance 

Cost per Unit 

None Assumed to be zero 

Energy Prices AEO 2010 Trend extrapolation from 2035 to 2062 

Electricity Siteto-Source 

Conversion 

Factor 

AEO 2010 Conversion factor does not change after 2035 

Discount Rate Office of Management 

and Budget 

Three and seven percent real 

Compliance 

Date of Standard 

EISA 2007 for EPSs Compliance date for battery charger standards 

matches that specified in the statute for EPS 

standards (2013) 

1. Shipments 

Forecasts of product shipments are needed to forecast the impacts standards will have on 

the Nation. DOE develops shipment forecasts based on an analysis of key market drivers for 

each considered product. In DOE’s shipments model, shipments of products were calculated 

based on current shipments of product applications powered by battery chargers or EPSs. The 

210 
inventory model takes an accounting approach, tracking remaining shipments and the vintage of 

units in the existing stock for each year of the analysis period. 

Stakeholders submitted several comments questioning DOE's assumption in the 

preliminary analysis that shipment volumes would not be affected by new or amended standards. 

AHAM and PTI stated that certain products, such as hair clippers, cordless vacuum cleaners, 

electric shavers, and DIY power tools, are discretionary purchases for consumers. Because of the 

discretionary nature of these purchases, AHAM and PTI claimed, standards that cause significant 

increases in the end-use product's price may lead some families to forgo purchasing these 

products and find other means to meet their needs. These parties asked DOE to consider lower 

shipments in its standards case forecasts. (AHAM, No. 42 at pp. 14-15; PTI, No. 45 at p. 12) In 

addition, AHAM, CEA, and Cobra Electronics all stated that increases in product price could 

lead some manufacturers to substitute primary batteries for rechargeable batteries in certain 

products, e.g., portable navigation devices and portable radios, reducing the number of battery 

chargers and EPSs for these products. (AHAM, No. 42 at p. 14; CEA, No. 46 at p. 3; Cobra, No. 

51 at p. 2) Lastly, Stanley Black & Decker and Lester stated that increases in product price for 

battery-operated gardening products and golf cars could drive consumers toward their gasolinepowered equivalents. (SBD, No. 44 at p. 2; Lester, No. 50 at p. 3) 

In response to these comments, DOE conducted a sensitivity analysis to examine how 

increases in end-use product prices resulting from standards might affect shipment volumes. To 

DOE’s knowledge, elasticity estimates are not readily available in existing literature for battery 

chargers, EPSs, or the end-use consumer products that DOE is analyzing in this rulemaking. 

211 
Because some applications using battery chargers and EPSs, such as smartphones and videogame 

consoles, could be considered more discretionary than home appliances, which have an estimated 

relative price elasticity of -0.34 (See – 

http://ees.ead.lbl.gov/bibliography/an_analysis_of_the_price_elasticity_of_demand_for_househo 

ld_appliances), DOE believed a higher elasticity of demand was possible. In its sensitivity 

analysis, DOE assumed a price elasticity of demand of -1, meaning a given percentage increase 

in the final product price would be accompanied by that same percentage decrease in shipments. 

Even under this relatively high assumption for price elasticity of demand, the standards 

being proposed today are unlikely to have a significant effect on the shipment volumes of those 

battery charger applications mentioned by stakeholders, with forecasted effects ranging from a 

decrease of 0.03 percent for electric shavers to a decrease of 1.46 percent for DIY power tools 

with detachable batteries. Results for all battery charger applications are contained in appendix 

9A to the TSD. The corresponding impacts on NES and NPV are included in appendix 10A. 

DOE did not conduct a similar analysis for EPS applications due to the small size of the price 

increases (relative to the price of EPS applications) expected to result from the EPS standards 

being proposed today. 

2. Shipment Growth Rate 

In the preliminary analysis, DOE noted that the market for battery chargers and EPSs has 

grown tremendously in the past 10 years. Additionally, DOE found that many market reports 

have predicted enormous future growth for the applications that employ battery chargers and 

EPSs. However, in forecasting the size of these markets over the next 32 years, DOE considered 

212 
the possibility that much of the market growth associated with these products has already 

occurred. In many reports predicting growth of applications that employ battery chargers or 

EPSs, DOE noted that growth was predicted for new applications, but older applications were 

generally not included. That is, the demand for battery chargers and EPSs had not grown, but 

rather the products that use such devices had transitioned to a new product mix. (See chapter 9 of 

the Preliminary TSD.) 

With this in mind, DOE took a conservative approach in its forecast and estimated that 

while the specific applications that use battery chargers or EPSs will change, the overall number 

of individual units that use battery chargers or EPSs will grow slowly, with new applications 

replacing some current applications, but with little change in per-capita consumption of battery 

chargers or EPSs over time. 

To estimate future market size while assuming no change in the per-capita battery 

charger and EPS purchase rate, DOE used population growth rate as the compound annual 

market growth rate. DOE presented this approach to stakeholders for comment and received no 

comments objecting to its use. Population growth rate values were obtained from the U.S. 

Census Bureau 2009 National Projections, which forecast population through 2050. DOE took 

the average annual population growth rate, 0.75 percent, and applied this rate to all battery 

charger and EPS product classes. For the NOPR analysis, DOE continues to apply this scenario. 

213 
3. Product Class Lifetime 

For the preliminary analysis, DOE calculated product class lifetime profiles using the 

percentage of shipments of applications within a given product class, and the lifetimes of those 

applications. These values were combined to estimate the percentage of units remaining in use 

for each year following the initial year in which those units were shipped. For the NOPR 

analysis, DOE continued to apply this scenario. 

For more information on the calculation of product class lifetime profiles, see chapter 10 

of the TSD. 

4. Forecasted Efficiency in the Base Case and Standards Cases 

A key component of the NIA is the trend in energy efficiency forecasted for the base case 

(without new or amended standards) and each of the standards cases. Section IV.A.2 above 

explains how DOE developed efficiency distributions (which yield shipment-weighted average 

efficiency) for battery charger and EPS product classes for the first year of the forecast period. 

To project the trend in efficiency over the entire forecast period, DOE considered recent 

standards, voluntary programs such as ENERGY STAR, and other trends. 

DOE received two comments regarding the effect of European Union (EU) energy 

efficiency standards on the efficiency of battery chargers and EPSs in the U.S. market. AHAM 

commented that the EU is planning to begin a series of battery charger efficiency standards in 

2011 that could have an effect on some non-wall-adapter battery chargers. (AHAM, No. 42 at p. 

15) Similarly, Cobra Electronics commented that the EU’s most recent energy efficiency 

214 
 

standard for EPSs was established at international efficiency marking protocol level V. (Cobra, 

No. 51 at p. 3) 

In the preliminary analysis, DOE found two programs that would influence EPS 

efficiency in the short term. The first is the ENERGY STAR program for EPSs (called “external 

power adapters”), which specified that EPSs be at or above CSL 1 in order to qualify. This 

voluntary program was very active, with more than 3,300 qualified products as of May 2010.51 

The second program influencing EPS efficiency is the European Union Ecodesign requirements 

on Energy Using Products, which includes legislation on EPSs that requires that EPSs sold in the 

EU be at or above CSL 1, effective April 2011. Europe currently represents approximately onethird of the global EPS market. DOE did not identify any programs that required efficiency 

above CSL 1. These factors apply to Class A EPSs. 

DOE agrees that standards established by the EU will affect the U.S. market, due to the 

global nature of EPS design, production, and distribution. With these programs in mind, DOE 

estimated that approximately half of the Class A EPS market at CSL 0 in 2009 would transition 

to CSL 1 by 2013. In updating its analysis for the NOPR, DOE reviewed these two programs for 

any changes. DOE found that no new European standards had been announced during the time 

between the preliminary analysis and the NOPR. However, in regard to the ENERGY STAR 

program, the U.S. Environmental Protection Agency announced that its program for EPSs would 

51EPA, "ENERGY STAR External Power Supplies AC-DC Product List," May 24, 2010 and EPA, "ENERGY 

STAR External Power Supplies AC-AC Product List," May 24, 2010. Both documents last retrieved on May 28, 

2010 from http://www.energystar.gov/index.cfm?c=ext_power_supplies.power_supplies_consumers. 

215 
 

be cancelled effective December 31, 2010.52 In preparing today's notice, DOE also noted that the 

European mobile phone industry agreed to adhere to the GSMA Universal Charging Solution, 

which incorporates a no-load (“standby”) power consumption requirement that is stricter than 

both the current Federal standard and ENERGY STAR version 2.0 criteria. 

In summary, DOE found no new evidence to support the long-term improvement of EPSs 

beyond the initial improvement of units as estimated during the preliminary analysis. Thus, DOE 

has maintained its earlier assumption that EPSs will not improve in efficiency after 2013 in the 

base case. 

For battery charger efficiency trends, DOE considered three key factors: European 

standards, the EPA's ENERGY STAR program, and the recently approved battery charger 

standards in California. 

The EU included battery chargers in a preparatory study on eco-design requirements that 

it published in January 2007. However, it has not yet announced plans to regulate battery 

chargers. Thus, DOE did not adjust the efficiency distributions that it calculated for battery 

chargers between the present-day and the compliance date in 2013 to account for European 

standards. 

52 EPA, "ENERGY STAR EPS EUP Sunset Decision Memo," July 19, 2010. Last retrieved on July 8, 2011 from 

http://www.energystar.gov/ia/partners/prod_development/revisions/downloads/eps_eup_sunset_decision_july2010.p 

df. 

216 
 

DOE examined the ENERGY STAR voluntary program for battery charging systems and 

found that as of January 22, 2010, less than 150 battery charging systems had been qualified. As 

of July 1, 2011, only 241 battery charging systems had been qualified.53 (Contrast this with the 

more than 3,300 EPSs that were ENERGY STAR-qualified as of May 2010.) Given the small 

number of qualified products, DOE also did not adjust its battery charger efficiency distributions 

to account for any potential market effects of the ENERGY STAR program. 

In the preliminary analysis, DOE found no battery charger standards slated to take effect 

by 2013. Subsequently, the California Energy Commission (CEC) approved battery charger 

standards on January 12, 2012 that will take effect on February 1, 2013 for most, if not all, of the 

battery chargers within the scope of DOE's rulemaking. Hence, DOE adjusted its base case 

efficiency distributions for battery chargers to account for these standards by assuming that in the 

absence of Federal standards all battery chargers sold in California would meet the CEC 

standards. In the absence of market share data, DOE assumed that California's share of the U.S. 

battery charger market is equivalent to its share of U.S. GDP (13 percent). Table IV-30 contrasts 

the resultant base case efficiency distributions, used in preparing today's notice, with those used 

in the preliminary analysis. 

Table IV-30 Changes to Base Case Efficiency Distributions to Account for CEC Standards 

DOE 

Product 

Class 

CSL that Best 

Approximates 

the CEC 

Standard 

Scenario 

Percent of Battery Charger Market at Given CSL Prior to 

Federal Standards Taking Effect 

CSL 0 CSL 1 CSL 2 CSL 3 

1 0 

Ref – Prelim. 77.8% 11.1% 11.1% 0.0% 

Ref. – NOPR 77.8% 11.1% 11.1% 0.0% 

Sensitivity Case 77.8% 11.1% 11.1% 0.0% 

53 EPA, "Qualified Product (QP) List for ENERGY STAR Qualified Battery Charging Systems." Retrieved on July 

8, 2011 from http://www.energystar.gov/ia/products/prod_lists/BCS_prod_list.xls. 

217 
DOE 

Product 

Class 

CSL that Best 

Approximates 

the CEC 

Standard 

Scenario 

Percent of Battery Charger Market at Given CSL Prior to 

Federal Standards Taking Effect 

CSL 0 CSL 1 CSL 2 CSL 3 

2 2 

Ref – Prelim. 20.6% 25.7% 50.6% 3.1% 

Ref. – NOPR 17.9% 22.3% 56.6% 3.1% 

Sensitivity Case 0.0% 0.0% 96.9% 3.1% 

3 2 

Ref – Prelim. 19.5% 71.1% 9.4% 0.0% 

Ref. – NOPR 17.0% 61.8% 21.2% 0.0% 

Sensitivity Case 0.0% 0.0% 100.0% 0.0% 

4 2 

Ref – Prelim. 10.6% 45.1% 44.3% 0.0% 

Ref. – NOPR 9.2% 39.3% 51.5% 0.0% 

Sensitivity Case 0.0% 0.0% 100.0% 0.0% 

5 3 

Ref – Prelim. 32.4% 59.5% 8.1% 0.0% 

Ref. – NOPR 28.2% 51.8% 7.0% 13.0% 

Sensitivity Case 0.0% 0.0% 0.0% 100.0% 

6 3 

Ref – Prelim. 40.9% 33.4% 25.7% 0.0% 

Ref. – NOPR 35.5% 29.1% 22.4% 13.0% 

Sensitivity Case 0.0% 0.0% 0.0% 100.0% 

7 1 

Ref – Prelim. 50.0% 50.0% 0.0% 0.0% 

Ref. – NOPR 43.5% 56.5% 0.0% 0.0% 

Sensitivity Case 0.0% 100.0% 0.0% 0.0% 

8 0 

Ref – Prelim. 50.0% 40.0% 10.0% 0.0% 

Ref. – NOPR 50.0% 40.0% 10.0% 0.0% 

Sensitivity Case 50.0% 40.0% 10.0% 0.0% 

10a/b 3 

Ref – Prelim. 100.0% 0.0% 0.0% 0.0% 

Ref. – NOPR 87.0% 0.0% 0.0% 13.0% 

Sensitivity Case 0.0% 0.0% 0.0% 100.0% 

DOE recognizes that the CEC standards may also raise the efficiency of battery chargers 

sold outside of California. However, the magnitude of this effect cannot be determined. 

Nevertheless, to explore the full range of possibilities DOE also evaluated the potential impacts 

of Federal standards under the assumption that the CEC standards become the de facto standard 

for the nation, i.e., all battery chargers sold in the United States just before the Federal standard 

takes effect in 2013 meet the CEC standards. The base case efficiency distributions assumed in 

218 
this sensitivity case are shown in Table IV-30. This scenario represents an upper bound on the 

possible impacts of the CEC standards and a lower bound on the energy savings that could be 

achieved by Federal standards. In fact, under this scenario, DOE might be limited to setting 

standards only for product classes 1 and 8, as further improvements to the efficiency of products 

in the other product classes are not currently projected to be cost-effective. Results of this 

sensitivity analysis can be found in Appendix 8-B and Appendix 10-A. 

DOE believes it is unlikely that all battery chargers sold in the United States will meet the 

CEC standards by February 1, 2013. First, manufacturers have been given an extremely short 

transition period of only one year; second, DOE's proposed standards are not as stringent as the 

CEC standards for product classes 2 through 6, which would potentially reduce the cost of 

production for these products and make it unlikely that they would be manufactured on a 

nationwide basis to the higher CEC levels; and third, the CEC standards will be preempted by 

Federal standards in the future if DOE finalizes standards for these products, giving 

manufacturers the option of specifically producing products solely for the California market for 

an interim period. 

DOE seeks comment on its assumptions concerning the impacts of the CEC standards on 

its base case efficiency distributions. In addition, DOE seeks comment on its assumptions about 

EPS efficiency, specifically, that EPSs within product classes B (DC output, basic-voltage), C 

(DC output, low-voltage), D (AC output, basic-voltage) and E (AC output, low-voltage) will 

improve in efficiency slightly prior to 2013, but then no longer improve in the absence of 

standards, and that EPSs within product classes X (multiple-voltage) and H (high-power) will not 

219 
improve in efficiency in the absence of standards. (See issues 10 and 11 under “Issues on Which 

DOE Seeks Comment” in section VII.E of this notice.) 

To estimate efficiency trends in the standards cases, DOE has used “roll-up” and/or 

“shift” scenarios in its standards rulemakings. Under the “roll-up” scenario, DOE assumes: (1) 

product efficiencies in the base case that do not meet the standard level under consideration 

would “roll-up” to meet the new standard level; and (2) product efficiencies above the standard 

level under consideration would not be affected. Under the “shift” scenario, DOE reorients the 

distribution above the new minimum energy conservation standard. 

In the preliminary analysis, DOE used a roll-up scenario to develop its forecasts of 

efficiency trends in the standards cases. The NOPR analysis also applies this scenario. For 

further details about the forecasted efficiency distributions, see chapter 9 of the TSD. 

5. Product Price Forecast 

As noted in section IV.F., DOE assumed no change in battery charger and EPS pricing 

over the 2013-2042 period. In addition, DOE conducted sensitivity analysis using three 

alternative price trends based on AEO indexes. These price trends, and the NPV results from the 

associated sensitivity cases, are described in appendix 10-B of the NOPR TSD. 

6. Unit Energy Consumption and Savings 

DOE uses the efficiency distributions for the base case along with the annual unit energy 

consumption values to estimate shipment-weighted average unit energy consumption under the 

220 
base and standards cases, which are then compared against one another to yield unit energy 

savings values for each CSL. 

To better evaluate actual energy savings when calculating unit energy consumption for a 

product class at a given CSL, DOE considered only those units that would actually be at that 

CSL and did not consider any units already at higher CSLs. That is, the shipment-weighted 

average unit energy consumption for a CSL ignored any shipments from higher CSLs. 

In addition, when calculating unit energy consumption for a product class, DOE used 

marginal energy consumption, which was taken to be the consumption of a unit above the 

minimum energy consumption possible for that unit. Marginal unit energy consumption values 

were calculated by subtracting the unit energy consumption values for the highest considered 

CSL from the unit energy consumption values at each CSL. 

For the NOPR, DOE assumes that energy efficiency would not improve after 2013 in the 

base case. Therefore, the projected UEC values in the NOPR analysis, as well as the unit energy 

savings values, do not vary over time. In addition, the analysis assumes that manufacturers 

would respond to a standard by improving the efficiency of underperforming products but not 

those that already meet or exceed the standard. 

For further details on the calculation of unit energy savings for the NIA, see chapter 10 of 

the NOPR TSD. 

221 
7. Unit Costs 

DOE uses the efficiency distributions for the base case along with the unit cost values to 

estimate shipment-weighted average unit costs under the base and standards cases, which are 

then compared against one another to give incremental unit cost values for each CSL. In 

addition, when calculating unit costs for a product class, DOE uses that product class’s marginal 

costs -- the costs of a given unit above the minimum costs for that unit. 

For further details on the calculation of unit costs for the NIA, see chapter 10 of the 

NOPR TSD. 

8. Repair and Maintenance Cost per Unit 

In the preliminary analysis, DOE did not consider repair or maintenance costs for battery 

chargers or EPSs because the vast majority cannot be repaired and do not require any 

maintenance. DOE maintains this assumption in its NOPR analysis. 

For the NOPR analysis, DOE considered the incremental maintenance cost for the 

replacement of lithium ion batteries in certain applications. After examining the possible impact 

of this cost in the life-cycle cost and payback period analyses, DOE determined that the actual 

impact at the product class level would most likely be negligible. Thus, DOE opted not to retool 

its NIA model to account for this cost in calculating NPV. For further discussion of this issue, 

see section IV.F.5 above. 

222 
9. Energy Prices 

In the preliminary analysis, DOE assumed that all energy consumption and savings 

would take place in the residential sector, and therefore any energy cost savings would be 

calculated using residential sector rates. 

However, DOE is aware that many products that employ battery chargers and EPSs are 

located within commercial buildings. Given this fact, the energy cost savings from such products 

should be calculated using commercial sector rates, which are lower in value than residential 

sector rates, and would lower the overall financial benefits derived from energy savings in the 

NPV. In order to account for these products in the NOPR analysis, DOE considered the impacts 

of battery charger and EPS usage in a commercial setting. 

In order to determine the energy usage split between the residential and commercial 

sector, DOE first separated products into residential and commercial categories. Then, for each 

product class, using shipment values for 2013, average lifetimes, and base-case unit energy 

consumption values, DOE calculated the approximate annual energy use split between the two 

sectors. DOE applied the resulting ratio to the electricity pricing to obtain a sector-weighted 

energy price. This ratio was held constant throughout the period of analysis. 

For further details on the calculation of sector-weighted energy prices for the NIA, see 

chapter 10 of the NOPR TSD. 

223 
10. Site-to-Source Energy Conversion 

To estimate the national energy savings expected from appliance standards, DOE uses a 

multiplicative factor to convert site energy savings (at the home or commercial building) into 

primary or source energy savings (the energy required to convert and deliver the site energy). 

These conversion factors account for the energy used at power plants to generate electricity and 

losses in transmission and distribution, as well as for natural gas losses from pipeline leakage and 

energy used for pumping. For electricity, the conversion factors vary over time due to projected 

changes in generation sources (i.e., the power plant types projected to provide electricity to the 

country). The factors that DOE developed are marginal values, which represent the response of 

the system to an incremental decrease in consumption associated with appliance standards. 

In the preliminary analysis, DOE used annual site-to-source conversion factors based on 

reported values in AEO2010, which provides energy forecasts through 2035. For 2036–2062, 

DOE used conversion factors that remain constant at the 2035 values. For the NOPR, DOE 

continued to use this approach. 

Section 1802 of the Energy Policy Act of 2005 (EPACT 2005) directed DOE to contract 

a study with the National Academy of Science (the Academy) to examine whether the goals of 

energy conservation standards are best served by measurement of energy consumed, and 

efficiency improvements, at the actual point-of-use or through the use of the full-fuel-cycle 

(FFC), beginning at the source of energy production. (Pub. L. No. 109-58). The FFC measure 

includes point-of-use energy plus the energy consumed in extracting, processing, and 

transporting primary fuels and the energy losses associated with generation, transmission, and 

224 
distribution of electricity. The study, “Review of Site (Point-of-Use) and Full-Fuel-Cycle 

Measurement Approaches to DOE/EERE Building Appliance Energy-Efficiency Standards,” 

was completed in May 2009 and provided five recommendations. A free copy of the study can 

be downloaded at: http://www.nap.edu/catalog.php?record_id=12670. 

The Academy’s primary recommendation was that “DOE consider moving over time to 

use of a FFC measure of energy consumption for assessment of national and environmental 

impact, especially levels of greenhouse gas emissions, and to providing more comprehensive 

information to the public through labels and other means, such as an enhanced website.” The 

Academy further recommended that DOE work with the Federal Trade Commission (FTC) to 

consider options for making product-specific GHG emissions estimates available to enable 

consumers to make cross-class product comparisons. 

More specifically, the Academy recommended that DOE use the FFC measure of energy 

consumption for the environmental assessment and national impact analyses used in energy 

conservation standards rulemakings. The FFC measure would provide more complete 

information about the total energy use and GHG emissions associated with operating an 

appliance than the primary energy measure currently used by DOE. Utilizing the FFC measure 

for environmental assessments and national impact analyses would not require alteration of the 

measures used to determine the energy efficiency of covered products and covered equipment as 

existing law still requires such measures to be based solely on the energy consumed at the pointof-use. (42 U.S.C. 6291(4), 6311(4)). However, using the FFC measure in lieu of primary energy 

225 
in environmental assessments and national impact analyses could affect DOE’s consideration of 

future alternative standard levels. 

In response to the NAS committee recommendations, on August 20, 2010, DOE issued a 

Notice of Proposed Policy proposing to incorporate a FFC analysis into the methods it uses to 

estimate the likely impacts of energy conservation standards on energy use and greenhouse gas 

(GHG) emissions, rather than the primary (extended site) energy measures it currently uses. 

Additionally, DOE proposed to work collaboratively with the FTC to make FFC energy and 

GHG emissions data available to the public to enable consumers to make cross-class 

comparisons. On October 7, 2010, DOE held an informal public meeting to discuss and receive 

comments on its planned approach. The Notice, a transcript of the public meeting and all public 

comments received by DOE are available at: 

http://www.regulations.gov/search/Regs/home.html#docketDetail?R=EERE-2010-BT-NOA0028. DOE is developing a final policy statement on these subjects and intends to begin 

implementing the policy in future energy conservation standards rulemakings. 

For further details about the calculation of national energy savings, see chapter 10 of the 

TSD. 

11. Discount Rates 

The inputs for determining the NPV of the total costs and benefits experienced by 

consumers of battery chargers and EPSs are: (1) total increased product cost, (2) total annual 

savings in operating costs, and (3) a discount factor. For each standards case, DOE calculates net 

226 
 

savings each year as total savings in operating costs less total increases in product costs, relative 

to the base case. DOE calculates operating cost savings over the life of each product shipped 

from 2013 through 2042. 

DOE multiplies the net savings in future years by a discount factor to determine their 

present value. For the preliminary analysis and today’s NOPR, DOE estimated the NPV of 

consumer benefits using both a 3-percent and a 7-percent real discount rate. DOE uses these 

discount rates in accordance with guidance provided by the Office of Management and Budget 

(OMB) to Federal agencies on the development of regulatory analysis.54 The 7-percent real value 

is an estimate of the average before-tax rate of return to private capital in the U.S. economy. The 

3-percent real value represents the “societal rate of time preference,” which is the rate at which 

society discounts future consumption flows to their present value. 

For further details about the calculation of net present value, see chapter 10 of the TSD. 

12. Benefits from Effects of Standards on Energy Prices 

The reduction in electricity consumption associated with new and amended standards for 

battery chargers and EPSs could affect overall electricity generation, and thus affect the 

electricity prices charged to consumers in all sectors of the economy. As a simplifying 

assumption in the preliminary analysis, DOE assumed no change in electricity prices as a result 

of energy savings from new or amended standards for battery chargers and EPSs. 

54 OMB Circular A-4 (Sept. 17, 2003), section E, “Identifying and Measuring Benefits and Costs. Available at: 

http://www.whitehouse.gov/omb/memoranda/m03-21.html. 

227 
Commenting on the preliminary analysis, NEEP stated that the economic benefits of the 

reduced need for new power plants should be estimated and requested that DOE quantify 

electricity demand reductions achieved by these updated standards in financial terms. (NEEP, 

No. 49 at p. 2) 

In preparing the NOPR analysis, DOE used NEMS-BT to assess the impacts of the 

reduced need for new electric power plants and infrastructure projected to result from standards. 

In NEMS-BT, changes in power generation infrastructure affect utility revenue requirements, 

which in turn affect electricity prices. From these data, DOE estimated the impact on electricity 

prices associated with each considered TSL. Although the aggregate benefits for electricity users 

are potentially large, there may be negative effects on some of the entities involved in electricity 

supply, particularly power plant providers and fuel suppliers. Because there is uncertainty about 

the extent to which the benefits for electricity users from reduced electricity prices would be a 

transfer from entities involved in electricity supply to electricity consumers, DOE tentatively 

concludes that, at present, it should not give a heavy weight to this factor in its consideration of 

the economic justification of new or amended standards. DOE is continuing to investigate the 

extent to which electricity price changes projected to result from standards represent a net gain to 

society. 

For further details about the effect of standards on energy prices, see chapter 10 of the 

TSD. 

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H. Consumer Subgroup Analysis 

In analyzing the potential impacts of new or amended standards, DOE evaluates the 

impacts on identifiable subgroups of consumers (e.g., low-income households or small 

businesses) that may be disproportionately affected by a national standard. In the preliminary 

analysis, DOE identified four consumer subgroups of interest -- low-income consumers, small 

businesses, top marginal electricity price tier consumers, and consumers of specific applications 

within a representative unit or product class. 

Interested parties supported DOE’s decision to analyze consumers of specific 

applications in the subgroup analysis. AHAM commented that DOE should consider subgroups 

of applications to ensure that CSLs are justified for applications with different energy usage 

characteristics from the product class. (AHAM, No. 42 at p. 12) Stanley Black & Decker also 

commented that outdoor gardening appliances were only operated a portion of the year, and 

would have different energy usage characteristics from the product class, necessitating a 

subgroup analysis. (SBD, No. 44 at pp. 1-2) Wahl Clipper commented that infrequently charged 

products should not be compared in the same fashion as those that are plugged in most of the 

time. (Wahl, No. 53 at p. 2) 

Additionally, manufacturers commented that averaging LCC results of various 

applications within the representative unit or product class would not lend enough weight to 

applications with fewer shipments. PTI noted that power tools have little in common with other 

applications aside from their battery energy and voltage levels. In its view, the averaging of LCC 

results would diminish the impact of the power tools on the LCC results for the entire product 

229 
class. (PTI, No. 45 at pp. 6, 13) Similarly, AHAM and PTI commented that certain applications 

sell at lower price points than other applications within the product class. They argued that 

averaging the LCC results across these applications would deemphasize the impacts on the 

individual applications. (AHAM, No. 42 at pp. 13-14; PTI, No. 45 at pp. 6, 13) 

DOE’s subgroup analysis for consumers of specific applications considered the LCC 

impacts of each application within a representative unit or product class. This approach allowed 

DOE to consider the LCC impacts of individual applications when choosing the proposed 

standard level, regardless of the application’s weighting in the calculation of average impacts. 

The impacts of the standard on the cost of the battery charger or EPS as a percentage of the 

application’s total purchase price are not relevant to DOE’s LCC analysis. The LCC considers 

the incremental cost between different standard levels. DOE used the cost of the EPS or battery 

charger component in the LCC, not the final price of the application. Therefore, a $2,000 and 

$20 product are assumed to have the same cost for a battery charger or EPS (e.g., $5) if they are 

within the same CSL of the same representative unit or product class. The LCC considers the 

incremental impacts on consumers who purchase the product, but does not account for price 

elasticity or the economic impacts of consumers switching to non-covered products. Instead, 

DOE explored these possibilities in a shipments sensitivity analysis, as explained in section 

IV.G.1 above. The application-specific subgroup analyses represent an estimate of the marginal 

impacts of standards on consumers of each application within a representative unit or product 

class. 

230 
At the preliminary analysis public meeting, AHAM commented that some applications 

span multiple battery charger product classes, making it difficult for the LCC to focus on specific 

applications. (AHAM, Pub. Mtg. Tr., No. 57 at p. 153) 

DOE notes that several applications span more than one product class or representative 

unit. Because each product class has associated characteristics and costs, it is difficult to 

aggregate LCC results across product classes. Therefore, DOE calculated application-specific 

results for each product class and representative unit. For applications that span multiple product 

classes, DOE calculated the LCC and PBP impacts for that application in each product class. 

For each subgroup, DOE considered variations on the standard inputs. DOE defined lowincome consumers as residential consumers with incomes at or below the poverty line, as defined 

by the U.S. Census Bureau. DOE found that these consumers face electricity prices that are 0.2 

cents per kWh lower, on average, than the prices faced by consumers above the poverty line. For 

small businesses, DOE analyzed the potential impacts of standards by conducting the analysis 

with different discount rates, as small businesses do not have the same access to capital as larger 

businesses. DOE estimated that for businesses purchasing battery chargers or EPSs, small 

companies have an average discount rate that is 4.5 percent higher than the industry average. For 

top tier marginal electricity price consumers, DOE researched inclined marginal block rates for 

the residential and commercial sectors. DOE found that top tier marginal rates for general usage 

in the residential and commercial sectors were $0.306 and $0.221, respectively. Lastly, for the 

application-specific subgroup, DOE used the inputs from each application for lifetime, markups, 

market efficiency distribution, and UEC to calculate LCC and PBP results. 

231 
Chapter 11 of the TSD contains further information on the LCC analyses for all 

subgroups. 

I. Manufacturer Impact Analysis 

1. Overview 

DOE conducted separate manufacturer impact analyses (MIA) for EPSs and battery 

chargers to estimate the financial impact of new or amended energy conservation standards on 

these industries. The MIA is both a quantitative and qualitative analysis. The quantitative part of 

the MIA relies on the Government Regulatory Impact Model (GRIM), an industry cash-flow 

model customized for EPSs and applications that include battery chargers covered in this 

rulemaking. The key MIA output is industry net present value, or INPV. DOE used the GRIM to 

calculate cash flows using standard accounting principles and to compare changes in INPV 

between a base case and various TSLs (the standards case). The difference in INPV between the 

base and standards cases represents the financial impact of the new and amended standards on 

manufacturers. Different sets of assumptions (scenarios) produce different results. 

DOE calculated the MIA impacts of new and amended energy conservation standards by 

creating separate GRIMs for EPS original device manufacturers (ODMs) and battery charger 

manufacturers. In each GRIM, DOE presents the industry impacts by grouping similarly 

impacted products. For EPSs DOE presented the industry impacts by grouping the four 

representative product class B units (with output powers at 2.5, 18, 60, and 120 Watts) to 

characterize the results for product classes B, C, D, and E. DOE also presented the results for 

product classes X and H separately. For battery chargers, DOE presented the industry impacts by 

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the major product class groupings for which TSLs are selected (product class 1; product classes 

2, 3, and 4; product classes 5 and 6; product class 7; product class 8; product class 10). When 

appropriate, DOE also presented the results for differentially impacted industries within and 

across those groupings. This is necessary because a given industry, depending upon how 

narrowly it is defined, may fall into several product classes. By segmenting the results into these 

similar industries, DOE is also able to discuss how subgroups of battery charger manufacturers 

will be impacted by new energy conservation standards. 

The complete MIA is presented in chapter 12 of the NOPR TSD. 

2. EPS MIA 

The MIA for EPSs focused on the original device manufacturers—or ODMs. These 

companies manufacture the EPS itself, as opposed to the application it is designed for or sold 

with. DOE analyzed the impact of standards on EPS manufacturers at the ODM level for three 

basic reasons: (1) the ODM typically certifies compliance with the DOE energy conservation 

standards and completes most design work for the EPS (even if EPS specifications are given by 

an OEM); (2) unlike battery chargers, the EPS is not fully integrated into end-use applications; 

and (3) most of the EPS final assembly and manufacturing is done by ODMs, which then ship 

the EPS as a component to OEMs. In essence, unlike a battery charger, the EPS typically 

becomes a final product when under the control of the ODMs, regardless of any additional steps 

in the distribution chain to the consumer. 

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a. EPS GRIM Key Inputs 

Many of the inputs to the GRIM come from the engineering analysis, the NIA, 

manufacturer interviews, and other research conducted during the MIA. The major GRIM inputs 

are described in detail in the sections below. 

i. EPS Manufacturer Production Costs 

The MIA is concerned with how changes in efficiency impact the manufacturer 

production costs (MPCs). The MPCs and the corresponding prices for which fully assembled 

EPSs are sold to OEMs, frequently referred to as “factory costs” in the industry, are major 

factors in industry value calculations. DOE’s MPCs include the cost of components (including 

integrated circuits), other direct materials of the finalized EPS, the labor to assemble all parts, 

factory overhead, and all other costs borne by the ODM to fully assemble the EPS. 

In the engineering analysis, cost-efficiency curves are developed for the four 

representative product class B units and product classes X and H, which were all analyzed 

directly. The MPCs are calculated in one of two ways. For the product class B representative 

units, DOE based its MPCs on information gathered during manufacturer interviews. In these 

interviews, manufacturers described the costs they would incur to achieve increases in energy 

efficiency. For product classes H and X, the engineering analysis created a complete bill of 

materials (BOM) derived from the disassembly of the units selected for teardown. 

234 
To calculate the percentage of the MPC attributable to labor, material, and overhead, 

DOE used the average percentages from all teardowns completed as part of the engineering 

analysis. 

For further detail, see the Engineering Analysis discussion in section IV.C.1 of this 

NOPR. 

ii. EPS Shipment Forecast 

Industry value, the key GRIM output, depends on industry revenue, which, in turn, 

depends on the quantity and prices of EPSs shipped in each year of the analysis period. Industry 

revenue calculations require forecasts of: (1) total annual shipment volume; (2) the distribution 

of shipments across analyzed representative units (because prices vary by representative unit); 

and, (3) the distribution of shipments across efficiencies (because prices vary with efficiency). 

In the NIA, DOE estimated total EPS shipments by application in 2009 and assumed a 

constant compound annual growth rate for total EPS shipments throughout the analysis period. 

DOE did not assume a decrease in shipments due to energy conservation standards. 

The GRIM requires that shipments be disaggregated by analyzed representative unit. In 

the LCC, DOE allocated total EPS shipments among all analyzed EPS applications. In the MIA, 

DOE assigned each application’s associated EPS shipments to one of the six representative units 

in the following manner. First, DOE assigned any EPS application that uses multiple voltages to 

product class X. Second, any EPS application with an output power greater than 250 Watts was 

235 
assigned to product class H. Lastly, DOE assigned each unit shipped in product classes B, C, D, 

and E to one of four groups, corresponding to one of the four representative units (output powers 

of 2.5, 18, 60, and 120 Watts), whichever has the closest output power. For example, if an 

application has an output power of 4 Watts, DOE assigned that application to the 2.5W 

representative unit grouping. 

As discussed above, revenue calculations also require knowledge of the efficiency 

distribution in each year of the analysis period. DOE first developed efficiency distributions for 

2009 based on products that DOE tested. Next, DOE estimated a 2013 efficiency distribution 

based on an assessment of recent trends in product efficiency. DOE then linearly extrapolated the 

efficiency distributions for the intermediate years between 2009 and 2013. DOE assumed a 

constant efficiency distribution in the base case throughout the analysis period. See section IV.G 

of this NOPR for more information about DOE’s base-case EPS shipments forecast. 

iii. EPS Product and Capital Conversion Costs 

DOE expects new and amended energy conservation standards to cause some 

manufacturers to incur one-time conversion costs to bring their production facilities and product 

designs into compliance with the new and amended standards. For the MIA, DOE classified 

these one-time conversion costs into two major groups: (1) product conversion costs and (2) 

capital conversion costs. Product conversion costs are one-time investments in research, 

development, testing, marketing, and other non-capitalized costs focused on making product 

designs comply with the new and amended energy conservation standards. Capital conversion 

236 
costs are one-time investments in property, plant, and equipment to adapt or change existing 

production facilities so that new product designs can be fabricated and assembled. 

DOE received several comments on the preliminary analysis about the impact of product 

and capital conversion costs on EPS manufacturers and OEMs. Many commenters expressed 

concerns about potential conversion costs. AHAM suggested that DOE seek input from 

manufacturers related to the impact of additional engineering, testing, and capital improvements 

that are associated with any significant design changes. Specifically, AHAM noted that changes 

to the outside housing of some battery chargers and EPSs will result in changes to plastic 

injection molds that cost tens of thousands of dollars each year, as well as changes in the size of 

external packaging of the product. (AHAM, No. 42 at p. 11) Similarly, Cobra suggested that 

incremental engineering design costs be assessed because they may become a significant part of 

the initial cost of the product. (Cobra, No. 51 at p. 2) 

DOE agrees that testing, certification, and engineering costs could represent a substantial 

cost for the EPS industry. DOE relied on a number of assumptions from other analyses and data 

gathered from publicly available sources to estimate product conversion costs. The key values 

used to estimate product conversion costs were application lifetimes, shipments of each 

application from 2011 and 2013, and typical industry research and development expenses. 

Because the product lifecycle tends to be shorter for electronics, DOE assumed that in the base 

case, a portion of the applications will be redesigned between the announcement of an energy 

conservation standard and the implementation of that energy conservation standard. Those 

237 
applications that are scheduled for redesign are excluded from the projected product conversion 

costs. 

DOE assumed that an application’s product lifetime -- the average number of years a 

product is used by consumers -- is equal to its production cycle, the average number of years 

between when manufacturers redesign that application. DOE based this simplifying assumption 

on feedback received from several manufacturers during manufacturer interviews. However, 

DOE is aware that not all product lifetimes directly correspond to their production cycle, as some 

products may have shorter or longer production cycles compared to their product lifetimes. DOE 

believes on average the product lifetime is an appropriate estimate of the production cycle for an 

application. So for example, for an application with a five-year product lifetime, DOE assumed 

that application to also have a five-year production cycle. Therefore on average one-fifth of these 

applications would be redesigned each year by manufacturers. Because there is a two-year time 

period between the announcement of the standard and its compliance date, two-fifths of the 

applications with a five-year production cycle will be redesigned in that timeframe, irrespective 

of whether a standard is implemented. As a result, three-fifths of the five-year applications would 

need to be redesigned as a result of a new or amended energy conservation standard. In addition, 

only those products that do not meet the established energy conservation standard would be 

required to be redesigned, as the efficiency of products meeting or exceeding the standard would 

remain unchanged. 

AHAM stated that products that undergo changes must be sent to third-party testing 

laboratories for energy efficiency testing and these testing costs must be factored into the overall 

238 
cost of changing a product’s design. AHAM suggested that DOE ask manufacturers for 

information on these costs. AHAM also argued the cost of safety certification should be included 

in the overall cost. (AHAM, No. 42 at pp. 11) Cobra commented that third-party testing would 

be an undue burden on manufacturers, stating that DOE should not require it unless a significant 

compliance problem with the current system is proven. (Cobra, No. 51 at p. 4) 

DOE notes that it does not currently require manufacturers to use third-party testing to 

demonstrate compliance with EPS or battery charger energy conservation standards as the above 

comments suggest. However, DOE recognizes other organizations that provide certifications for 

safety or other product attributes may constitute part of the total product conversion costs (such 

as UL certification). DOE also understands that many ODMs and/or OEMs will likely pay for 

third-party testing to ensure compliance with the energy conservation standard because many do 

not have certified labs. DOE included testing costs as part of the research and development costs 

used to calculate the product conversion cost for the industry because these costs represent a 

significant portion of existing expenses that are factored into the methodology. 

DOE used a similar approach to calculate capital conversion costs, using application 

lifetimes and the shipments of each application between 2011 and 2013 as the key assumptions. 

Whereas DOE estimated product conversion costs using a multiple of typical industry R&D 

expenditures, DOE estimated capital conversion costs using a multiple of typical industry capital 

expenditures. In response to AHAM’s comment regarding the potential changes to the plastic 

injection molds used to cast the external casings of EPSs, DOE assumed in its analysis that the 

changes for the actual EPS designs would require a lower capital investment than for battery 

239 
chargers because these changes would affect only the external housing of an EPS. By 

comparison, battery chargers may require changes to the entire housing, which would require a 

greater capital investment. 

Cobra also expressed concerns about conversion costs for manufacturers of linear EPSs 

because, depending on the efficiency level DOE sets, a manufacturer would have to transition 

from a mechanical assembly process to an automated printed circuit board (PCB) assembly 

process. (Cobra, No. 51 at p. 3) 

The capital cost of transitioning from a mechanical assembly process to an automated 

PCB assembly process would be borne by the EPS ODM in most cases. For most CSLs, there are 

a variety of technologies available for EPSs and many ODMs do not exclusively offer linear 

EPSs. OEMs that do not own their own manufacturing facilities will also be impacted by this 

transition, but the impact will manifest itself primarily through higher factory costs after 

standards apply. DOE fully analyzed these costs in the engineering costs and the GRIM’s INPV 

calculations. In particular, the capital conversion cost assumptions that DOE used increase at 

CSLs that require a technology change because, as Cobra states, these transitions greatly increase 

the required capital and product conversion costs, especially for manufacturers that must 

transition to a new assembly process. This factor is taken into account for the 2.5W 

representative unit. DOE assumed the product and capital conversion costs associated with 

upgrading CSL 1 and baseline 2.5W representative units would be greater than the product and 

capital conversion costs of other representative units because the technology employed in 

upgrading those 2.5W representative units change from linear to switch mode technology. This 

240 
technology change would be more costly than an ordinary product redesign because companies 

focusing on incremental changes for applications using linear technology may not have the 

experience and expertise to implement switch mode technology in their applications without 

additional product development efforts. 

See chapter 12 of the TSD for a complete description of DOE’s assumptions for the 

capital and product conversion costs. 

iv. Financial Inputs 

DOE was unable to locate sufficient data on publicly-traded EPS manufacturers because 

few, if any, major EPS ODMs are publicly traded in the United States. Consequently, few, if any, 

of these companies file annual 10-K reports with the Securities and Exchange Commission. 

Because these documents were not available, the preliminary MIA DOE developed began with 

the basic financial parameters used in the ballast rulemaking (such as R&D percentage of 

revenue, capital expenditure percentage of revenue, SG&A percentage of revenue, tax rate as a 

percentage of revenue, etc.) because many of the companies included in that analysis were 

structured similarly to EPS manufacturers, manufacture products in similar locations, and use 

similar production processes [76 FR 20090, 20134-20135 April 11, 2011 (notice of proposed 

rulemaking to set amended efficiency standards for fluorescent lamp ballasts, describing various 

aspects of the manufacturing industry) and section 4.3 of chapter 13 of the NOPR TSD 

accompanying that notice]. During manufacturer interviews, DOE asked EPS manufacturers to 

comment on these initial financial parameters. Several EPS manufacturers interviewed 

confirmed that these initial financial parameters were an appropriate representation of the EPS 

241 
industry. Consequently, DOE applied these parameters in analyzing the EPS industry in the 

MIA. 

v. EPS Standards-Case Shipments 

The base-case efficiency distribution and growth rate drive total industry revenue in the 

base case. In the standards case, DOE assumed that manufacturers will respond to new and 

amended standards by improving only those products that do not meet the standards in 2013, but 

not exceed, the new and amended standard level. Products that already meet or exceed the 

proposed level remain unaffected. This is referred to as a “roll-up” scenario. See chapter 9 of the 

TSD for a complete explanation of the efficiency distribution of EPSs and battery chargers by 

product class. 

vi. EPS Markup Scenarios 

As discussed above, the MPCs of the six representative units are the factory costs of the 

ODM and include direct labor, material, overhead, and depreciation. The MSP is the price the 

ODM sells an EPS to an OEM. The MSP is equal to the MPC multiplied by the manufacturer 

markup. The manufacturer markup covers all the ODM’s non-production costs (i.e., SG&A, 

R&D, and interest, etc.) and profit. Total EPS revenue is equal to the MSPs at each CSL 

multiplied by the shipments at that CSL. 

Modifying these manufacturer markups in the standards case yields different sets of 

impacts on manufacturers. For the MIA, DOE modeled two standards-case markup scenarios to 

represent the uncertainty regarding the potential impacts on prices and profitability for 

242 
manufacturers following the implementation of new and amended energy conservation 

standards: (1) a flat markup scenario and (2) a preservation of operating profit scenario. These 

scenarios lead to different markups values, which, when applied to the inputted MPCs, result in 

varying revenue and cash flow impacts. 

The flat markup scenario assumed that the cost of goods sold for each product is marked 

up by a flat percentage to cover SG&A expenses, R&D expenses, and profit. This scenario 

represents the upper bound of industry profitability in the standards case because manufacturers 

are able to fully pass through additional costs due to standards to their customers. 

DOE also modeled a lower-bound profitability scenario. During interviews, ODMs and 

OEMs indicated that the electronics industry is extremely price sensitive throughout the 

distribution chain. Because of the highly competitive market, this scenario models the case in 

which ODMs’ higher production costs for more efficient EPSs cannot be fully passed through to 

OEMs. In this scenario, the manufacturer markups are lowered such that manufacturers are only 

able to maintain the base-case total operating profit in absolute dollars in the standards case, 

despite higher product costs and required investment. DOE implemented this scenario in the 

GRIM by lowering the manufacturer markups at each TSL to yield approximately the same 

earnings before interest and taxes in both the base case and standards cases in the year after the 

compliance date for the new and amended standards. This scenario represents the lower bound of 

industry profitability following new and amended energy conservation standards because higher 

production costs and the investments required to comply with the new and amended energy 

conservation standard do not yield additional operating profit. 

243 
b. Comments from Interested Parties Related to EPSs 

DOE also received comments on the potential manufacturer impacts that would result 

from DOE’s treatment of EPSs as both a stand-alone product and a component of another 

regulated product (the battery charger). AHAM stated that this treatment could lead to 

duplicative testing if this rulemaking were to establish different compliance dates for EPSs and 

battery chargers, or if future standards were to be updated at different points for battery charger 

and EPSs. (AHAM No. 44 at p. 11) 

In response, DOE notes that EPS and battery charger standards for this rulemaking will 

go into effect on the same date. Therefore, DOE does not foresee a situation in which updated 

regulations would occur at different intervals. 

To account for the compliance costs for certifying an EPS alone and as a component of a 

battery charging system, DOE has included compliance costs for both the EPS and the battery 

charging system in its conversion cost estimates in the EPS GRIM and the battery charger 

GRIM, respectively. DOE also notes for product class N EPSs, which only function as a battery 

charger component (as opposed to EPSs that can directly power the application), the Class A 

EPS standards prescribed in 42 U.S.C. 6295(u)(3) will continue to apply to the Class A EPSs in 

product class N. Any additional energy-related savings generated by the use of more efficient 

product class N EPSs will be captured through the battery charger standards that DOE is 

proposing to set. Consequently, conversion costs for product class N EPSs are not included in the 

EPS analysis, but the conversion costs for the battery charging portion of the application are 

244 
included in the battery charger GRIM for these applications. DOE believes that this approach 

will help to ensure that additional energy savings can be obtained by applying more stringent 

levels in a manner that reduces the complexity of the overall standards that are set. Depending on 

the additional information that DOE receives in response to this proposed approach, the agency 

may alter the approach to account for that additional information. 

In response to the preliminary analysis, Cobra suggested that DOE account for 

incremental engineering design costs in the rulemaking analysis, as those costs may comprise a 

significant portion of the product’s initial cost. DOE notes that the incremental engineering costs 

are directly accounted for in the MPCs which are a central input to the GRIM. 

Cobra also questioned what it viewed as a DOE assumption that achieving a new or 

amended standard can be done with present staffing and within the two years between the notice 

and the compliance date. Cobra stated that while this may be possible if the standard is set close 

to today’s standards, it will not continue to be the case if the standard is set closer to the max 

tech level. Cobra stated that achieving a new or amended standard will take even longer if DOE 

regulates products under an EPS and battery charger regulation at the same time due to 

additional design burdens. (Cobra, No. 51 at p. 2) 

Partly in recognition of this situation, DOE is not proposing new or amended standards 

for product class N EPSs in today's notice. This approach allows manufacturers to focus on 

improving the efficiency of these products as a system. As shown by DOE’s capital and product 

conversion costs that increase at each higher efficiency level, DOE also agrees that standards that 

245 
are closer to max-tech would require a more substantial research and development effort by 

manufacturers and are accounted for in DOE’s analysis. However, DOE does not assume that 

standards set closer to the max tech level could be met by all manufacturers with their present 

staffing. In addition to standard research and development expenses that account for ongoing 

product development, DOE’s methodology accounts for the additional product conversion costs 

that would be required for products that fall below the required efficiency level or would not 

have been redesigned in the period between the final rule’s issuance and the compliance date of 

the standard. The EPS conversion cost estimates also account for any additional engineering or 

product development resources necessary to meet new or amended energy conservation 

standards. 

c. High-Power EPS Manufacturer Interviews 

To better understand the possible impacts on product class H, DOE attempted to gather 

more information about the possible impacts on high-power EPS ODMs. DOE identified a total 

of 13 manufacturers of high-power EPSs. DOE attempted to contact all manufacturers of highpower EPSs. DOE managed to locate contact information for eleven of these manufacturers and 

contacted each to schedule interviews. Six of these eleven were domestic manufacturers and five 

were foreign manufacturers. Of these eleven manufacturers for whom DOE found contact 

information, five were non-responsive. The remaining six declined to discuss the impacts of new 

standards on high-power EPSs. Four of the six manufacturers that declined to be interviewed 

were domestic manufacturers and two were foreign manufacturers. 

246 
3. Battery Charger MIA 

In the battery charger MIA, DOE analyzed the impacts of standards on manufacturers of 

the applications that incorporate the covered battery chargers (the application OEMs). DOE 

believes this MIA focus, which differs from the approach DOE is using for the EPS MIA, is 

appropriate for several reasons. 

First, the application OEM will be the party most directly financially impacted by any 

energy conservation standards, as evidenced by their participation in the rulemaking process. 

Battery chargers are almost always integrated into and/or sold with the final application – 

meaning the severity of necessary conversion costs and the financial impact of higher battery 

charger costs can only be assessed meaningfully at the application level. Because most battery 

chargers are sold with, or fully integrated into, the end-use application, OEMs will pay for any 

costs required to alter the application if the new battery charger design requires it. These costs 

will vary from application to application, even within a product class. 

Second, the battery charger value chain varies greatly and is principally dictated by the 

application for which it is designed and with which it is sold. While EPSs are almost exclusively 

sold as finalized components, battery charger manufacturing is split between companies that 

produce battery chargers for OEMs and OEMs that produce battery chargers “in house.” 

Third, the OEM typically designs the battery charger and would certify compliance with 

any DOE regulations because it is often impossible to separate the battery charger from the 

application. 

247 
Fourth, even if the OEM does not design the battery charger, it typically will still 

integrate it into the final product. As a result, even if an OEM did not design the battery charger, 

it must still integrate it into the final application. Therefore, the OEM will be responsible for any 

changes to the application (such as the plastic housing) which are necessary due to the changes in 

the battery charger. 

Lastly, within a given product class, individual applications may be much more severely 

impacted than others within the same product class -- even at the same CSL. These differential 

impacts would be obscured if DOE did not consider the different characteristics of the 

application industries. 

In some industries, particularly those that utilize high-energy battery chargers, the 

directly impacted party will likely be the battery charger ODM (as opposed to the OEM). 

Manufacturers of battery chargers for golf cars, for example, produce and sell stand alone battery 

chargers and would be responsible for compliance with energy conservation standards and all 

associated conversion costs. DOE conducted a subgroup analysis for product class 7, which it 

presents in the regulatory flexibility analysis, section VI.B. That analysis addresses the potential 

impacts of the proposed standards on small businesses. DOE is following this approach because 

the only manufacturers of these products that DOE identified are small businesses. 

To calculate impacts on the application OEM, DOE analyzed the industries of the 

applications that use covered battery chargers. DOE presents results in two different ways. First, 

248 
DOE presents the industry impacts by the major product class groupings for which TSLs are 

derived (product class 1; product classes 2, 3, and 4; product classes 5 and 6; product class 7; 

product class 8; product class 10). 

Second, DOE used an alternative construction for evaluating the MIA results for battery 

chargers. DOE has developed this approach because if it grouped results in the same manner as 

the TSL product class groupings noted above, they would not adequately account for the fact that 

many applications within the same product class groupings are very dissimilar. The aggregate 

projected impacts would not necessarily be representative of each particular industry within each 

product class grouping. To address this potential problem, the analysis (particularly for product 

classes 2, 3, and 4) groups applications into four industry subcategories. These industry 

subgroups share similar characteristics and the proposed standards are projected to affect these 

industry subgroups similarly. To group the applications, DOE assigned each application to one 

of four distinct industry subgroups: small appliances, consumer electronics, power tools, and 

high-energy products (“high-energy” products are those applications that fit into product classes 

5, 6, and 7). This additional approach enhances the interpretability and transparency of the MIA 

results by providing a meaningful way to compare impacts across applications. 

DOE has set up a flexible methodology that allows the analysis of individual applications 

or a set of applications. DOE reports these quantitative MIA results for each individual 

application, product class, and industry subgroup in chapter 12 of the TSD. 

249 
a. Battery Charger GRIM Key Inputs 

Many of the inputs to the GRIM come from the engineering analysis, the NIA, 

manufacturer interviews, and other research conducted in preparing the MIA. The major GRIM 

inputs are described in detail in the sections below. 

i. Battery Charger Manufacturer Production Costs and Application Prices 

Calculating manufacturer impacts at the OEM level for battery chargers requires two 

critical inputs: First, the price that the application OEM charges for its finished product (to 

calculate revenue); and, second, the portion of that price represented by its battery charger (to 

calculate costs) at each CSL. 

For the first component, DOE determined representative retail prices for each application 

by surveying popular online retailer websites to sample a number of price points of the most 

commonly sold products for each application. The price of each application can vary greatly 

depending on many factors (such as the features of each individual product). For each 

application, DOE used the average application price found in the product survey. DOE then 

discounted this representative retail price back to the application MSP using the retail markups 

derived from annual SEC 10-K reports in the Markups Analysis, as discussed in section IV.F. 

DOE calculated the second figure—the price of the battery charger itself at each CSL—in 

the engineering analysis. The engineering analysis calculated a separate cost efficiency curve for 

each of the 10 battery charger product classes. Based on product testing data, tear-down data and 

manufacturer feedback, DOE created a BOM at the ODM level to which markups were applied 

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to calculate the MSP of the battery charger at each CSL. DOE then allocated the battery charger 

MSPs of each product class to all the applications within each product class. In this way, DOE 

arrived at the cost to the application OEM of the battery charger for each application. 

ii. Battery Charger Financial Parameters 

Because any two application OEMs may compete in very different markets, a single set 

of financial parameters cannot adequately characterize each manufacturer’s cost structure. To 

address this limitation, DOE gathered and disaggregated publicly available financial data for 

representative manufacturers in each of the four industry categories it analyzes: small appliance 

manufacturers, consumer electronics manufacturers, power tool manufacturers, and high-energy 

product manufacturers. DOE then assigned each application to one of the four industry 

subgroups. In the GRIM, each individual application uses the cost structure of the industry 

subgroup to which it belongs. 

iii. Battery Charger Shipment Forecast 

As with EPS shipments, DOE estimated total domestic shipments of each analyzed 

application for 2013 that is sold with a battery charger. DOE then distributed the associated 

shipments among the 10 product classes and among the four industry subgroups. See chapter 12 

of the TSD for a complete list of the applications DOE included in each of the four industry 

subgroups. DOE also adjusted its efficiency distributions and shipments in the base case, to 

account for pending efficiency regulations in California (for more information please see 

IV.A.2.d). In the GRIM, DOE used the battery charger shipment projections from 2009 to 2042 

that were generated in the NIA. 

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iv. Battery Charger Product and Capital Conversion Costs 

Capital and product conversion costs triggered by a new energy conservation standard are 

critical inputs to the GRIM. DOE received various comments about the impact of product and 

capital conversion costs on manufacturers of applications that incorporate covered battery 

chargers. 

AHAM suggested that DOE seek manufacturer input regarding the impact of additional 

engineering, testing, and capital improvements that are associated with any significant design 

changes that would be needed to satisfy new standards for battery chargers. Specifically, AHAM 

noted that changes to the outside housing of some battery chargers will result in changes to 

plastic injection molds that cost tens of thousands of dollars each year, as well as changes in the 

size of the external packaging of the product. (AHAM, No. 42 at p. 11) PTI stated that 

manufacturers will encounter redesigning, retooling and re-qualifying costs for battery chargers 

used in power tools. The magnitude of these costs will depend on the final CSL selected. For 

example, the difference between CSL 1 and CSL 2 for product class 4 could be hundreds of 

thousands of dollars. (PTI, No. 45 at p. 13) Similarly, Cobra argued that incremental engineering 

design costs should be included in the analysis because they may become a significant part of the 

initial cost of the product. (Cobra, No. 51 at p. 2) 

DOE agrees that testing and engineering costs could represent a substantial cost burden to 

manufacturers, depending on the efficiency levels eventually selected. DOE has included the 

testing costs for battery charger applications to comply with the energy conservation standards in 

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its calculation of conversion costs. At the higher CSLs, manufacturers could be compelled to 

redesign products that would have been redesigned years later in the base case. DOE accounts 

for the additional testing and engineering time by assuming that energy conservation standards 

would require manufacturers to alter products before the end of their natural lifecycle, resulting 

in substantial product conversion costs. The extent of the product conversion costs depends 

largely on whether a given standard level requires a technology change—moving from NiMH to 

lithium ion chemistry, for example—or only minor design tweaks. Within a given product class, 

some applications will face technology changes and the associated major redesigns at much 

lower CSLs than other applications. Therefore, DOE estimated product conversion costs for each 

individual application, rather than in aggregate by product class. 

Because of the large number of applications analyzed, DOE approximates the impacts of 

standards-driven conversion costs by assuming manufacturers will incur a given multiple of 

normal R&D and normal capital expenditures. The exact multiple used depends on each CSL 

and each product class and is calibrated to manufacturer feedback received during interviews. 

Intuitively, this approach to product and capital expenditures accelerates the product cycle and 

compresses resources that would normally have been spread over a number of years into a 

shorter timeframe. In the standards case, these expenditures are in addition to, and not in lieu of, 

normal engineering, testing and equipment costs. DOE only assumes conversion costs for the 

proportion of shipments that fall below the analyzed TSL within any given application. Also, 

DOE separately calculated the conversion costs associated with the products sold in California 

that would have to comply with the CEC battery charger standard. These conversion costs are 

included in the base case and separate from the conversion costs associated with the DOE 

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standard. For example, in product class 4, computer notebooks would not be impacted at CSL 1 

because all computer notebooks meet CSL 1 in the base case. In contrast, DIY power tools 

would face more substantial conversion costs at CSL 1 because 40 percent of all models would 

not meet this level and would need to be upgraded. Therefore, DOE assumes these applications, 

despite incorporating battery chargers that are in the same product class, would incur different 

levels of R&D and capital expenditures. 

Based on manufacturer interviews and the engineering analysis, DOE anticipates that 

new standards may result in the alteration of the external housing in the application, which would 

trigger additional design costs and expenses for new injection molds used to construct these 

housings. DOE tentatively believes these changes would most likely occur in those applications 

incorporating battery chargers that require a substantial technology shift to meet the new 

standards. DOE includes the associated housing costs in its estimates of the capital conversion 

costs and believes its methodology accounts for these changes. 

As discussed in section IV.I.2.a.iii of the EPS MIA methodology, AHAM and Cobra 

communicated concerns regarding testing and certification costs that are associated with changes 

in products due to new standards. (AHAM, No. 42 at p. 11; Cobra, No. 51 at p. 4) DOE 

summarizes and responds to these comments, which relate to battery chargers as well as EPSs, in 

section IV.I.2.a.iii. 

PTI also noted that manufacturers will encounter “stranded costs” when forced to retire 

tooling before the end of its service life, resulting in unused inventory. Stranded costs are capital 

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assets that are not yet fully depreciated, but are made obsolete by a new or amended energy 

conservation standard. (PTI, No. 47 at p. 13) 

DOE agrees with PTI that energy conservation standards could strand tooling before the 

end of its useful life. DOE has estimated these costs as part of stranded assets, which are treated 

as a non-cash expense in the compliance year of the standard. 

PTI asserted that the resources that manufacturers would ordinarily devote to new 

product development, which drives much of the power tool industry, would be reduced in order 

to meet any new regulations. (PTI, No. 47 at p. 13) 

DOE understands there are opportunity costs related to any investment and that 

manufacturers may face difficult decisions in selecting non-energy related product development 

projects when faced with the prospect of standards-induced resource allocation. DOE notes that 

the GRIM analysis accounts for both ordinary, ongoing research and development efforts, as 

well as those prompted by new energy standards. DOE weighs these impacts when deciding the 

most appropriate TSL for the proposed standard. 

PTI stated that the power tool industry is somewhat unique because a significant 

proportion of its members’ product offerings revolve around detachable pack battery systems. 

Achieving higher CSLs depends on fulfilling certain technical changes that would require 

redesigning the entire battery charger, including the battery pack. According to PTI, this situation 

would disrupt the market because manufacturers would be required to abandon these legacy 

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systems and strand a large installed base of consumers with unsupported systems. For example, 

in product class 4, PTI argued that CSL 2 would require nickel-based systems to switch to Liion, which would most likely require a complete redesign of the system that is unlikely to be 

backward compatible with existing tools. (PTI, No. 47 at p. 12) 

DOE agrees it would take a substantial research and development effort to redesign 

nickel-based systems to Li-ion. For power tools, the backward compatibility issues described by 

PTI arise from designing the entire battery chargers (including the battery pack) for power tool 

applications. Based on its engineering analysis, DOE tentatively believes that the technical 

challenges to achieving backward compatibility could be met at CSL 2 in the context of a 

complete redesign. DOE has accounted for the additional engineering costs in the MIA. 

v. Battery Charger Standards-Case Shipments 

The base-case efficiency distribution and growth rate drive total industry revenue in the 

base case. As with EPS shipments, the standards case assumes that manufacturers will respond to 

standards by improving those products that do not meet the new standards to meet, but not 

exceed, the standard level. Products that are already as efficient as, or more efficient than, the 

standard level would remain unaffected under this approach. This is referred to as a “roll-up” 

scenario. DOE did not consider elasticity or substitution away from battery chargers in the 

standards case in the main NIA scenario. However, this was considered as a sensitivity analysis 

which is included as an appendix in chapter 12 of the NOPR TSD. 

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vi. Battery Charger Markup Scenarios 

The revenue DOE calculates for the battery charger GRIM is the revenue generated from 

the sale of the application that incorporates the covered battery charger. It is the revenue earned 

on the sale of the product to the OEM’s first customer (e.g., the retailer). After calculating the 

average retail price from the product price survey as discussed above, DOE discounted the price 

by the appropriate retailer markup (calculated in the market and technology assessment) to 

calculate the per-unit revenue the OEM generates for each application. To calculate the potential 

impacts on manufacturer profitability in the standards case, DOE analyzed how the incremental 

costs of more efficient battery chargers would impact this revenue stream on an application-byapplication basis. 

In comments, manufacturers raised concerns about higher battery charger input costs 

resulting in reduced profit margins. PTI stated that many manufacturers only sell through 

retailers and have “price points” that they must hit, particularly in the “do-it-yourself” (DIY) 

market. Although the cost to produce the product may change with more efficient battery 

chargers, in its view, there would be no change in price for the consumer. Faced with higher 

product costs, PTI asserted that manufacturers will have to reduce gross margin or ultimately 

reduce the utility of the product. (PTI, No. 47 at p. 12) Lester also expressed concerns about 

increased costs to produce golf cars, which will either be passed along to purchasers or result in 

reduced profit margins for the manufacturers. (Lester, No. 52 at p. 1) 

DOE acknowledges that new or amended standards have the potential to increase product 

prices and disrupt manufacturer profitability, particularly as the market transitions to meet a new 

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energy conservation standard. Based on the comments from interested parties and DOE’s 

manufacturer interviews, there is a great deal of uncertainty regarding how the markets for such a 

wide variety of applications will adjust, both in the near term and long term. To account for this 

uncertainty, DOE analyzes three profitability, or markup, scenarios in the GRIM: the “constant 

price,” “pass through,” and “flat markup” scenarios. 

The constant price scenario analyzes the situation in which manufacturers of applications 

are unable to pass on any incremental costs of more efficient battery chargers to their customers. 

This scenario is reflective of some manufacturers’ description of the negotiating power of large 

retailers, who account for the vast majority of shipments of some applications. Manufacturers 

believe these large retailers would be unwilling to accept any price increases. This scenario 

results in the most significant negative impacts because no incremental costs added to the 

application—either because of higher battery charger component costs or because of investments 

in tooling and design—can be recouped. As a result, manufacturer gross margins decline as costof-goods-sold increase, on a dollar-for-dollar basis. The higher the incremental cost of the 

battery charger with respect to the total application price, the greater the impacts on the 

manufacturer. For example, the impact of an incremental $2.00 increase in the cost of the battery 

charger is much greater on a product that sells for $50 than on a product that retails for $500. 

For some applications in certain product classes, the max-tech battery charger price is 

nearly as expensive as the total base case application price itself. Under the constant price 

scenario, such circumstances can yield highly negative results, which are not meaningful 

because, in reality, producers would not continue to produce at prices that did not cover variable 

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costs. If prices fell below the level necessary to cover variable costs, a firm would be better off 

not producing anything at all. Therefore, DOE applies a boundary condition in the constant price 

scenario, which assumes that as battery charger costs increase, application prices remain constant 

(and gross margin would continue to decline) only until manufacturers cease to cover their 

variable costs (where gross margin is zero). At that point, DOE assumes manufacturers can pass 

on any further incremental costs of the battery charger on a dollar-for-dollar basis to their 

customers. 

In the pass through scenario, DOE assumes that manufacturers are able to pass through 

the incremental costs of more efficient battery chargers to their customers, but without earning 

any additional operating profit on those higher costs. Therefore, though less severe than the 

constant price scenario in which manufacturers absorb all incremental costs, this scenario also 

results in margin compression and adverse financial impacts as battery charger costs increase. 

Lastly, DOE considers a flat markup scenario to analyze the upper bound (most positive) 

of profitability impacts following the compliance date of new standards. In this scenario, 

manufacturers are able to maintain their base case gross margin as a percentage of revenue at 

higher CSLs despite higher product costs of more efficient battery chargers. In other words, 

manufacturers are able to pass on, and fully mark up, the higher incremental product costs due to 

more efficient battery chargers. This scenario is a more likely outcome for high-value, 

differentiated products, for which energy efficiency indirectly drives customer-valued benefits 

such as lighter weight and greater transportability. For other applications, particularly low-cost 

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products for which energy efficiency is not an important selling attribute, the scenario is less 

likely. 

In summary, DOE believes these three scenarios present the potential range of 

profitability impacts on OEM application manufacturers. 

b. Battery Charger Comments from Interested Parties 

The following section discusses interested parties’ comments on the preliminary analyses 

that impact the battery charger MIA methodology. In general, DOE provides background on an 

issue that was raised by interested parties, summarizes the interested parties’ comments, and 

responds to those comments. 

i. Compliance Date and Implementation Period 

Many manufacturers commented on the implementation timeline of a new standard. For 

example, with respect to medical devices, Philips noted that the development life cycle is at least 

two to four years. Philips also mentioned that the regulatory approval cycle for medical products 

is longer than for consumer grade products, suggesting that medical devices should either be 

exempt or be given a longer transition time. (Philips, No. 43 at p. 3) 

Lester expressed similar concerns, noting that the proposed timelines are not reasonable 

for large, integrated vehicle manufacturers. It added that properly designing, testing, and ramping 

up production of a battery charging system commonly exceeds three years. Furthermore, Lester 

stated that an insufficient timeline could lead manufacturers to utilize components that have not 

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been designed or tested properly. Additionally, a premature compliance date could cause product 

shortages, defects, increased costs, and unplanned capital expenditures that will either be passed 

on to purchasers or result in reduced profits. Lester suggested a timeline extension to five years. 

(Lester, No. 52 at p. 1, 2) Similarly, Cobra stated that two years will not be enough time to 

comply if DOE sets the standard level near max tech. (Cobra, No. 51 at p. 2) 

AHAM commented that the effective date should be two years after the final rule for 

small appliance battery charger products, but noted a longer time period might be necessary for 

some other product groups. AHAM argued that an earlier effective date would facilitate 

consistency across all 50 states. However, AHAM also mentioned that DOE must factor in 

additional time due to new requirements for third-party testing. (AHAM, No. 44 at p. 3, 11) 

Lastly, AHAM pointed out that the time needed depends significantly upon which standard level 

DOE chooses, as well as whether products are treated as both EPSs and battery chargers. 

(AHAM, Pub. Mtg. Tr., No. 37 at p. 373, 374) 

EISA 2007 prescribed a two-year period between the issuance of the final rule for Class 

A EPSs and the compliance date of the amended energy conservation standard. See 42 U.S.C. 

6295(u)(3)(D). Congress did not grant DOE with the specific authority to change this date for 

individual product classes falling within Class A as requested by Philips, Lester, and AHAM. 

However, DOE notes that Congress did not impose a specific compliance date timeline for 

battery chargers and newly covered non-Class A EPSs. For these products, DOE has tentatively 

concluded that the two-year window between the announcement of the final rule and compliance 

with rule is sufficient for manufacturers to meet the TSLs analyzed in today’s rule. As the 

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comments suggest, depending on the resources available to a given manufacturer, their 

technological starting point, and the proposed CSL, the typical product design cycle will vary 

significantly. As such, some manufacturers will likely have to dedicate more resources than 

others to upgrade some or all of their product lines. DOE notes, however, that designs achieving 

the levels proposed in today’s NOPR are currently on the market for all product classes except 

battery charger product class 10. For all of these product classes, the TSLs proposed are below 

the max-tech level and either represent the best-in-market efficiency or a lower level. For battery 

charger product class 10, however, DOE is proposing the max-tech level based on information 

derived from manufacturer input. Therefore, DOE has tentatively concluded that the 

technologies required to reach the efficiencies proposed in today’s rule are achievable within two 

years. 

DOE requests comment on what an appropriate compliance date for battery chargers and 

non-Class A EPSs would be, including whether a two-year lead time would be reasonable. DOE 

may decide to adjust the compliance date for these products depending on the nature of the 

information it receives on this issue. 

With respect to unplanned capital expenditures, DOE agrees that standards may require 

changes to tooling and equipment, as well as incremental engineering efforts. Ultimately, 

whether any manufacturer chooses to allocate the resources necessary to upgrade some or all of 

their product lines, or to source some or all of them, is a business decision. Regardless of these 

decisions, DOE accounts for the conversion costs for manufacturers to upgrade all their noncompliant products to comply with each TSL. DOE considers the results of this analysis in 

262 
weighing the projected benefits and burdens associated with the rule. See section 0 for that 

determination. 

ii. Cumulative Regulatory Burden 

Several manufacturers expressed concerns about other regulations that affect battery 

chargers. Three potential regulations are the U.S. Department of Transportation’s regulation of 

the packaging and transportation of Li-ion cells in both end-products and in cell configurations, 

see 75 FR 1302 (Jan. 11, 2010), the future series of regulations on battery chargers from the 

European Union, (Commission Regulation (EC) No 278/2009 of 6 April 2009), and the 

California battery charger standard set by CEC (Docket # 11-AAER-2). (AHAM, No. 44 at p. 

11, 15) 

For the cumulative regulatory burden, DOE attempts to quantify and/or describe the 

impacts of other Federal regulations that have a compliance date within three years of the 

compliance date of this rulemaking. This analysis does not include the Department of 

Transportation’s proposal to regulate the packaging and transportation of lithium ion cells given 

that no requirements are yet in place and any analysis attempting to account for what these 

requirements might be would be speculative. DOE does acknowledge that EU regulations on 

battery chargers would be an overlapping regulatory burden on manufacturers, if the EU decides 

to regulate battery chargers in the future, because identical products are sold throughout the 

world. At this time the EU has specifically excluded battery chargers from their regulations but 

will consider in the future to expand the scope of the regulation to include battery chargers (see 

the adopted draft regulation of EC No 278/2009, 17 October 2008, p. 10). DOE does not include 

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the costs to comply with future regulations in the EU because they are outside the scope of the 

cumulative regulatory burden, which focuses on Federal regulations. However, DOE did 

quantitatively assess the impacts of the CEC battery charger standard on battery charger 

manufacturers in section V.B.2.e of this NOPR. 

iii. Employment 

Lester expressed concerns about losing domestic manufacturing jobs to low-cost 

countries as a result of implementing the new standard. The company stated that because switchmode battery charger assembly is more labor intensive than other designs, it expects standards 

requiring switch-mode designs to accelerate the trend towards offshore manufacturing. Lester 

added that DOE should prioritize the impact to manufacturing in the U.S. among other criteria in 

determining which standards to adopt. According to Lester, battery chargers for applications that 

use transformer-based battery chargers, which are typically used in high-energy applications, 

tend to correlate with requirements for longer life, greater durability, and higher reliability. 

(Lester, No. 52 at p. 3) 

While the vast majority of applications using EPSs and battery chargers are manufactured 

overseas, DOE agrees that new or amended standards could adversely impact domestic 

employment for companies currently producing covered products in the United States. This is 

especially a concern for the golf car industry because battery chargers for this application still 

have a significant U.S. manufacturing presence. Any manufacturers that would be forced to 

develop a new technology to meet new standards, especially one that is more labor intensive, 

would face significant economic pressures to move operations overseas or source products 

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directly from overseas third-party suppliers. DOE’s direct employment analysis (see section 

V.B.2.b) discusses the preliminary estimates for the impacts on changes in employment at the 

analyzed TSLs. 

In selecting the TSLs proposed in today’s notice, the Secretary considers a variety of 

factors to weigh the overall benefits and burdens of the rule, including, as Lester notes, the 

impact on United States manufacturing. DOE also notes that the impacts on small businesses are 

treated directly in the Regulatory Flexibility Analysis in section VI.B. 

iv. Supply Chain 

Lester expressed concerns over the potential for supply chain disruptions, noting that as 

production of chargers is moved to lower-cost countries, manufacturers of electric vehicles will 

face logistical risks that are less likely to occur domestically. (Lester, No. 52 at p. 2) 

DOE agrees that overseas manufacturing can complicate the supply chain of firms that 

elect to move production offshore. However, such a strategy is a business decision and not one 

that is required to meet the TSLs analyzed in today’s rulemaking. DOE also notes that the vast 

majority of all battery chargers on the market already make use of global supply chains. 

4. Comments from Interested Parties Related to EPSs and Battery Chargers 

The following section discusses interested parties’ comments on the preliminary analyses 

that impact the both the EPS and battery charger MIA methodology. This section provides 

265 
background on specific issues raised by interested parties, summarizes the relevant comments, 

and discusses DOE’s response. 

a. Cumulative Burden 

AHAM expressed concern about the possibility of DOE applying CEC’s Tier 2 EPS 

standards which, it asserts, are wrongly applied to the wall adapters of battery chargers. (AHAM, 

No. 44 at p. 15) PTI added that DOE should consider the cumulative regulatory burden that 

would be imposed if the CEC were to regulate the power factor of battery chargers. This would 

increase the costs of achieving higher efficiencies. (PTI, No. 47 at p. 11) 

With respect to the CEC standards, DOE notes that the proposed EPS standards in 

today’s NOPR would preempt state regulations on EPS efficiencies. As for potential power 

factor regulation, DOE has included a quantitative analysis of the CEC standard on battery 

charger manufacturers in section V.B.2.e. 

Similarly, Philips expressed concerns about FDA regulations on medical products, which 

can delay the time-to-market from a few weeks to many months. Philips also noted that the EU 

Directive on the Restriction of Hazardous Substances (RoHS) proposed a minimum of six years 

for medical device manufacturers to reach compliance, which reflects a longer product design 

cycle and regulatory approval process. (Philips, No. 43 at p. 3) 

DOE acknowledges that the EU RoHS proposed a minimum of six years for medical 

device manufacturers to comply with the directive. However, EU’s RoHS regulations have the 

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potential to affect the entire medical application, while the DOE energy conservation standards at 

issue here cover only the battery charger or EPS portion of the device. DOE does not include the 

costs to comply with future regulations in the EU as part of the cumulative regulatory burden 

because they are outside its scope, which focuses on U.S. regulations. DOE notes that it has the 

authority to set a compliance period for non-Class A EPSs and battery chargers that varies from 

the two-year lag between the issuance of the final rule and the compliance date of the standard 

prescribed in EISA for Class A EPSs. However, DOE has consulted with the FDA and does not 

believe that this extension for non-Class A EPSs is necessary. This situation is described in detail 

in chapter 3 of the TSD. DOE also does not believe there are technical differences between 

medical EPSs and non-medical EPSs that would affect the ability of manufacturers to improve 

the efficiency of medical EPSs. However, DOE requests further comment on the appropriateness 

of the proposed compliance date for non-Class A EPS and battery charger product classes and if 

there are any specific medical applications that would be adversely affected by a 2013 date that 

mirrors the statutorily-prescribed compliance date for Class A EPSs. 

Cobra commented on the significant burden facing small manufacturers from recent 

regulatory actions including EISA 2007, the Consumer Product Safety Improvement Act of 2008 

(CPSIA 2008), California’s Safe Drinking Water and Toxic Enforcement Act of 1986 

(Proposition 65), Mercury-Containing and Rechargeable Battery Management Act, recycling 

regulations, and EU’s RoHS. Cobra contended that these regulations challenge its ability to 

compete against larger companies while spending resources to prove compliance with all 

established regulations. Cobra also mentioned that while it does not manufacture products that 

267 
are covered under CPSIA 2008, it asserted that it needs to demonstrate to customers that its 

products can still satisfy those requirements for marketing purposes. (Cobra, No. 53 at pp. 1, 2) 

DOE agrees that maintaining compliance with the various standards may be a challenge 

for manufacturers, especially smaller manufacturers. Furthermore, DOE understands that 

because products with EPSs and battery chargers are sold globally, the design of these products 

are more harmonized than for other appliances. DOE has analyzed the cost to comply with the 

EISA requirements in this rulemaking. DOE also further describes the recycling requirements 

and RoHS in chapter 12 of the TSD. DOE has also attempted to quantify these costs where 

applicable. 

b. Competition 

AHAM asked DOE to evaluate the potential for a reduction in competition, in the event 

standards cause manufacturers of low-cost products to leave the market. (AHAM, Pub. Mtg. Tr., 

No. , No. 37 at p. 144) 

EPCA directs DOE to consider any lessening of competition likely to result from 

standards. It directs the Attorney General to determine the impact, if any, of any lessening of 

competition likely to result from a proposed standard and to transmit such determination to the 

Secretary, not later than 60 days after the publication of a proposed rule, together with an 

analysis of the nature and extent of such impact. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) 

DOE will transmit a copy of today’s proposed rule to the Attorney General and request that the 

U.S. Department of Justice (DOJ) provide its determination on this issue. DOE will publish and 

268 
address the Attorney General’s determination in the final rule, if any, and will pay particular 

attention to any potential competitive impacts in that determination. 

At this time, DOE does not believe there is significant potential for a reduction in 

competition due to the standards proposed in this rule. Particularly for some of the low-cost 

products, there are relatively few barriers to entry and the TSLs proposed in today’s rule do not 

require use of patented technology. Technology that can be used exclusively by one 

manufacturer does not pass the screening analysis. 

However, given the wide array of applications that incorporate covered EPSs and battery 

chargers, DOE seeks comment on which specific markets, if any, exhibit the potential for a 

reduction in competition. 

5. Manufacturer Interviews 

DOE conducted additional interviews with manufacturers following the preliminary 

analysis in preparation for the NOPR analysis. In these interviews, DOE asked manufacturers to 

describe their major concerns with this rulemaking. The following section describes the key 

issues identified by manufacturers during these interviews. 

a. Product Groupings 

Several manufacturers expressed concern over the approach DOE outlined in which a 

variety of different applications would be grouped together within the same product class and 

would have to meet equivalent standards. EPS and battery charger product classes are defined by 

269 
characteristics such as type of current conversion, voltage, and output power. However, the 

proposed EPS and battery charger product classes do not necessarily group applications 

performing similar end-use functions. Manufacturers stated that grouping applications that 

consume a larger amount of electricity over their lifetime with applications that consume only a 

fraction of electricity over their lifetime can put the applications that are used less frequently at 

an unfair disadvantage. 

Manufacturers were particularly concerned about the potential for groupings to impact 

specific battery charger applications after finalizing the standard. For battery chargers, DOE is 

proposing standards using one UEC equation for each product class. Specific applications can be 

grouped into a product class whose individual usage profile differs from the usual profile of the 

product class. This is especially true if the shipments of one application are significantly greater 

than the shipments of another application with a very different usage profile (i.e., the millions of 

laptop shipments versus DIY power tools). Both laptops and DIY power tools would be 

regulated using the same usage profile parameters to satisfy a given energy conservation 

standard. Therefore, there is less potential for consumers to save energy cost effectively with 

respect to those applications that are not used frequently compared to applications that are used 

continuously even though both applications would be required to meet the same standard. 

DOE recognizes manufacturer concerns over how specific applications are grouped 

together as a result of the proposed division of product classes. DOE’s LCC analysis and 

manufacturing impact analysis evaluate the impacts on users and manufacturers, respectively, on 

a applications-specific basis. Although the UEC is established at the product class level, the 

270 
granularity of these analyses enables DOE to consider the benefits and burdens on users and 

manufacturers of specific applications, and take those results into consideration in determining 

which TSLs to select. 

b. Competition from Substitutes 

Manufacturers have stated that several of their applications compete directly with 

applications using other forms of energy, such as products powered by gasoline, disposable 

alkaline batteries, or corded products. Products that use battery chargers must remain cost 

competitive with these alternatively powered products because these products are close 

substitutes. Manufacturers of lawn care products, such as mowers and trimmers, and mobility 

units, such as motorized bikes and golf cars, are competing in the same markets as gas-powered 

versions of these applications. Similarly, manufacturers of smaller electronic devices, such as 

digital cameras, are competing in the same market as disposable alkaline battery-powered digital 

cameras. Several applications also have direct competition with similar non-electric applications, 

such as electric toothbrushes and DIY power tools. Having products powered by a rechargeable 

battery is a feature that adds value for consumers. A significant increase in the cost of 

manufacturing the battery charger could lead manufacturers to remove the rechargeable feature 

of an application or choose an alternative method to power the device, ultimately reducing the 

consumer utility for these applications. If energy conservation standards lead to a significant 

price increase, consumers could switch to these alternatives. 

271 
Based on these concerns, DOE considered the impact of price elasticity on application 

shipment volumes. These price elasticity sensitivity results are presented in Appendix 12-B of 

the TSD. 

c. Test Procedure Concerns 

While most manufacturers agree that using the UEC is an appropriate test procedure 

metric for battery chargers, some battery charger manufacturers stated there is a problem of 

separating the battery charging function of an application from the other functions being 

performed by the application. In their view, it is not easy to isolate the battery charging portion 

of the application for testing and/or creating cost-efficiency curves. Manufacturers stated that the 

test procedure must clearly separate out the charging portion of the energy consumption in order 

to regulate its efficiency accurately. DOE specifically took this factor into consideration for UPS 

manufacturers and explains its approach in detail in section IV.C.2.i of this NOPR. 

d. Multiple Regulation of EPSs and Battery Chargers 

Manufacturers raised concerns that specific applications that are shipped with both an 

EPS and a battery charger would be subject to regulations for both components - one energy 

conservation standard for the EPS and a separate energy conservation standard for the battery 

charger of the same application. Having to meet two separate standards may not allow the 

manufacturers to maximize the efficiency of both the EPS and the battery charger together and 

could add to the overall cost of the application. DOE took these comments into consideration but 

has tentatively determined that establishing standards for each product was the most appropriate 

272 
action given the statutory requirements to set standards for these products. For further detail and 

DOE’s rationale for this decision, see section IV.A.1 of this NOPR. 

e. Profitability Impacts 

Several manufacturers stated that they expect energy conservation standards to negatively 

impact the profitability of battery chargers. At higher CSLs, standards could increase MPCs and 

manufacturers believed these higher costs would not necessarily be passed on to consumers. 

Several applications use specific price points that consumers expect those applications to have. 

Consequently, manufacturers believe that cost increases would be at least partly absorbed by 

manufacturers to keep retail prices from rising sharply. 

The battery charger often represents a significant portion of the overall cost of the 

application. Any increase in the cost of the battery charger would have a significant impact on 

the cost of these applications as a whole. If energy conservation standards led to a significant 

reduction in profitability, some manufacturers could potentially exit the market and reduce the 

number of competitors. Additionally, many electronic applications are considered luxury items 

so consumers could also chose to forgo their purchases altogether if the application prices 

increased substantially. 

As discussed in section IV.I.2.a and IV.I.3.a of this NOPR, DOE evaluates a range of 

profitability scenarios in the MIA that take these specific concerns into account. These sections 

and Chapter 12 of the TSD discuss the results and details of those analyses. 

273 
f. Potential Changes to Product Utility 

Manufacturers believe adverse impacts from new and amended standards could also 

indirectly affect product utility. Several manufacturers indicated that other features that do not 

affect efficiency could be removed or component quality could be sacrificed to meet new and 

amended standard levels and maintain current application prices. Manufacturers also stated that 

the financial burden of developing products to meet new and amended energy conservation 

standards has an opportunity cost due to limited capital and R&D dollars. Investments incurred 

to meet new and amended energy conservation standards reflect foregone investments in 

innovation and the development of new features that consumers value and on which 

manufacturers earn higher absolute profit. 

DOE’s engineering analysis only analyzes utility-neutral design changes to meet higher 

efficiency standards and accounts for the costs incurred to achieve those levels. While there may 

be cheaper ways to meet a given efficiency level by reducing other features that provide utility, 

those design paths are not assumed in DOE’s analyses. DOE recognizes the opportunity cost of 

standards-induced investment and accounts for the conversion expenditures manufacturers may 

incur at each TSL, as discussed in section IV.I.3.a.iv. Whether a given manufacturer chooses to 

mitigate these costs (and the associated product costs illustrated in the engineering analysis’ costefficiency curves) by reducing product utility is a business decision and not one mandated by the 

proposed energy conservation standards. 

274 
 

J. Employment Impact Analysis 

DOE considers employment impacts in the domestic economy as one factor in selecting a 

proposed standard. Employment impacts include direct and indirect impacts. Direct employment 

impacts are changes in the number of employees of manufacturers of the products subject to 

standards, their suppliers, and related service firms. The MIA addresses the direct employment 

impacts that concern manufacturers of battery chargers and EPSs. Indirect employment impacts 

from standards consist of the jobs created or eliminated in the national economy, other than in 

the manufacturing sector being regulated, due to: (1) reduced spending by end users on energy; 

(2) reduced spending on new energy supplies by the utility industry; (3) increased spending on 

new products to which the new standards apply; and (4) the effects of those three factors 

throughout the economy. 

One method for assessing the possible effects on the demand for labor of such shifts in 

economic activity is to compare sectoral employment statistics developed by the Labor 

Department’s Bureau of Labor Statistics (BLS). The BLS regularly publishes its estimates of the 

number of jobs per million dollars of economic activity in different sectors of the economy, as 

well as the jobs created elsewhere in the economy by this same economic activity. Data from 

BLS indicate that expenditures in the utility sector generally create fewer jobs (both directly and 

indirectly) than do expenditures in other sectors of the economy.55 There are many reasons for 

these differences, including wage differences and the fact that the utility sector is more capitalintensive and less labor-intensive than other sectors. Energy conservation standards have the 

effect of reducing consumer utility bills. Because reduced consumer expenditures for energy 

55 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional Input-Output 

Modeling System (RIMS II), U.S. Department of Commerce (1992). 

275 
 

 

likely lead to increased expenditures in other sectors of the economy, the general effect of energy 

conservation standards is to shift economic activity from a less labor-intensive sector (i.e., the 

utility sector) to more labor-intensive sectors (e.g., the retail and service sectors). Thus, based on 

the BLS data alone, the Department believes net national indirect employment may increase due 

to shifts in economic activity resulting from amended standards for Class A EPSs and new 

standards for non-Class A EPSs and battery chargers. 

In developing today’s NOPR, DOE estimated indirect national employment impacts 

using an input/output (I–O) model of the U.S. economy called Impact of Sector Energy 

Technologies version 3.1.1 (ImSET).56 ImSET is a special purpose version of the “U.S. 

Benchmark National Input-Output” model, designed to estimate the national employment and 

income effects of energy-saving technologies. The ImSET software includes a computer-based 

I–O model with structural coefficients to characterize economic flows among 187 sectors most 

relevant to industrial, commercial, and residential building energy use. DOE notes that ImSET is 

not a general equilibrium forecasting model. Given the relatively small change to expenditures 

due to efficiency standards and the resulting small changes to employment, however, DOE 

believes that the size of any forecast error caused by using ImSET will be small. 

No comments were received on the preliminary TSD for battery chargers and EPSs 

concerning the employment impacts analysis. For more details on the employment impact 

analysis, see chapter 13 of the NOPR TSD. 

56 M.J. Scott, O.V. Livingston, J.M. Roop, R.W. Schultz, and P.J. Balducci, ImSET 3.1: Impact of Sector Energy 

Technologies; Model Description and User’s Guide (2009) (Available at: 

http://www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf). 

276 
K. Utility Impact Analysis 

The utility impact analysis estimates several important effects on the utility industry that 

would result from the adoption of new or amended energy conservation standards. For the NOPR 

analysis, DOE used the NEMS-BT model to generate forecasts of electricity and natural gas 

consumption, electricity generation by plant type, and electric generating capacity by plant type, 

that would result from each considered TSL. DOE obtained the energy savings inputs associated 

with efficiency improvements to the subject products from the NIA. DOE conducts the utility 

impact analysis as a scenario that departs from the latest AEO Reference case. For this NOPR, 

the estimated impacts of amended energy conservation standards are the differences between 

values forecasted by NEMS–BT and the values in the AEO2010 Reference case (which does not 

contemplate amended standards). 

As part of the utility impact analysis, DOE used NEMS-BT to assess the impacts on 

natural gas prices of the reduced demand for natural gas projected to result from the considered 

standards. DOE also used NEMS-BT to assess the impacts on electricity prices of the reduced 

need for new electric power plants and infrastructure projected to result from the considered 

standards. In NEMS-BT, changes in power generation infrastructure affect utility revenue, which 

in turn affects electricity prices. DOE estimated the change in electricity prices projected to 

result over time from each considered TSL. The benefits associated with the impacts of proposed 

standards on energy prices are discussed in section IV.G.5. 

For more details on the utility impact analysis, see chapter 14 of the NOPR TSD 

277 
L. Emissions Analysis 

In the emissions analysis, DOE estimated the reduction in power sector emissions of 

carbon dioxide (CO2), nitrogen oxides (NOx), and mercury (Hg) from amended energy 

conservation standards for Class A EPSs and new energy conservation standards for non-Class A 

EPSs and battery chargers. DOE used the NEMS-BT computer model, which is run similarly to 

the AEO NEMS, except that battery charger and EPS energy use is reduced by the amount of 

energy saved (by fuel type) due to each TSL. The inputs of national energy savings come from 

the NIA spreadsheet model, while the output is the forecasted physical emissions. The net benefit 

of each TSL in today’s proposed rule is the difference between the forecasted emissions 

estimated by NEMS-BT at each TSL and the AEO 2010 Reference Case. NEMS-BT tracks CO2 

emissions using a detailed module that provides results with broad coverage of all sectors and 

inclusion of interactive effects. For today’s NOPR, DOE used the version of NEMS-BT based on 

AEO2010, which incorporated projected effects of all emissions regulations promulgated as of 

January 31, 2010. For the final rule, DOE intends to revise the emissions analysis using the most 

current version of NEMS-BT. 

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide 

and regional emissions cap-and-trade programs, and DOE has preliminarily determined that 

these programs create uncertainty about the impact of energy conservation standards on SO2 

emissions. Title IV of the Clean Air Act sets an annual emissions cap on SO2 for affected EGUs 

in the 48 contiguous States and the District of Columbia (D.C.). SO2 emissions from 28 eastern 

states and D.C. are also limited under the Clean Air Interstate Rule (CAIR; 70 FR 25162 (May 

278 
12, 2005)), which created an allowance-based trading program. Although CAIR was remanded 

to EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit), see 

North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008), it remains in effect temporarily, 

consistent with the D.C. Circuit’s earlier opinion in North Carolina v. EPA, 531 F.3d 896 (D.C. 

Cir. 2008). On July 6, 2011 EPA issued a replacement for CAIR, the Cross-State Air Pollution 

Rule. 76 FR 48208 (August 8, 2011). (See http://www.epa.gov/crossstaterule/). On December 

30, 2011, however, the D.C. Circuit stayed the new rules while a panel of judges reviews them, 

and told EPA to continue enforcing CAIR (see EME Homer City Generation v. EPA, No. 11­

1302, Order at *2 (D.C. Cir. Dec. 30, 2011)). The AEO 2010 NEMS used for today’s NOPR 

assumes the implementation of CAIR. 

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations 

any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

imposition of an efficiency standard could be used to permit offsetting increases in SO2 

emissions by any regulated EGU. However, if the amended and new standards resulted in a 

permanent increase in the quantity of unused emissions allowances, there would be an overall 

reduction in SO2 emissions from the standards. While there remains some uncertainty about the 

ultimate effects of efficiency standards on SO2 emissions covered by the existing cap-and-trade 

system, the NEMS-BT modeling system that DOE uses to forecast emissions reductions 

currently indicates that no physical reductions in power sector emissions would occur for SO2. 

279 
As discussed above, the AEO 2010 NEMS used for today’s NOPR assumes the 

implementation of CAIR, which established a cap on NOx emissions in 28 eastern States and the 

District of Columbia. With CAIR in effect, the energy conservation standards for battery 

chargers and EPSs are expected to have little or no physical effect on NOx emissions in those 

States covered by CAIR, for the same reasons that they may have little effect on SO2 emissions. 

However, the proposed standards would be expected to reduce NOx emissions in the 22 States 

not affected by CAIR. For these 22 States, DOE is using the NEMS-BT to estimate NOx 

emissions reductions from the standards considered in today’s NOPR. 

On December 21, 2011, EPA announced national emissions standards for hazardous air 

pollutants (NESHAPs) for mercury and certain other pollutants emitted from coal and oil-fired 

EGUs. (See http://epa.gov/mats/pdfs/20111216MATSfinal.pdf). The NESHAPs do not include a 

trading program and, as such, DOE’s energy conservation standards would likely reduce Hg 

emissions. For the emissions analysis for this rulemaking, DOE estimated mercury emissions 

reductions using NEMS-BT based on AEO2010, which does not incorporate the NESHAPs. 

DOE expects that future versions of the NEMS-BT model will reflect the implementation of the 

NESHAPs. 

For more details on the emissions analysis, see chapter 15 of the NOPR TSD. 

M. Monetizing Carbon Dioxide and Other Emissions Impacts 

As part of the development of this proposed rule, DOE considered the estimated 

monetary benefits likely to result from the reduced emissions of CO2 and NOX that are expected 

280 
 

 

to result from each of the TSLs considered. In order to make this calculation similar to the 

calculation of the NPV of consumer benefit, DOE considered the reduced emissions expected to 

result over the lifetime of products shipped in the forecast period for each TSL. This section 

summarizes the basis for the monetary values used for each of these emissions and presents 

values considered in this rulemaking. 

For today’s NOPR, DOE is relying on a set of values for the social cost of carbon (SCC) 

that was developed by an interagency process. A summary of the basis for these values is 

provided below, and a more detailed description of the methodologies used is provided as an 

appendix to chapter 16 of the TSD. 

1. Social Cost of Carbon 

Under section 1(b) of Executive Order 12866, agencies must, to the extent permitted by 

law, “assess both the costs and the benefits of the intended regulation and, recognizing that some 

costs and benefits are difficult to quantify, propose or adopt a regulation only upon a reasoned 

determination that the benefits of the intended regulation justify its costs.” The purpose of the 

SCC estimates presented here is to allow agencies to incorporate the monetized social benefits of 

reducing CO2 emissions into cost-benefit analyses of regulatory actions that have small, or 

“marginal,” impacts on cumulative global emissions. The estimates are presented with an 

acknowledgement of the many uncertainties involved and with a clear understanding that they 

should be updated over time to reflect increasing knowledge of the science and economics of 

climate impacts. 

281 
 

 

As part of the interagency process that developed these SCC estimates, technical experts 

from numerous agencies met on a regular basis to consider public comments, explore the 

technical literature in relevant fields, and discuss key model inputs and assumptions. The main 

objective of this process was to develop a range of SCC values using a defensible set of input 

assumptions grounded in the existing scientific and economic literatures. In this way, key 

uncertainties and model differences transparently and consistently inform the range of SCC 

estimates used in the rulemaking process. 

a. Monetizing Carbon Dioxide Emissions 

The SCC is an estimate of the monetized damages associated with an incremental 

increase in carbon emissions in a given year. It is intended to include (but is not limited to) 

changes in net agricultural productivity, human health, property damages from increased flood 

risk, and the value of ecosystem services. Estimates of the SCC are provided in dollars per metric 

ton of carbon dioxide. 

When attempting to assess the incremental economic impacts of carbon dioxide 

emissions, the analyst faces a number of serious challenges. A recent report from the National 

Research Council57 points out that any assessment will suffer from uncertainty, speculation, and 

lack of information about (1) future emissions of greenhouse gases, (2) the effects of past and 

future emissions on the climate system, (3) the impact of changes in climate on the physical and 

biological environment, and (4) the translation of these environmental impacts into economic 

57 National Research Council. Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use. 

National Academies Press: Washington, DC (2009). 

282 
damages. As a result, any effort to quantify and monetize the harms associated with climate 

change will raise serious questions of science, economics, and ethics and should be viewed as 

provisional. 

Despite the serious limits of both quantification and monetization, SCC estimates can be 

useful in estimating the social benefits of reducing carbon dioxide emissions. Consistent with the 

directive in Executive Order 12866 quoted above, the purpose of the SCC estimates presented 

here is to make it possible for Federal agencies to incorporate the social benefits from reducing 

carbon dioxide emissions into cost-benefit analyses of regulatory actions that have small, or 

“marginal,” impacts on cumulative global emissions. Most Federal regulatory actions can be 

expected to have marginal impacts on global emissions. 

For such policies, the agency can estimate the benefits from reduced (or costs from 

increased) emissions in any future year by multiplying the change in emissions in that year by 

the SCC value appropriate for that year. The net present value of the benefits can then be 

calculated by multiplying each of these future benefits by an appropriate discount factor and 

summing across all affected years. This approach assumes that the marginal damages from 

increased emissions are constant for small departures from the baseline emissions path, an 

approximation that is reasonable for policies that have effects on emissions that are small relative 

to cumulative global carbon dioxide emissions. For policies that have a large (non-marginal) 

impact on global cumulative emissions, there is a separate question of whether the SCC is an 

appropriate tool for calculating the benefits of reduced emissions. This concern is not applicable 

to this notice, and DOE does not attempt to answer that question here. 

283 
 

 

 

At the time of the preparation of this notice, the most recent interagency estimates of the 

potential global benefits resulting from reduced CO2 emissions in 2010, expressed in 2010$, 

were $4.9, $22.3, $36.5, and $67.6 per metric ton avoided. For emissions reductions that occur in 

later years, these values grow in real terms over time. Additionally, the interagency group 

determined that a range of values from 7 percent to 23 percent should be used to adjust the global 

SCC to calculate domestic effects,58 although preference is given to consideration of the global 

benefits of reducing CO2 emissions. 

It is important to emphasize that the interagency process is committed to updating these 

estimates as the science and economic understanding of climate change and its impacts on 

society improves over time. Specifically, the interagency group has set a preliminary goal of 

revisiting the SCC values within 2 years or at such time as substantially updated models become 

available, and to continue to support research in this area. In the meantime, the interagency group 

will continue to explore the issues raised by this analysis and consider public comments as part 

of the ongoing interagency process. 

b. Social Cost of Carbon Values Used in Past Regulatory Analyses 

To date, economic analyses for Federal regulations have used a wide range of values to 

estimate the benefits associated with reducing carbon dioxide emissions. In the final model year 

2011 CAFE rule, the U.S. Department of Transportation (DOT) used both a “domestic” SCC 

58 It is recognized that this calculation for domestic values is approximate, provisional, and highly speculative. There 

is no a priori reason why domestic benefits should be a constant fraction of net global damages over time. 

284 
 

value of $2 per ton of CO2 and a “global” SCC value of $33 per ton of CO2 for 2007 emission 

reductions (in 2007$), increasing both values at 2.4 percent per year.59 DOT also included a 

sensitivity analysis at $80 per ton of CO2. See Average Fuel Economy Standards Passenger Cars 

and Light Trucks Model Year 2011, 74 FR 14196 (March 30, 2009) (Final Rule); Final 

Environmental Impact Statement Corporate Average Fuel Economy Standards, Passenger Cars 

and Light Trucks, Model Years 2011-2015 at 3-90 (Oct. 2008) (Available at: 

http://www.nhtsa.gov/fuel-economy). A domestic SCC value is meant to reflect the value of 

damages in the United States resulting from a unit change in carbon dioxide emissions, while a 

global SCC value is meant to reflect the value of damages worldwide. 

A 2008 regulation proposed by DOT assumed a domestic SCC value of $7 per ton of CO2 

(in 2006$) for 2011 emission reductions (with a range of $0$14 for sensitivity analysis), also 

increasing at 2.4 percent per year. See Average Fuel Economy Standards, Passenger Cars and 

Light Trucks, Model Years 2011-2015, 73 FR 24352 (May 2, 2008) (Proposed Rule); Draft 

Environmental Impact Statement Corporate Average Fuel Economy Standards, Passenger Cars 

and Light Trucks, Model Years 2011-2015 at 3-58 (June 2008) (Available at: 

http://www.nhtsa.gov/fuel-economy). A regulation for packaged terminal air conditioners and 

packaged terminal heat pumps finalized by DOE in October of 2008 used a domestic SCC range 

of $0 to $20 per ton CO2 for 2007 emission reductions (in 2007$).73 FR 58772, 58814 (Oct. 7, 

2008) In addition, EPA’s 2008 Advance Notice of Proposed Rulemaking on Regulating 

Greenhouse Gas Emissions Under the Clean Air Act identified what it described as “very 

preliminary” SCC estimates subject to revision. 73 FR 44354 (July 30, 2008). EPA’s global 

59 Throughout this section, references to tons of CO2 refer to metric tons. 

285 
mean values were $68 and $40 per ton CO2 for discount rates of approximately 2 percent and 3 

percent, respectively (in 2006$ for 2007 emissions). 

In 2009, an interagency process was initiated to offer a preliminary assessment of how 

best to quantify the benefits from reducing carbon dioxide emissions. To ensure consistency in 

how benefits are evaluated across agencies, the Administration sought to develop a transparent 

and defensible method, specifically designed for the rulemaking process, to quantify avoided 

climate change damages from reduced CO2 emissions. The interagency group did not undertake 

any original analysis. Instead, it combined SCC estimates from the existing literature to use as 

interim values until a more comprehensive analysis could be conducted. The outcome of the 

preliminary assessment by the interagency group was a set of five interim values: global SCC 

estimates for 2007 (in 2006$) of $55, $33, $19, $10, and $5 per ton of CO2. 

These interim values represent the first sustained interagency effort within the U.S. 

government to develop an SCC for use in regulatory analysis. The results of this preliminary 

effort were presented in several proposed and final rules and were offered for public comment in 

connection with proposed rules, including the joint EPA-DOT fuel economy and CO2 tailpipe 

emission proposed rules. 

c. Current Approach and Key Assumptions 

Since the release of the interim values, the interagency group reconvened on a regular 

basis to generate improved SCC estimates, which were considered for this proposed rule. 

286 
 

Specifically, the group considered public comments and further explored the technical literature 

in relevant fields. The interagency group relied on three integrated assessment models (IAMs) 

commonly used to estimate the SCC: the FUND, DICE, and PAGE models.60 These models are 

frequently cited in the peer-reviewed literature and were used in the last assessment of the 

Intergovernmental Panel on Climate Change. Each model was given equal weight in the SCC 

values that were developed. 

Each model takes a slightly different approach to model how changes in emissions result 

in changes in economic damages. A key objective of the interagency process was to enable a 

consistent exploration of the three models while respecting the different approaches to 

quantifying damages taken by the key modelers in the field. An extensive review of the literature 

was conducted to select three sets of input parameters for these models: climate sensitivity, 

socio-economic and emissions trajectories, and discount rates. A probability distribution for 

climate sensitivity was specified as an input into all three models. In addition, the interagency 

group used a range of scenarios for the socio-economic parameters and a range of values for the 

discount rate. All other model features were left unchanged, relying on the model developers’ 

best estimates and judgments. 

The interagency group selected four SCC values for use in regulatory analyses. Three 

values are based on the average SCC from three integrated assessment models, at discount rates 

of 2.5, 3, and 5 percent. The fourth value, which represents the 95th percentile SCC estimate 

across all three models at a 3-percent discount rate, is included to represent higher-than-expected 

60 The models are described in appendix 16-A of the TSD. 

287 
 

impacts from temperature change further out in the tails of the SCC distribution. For emissions 

(or emission reductions) that occur in later years, these values grow in real terms over time, as 

depicted in Table IV-31. 

Table IV-31 Social Cost of CO2, 2010–2050 (in 2007 dollars per metric ton) 

Discount Rate 

5% 3% 2.5% 3% 

Avg Avg Avg 95th 

2010 4.7 21.4 35.1 64.9 

2015 5.7 23.8 38.4 72.8 

2020 6.8 26.3 41.7 80.7 

2025 8.2 29.6 45.9 90.4 

2030 9.7 32.8 50.0 100.0 

2035 11.2 36.0 54.2 109.7 

2040 12.7 39.2 58.4 119.3 

2045 14.2 42.1 61.7 127.8 

2050 15.7 44.9 65.0 136.2 

It is important to recognize that a number of key uncertainties remain, and that current 

SCC estimates should be treated as provisional and revisable since they will evolve with 

improved scientific and economic understanding. The interagency group also recognizes that the 

existing models are imperfect and incomplete. The National Research Council report mentioned 

above points out that there is tension between the goal of producing quantified estimates of the 

economic damages from an incremental ton of carbon and the limits of existing efforts to model 

these effects. There are a number of concerns and problems that should be addressed by the 

research community, including research programs housed in many of the Federal agencies 

participating in the interagency process to estimate the SCC. 

288 
 

 

 

DOE recognizes the uncertainties embedded in the estimates of the SCC used for costbenefit analyses. As such, DOE and others in the U.S. Government intend to periodically review 

and reconsider those estimates to reflect increasing knowledge of the science and economics of 

climate impacts, as well as improvements in modeling. In this context, statements recognizing 

the limitations of the analysis and calling for further research take on exceptional significance. 

In summary, in considering the potential global benefits resulting from reduced CO2 

emissions, DOE used the most recent values identified by the interagency process, adjusted to 

2010$ using the GDP price deflator. For each of the four cases specified, the values used for 

emissions in 2010 were $4.9, $22.3, $36.5, and $67.6 per metric ton avoided (values expressed in 

2010$).61 To monetize the CO2 emissions reductions expected to result from amended standards 

for Class A EPSs and new standards for non-Class A EPSs and battery chargers in 2013–2042, 

DOE used the values identified in Table A1 of the “Social Cost of Carbon for Regulatory Impact 

Analysis Under Executive Order 12866,” which is reprinted in appendix 16-A of the NOPR 

TSD, appropriately adjusted to 2010$. To calculate a present value of the stream of monetary 

values, DOE discounted the values in each of the four cases using the specific discount rate that 

had been used to obtain the SCC values in each case. 

d. Valuation of Other Emissions Reductions 

DOE investigated the potential monetary benefit of reduced NOx emissions from the 

TSLs it considered. As noted above, new or amended energy conservation standards would 

reduce NOx emissions in those 22 states that are not affected by the CAIR. DOE estimated the 

61 Table A1 presents SCC values through 2050. For DOE’s calculation, it derived values after 2050 using the 3­

percent per year escalation rate used by the interagency group. 

289 
 

 

monetized value of NOx emissions reductions resulting from each of the TSLs considered for 

today’s NOPR based on environmental damage estimates found in the relevant scientific 

literature. Available estimates suggest a very wide range of monetary values, ranging from $370 

per ton to $3,800 per ton of NOx from stationary sources, measured in 2001$ (equivalent to a 

range of $450 to $4,623 per ton in 2010$).62 In accordance with OMB guidance, DOE conducted 

two calculations of the monetary benefits derived using each of the economic values used for 

NOx, one using a real discount rate of 3 percent and another using a real discount rate of 7 

percent.63 

DOE is aware of multiple agency efforts to determine the appropriate range of values used in 

evaluating the potential economic benefits of reduced Hg emissions. DOE has decided to await 

further guidance regarding consistent valuation and reporting of Hg emissions before it once 

again monetizes Hg emissions in its rulemakings. 

N. Discussion of Other Comments 

NEEP viewed the adoption of strong Federal energy conservation standards for battery 

chargers and EPSs as smart, minimal-cost mechanisms to help Northeast states achieve their 

aggressive energy savings goals. (NEEP, No. 49 at p. 3) 

Lester suggested that DOE consider establishing incentive programs for U.S. 

manufacturers as an alternative to setting efficiency standards. The company claimed that these 

62 For additional information, refer to U.S. Office of Management and Budget, Office of Information and Regulatory 

Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on 

State, Local, and Tribal Entities, Washington, DC. 

63 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 

290 
incentives would encourage the development of efficient, domestically produced products. 

(Lester, No. 50 at p. 3) DOE notes that this rulemaking constitutes an “economically significant 

regulatory action” under Executive Order (E.O.) 12866, Regulatory Planning and Review. 58 FR 

51735 (October 4, 1993) Under 10 CFR part 430, subpart C, appendix A, section III.12, DOE 

must evaluate non-regulatory alternatives to proposed standards by performing a regulatory 

impact analysis (RIA). 61 FR 36981 at p. 36978 (July 15, 1996) In this RIA, DOE compared the 

effectiveness of multiple possible alternatives to standards, including manufacturer tax credits for 

efficient battery chargers and EPSs. The results of this analysis are available in chapter 17 of the 

TSD. 

During manufacturer interviews, DOE also received questions regarding multi-voltage 

and multi-capacity battery chargers. Particularly with multi-voltage battery chargers, it is 

possible for the device to fall into more than one product class and manufacturers sought 

clarification on how to certify these devices. DOE notes that its recently promulgated test 

procedure describes the manner in which a multi-voltage or multi-capacity device must be tested. 

76 FR 31750. For these devices, manufacturers may be required to test their product more than 

once and the batteries with which the devices are used for each test may put the battery charger 

into two product classes. If that is the case, the device would need to be certified for each product 

class for which it has been tested. This approach is consistent with DOE’s approach for switchselectable EPSs and DOE tentatively believes that this approach will result in the maximum 

energy savings for its proposed standards. DOE will consider alternative approaches and requests 

feedback from manufacturers and other interested parties on this proposal and any others, such as 

certifying at just the highest or lowest capacity or voltage. 

291 
 

O. Marking Requirements 

Under 42 U.S.C. 6294(a)(5), Congress granted DOE with the specific authority to 

establish labeling or marking requirements for a number of consumer products. Among these 

products are battery chargers and EPSs. DOE notes that the creation of such marking 

requirements, particularly for a portion of the products covered by today’s proposal, was 

specifically contemplated by Congress. In particular, EISA 2007 set standards for Class A EPSs 

and created marking requirements for these products. Section 301 of that public law specified 

that all Class A EPSs shall be clearly and permanently marked in accordance with the 

"International Efficiency Marking Protocol for External Power Supplies" (the "Marking 

Protocol").64 (42 U.S.C. 6295(u)(3)(C)) 

The Marking Protocol, developed by the EPA in consultation with stakeholders both 

within and outside the United States, was originally designed in 2005 and updated in 2008 to 

meet the needs of those voluntary and regulatory programs in place at those times. In particular, 

the Marking Protocol defines efficiency mark "IV", which corresponds to the current Federal 

standard for Class A EPSs, and efficiency mark "V", which corresponds to ENERGY STAR 

version 2.0. (The ENERGY STAR program for EPSs ended on December 31, 2010.) In addition, 

these marks currently apply only to single-voltage EPSs with nameplate output power less than 

250 watts, but not to multiple-voltage or high-power EPSs. 

64 U.S. EPA, "International Efficiency Marking Protocol for External Power Supplies," October 2008, available at 

Docket No. 62. 

292 
In today's notice, DOE proposes to amend the product marking (or "labeling") 

requirements for EPSs and is considering adopting a similar requirement for battery chargers. 

Specifically, DOE proposes to (1) extend to all EPSs the marking requirement created by EISA 

2007, which currently applies only to Class A EPSs; (2) reserve an efficiency mark (or marks) in 

the Marking Protocol for standard levels in the final rule that do not already have a 

corresponding mark; and (3) require that EPSs in proposed product class N bear a specific 

marking to distinguish them from other EPSs and facilitate compliance verification. In addition, 

DOE is considering establishing a distinguishing mark for EPSs for certain security or life safety 

alarm or surveillance systems and is considering requiring that battery chargers be marked in 

accordance with a battery charger marking protocol similar to that for EPSs. DOE welcomes 

comment on all of these issues. 

DOE notes that it is proposing standards for EPSs in product classes B, C, D, and E that 

exceed efficiency level "V", the highest level currently defined in the Marking Protocol. In 

addition, it is proposing standards for multiple-voltage and high-power EPSs. DOE is working 

with EPA to revise the Marking Protocol to accommodate all of the new and amended standards 

for EPSs being proposed today. 

DOE is also proposing to create a separate product class (product class N) for EPSs that 

cannot power an end-use consumer product directly. They would be subject to less stringent 

standards than those being proposed today for their "direct operation" counterparts. To aid in 

determining whether EPSs are in compliance with standards, DOE proposes that (1) a Class A 

EPS in product class N be permanently marked with an "N" as a superscript to the circle that 

293 
contains the appropriate Roman numeral; (2) a non-Class A EPS in product class N be 

permanently marked with the abbreviation "EPS-N"; (3) an EPS in product class N that is sold 

separately from the battery charger or end-use consumer product with which it is intended to be 

used shall also be permanently marked with the manufacturer and model number of that battery 

charger or end-use consumer product; and (4) an EPS that is in product class N but, nonetheless, 

meets the relevant standard set for direct operation EPSs (and bears the appropriate Roman 

numeral) need not be marked with an "N", with "EPS-N", nor with the manufacturer and model 

number of the associated device. 

DOE seeks input on what distinguishing mark should appear on EPSs for certain security 

and life safety equipment. A recently enacted law amended EPCA to exclude these devices from 

the no-load mode efficiency standards. Pub. L. 111-360 (Jan. 4, 2011) (to be codified at 42 

U.S.C. 6295(u)(3)). The exclusion applies to AC-AC EPSs manufactured before July 1, 2017, 

that have nameplate output of 20 watts or more, are certified as being designed to be connected 

to a security or life safety alarm or surveillance system component (as defined in the law), and 

are permanently marked with a distinguishing mark for such products as established within the 

Marking Protocol. No such distinguishing mark exists within the Marking Protocol, but DOE 

intends to work with EPA and other stakeholders to establish such a mark. The mark, which 

could be the word "ACTIVE" or an "A" in a circle, for example, would likely be required to 

appear adjacent to the appropriate Roman numeral. DOE welcomes input on what mark would 

be appropriate, where it should be located, and any other details related to how that mark should 

be presented on a given device. 

294 
Lastly, EPS efficiency markings can be useful in certain circumstances to help verify 

whether a given product complies with the relevant standards. To assist in ensuring that 

compliant products can be readily identified, DOE is also considering marking requirements for 

battery chargers. NRDC submitted a comment in November 2010, after the close of the 

preliminary analysis comment period, requesting that DOE consider such a marking protocol for 

battery chargers. (NRDC, No. 56) NRDC claimed that establishing an efficiency marking 

protocol for battery chargers would have several benefits, including creating a simple vocabulary 

for all stakeholders, facilitating enforcement, lowering the cost of compliance for industry by 

facilitating international adoption, and encouraging voluntary adoption of higher levels. NRDC 

proposed using Roman numerals, as is done for EPSs. To avoid confusion, the Roman numerals 

on battery chargers would appear next to the word "BC", as shown in Table IV-32, in contrast to 

the Roman numerals on EPSs, which stand alone. NRDC's comment also includes 

recommendations on where the mark should be located. 

Consistent with this suggestion, DOE is considering adopting a marking protocol for 

battery chargers that would have "BC III" denote the battery charger standard levels adopted in 

the final rule. This marking would give other standards-setting bodies the option of defining a 

lower efficiency level ("BC II") for use on BCs sold to consumers outside the United States and 

would reserve "BC I" for products that do not meet the criteria for the other (higher) marks. A 

similar approach was used when the efficiency marking protocol for EPSs was established. The 

formulas given for each of the battery charger product classes for BC Level III match the 

standards being proposed today and could change. 

295 
Table IV-32 Proposed Efficiency Marking Protocol for Battery Chargers 

Level Description Maximum Annual Energy Consumption† 

BC I Used if no other criteria are met 

BC II Less than Level III TBD 

BC 

DOE standards 

(compliance date in 

2013) 

PC 1 3.04 

PC 2 = 0.2095(Ebatt*) + 5.87 

PC 3 

For Ebatt < 9.74 Wh, 

= 4.68 

For Ebatt ≥ 9.74 Wh, 

= 0.0933(Ebatt) + 3.77 

PC 4 

For Ebatt < 9.71 Wh, 

= 9.03 

For Ebatt ≥ 9.71 Wh, 

= 0.2411(Ebatt) + 6.69 

PC 5 

For Ebatt < 355.18 Wh, 

= 20.06 

For Ebatt ≥ 355.18 Wh, 

= 0.0219(Ebatt) + 12.28 

PC 6 

For Ebatt < 239.48 Wh 

= 30.37 

For Ebatt ≥ 239.48 Wh 

= 0.0495(Ebatt) + 18.51 

PC 7 = 0.502(Ebatt) + 4.53 

PC 8 0.66 

PC 9 See Product Class 2, 3, or 4 depending 

upon battery voltage. 

PC 10 1.50 

and higher 

BC Reserved for future use TBD 

†

 Annual energy consumption is determined using the DOE test procedure and compliance 

formulas. Ebatt stands for battery energy. 

296 
DOE is considering multiple approaches for determining where on the external housing 

of the battery charger the mark shall be placed. NRDC's proposal specifies where the mark shall 

be placed in cases where the battery charger has more than one housing, as described in Table 

IV-33. (NRDC, No. 56) DOE's concern with NRDC's proposal is the difficulty in accurately 

identifying and locating charge control in a battery charger. Alternatively, DOE could give 

manufacturers the flexibility to choose where to place the mark. DOE expects that manufacturers 

will most often choose to place the mark on a cradle or charging base, if one is present, or on the 

end-use consumer product. 

Table IV-33 Proposed Location for Battery Charger Marking 

Form Factor Location of Battery Charger Marking 

Three separate housings Charge control component 

Power supply and charge control together, 

battery separate 

Power supply & charge control component 

Charge control and battery together, power 

supply separate 

Charge control & battery component 

DOE is also considering other requirements for the battery charger mark. For example, 

DOE could require that the mark be placed on a nameplate or in an equally visible location or 

that the font size used for the mark be similar to that used for other markings on the product such 

as the UL and CE symbols. DOE is aware that the CEC also is considering establishing marking 

requirements for battery chargers and is following that process as it develops. If the CEC adopts 

marking requirements for battery chargers within the scope of today's notice, those requirements 

would be preempted by any future battery charger marking requirements adopted by DOE. 

Manufacturers would then have to transition from meeting the CEC's requirements to meeting 

DOE's requirements. Therefore, DOE would consider adopting the CEC's requirements to 

minimize the burden associated with that transition. 

297 
DOE recognizes that there are several challenges inherent in creating a marking protocol 

for battery chargers. First, it may prove difficult to specify unambiguously where the mark 

should be placed given the variety of form factors found in the marketplace. Second, in contrast 

to EPSs, some battery chargers may not have a nameplate to add a mark to. Third, in those cases 

where the mark is placed on an end-use consumer product containing a battery charger, it may be 

misinterpreted by consumers as an endorsement of that product. DOE welcomes comment on 

these issues, NRDC's proposal, and any other issues related to efficiency markings for battery 

chargers. 

P. Reporting Requirements 

For battery chargers and non-Class A external power supplies, DOE will establish 

certification, compliance, and enforcement provisions in a future rulemaking. This future 

rulemaking will outline the necessary information that manufacturers must provide in order to 

certify compliance with any energy conservation standards established by this rulemaking. 

V. Analytical Results 

The following section addresses the results from DOE’s analyses with respect to potential 

energy efficiency standards for the various product classes examined as part of this rulemaking. 

Issues discussed include the TSLs examined by DOE, the projected impacts of each of these 

levels if adopted as energy efficiency standards for battery chargers and EPSs, and the standards 

levels that DOE is tentatively proposing in today’s NOPR. Additional details regarding the 

analyses conducted by the agency are contained in the publicly available TSD supporting this 

proposal. 

298 
A. Trial Standard Levels 

DOE analyzed the benefits and burdens of multiple TSLs for the products that are the 

subject of today’s proposed rule. A description of each TSL DOE analyzed is provided below. 

DOE attempted to limit the number of TSLs considered for the NOPR by excluding efficiency 

levels that do not exhibit significantly different economic and/or engineering characteristics from 

the efficiency levels already selected as a TSL. While the NOPR presents only the results for 

those efficiency levels in TSL combinations, the TSD contains a more fulsome discussion and 

includes results for all efficiency levels that DOE examined. 

1. External Power Supply TSLs 

Table V-1 presents the TSLs for EPSs and the corresponding efficiency levels. DOE 

chose to analyze product class B directly and scale the results from the engineering analysis to 

product classes C, D, and E. As a result, the TSLs for these three product classes correspond to 

the TSLs for product class B. DOE created separate TSLs for the multiple-voltage (product class 

X) and high-power (product class H) EPSs to determine their standards. DOE did not analyze 

TSLs above the baseline CSL for product class N and instead proposes applying the baseline 

EISA 2007 standard to all EPSs in this product class, as discussed in section B below. 

Table V-1 Trial Standard Levels for External Power Supplies 

Product Class 

Trial Standard Level 

TSL 1 TSL 2 TSL 3 

DC Output, Basic-Voltage (B) CSL 2 CSL 3 CSL 4 

DC Output, Low-Voltage (C) Scaled Product Classes 

AC Output, Basic-Voltage (D) (Same CSLs as Product Class B) 

299 
AC Output, Low-Voltage (E) 

Multiple Voltage (X) CSL 1 CSL 2 CSL 3 

High-Power (H) CSL 2 CSL 3 CSL 4 

For EPS product class B, DOE examined three TSLs corresponding to each candidate 

standard level of efficiency developed in the engineering analysis. TSL 1 is an intermediate level 

of performance above ENERGY STAR, which offers the greatest consumer NPV. TSL 2 is 

equivalent to the best-in-market CSL and represents an incremental rise in energy savings over 

TSL 1. TSL 3 is the max-tech level and corresponds to the greatest NES. 

For product class X, DOE examined three TSLs above the baseline. TSL 1 is an 

intermediate level of performance above the baseline. TSL 2 is equivalent to the best-in-market 

CSL and corresponds to the maximum consumer NPV. TSL 3 is the max-tech level and 

corresponds to the greatest NES. 

For product class H, DOE examined three TSLs above the baseline. TSL 1 corresponds to 

an intermediate level of efficiency. TSL 2 is the scaled best-in-market CSL and corresponds to 

the maximum consumer NPV. TSL 3 is the scaled max-tech level, which provides the highest 

NES. 

2. Battery Charger TSLs 

Table V-2 presents the TSLs and corresponding candidate standard levels for battery 

chargers. While DOE examined most product classes individually, there were two groups of 

product classes that use generally similar technology options and cover the exact same range of 

300 
battery energies. Because of this situation, DOE grouped all three low-energy, non-inductive, 

product classes (i.e. 2, 3, and 4) together and examined the results. Similarly, DOE grouped the 

two medium energy product classes, product classes 5 and 6, together when it examined those 

results. 

Table V-2 Trial Standard Levels for Battery Chargers 

Product Class 

Trial Standard Level 

TSL 1 TSL 2 TSL 3 TSL 4 

Low-Energy, Inductive (1) CSL 1 CSL 2 CSL 3 -

Low-Energy, Low-Voltage (2) 

Low-Energy, Med.-Voltage (3) 

Low-Energy, High-Voltage (4) 

CSL 1 

CSL 1 

CSL 1 

CSL 2 

CSL 1 

CSL 1 

CSL 3 

CSL 2 

CSL 2 

CSL 4 

CSL 3 

CSL 3 

Med.-Energy, Low-Voltage (5) 

Med.-Energy, High-Voltage (6) 

CSL 1 

CSL 1 

CSL 2 

CSL 2 

CSL 3 

CSL 3 

-

-

High-Energy (7) CSL 1 CSL 2 - -

Low-Voltage DC Input (8) CSL 1 CSL 2 CSL 3 -

High-Voltage DC Input (9) - - - -

AC Input, AC Output (10) CSL 1 CSL 2 CSL 3 -

For battery charger product class 1 (low-energy, inductive), DOE examined three trial 

standard levels corresponding to each candidate standard level developed in the engineering 

analysis. TSL 1 is an intermediate level of performance above the baseline. TSL 2 is equivalent 

to the best-in-market and corresponds to the maximum consumer NPV. TSL 3 is the max-tech 

level and corresponds to the greatest NES. 

For its second set of TSLs, which covers product classes 2 (low-energy, low-voltage), 3 

(low-energy, medium-voltage), and 4 (low-energy, high-voltage), DOE examined four TSLs of 

different combinations of the various efficiency levels found for each product class in the 

301 
engineering analysis. In this grouping, TSL 1 is an intermediate efficiency level above the 

baseline for each product class and corresponds to the maximum consumer NPV. For 2 of the 3 

product classes, TSL 2 corresponds to the same efficiency level, but for the third class, product 

class 2, TSL 2 represents an incremental efficiency level below best-in-market. TSL 3 

corresponds to the best-in-market efficiency level for all product classes. Finally, TSL 4 

corresponds to the max-tech efficiency level for all product classes and therefore, the maximum 

NES. 

DOE’s third set of TSLs corresponds to the grouping of product classes 5 (mediumenergy, low-voltage) and 6 (medium-energy, high-voltage). For this grouping, three TSLs 

corresponding to different combinations of efficiency levels were examined. For both product 

classes, TSL 1 is an intermediate efficiency level above the baseline. TSL 2 corresponds to the 

best-in-market efficiency level for both product classes and is the level with the highest 

consumer NPV. Finally, TSL 3 corresponds to the max-tech efficiency level for both product 

classes and the maximum NES. 

For product class 7 (high-energy), DOE examined only two TSLs because of the paucity 

of products available on the market. TSL 1 corresponds to an efficiency level equivalent to the 

best-in-market and maximizes consumer NPV is maximized. TSL 2 is the max-tech level and 

corresponds to the level with the maximum NES. 

For product class 8 (low-voltage DC input), DOE examined three TSLs at incremental 

levels above the baseline. TSL 1 is the first incremental level between the baseline and best-in302 
 

market. Consumer NPV is maximized at this level. TSL 2 is the best-in-market efficiency level 

and is projected to yield higher NES levels over TSL 1. Finally, at TSL 3, or the max-tech 

efficiency level, NES is maximized. 

For product class 9 (high-voltage DC input), DOE did not examine any TSLs in depth. 

Rather, when DOE completed its engineering analysis, it conducted its LCC analysis on the 

efficiency levels that had been developed and found that all efficiency levels above the baseline 

showed negative LCC savings. This fact, combined with the minimal energy consumed per year 

for these devices, led DOE to propose an alternative standard level for these products. DOE’s 

proposal for this product class is discussed in section V.B.2.f below. 

For product class 10 (AC input, AC output), DOE examined three TSLs, each 

corresponding to an efficiency level developed in the engineering analysis. TSL 1 corresponds to 

an incremental level of performance above the baseline. TSL 2 is equivalent to what 

manufacturers stated would be equivalent to the best-in-market level. TSL 3, which DOE 

projects to yield maximized NPV and NES values, is equivalent to the max-tech efficiency level 

for product class 10. 

B. Economic Justification and Energy Savings 

As discussed in section II.A, EPCA provides seven factors to be evaluated in determining 

whether a potential energy conservation standard is economically justified. (42 U.S.C. 

6295(o)(2)(B)(i)) The following sections generally discuss how DOE is addressing each of those 

303 
seven factors in this rulemaking. For further details and the results of DOE’s analyses pertaining 

to economic justification, see sections IV and V of today’s notice. 

1. Economic Impacts on Individual Consumers 

For individual consumers, measures of economic impact include the changes in LCC and 

the PBP associated with new or amended standards. The LCC, which is also separately specified 

as one of the seven factors to be considered in determining the economic justification for a new 

or amended standard (42 U.S.C. 6295(o)(2)(B)(i)(II)), is discussed in the following section. For 

consumers in the aggregate, DOE also calculates the net present value from a national 

perspective of the economic impacts on consumers over the forecast period used in a particular 

rulemaking. 

a. Life-Cycle Cost and Payback Period 

As in the preliminary analysis phase, DOE calculated the average LCC savings relative to 

the base case market efficiency distribution for each representative unit and product class. DOE’s 

projections indicate that a new standard would affect different battery charger and EPS 

consumers differently, depending on the market segment to which they belong and their usage 

characteristics. Section IV.F discusses the inputs used for calculating the LCC and PBP. Inputs 

used for calculating the LCC include total installed costs, annual energy savings, electricity rates, 

electricity price trends, product lifetime, and discount rates. 

The key outputs of the LCC analysis are average LCC savings for each product class for 

each considered efficiency level, relative to the base case, as well as a probability distribution of 

304 
 

LCC reduction or increase. The LCC analysis also estimates, for each product class or 

representative unit, the fraction of customers for which the LCC will either decrease (net 

benefit), or increase (net cost), or exhibit no change (no impact) relative to the base case forecast. 

No impacts occur when the product efficiencies of the base case forecast already equal or exceed 

the considered efficiency level. Battery chargers and EPSs are used in applications that can have 

a wide range of operating hours. Battery chargers and EPSs that are used more frequently will 

tend to have a larger net LCC benefit than those that are used less frequently because of the large 

operating cost savings. 

Another key output of the LCC analysis is the median payback period at each CSL. DOE 

presents the median payback period rather than the mean payback period because it is more 

robust in the presence of outliers in the data.65 These outliers skew the mean payback period 

calculation but have little effect on the median payback period calculation. A small change in 

operating costs, which derive the denominator of the payback period calculation, can sometimes 

result in a very large payback period, which skews the mean payback period calculation. For 

example, consider a sample of PBPs of 2, 2, 2, and 20 years, where 20 years is an outlier. The 

mean PBP would return a value of 6.5 years, whereas the median PBP would return a value of 2 

years. Therefore, DOE considers the median payback period, which is not skewed by occasional 

outliers. Table V-3 through Table V-5 show the results for the representative units and product 

classes analyzed for EPSs and battery chargers. Additional detail for these results, including 

frequency plots of the distributions of life-cycle costs and payback periods, are available in 

chapter 8 of the TSD. 

65 DOE notes that it uses the median payback period to reduce the effect of outliers on the data. This method, 

however, does not eliminate the outliers from the data. 

305 
 

 

Table V-3 LCC Savings and Payback Period for DC Output, Basic-Voltage External Power 

Supplies 

Weighted Average LCC Savings2010$] Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

2.5W AC-DC, Basic V 0.10 0.04 0.02 3.5 4.3 4.3 

18W AC-DC, Basic V 0.68 0.69 (1.19) 1.2 3.1 8.1 

60W AC-DC, Basic V (0.33) (0.45) (1.38) 6.3 5.4 6.4 

120W AC-DC, Basic V 0.60 0.61 (5.49) 1.4 1.9 9.1 

For EPS product class B (basic-voltage, AC-DC, class A EPSs), each representative unit 

has a unique value for LCC savings and median PBP. The 2.5W representative unit has positive 

LCC savings at all TSLs considered, while the 60W representative unit has negative LCC 

savings at all TSLs. Both the 18W and 120W representative units have positive LCC savings 

through TSL 2, but turn negative at TSL 3. 

Table V-4 LCC Savings and Payback Period for Non-Class A External Power Supplies 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

203W Multiple Voltage 2.05 2.07 (3.09) 0.4 4.7 13.2 

345W High-Power 124.82 129.08 92.96 0.0 0.2 2.5 

The Non-Class A EPSs have varying LCC results at each TSL. See Table V-4. The 203W 

Multiple Voltage unit (product class X) has positive LCC savings through TSL 2. DOE notes 

that for this product class, the LCC savings remain largely the same for TSL 1 and 2 because the 

difference in LCC is approximately $0.01 and 95 percent of this market consists of purchased 

products that are already at TSL 1. Therefore, the effects are largely from the movement of the 5 

percent of the market up from the baseline. The 345W High-Power unit (product class H) has 

positive LCC savings for each TSL. This projection is largely attributable to the installed price of 

the baseline unit, a linear switching device, which is more costly than higher efficiency switch306 
 

 

 

 

 

 

 

 

mode power devices, so as consumers move to higher efficiencies, the purchase price actually 

decreases, resulting in savings. 

Table V-5 LCC Savings and Payback Period for Battery Chargers 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 4 TSL 1 TSL 2 TSL 3 TSL 4 

PC1 - Low E, 

Inductive 0.76 1.52 (2.87) N/A 1.2 1.7 8.5 N/A 

PC2 - Low E, 

Low-Voltage 0.16 (0.12) (1.81) (4.54) 0.5 5.2 8.5 16.9 

PC3 - Low E, 

Medium-Voltage 0.35 0.35 (2.12) (2.15) 3.9 3.9 21.9 21.5 

PC4 - Low E, 

High-Voltage 0.43 0.43 (2.73) (10.14) 3.0 3.0 13.8 37.6 

PC5 - Medium E, 

Low-Voltage 9.69 33.79 (104.58) N/A 1.7 0.0 53.4 N/A 

PC6 - Medium E, 

High-Voltage 9.96 40.78 (86.76) N/A 1.2 0.0 20.8 N/A 

PC7 - High E 38.26 (127.30) N/A N/A 0.0 27.2 N/A N/A 

PC8 - DC-DC, 

<9V Input 3.04 (1.96) (2.31) N/A 0.0 0.0 24.9 N/A 

PC9 - DC-DC, ≥9 

V Input (0.09) (0.25) 0.00 N/A 7.2 8.8 0.0 N/A 

PC10 - Low E, 

AC Out 6.41 7.26 8.30 N/A 1.3 1.4 1.5 N/A 

The LCC results for battery chargers depend on the product class being considered. See 

Table V-5. For product class 1, LCC results are positive through TSL 2. For the low-energy 

product classes (PC2, 3, and 4), LCC results are generally positive through TSL 2, with the 

exception of product class 2, and become negative at TSL 3. The medium-energy product classes 

(PC5 and 6) are positive through TSL 2 and negative at TSL 3. The high-energy product class 

(PC7) has positive LCC savings of $38.26 at TSL 1, and then becomes negative at TSL 2. 

Product class 8 has positive LCC savings only at TSL 1, while product class 10 has positive LCC 

savings at each TSL (see entries for PC8 and PC10 in Table V-5). 

307 
b. Consumer Subgroup Analysis 

Certain consumer subgroups may be disproportionately affected by standards. DOE 

performed LCC subgroup analyses in this NOPR for low-income consumers, small businesses, 

top tier marginal electricity price consumers, and consumers of specific applications. See section 

IV.F of this NOPR for a review of the inputs to the LCC analysis. The following discussion 

presents the most significant results from the LCC subgroup analysis. 

Low-Income Consumers 

For low-income consumers, the LCC impacts and payback periods are different than for 

the general population. This subgroup considers only the residential sector, and uses an adjusted 

electricity price from the reference case scenario. DOE found that low-income consumers below 

the poverty line typically paid electricity prices that were 0.2 cents per kWh lower than the 

general population. To account for this difference, DOE adjusted electricity prices by a factor of 

0.9814 to derive electricity prices for this subgroup. Table V-6 through Table V-8 show the LCC 

impacts and payback periods for low-income consumers purchasing EPSs and battery chargers. 

The LCC savings and PBPs of low-income consumers is similar to that of the total 

population of consumers. In general, low-income consumers experience slightly reduced LCC 

savings, particularly in product classes dominated by residential applications. However, product 

classes with a large proportion of commercial applications experience less of an effect under the 

low-income consumer scenario, which is specific to the residential sector, and sometimes have 

greater LCC savings than the reference case results. None of the changes in LCC savings move a 

TSL from positive to negative LCC savings, or vice versa. 

308 
 

 

 

 

 

 

 

 

 

 

 

 

Table V-6 DC Output, Basic-Voltage External Power Supplies: Low-Income Consumer 

Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

2.5W AC-DC, Basic V 0.10 0.04 0.01 3.5 4.4 4.4 

18W AC-DC, Basic V 0.69 0.70 (1.19) 1.2 3.4 9.8 

60W AC-DC, Basic V (0.29) (0.35) (1.19) 6.4 5.3 6.3 

120W AC-DC, Basic V 0.65 0.68 (5.32) 1.3 1.8 8.8 

Table V-7 Non-Class A External Power Supplies: Low-Income Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

203W Multiple-Voltage 2.00 2.01 (3.20) 0.4 4.8 13.5 

345W High-Power 122.51 126.61 90.23 0.0 0.4 4.3 

Table V-8 Battery Chargers: Low-Income Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 4 TSL 1 TSL 2 TSL 3 TSL 4 

PC1 - Low E, 

Inductive 0.74 1.47 (2.94) N/A 1.3 1.7 8.6 N/A 

PC2 - Low E, LowVoltage 0.15 (0.16) (1.87) (4.60) 0.5 5.5 8.7 17.2 

PC3 - Low E, 

Medium-Voltage 0.31 0.31 (2.21) (2.25) 4.4 4.4 22.4 22.4 

PC4 - Low E, 

High-Voltage 0.61 0.61 (2.79) (10.28) 3.2 3.2 12.3 43.1 

PC5 - Medium E, 

Low-Voltage 9.47 33.26 (105.27) N/A 1.8 0.0 54.5 N/A 

PC6 - Medium E, 

High-Voltage 9.72 40.06 (87.83) N/A 1.3 0.0 21.2 N/A 

PC7 - High E 39.20 (135.53) N/A N/A 0.0 126.6 N/A N/A 

PC8 - DC-DC, <9V 

Input 3.05 (1.93) (2.29) N/A 0.0 0.0 26.6 N/A 

PC9 - DC-DC, ≥9 

V Input (0.09) (0.25) 0.00 N/A 7.2 8.8 0.0 N/A 

PC10 - Low E, AC 

Out 6.24 7.08 8.08 N/A 1.3 1.4 1.5 N/A 

309 
 

Small Businesses 

For small business customers, the LCC impacts and payback periods are different than 

for the general population. This subgroup considers only the commercial sector, and uses an 

adjusted discount rate from the reference case scenario. DOE found that small businesses 

typically have a cost of capital that is 4.48 percent higher than the industry average, which was 

applied to the discount rate for the small business consumer subgroup. 

The small business consumer subgroup LCC results are not directly comparable to the 

reference case LCC results because this subgroup only considers commercial applications. In the 

reference case scenario, the LCC results are strongly influenced by the presence of residential 

applications, which typically comprise the majority of application shipments. For EPS product 

class B, the LCC savings for the 2.5W representative unit become negative at TSL 2 and 3 under 

the small business scenario, but none of the savings for other representative units change from 

positive to negative, or vice versa. Similarly, none of the battery charger product classes that 

were positive in the reference case become negative in the small business subgroup analysis, and 

vice versa. This observation indicates that small business consumers would experience similar 

LCC impacts as the general population. 

Table V-9 and Table V-10 show the LCC impacts and payback periods for small 

businesses purchasing EPSs and battery chargers. DOE did not identify any commercial 

applications for Non-Class A EPSs, and, consequently, did not evaluate these products as part of 

the small business consumer subgroup analysis. 

310 
 

 

 

 

 

 

 

 

 

 

 

 

Table V-9 DC Output, Basic-Voltage External Power Supplies: Small Business Consumer 

Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

2.5W AC-DC, Basic V 0.03 (0.04) (0.08) 4.4 5.0 5.0 

18W AC-DC, Basic V 0.44 0.32 (1.81) 1.1 2.8 6.9 

60W AC-DC, Basic V (0.46) (0.73) (1.93) 7.1 6.0 7.2 

120W AC-DC, Basic V 0.46 0.45 (5.98) 1.4 2.0 9.2 

Table V-10 Battery Chargers: Small Business Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 4 TSL 1 TSL 2 TSL 3 TSL 4 

PC1 - Low E, 

Inductive* N/A N/A N/A N/A N/A N/A N/A N/A 

PC2 - Low E, LowVoltage 0.18 (0.18) (1.88) (4.66) 0.5 4.4 8.4 15.4 

PC3 - Low E, 

Medium-Voltage 1.08 1.08 (0.85) (0.75) 1.2 1.2 4.7 4.6 

PC4 - Low E, HighVoltage 0.06 0.06 (2.82) (10.18) 2.3 2.3 17.0 34.8 

PC5 - Medium E, 

Low-Voltage* N/A N/A N/A N/A N/A N/A N/A N/A 

PC6 - Medium E, 

High-Voltage* N/A N/A N/A N/A N/A N/A N/A N/A 

PC7 - High E 37.40 (128.58) N/A N/A 0.0 27.2 N/A N/A 

PC8 - DC-DC, <9V 

Input 3.00 (2.00) (2.36) N/A 0.0 0.0 10.9 N/A 

PC9 - DC-DC, ≥9 

V Input* N/A N/A N/A N/A N/A N/A N/A N/A 

PC10 - Low E, AC 

Out 3.71 4.14 4.65 N/A 1.5 1.7 1.8 N/A 

* These product classes do not contain any commercial applications, so the small business consumer subgroup is not 

applicable. 

Top Tier Marginal Electricity Price Consumers 

For top tier marginal electricity price consumers, the LCC impacts and payback periods 

are different than for the general population. The analyses for this subgroup consider a weightedaverage of the residential and commercial sectors, and uses an adjusted electricity price from the 

reference case scenario. DOE used an upper tier inclined marginal block rate for the electricity 

price in the residential and commercial sectors, resulting in a price of $0.310 and $0.225 per 

311 
 

 

 

 

 

 

kWh, respectively. Table V-11 through Table V-13 show the LCC impacts and payback periods 

for top tier marginal electricity price consumers purchasing EPSs and battery chargers. 

Consumers in the top tier marginal electricity price bracket experience greater LCC 

savings than those in the reference case scenario. This result occurs because these consumers pay 

more for their electricity than other consumers, and, therefore, experience greater savings when 

using products that are more energy efficient. This subgroup analysis changed many of the 

negative LCC savings results to positive LCC savings. Some product classes and representative 

units still have negative LCC savings, which indicates that these product classes have increasing 

installed costs (purchase price plus installation costs, the latter of which are assumed to be zero) 

at higher TSLs that cannot be overcome through operating cost savings using top tier marginal 

electricity prices. 

Table V-11 DC Output, Basic-Voltage External Power Supplies: Top Tier Marginal 

Electricity Price Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

2.5W AC-DC, Basic V 0.86 0.97 1.08 1.4 1.7 1.7 

18W AC-DC, Basic V 2.14 3.19 3.54 0.4 1.2 3.2 

60W AC-DC, Basic V 0.73 1.51 2.45 2.1 1.9 2.2 

120W AC-DC, Basic V 2.05 2.38 (0.28) 0.5 0.6 3.8 

Table V-12 Non-Class A External Power Supplies: Top Tier Marginal Electricity Price 

Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 1 TSL 2 TSL 3 

203W Multiple Voltage 6.02 6.62 6.25 0.1 1.5 4.2 

345W High-Power 313.34 331.76 318.23 0.0 0.0 0.2 

312 
 

 

 

 

 

 

 

 

 

 

Table V-13 Battery Chargers: Top Tier Marginal Electricity Price Consumer Subgroup 

Weighted Average LCC Savings 

[2010$] 

Median Payback Period 

[yrs] 

Rep. Unit TSL 1 TSL 2 TSL 3 TSL 4 TSL 1 TSL 2 TSL 3 TSL 4 

PC1 - Low E, 

Inductive 2.55 5.71 2.86 N/A 0.4 0.5 2.7 N/A 

PC2 - Low E, LowVoltage 0.46 1.13 0.83 (1.75) 0.2 1.8 3.0 6.0 

PC3 - Low E, 

Medium-Voltage 1.47 1.47 1.60 1.60 1.4 1.4 7.1 7.2 

PC4 - Low E, HighVoltage 1.83 1.83 0.22 (6.34) 1.0 1.0 6.4 14.7 

PC5 - Medium E, 

Low-Voltage 29.35 79.29 (44.77) N/A 0.9 0.0 21.3 N/A 

PC6 - Medium E, 

High-Voltage 30.62 102.95 6.30 N/A 0.4 0.0 6.7 N/A 

PC7 - High E 49.74 (94.46) N/A N/A 0.0 13.6 N/A N/A 

PC8 - DC-DC, <9V 

Input 3.13 (1.57) (1.89) N/A 0.0 0.0 8.1 N/A 

PC9 - DC-DC, ≥9 

V Input (0.09) (0.25) 0.00 N/A 7.2 8.8 0.0 N/A 

PC10 - Low E, AC 

Out 20.43 23.53 27.27 N/A 0.4 0.4 0.5 N/A 

Consumers of Specific Applications 

DOE performed an LCC and PBP analysis on every application within each 

representative unit and product class. This subgroup analysis used the application’s specific 

inputs for lifetime, markups, base case market efficiency distribution, and UEC. Many 

applications in each representative unit or product class experienced LCC impacts and payback 

periods that were different from the average results across the representative unit or product 

class. Because of the large number of applications considered in the analysis, some of which 

span multiple representative units or product classes, DOE did not present application-specific 

LCC results here. Detailed results on each application are available in chapter 11 of the TSD. 

For EPS product class B, the application-specific LCC results indicate that most 

applications will experience similar levels of LCC savings as the representative unit’s average 

313 
LCC savings. The 2.5W representative unit has positive LCC savings for each TSL, but 

infrequently charged applications, such as beard and moustache trimmers (among others), 

experience negative LCC savings. Similarly, the 18W representative unit has projected positive 

LCC savings through TSL 2, but other applications using EPSs, such as portable DVD players 

and camcorders, have negative savings. For the 60W representative unit, all applications follow 

the shipment-weighted average trends, except EPSs used in sleep apnea machines, which have 

positive LCC savings at each TSL. The same is true for the 120W representative unit, except for 

EPSs used in portable O2 concentrator applications, which are projected to yield negative LCC 

results for all TSLs. 

For battery charger product classes, DOE noted similar trends where less frequently used 

applications experienced lower LCC savings. For product class 2, LCC savings are negative 

beyond TSL 1, but frequently used applications within that class -- e.g. answering machines, 

cordless phones, and home security systems -- experience positive LCC savings. The top three 

product class 3 applications (which account for over 50 percent of total shipments) have negative 

LCC savings and contribute to the negative LCC savings of the product class average. However, 

some applications have significantly positive LCC savings, such as handheld vacuums, LAN 

equipment, stick vacuums, and universal battery chargers, which together comprise 15 percent of 

the total shipments in PC3. Product class 4 (e.g. notebooks and netbooks) have no impacts at 

TSL 1 or TSL 2 because these products already use battery charger technology above the 

baseline efficiency level. In the other battery charger product classes, the disparate applications 

tend to experience similar LCC savings. See chapter 11 of the TSD for further detail. 

314 
c. Rebuttable Presumption Payback 

As discussed in section III.D.2, EPCA provides a rebuttable presumption where, in 

essence, an energy conservation standard is economically justified if the increased purchase cost 

for a product that meets the standard is less than three times the value of the first-year energy 

savings resulting from the standard. However, DOE routinely conducts a full economic analysis 

that considers the full range of impacts, including those to the customer, manufacturer, Nation, 

and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i) and 42 U.S.C. 6316(e)(1). The 

results of this analysis serve as the basis for DOE to evaluate definitively the economic 

justification for a potential standard level (thereby supporting or rebutting the results of any 

preliminary determination of economic justification). 

For EPSs and battery chargers, energy savings calculations in the LCC and PBP analyses 

used both the relevant test procedures as well as the relevant usage profiles. DOE’s recent 

changes to the test procedures did not affect any characteristics that impact the payback period 

calculation. Because DOE calculated payback periods using a methodology consistent with the 

rebuttable presumption test for EPSs and battery chargers in the LCC and payback period 

analyses, DOE did not perform a stand-alone rebuttable presumption analysis, as it was already 

embodied in the LCC and PBP analyses. 

2. Economic Impacts on Manufacturers 

DOE performed an MIA to estimate the impact of new and amended energy conservation 

standards on manufacturers of EPSs and battery chargers. The section below describes the 

expected impacts on manufacturers at each potential TSL. 

315 
a. Cash-Flow Analysis Results 

The INPV results refer to the difference in industry value between the base case and the 

standards case, which DOE calculated by summing the discounted industry cash flows from the 

base year (2011) through the end of the analysis period. The discussion also notes the difference 

in cash flow between the base case and the standards case in the year before the compliance date 

of potential new and amended energy conservation standards. This figure provides a proxy for 

the magnitude of the required conversion costs, relative to the cash flow generated by the 

industry in the base case. 

i. EPS Cash Flow Impacts 

For EPSs, the MIA describes the impacts on EPS ODMs. Each set of results below shows 

two tables of INPV impacts on the ODM. The first table reflects the lower (less severe) bound of 

impacts and the second represents the upper (more severe) bound. To evaluate this range of cashflow impacts on EPS manufacturers, DOE modeled two different scenarios using different 

markup assumptions. These assumptions correspond to the bounds of a range of market 

responses that DOE anticipates could occur in the standards case. Each scenario results in a 

unique set of cash flows and corresponding industry value at each TSL. 

To assess the lower (less severe) end of the range of potential impacts, DOE modeled the 

flat markup scenario. The flat markup scenario assumes that in the standards case manufacturers 

would be able to pass the higher production costs required to manufacture more efficient 

products on to their customers. To assess the higher (more severe) end of the range of potential 

316 
 

 

impacts, DOE modeled the preservation of operating profit markup scenario in which higher 

energy conservation standards result in lower manufacturer markups. DOE used the main NIA 

shipment scenario for both the lower- and higher-bound MIA scenarios that were used to 

characterize the potential INPV impacts. 

Product Classes B, C, D, and E 

Table V-14 and Table V-15 present the projected results for product classes B, C, D, and 

E under the flat and preservation of operating profit markup scenarios. DOE examined four 

representative units in product class B and scaled the results to product classes C, D, and E using 

the most appropriate representative unit for each product class. 

Table V-14 Manufacturer Impact Analysis for Product Classes B, C, D, and E – Flat 

Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV (2010$ millions) 231.9 193.0 196.7 249.8 

Change in INPV (2010$ millions) - (38.9) (35.2) 17.9 

(%) - -16.8% -15.2% 7.7% 

Product Conversion Costs (2010$ millions) - 29.1 34.5 36.3 

Capital Conversion Costs (2010$ millions) - 32.2 38.1 40.1 

Total Conversion Costs (2010$ millions) - 61.4 72.6 76.4 

Table V-15 Manufacturer Impact Analysis for Product Classes B, C, D, and E – 

Preservation of Operating Profit Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV (2010$ millions) 231.9 169.4 150.5 108.4 

Change in INPV (2010$ millions) - (62.5) (81.4) (123.5) 

(%) - -26.9% -35.1% -53.2% 

Product Conversion Costs (2010$ millions) - 29.1 34.5 36.3 

Capital Conversion Costs (2010$ millions) - 32.2 38.1 40.1 

Total Conversion Costs (2010$ millions) - 61.4 72.6 76.4 

At TSL 1, DOE estimates impacts on INPV to range from -$38.9 million to -$62.5 

million, or a change in INPV of -16.8 percent to -26.9 percent. At this level, industry free cash 

317 
flow is estimated to decrease by approximately 179.2 percent to -$10.8 million, compared to the 

base-case value of $13.6 million in the year leading up to when the new and amended energy 

conservation standards would need to be met. 

At TSL 1, manufacturers of product class B, C, D, and E EPSs face a moderate loss in 

INPV. For these product classes, the required efficiencies at TSL 1 correspond to an intermediate 

level above the ENERGY STAR 2.0 levels but below the best in market efficiencies. The 

conversion costs are a major contribution of the decrease in INPV because the vast majority of 

the product class B, C, D, and E EPS shipments fall below CSL 2. Manufacturers will incur 

product and capital conversion costs of approximately $61.4 million at TSL 1. In 2013, 

approximately 84 percent of product class B, C, D, and E shipments are projected to fall below 

the proposed amended energy conservation standards. In addition, 92 percent of the products for 

the 2.5W representative unit are projected to fall below the proposed efficiency standard, and 

would likely require more substantial conversion costs because meeting the efficiency standard 

would require 2.5W representative units to switch from linear to switch mode technology. This 

change would increase the conversion costs for these 2.5W representative units, which account 

for approximately a quarter of all the product class B, C, D, and E shipments. 

At TSL 1, the MPC increases 45 percent for the 2.5W representative units (a 

representative unit for product class B and all shipments of product classes C and E), 5 percent 

for the 18 Watt representative units (a representative unit for product class B and all shipments of 

product class D), 14 percent for the 60W representative units, and 3 percent for the 120W 

representative units over the baseline. The conversion costs are significant enough to cause a 

318 
moderately negative industry impact even if the incremental change in MPCs is fully passed on 

to OEMs. Impacts are more significant under the preservation of operating profit scenario 

because under this scenario manufacturers would be unable to pass on the full increase product 

cost. 

At TSL 2, DOE estimates impacts on INPV to range from -$35.2 million to -$81.4 

million, or a change in INPV of -15.2 percent to -35.1 percent. At this level, industry free cash 

flow is estimated to decrease by approximately 212.1 percent to -$15.2 million, compared to the 

base-case value of $13.6 million in the year before the compliance date. 

TSL 2 represents the best-in-market efficiencies for product class B, C, D, and E EPSs. 

The difference in conversion costs and incremental production costs at TSL 2 make the INPV 

impacts slightly better than TSL 1 in the flat markup scenario and worse under the preservation 

of operating profit scenario. The product conversion costs increase by $5.4 million and the 

capital conversion costs increase by $5.9 million from TSL 1 because the vast majority of current 

products fall below the efficiency requirements at TSL 2. Also, at TSL 2, the MPC increases 60 

percent for the 2.5W representative units (a representative unit for product class B and all 

shipments of product classes C and E), 18 percent for the 18 Watt representative units (this is a 

representative unit for product class B and all shipments of product class D), 22 percent for the 

60W representative units, and 4 percent for the 120W representative units over the baseline. 

However, the similar conversion costs and relatively minor additional incremental costs make 

the industry impacts at TSL 2 similar to those at TSL 1. 

319 
At TSL 3, DOE estimates impacts on INPV to range from $17.9 million to -$123.5 

million, or a change in INPV of 7.7 percent to -53.2 percent. At this level, industry free cash 

flow is estimated to decrease by approximately 223.0 percent to -$16.7 million, compared to the 

base-case value of $13.6 million in the year before the compliance date. 

TSL 3 represents the max-tech CSL for product class B, C, D, and E EPSs. At TSL 3, 

DOE modeled a wide range of industry impacts because the very large increases in per-unit costs 

lead to a wide range of potential impacts depending on who captures the additional value in the 

distribution chain. None of the existing products on the market meet the efficiency requirements 

at TSL 3. However, since most of the products at TSL 2 also fall below the standard level, there 

is only a slight difference between the conversion costs at TSL 2 and TSL 3. The different INPV 

impacts occur due to the large changes in incremental MPCs at the max-tech level. At TSL 3, the 

MPC increases 69 percent for the 2.5W representative unit (this is a representative unit for 

product class B and all shipments for product classes C and E), 80 percent for the 18 Watt 

representative units (this is a representative unit for product class B and all shipments for product 

class D), 46 percent for the 60W representative units, and 53 percent for the 120W representative 

units over the baseline. If manufacturers are able to fully pass on these costs to OEMs (the flat 

markup scenario), the increase in cash flow from operations is enough to overcome the 

conversion costs to meet the max-tech level and INPV increases slightly. However, if the 

manufacturers are unable to pass on these costs and only maintain the current operating profit 

(the preservation of operating profit markup scenario), there is a large, negative impact on INPV, 

because substantial increases in working capital drain operating cash flow. The conversion costs 

associated with switching the entire market, the large increase in incremental MPCs, and the 

320 
 

 

 

 

extreme pressure from OEMs to keep product prices down make it more likely that ODMs will 

not be able to fully pass on these costs to OEMs and the ODMS would face a substantial loss 

instead of a slight gain in INPV at TSL 3. 

Product Class X 

Table V-16 and Table V-17 below present the projected results for product class X under 

the flat and preservation of operating profit markup scenarios. 

Table V-16 Manufacturer Impact Analysis for Product Class X EPS – Flat Markup 

Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 

INPV (2010$ millions) 44.1 43.7 32.2 39.6 

Change in INPV (2010$ millions) - (0.4) (12.0) (4.6) 

(%) - -1.0% -27.1% -10.3% 

Product Conversion Costs (2010$ millions) - 0.3 6.9 6.9 

Capital Conversion Costs (2010$ millions) - 0.4 7.6 7.6 

Total Conversion Costs (2010$ millions) - 0.7 14.4 14.4 

Table V-17 Manufacturer Impact Analysis for Product Class X EPS – Preservation of 

Operating Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 

INPV (2010$ millions) 44.1 43.4 31.4 26.3 

Change in INPV (2010$ millions) - (0.7) (12.8) (17.9) 

(%) - -1.7% -28.9% -40.5% 

Product Conversion Costs (2010$ millions) - 0.3 6.9 6.9 

Capital Conversion Costs (2010$ millions) - 0.4 7.6 7.6 

Total Conversion Costs (2010$ millions) - 0.7 14.4 14.4 

At TSL 1, DOE estimates impacts on INPV to range from -$0.4 million to -$0.7 million, 

or a change in INPV of -1.0 percent to -1.7 percent. At this level, industry free cash flow is 

estimated to decrease by approximately 10.9 percent to $2.3 million, compared to the base-case 

value of $2.6 million in the year before the compliance date. 

321 
At TSL 1, manufacturers of product class X face a very slight decline in INPV because 

most of the market already meets TSL 1. The total conversion costs are approximately $0.7 

million. Conversion costs are low because 95 percent of the products already meet the TSL 1 

efficiency requirements. 

At TSL 2, DOE estimates impacts on INPV to range from -$12.0 million to -$12.8 

million, or a change in INPV of -27.1 percent to -28.9 percent. At this level, industry free cash 

flow is estimated to decrease by approximately 218.6 percent to -$3.1 million, compared to the 

base-case value of $2.6 million in the year leading up to when the new energy conservation 

standards would need to be met. 

At TSL 2, manufacturers face a more noticeable loss in industry value. DOE estimates 

that manufacturers will incur total product and capital conversion costs of $14.4 million at TSL 

2. The conversion costs increase at TSL 2 because the entire market falls below the efficiency 

requirements at TSL 2. However, the total impacts are also driven by the incremental MPCs at 

TSL 2. At TSL 2, the MPC increases 16 percent over the baseline. Therefore, the projected 

changes in INPV under both the flat and preservation of operating profit markup scenarios are 

similar. 

At TSL 3, DOE estimates impacts on INPV to range from -$4.6 million to -$17.9 million, 

or a change in INPV of -10.3 percent to -40.5 percent. At this level, industry free cash flow is 

estimated to decrease by approximately 218.6 percent to $3.1 million, compared to the base-case 

value of $2.6 million in the year before the compliance date. 

322 
TSL 3 could result in substantial impacts on INPV. As with TSL 2, the entire market falls 

below the required efficiency at TSL 3 and total industry conversion costs are also $14.4 million. 

However, the main difference at TSL 3 is the increase in the MPC. At TSL 3, the MPC increases 

46 percent over the baseline. If the ODM can pass on the higher price of these products to the 

OEM at TSL 3, the decline in INPV is not severe. However, if ODMs cannot pass on these 

higher MPCs to OEMs, the loss in INPV is much more substantial. 

Product Class H 

Table V-18 and Table V-19 present the projected results for product class H under the 

flat and preservation of operating profit markup scenarios. 

Table V-18 Manufacturer Impact Analysis for Product Class H EPS – Flat Markup 

Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV (2010$ millions) 0.11 0.06 0.06 0.08 

Change in INPV (2010$ millions) - (0.05) (0.05) (0.03) 

(%) - -45.5% -44.0% -24.4% 

Product Conversion Costs (2010$ millions) - 0.02 0.02 0.02 

Capital Conversion Costs (2010$ millions) - 0.02 0.02 0.02 

Total Conversion Costs (2010$ millions) - 0.05 0.05 0.05 

Table V-19 Manufacturer Impact Analysis for Product Class H EPS – Preservation of 

Operating Profit Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV (2010$ millions) 0.11 0.07 0.07 0.06 

Change in INPV (2010$ millions) - (0.04) (0.04) (0.05) 

(%) - -32.7% -33.8% -47.3% 

Product Conversion Costs (2010$ millions) - 0.02 0.02 0.02 

Capital Conversion Costs (2010$ millions) - 0.02 0.02 0.02 

Total Conversion Costs (2010$ millions) - 0.05 0.05 0.05 

323 
A t TSL 1, DOE estimates impacts on INPV to range -$0.04 million to -$0.05 million, or 

a change in INPV of -32.7 percent to -45.5 percent. At this level, industry free cash flow is 

estimated to decrease by approximately 284.4 percent to -$0.01 million, compared to the basecase value of $0.01 million in the year before the compliance date. 

At TSL 1, product class H manufacturers face a significant relative loss in industry value. 

The base case industry value of $100,000 is low and since DOE estimates that total conversion 

costs at TSL 1 would be approximately $50,000, the conversion costs represent a substantial 

portion of total industry value. The conversion costs are high relative to the base case INPV 

because the entire market in 2013 is projected to fall below an efficiency standard set at TSL 1. 

This means that all products in product class H would have to be redesigned to meet the 

efficiency level at TSL 1, leading to total conversion costs that are large relative to the base case 

industry value. In addition, the MPC at TSL 1 declines by 21 percent compared to the baseline 

since the switching technology that would be required to meet this efficiency level is less costly 

to manufacture than baseline products that use linear technology. This situation results in a lower 

MSP and lower revenues for manufacturers of baseline products, which exacerbates the impacts 

on INPV from new energy conservation standards for these products. 

At TSL 2, DOE estimates impacts on INPV to range from -$0.04 million to -$0.05 

million, or a change in INPV of -33.8 percent to -44.0 percent. At this level, industry free cash 

flow is estimated to decrease by approximately 284.4 percent to -$0.01 million, compared to the 

base-case value of $0.01 million in the year before the compliance date. 

324 
The impacts on INPV at TSL 2 are similar to TSL 1. The conversion costs are the same 

since the entire market in 2013 would fall below the required efficiency at both TSL 1 and TSL 

2. Also, the MPC is projected to decrease by 19 percent at TSL 2 compared to the baseline, 

which is similar to the 21 percent decrease at TSL 1. Overall, the similar conversion costs and 

lower industry revenue for the minimally compliant products make the INPV impacts at TSL 2 

similar to TSL 1. 

At TSL 3, DOE estimates impacts on INPV to range from -$0.03 million to -$0.05 

million, or a change in INPV of -24.4 percent to -47.3 percent. At this level, industry free cash 

flow is estimated to decrease by approximately 284.4 percent to -$0.01 million, compared to the 

base-case value of $0.01 million in the year leading up to when the new energy conservation 

standards would need to be met. 

Impacts on INPV range from moderately to substantially negative at TSL 3. As with TSL 

1 and TSL 2, the entire market falls below the required efficiency and the total industry 

conversion costs estimated by DOE remain at $50,000. However, the MPC increases at TSL 3 

relative to the estimated cost of the baseline unit and changes the possible impacts on INPV at 

TSL 3. If ODMs can fully pass on the higher production cost of these products to the OEM at 

TSL 3, the decline in INPV is less severe. However, if the ODM cannot pass on these higher 

MPC to OEM then the loss in INPV is much more substantial. 

325 
ii. Battery Charger Cash Flow Impacts 

DOE reports INPV impacts at each TSL for the six product class groupings below. When 

appropriate, DOE also discusses the results for groups of related applications that would 

experience impacts significantly different from the overall product class group to which they 

belong. 

In general, two major factors drive the INPV results: (1) the relative difference between a 

given application’s MSP and the incremental cost of improving its battery charger; and (2) the 

dominant base case battery charger technology that a given application utilizes, which is 

approximated by the application’s efficiency distribution. 

With respect to the first point, the higher the MSP of the application relative to the 

battery charger cost, the lower the impacts of battery charger standards on OEMs of the 

application. For example, an industry that sells an application for $500 would be less affected by 

a $2 increase in battery charger costs than one that sells its application for $10. On the second 

point regarding base case efficiency distribution, some industries, such as producers of laptop 

computers, already incorporate highly efficient battery chargers. Therefore, a higher standard 

would be unlikely to impact the laptop industry as it would other applications using baseline 

technology in the same product class. 

As discussed in section IV.I, DOE analyzed three markup scenarios—constant price, pass 

through, and flat markup. These scenarios were described earlier. The constant price scenario 

analyzes the situation in which application manufacturers are unable to pass on any incremental 

326 
 

 

costs of more efficient battery chargers to their customers. This scenario generally results in the 

most significant negative impacts66 because no incremental costs added to the application— 

whether driven by higher battery charger component costs or depreciation of required capital 

investments—can be recouped. 

In the pass through scenario, DOE assumes that manufacturers are able to pass the 

incremental costs of more efficient battery chargers through to their customers, but not with any 

markup to cover overhead and profit. Therefore, though less severe than the constant price 

scenario in which manufacturers absorb all incremental costs, this scenario results in negative 

cash flow impacts due to margin compression and greater working capital requirements. 

Finally, DOE considers a flat markup scenario to analyze the upper bound (most positive) 

of profitability impacts.67 In this scenario, manufacturers are able to maintain their base case 

gross margin, as a percentage of revenue, at higher CSLs, despite the higher product costs 

associated with more efficient battery chargers. In other words, manufacturers can fully pass 

on—and mark up—the higher incremental product costs associated with more efficient battery 

chargers. 

Product Class 1 

The following tables (Table V-20 through Table V-23) summarize information related to 

66 Notably, this is not the case with negative sloping cost-efficiency curves. When a higher efficiency level can be 

achieved at a lower product cost, the constant price scenario yields positive impacts because larger margins are 

realized by the manufacturer on each unit produced.

67 While the Flat Markup scenario typically results in the most positive impacts of any scenario, a negatively sloping 

cost-efficiency curve will yield the opposite effect. When a higher efficiency level can be achieved at a lower 

product cost, the margin on each unit produced is lower, in absolute terms, in the Flat Markup scenario. This effect 

leads to lower operating profit, cash flow, and INPV. 

327 
 

 

the analysis performed to project the potential impacts on product class 1 battery charger 

manufacturers. 

Table V-20 Applications in Product Class 1 

Product Class 1 

Rechargeable Toothbrushes 

Rechargeable Water Jets 

Table V-21 Cash Flow Results – Product Class 1 – Flat Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 491 492 493 520 

Change in INPV 2010$ Millions - 1 1 29 

(%) - 0.1% 0.3% 5.9% 

Product Conversion Costs 2010$ Millions - 0.8 1.9 4.3 

Capital Conversion Costs 2010$ Millions - 0.0 1.8 2.0 

Total Investment Required 2010$ Millions - 0.8 3.7 6.3 

Table V-22 Cash Flow Results – Product Class 1 – Pass Through Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 491 479 461 318 

Change in INPV 2010$ Millions - (12) (31) (173) 

(%) - -2.5% -6.2% -35.3% 

Product Conversion Costs 2010$ Millions - 0.8 1.9 4.3 

Capital Conversion Costs 2010$ Millions - 0.0 1.8 2.0 

Total Investment Required 2010$ Millions - 0.8 3.7 6.3 

Table V-23 Cash Flow Results – Product Class 1 – Constant Price Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 491 450 390 51 

Change in INPV 

2010$ Millions - (41) (101) (441) 

(%) - -8.4% -20.6% -89.7% 

Product Conversion Costs 2010$ Millions - 0.8 1.9 4.3 

Capital Conversion Costs 2010$ Millions - 0.0 1.8 2.0 

Total Investment Required 2010$ Millions - 0.8 3.7 6.3 

Product class 1 has only two applications: rechargeable toothbrushes and water jets. 

Rechargeable toothbrushes represent 99.9 percent of the product class 1 shipments. DOE found 

328 
the majority of these models include nickel-cadmium (Ni-Cd) battery chemistries, although 

products with NiMH and Li-ion chemistries exist in the market. More than three quarters of 

market shipments are at the baseline CSL. However, the efficiency distribution is not necessarily 

indicative of the distribution of retail price points. During interviews, manufacturers indicated 

that energy efficiency was not a primary selling point in this market. As a consequence, 

manufacturers expect that stringent standards would likely impact the low-end of the market, 

where price competition is most fierce and retail selling prices are lowest. 

The incremental costs of meeting TSL 1 and TSL 2, which represent CSL 1 and CSL 2 

for product class 1, respectively, are relatively minor compared to the average application MSP 

of $58.36. While most applications will have to be altered at these TSLs, the relatively small 

increase in battery charger costs do not greatly impact industry cash flow even if none of these 

incremental costs can be passed on to retailers. At max-tech, however, the battery charger is 3.3 

times more expensive than the baseline charger. The baseline level is set at the CSL at which the 

majority of the market currently ships. Therefore, in addition to the R&D efforts necessary to 

prepare all product lines to incorporate the max-tech levels, the inability to pass those much 

higher battery charger costs down the distribution chain drive the negative impacts at max-tech 

in the worst-case constant price scenario. 

Product Classes 2, 3, and 4 

The following tables (Table V-24 through Table V-30) summarize information related to 

the analysis performed to project the potential impacts on manufacturers of devices falling into 

product classes 2, 3, and 4. 

329 
 

 

 

 

Table V-24 Applications in Product Classes 2, 3, and 4 

Product Class 2 Product Class 3 Product Class 4 

Answering Machines Air Mattress Pumps DIY Power Tools (External) 

Baby Monitors Blenders Flashlights/Lanterns 

Beard and Moustache Trimmers Camcorders Handheld Vacuums 

Bluetooth Headsets DIY Power Tools (External) Medical Nebulizers 

Can Openers DIY Power Tools (Integral) Netbooks 

Consumer Two-Way Radios Handheld Vacuums Notebooks 

Cordless Phones Mixers Portable Printers 

Digital Cameras Portable DVD Players Professional Power Tools 

DIY Power Tools (Integral) Portable Printers Professional Power Tools 

E-Books RC Toys Rechargeable Garden Care Products 

Hair Clippers Stick Vacuums Robotic Vacuums 

Handheld GPS Toy Ride-On Vehicles Sleep Apnea Machines 

Home Security Systems Universal Battery Chargers Stick Vacuums 

In-Vehicle GPS VoIP Adapters Universal Battery Chargers 

Media Tablets Wireless Speakers 

Mobile Internet Hotspots 

Mobile Phones 

MP3 Players 

MP3 Speaker Docks 

Personal Digital Assistants 

Portable Video Game Systems 

Shavers 

Smartphone 

Video Game Consoles 

Wireless Headphones 

Table V-25 Cash Flow Results – Product Classes 2, 3, and 4 – Flat Markup Scenario 

Units Base 

Case* 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 44,492 44,506 44,625 45,020 45,467 

Change in INPV 2010$ Millions - 15 134 528 975 

(%) - 0.0% 0.3% 1.2% 2.2% 

Product Conversion Costs 2010$ Millions - 7.1 25.5 160.8 294.5 

Capital Conversion Costs 2010$ Millions - 1.3 6.1 45.4 60.5 

Total Investment Required 2010$ Millions - 8.4 31.6 206.2 355.0 

* The reason the Base Case INPV value varies for this product class grouping is because of the uncertainty of how 

manufacturers will markup their products sold in California due to the CEC standard. The markup scenario used in 

each table for the DOE standard is also applied to those products sold in California. Therefore in the Flat Markup 

table above a flat markup is applied to all products sold in California after the CEC standard goes into effect. 

330 
 

 

Table V-26 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup 

Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 44,268 42,679 42,360 40,810 38,949 

Change in INPV 2010$ Millions - (1,589) (1,908) (3,458) (5,318) 

(%) - -3.6% -4.3% -7.8% -12.0% 

Product Conversion Costs 2010$ Millions - 7.1 25.5 160.8 294.5 

Capital Conversion Costs 2010$ Millions - 1.3 6.1 45.4 60.5 

Total Investment Required 2010$ Millions - 8.4 31.6 206.2 355.0 

Table V-27 Cash Flow Results – Product Classes 2, 3, and 4 – Constant Price Markup 

Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 43,808 38,911 37,752 32,944 29,246 

Change in INPV 2010$ Millions - (4,897) (6,055) (10,863) (14,562) 

(%) - -11.2% -13.8% -24.8% -33.2% 

Product Conversion Costs 2010$ Millions - 7.1 25.5 160.8 294.5 

Capital Conversion Costs 2010$ Millions - 1.3 6.1 45.4 60.5 

Total Investment Required 2010$ Millions - 8.4 31.6 206.2 355.0 

Taken together, product classes 2, 3, and 4 include the greatest number of applications 

and account for more than 75 percent of total battery charger shipments in 2013, the anticipated 

compliance year for new energy conservation standards. These product classes also include a 

wide variety of applications, characterized by differing shipment volumes, base case efficiency 

distributions, and MSPs. Because of this variety, this product class grouping, more than any 

other, requires a greater level of disaggregation to evaluate specific industry impacts. Presented 

only on a product class basis, industry impacts are effectively shipment-weighted and mask 

impacts on certain industry applications that vary substantially from the aggregate results. 

Therefore, in addition to the overall product class group results, DOE also presents results by 

industry subgroups—consumer electronics, small appliances, power tools, and high-energy 

applications—in the pass through scenario, which approximates the mid-point of the potential 

range of impacts. These results highlight impacts at various TSLs. 

331 
TSL 1 would require battery chargers in product classes 2, 3 and 4 to each meet CSL 1. 

Impacts on INPV are relatively moderate at TSL 1 because a majority of application shipments 

in these product classes already meet CSL 1. However, those shipments already meeting CSL 1 

are heavily weighted toward the consumer electronics sector. In most cases, CSL 1 could be met 

with incremental circuit design improvements and higher efficiency components. Satisfying this 

level would not require a full topology redesign or a move to Li-ion chemistry, although 

manufacturers of some applications indicated in interviews that they may elect such a design 

path. 

TSL 2 has the same efficiency requirements for product classes 3 and 4 as TSL 1 (CSL 

1). Product class 2 manufacturers would have to meet CSL 2 at TSL 2, which would likely 

require battery charger design changes (e.g., moving to switched-mode and Li-ion chemistries) 

that would likely cause application manufacturers to incur significant R&D expenditures relative 

to what is normally budgeted for battery chargers. However, the financial impact of this 

investment effect would be minor compared to the base case industry value, which is largely 

driven by consumer electronics applications. 

Industry impacts would become more acute at TSL 3 and TSL 4, as best-in-market or 

max-tech designs would be required for all battery chargers. The cost of a battery charger in 

product classes 3 and 4 rises sharply at CSL 2 (best in market) and further at CSL 3 (max-tech). 

For relatively inexpensive applications, the inability to fully pass on these substantially higher 

costs (as assumed in the pass through and, to a greater extent, the constant price scenario) leads 

332 
to significant margin compression, working capital drains, and, ultimately, reductions in INPV at 

the max-tech TSL. 

As discussed above, these aggregated results can mask differentially impacted industries 

and manufacturer subgroups. Nearly 90 percent of shipments in product classes 2, 3 and 4 fall 

under the broader consumer electronics category, with the remaining share split between small 

appliances and power tools. Consumer electronics applications have a much higher shipmentweighted average MSP ($175) than the other product categories ($80 for power tools and $60 for 

small appliances). Consequently, consumer electronics manufacturers are better able to absorb 

higher battery charger costs than small appliance and power tool manufacturers. Further, 

consumer electronics typically incorporate higher efficiency battery chargers already, while 

small appliances and power tool applications tend to cluster around baseline and CSL 1 

efficiencies. These factors lead to proportionally greater impacts on small appliance and power 

tool manufacturers in the event they are not able to pass on and markup higher battery charger 

costs. 

Table V-28 through Table V-30 present INPV impacts in the pass through markup 

scenario for consumer electronic, power tool, and small appliance applications, respectively (for 

only those applications incorporating battery chargers in product class 2, 3 or 4). The results 

clearly indicate manufacturers of power tools and small appliances would face disproportionately 

adverse impacts, as compared to consumer electronics manufacturers and the overall product 

group’s results (shown above in Table V-25 through Table V-27), if they are not able to mark up 

the incremental product costs. 

333 
 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-28 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup 

Scenario – Consumer Electronics 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 41,894 40,679 40,373 39,160 37,683 

Change in INPV 2010$ Millions - (1,215) (1,521) (2,734) (4,211) 

(%) - -2.9% -3.6% -6.5% -10.1% 

Product Conversion Costs 2010$ Millions - 4.8 22.7 140.4 249.2 

Capital Conversion Costs 2010$ Millions - 1.2 5.8 36.1 48.1 

Total Investment Required 2010$ Millions - 5.9 28.5 176.5 297.3 

Table V-29 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup 

Scenario - Power Tools 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 1,814 1,566 1,560 1,344 1,098 

Change in INPV 2010$ Millions - (248) (254) (470) (716) 

(%) - -13.7% -14.0% -25.9% -39.5% 

Product Conversion Costs 2010$ Millions - 1.7 1.8 10.5 26.7 

Capital Conversion Costs 2010$ Millions - 0.1 0.1 4.7 6.2 

Total Investment Required 2010$ Millions - 1.7 2.0 15.3 32.9 

Table V-30 Cash Flow Results – Product Classes 2, 3, and 4 – Pass Through Markup 

Scenario – Small Appliances 

Units Base 

Case 

Trial Standard Level 

1 2 3 4 

INPV 2010$ Millions 560 435 427 305 168 

Change in INPV 2010$ Millions - (125) (133) (255) (392) 

(%) - -22.4% -23.7% -45.4% -70.0% 

Product Conversion Costs 2010$ Millions - 0.7 0.9 9.9 18.6 

Capital Conversion Costs 2010$ Millions - 0.1 0.2 4.5 6.2 

Total Investment Required 2010$ Millions - 0.7 1.1 14.5 24.7 

Product Classes 5 and 6 

The following tables (Table V-31 through Table V-34) summarize information related to 

the analysis performed to project the potential impacts on manufacturers of devices falling into 

product classes 5 and 6. 

334 
Table V-31 Applications in Product Classes 5 and 6 

Product Class 5 Product Class 6 

Marine/Automotive/RV Chargers Electric Scooters 

Mobility Scooters Lawn Mowers 

Portable O2 Concentrators Motorized Bicycles 

Ride-On Toy Vehicles Wheelchairs 

Wheelchairs 

Ride-on toy vehicles represent nearly three quarters of the combined shipment volume in 

product classes 5 and 6, with marine chargers and electric scooters accounting for the majority of 

the remaining share. DOE’s market survey and interviews found that nearly all of the higher 

energy applications incorporate battery chargers with lead acid battery chemistries. With the 

exception of battery chargers for toy ride-on vehicles and lawn mowers, the majority of products 

in these groupings use baseline battery chargers. 

Table V-32 Cash Flow Results – Product Classes 5 and 6 – Flat Markup Scenario 

Units Base Case* Trial Standard Level 

1 2 3 

INPV 2010$ Millions 1,584 1,589 1,543 2,275 

Change in INPV 2010$ Millions - 6 (40) 692 

(%) - 0.3% -2.5% 43.7% 

Product Conversion Costs 2010$ Millions - 1.8 9.8 16.3 

Capital Conversion Costs 2010$ Millions - 0.0 2.1 4.6 

Total Investment Required 2010$ Millions - 1.8 11.9 20.9 

* The reason the Base Case INPV value varies for this product class grouping is because of the uncertainty of how 

manufacturers will markup their products sold in California due to the CEC standard. The markup scenario used in 

each table for the DOE standard is also applied to those products sold in California. Therefore in the Flat Markup 

table above a flat markup is applied to all products sold in California after the CEC standard goes into effect. 

Table V-33 Cash Flow Results – Product Classes 5 and 6 – Pass Through Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 1,549 1,281 1,324 235 

Change in INPV 2010$ Millions - (268) (225) (1,314) 

(%) - -17.3% -14.5% -84.8% 

Product Conversion Costs 2010$ Millions - 1.8 9.8 16.3 

Capital Conversion Costs 2010$ Millions - 0.0 2.1 4.6 

Total Investment Required 2010$ Millions - 1.8 11.9 20.9 

335 
Table V-34 Cash Flow Results – Product Classes 5 and 6 – Constant Price Markup 

Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 1,552 1,226 1,429 409 

Change in INPV 2010$ Millions - (327) (123) (1,143) 

(%) - -21.0% -7.9% -73.6% 

Product Conversion Costs 2010$ Millions - 1.8 9.8 16.3 

Capital Conversion Costs 2010$ Millions - 0.0 2.1 4.6 

Total Investment Required 2010$ Millions - 1.8 11.9 20.9 

TSL 1, TSL 2, and TSL 3 represent CSL 1, CSL 2, and CSL 3, respectively, for both 

product class 5 and product class 6. The battery charger cost associated with each CSL is the 

same for product classes 5 and 6. The industry impacts at TSL 1 are minor to moderate because a 

large percentage of the market already meets the CSLs represented in that TSL and because the 

incremental battery charger product costs are minor relative to the average application MSP of 

$220. At TSL 2, the battery charger cost declines compared to the baseline because of the 

technology shift from a line-frequency power supply to a switch-mode power supply, and the 

resulting impacts are projected to remain fairly moderate. At TSL 3, however, the impacts on 

INPV are severe because the required max-tech battery chargers would cost nearly seven times 

the cost of a baseline charger. 

Under the flat markup scenario, which assumes manufacturers could fully mark up the 

product to recover this additional cost, such an increase generates substantially greater cash flow 

and industry value. However, as noted earlier, the greater the increase in product costs, the less 

likely DOE believes that manufacturers will be able to fully markup the substantially higher 

production costs (the flat markup scenario). DOE believes manufacturers would be forced to 

absorb much of this dramatic cost increase at max-tech, yielding the substantially negative 

industry impacts, as shown by the lower-bound results. 

336 
 

 

Product Class 7 

The following tables (Table V-35 through Table V-38) summarize information related to 

the analysis performed to project the potential impacts on manufacturers of devices falling into 

product class 7. 

Table V-35 Applications in Product Class 7 

Product Class 7 

Golf Cars 

Table V-36 Cash Flow Results – Product Class 7 – Flat Markup Scenario 

Units Base Case* Trial Standard Level 

1 2 

INPV 2010$ Millions 1,034 1,030 1,057 

Change in INPV 2010$ Millions - (4) 23 

(%) - -0.4% 2.2% 

Product Conversion Costs 2010$ Millions - 0.6 2.6 

Capital Conversion Costs 2010$ Millions - 0.2 1.5 

Total Investment Required 2010$ Millions - 0.7 4.1 

* The reason the Base Case INPV value varies for this product class grouping is because of the uncertainty of how 

manufacturers will markup their products sold in California due to the CEC standard. The markup scenario used in 

each table for the DOE standard is also applied to those products sold in California. Therefore in the Flat Markup 

table above a flat markup is applied to all products sold in California after the CEC standard goes into effect. 

Table V-37 Cash Flow Results – Product Class 7 – Pass Through Markup Scenario 

Units Base Case Trial Standard Level 

1 2 

INPV 2010$ Millions 1,036 1,050 1,003 

Change in INPV 2010$ Millions - 14 (33) 

(%) - 1.4% -3.2% 

Product Conversion Costs 2010$ Millions - 0.6 2.6 

Capital Conversion Costs 2010$ Millions - 0.2 1.5 

Total Investment Required 2010$ Millions - 0.7 4.1 

337 
 

Table V-38 Cash Flow Results – Product Class 7 – Constant Price Markup Scenario 

Units Base Case Trial Standard Level 

1 2 

INPV 2010$ Millions 1,039 1,086 903 

Change in INPV 2010$ Millions - 47 (136) 

(%) - 4.5% -13.1% 

Product Conversion Costs 2010$ Millions - 0.6 2.6 

Capital Conversion Costs 2010$ Millions - 0.2 1.5 

Total Investment Required 2010$ Millions - 0.7 4.1 

Golf cars are the only application in product class 7. Approximately half the market 

incorporates baseline battery charger technology -- the other half employs technology that meets 

the efficiency requirements at CSL 1. The cost of a battery charger in product class 7, though 

higher relative to other product classes, remains a small portion of the overall selling price of a 

golf car. As such, large percentage increases in the cost of the battery charger, as in the case of 

max-tech, do not yield severe impacts on golf car OEMs, even in the constant price scenario. 

Note, however, this analysis focuses on the application manufacturer, or the OEM. DOE did 

identify a U.S. small business manufacturer of the golf car battery charger itself (as opposed to 

the application). DOE evaluates the impacts on standards on such manufacturers in the 

Regulatory Flexibility Analysis (see section VI.B for the results of that analysis). 

Product Class 8 

The following tables (Table V-39 through Table V-42) summarize information related to 

the analysis performed to project the potential impacts on manufacturers of devices falling into 

product class 8. 

338 
 

 

Table V-39 Applications in Product Class 8 

Product Class 8 

Bluetooth Headsets 

Camcorders 

Digital Cameras 

E-Books 

Handheld GPS 

Handheld Image Scanners 

Mobile Phones 

MP3 Players 

Personal Digital Assistants 

Table V-40 Cash Flow Results – Product Class 8 – Flat Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 5,703 5,628 5,707 5,672 

Change in INPV 2010$ Millions - (75) 4 (30) 

(%) - -1.3% 0.1% -0.5% 

Product Conversion Costs 2010$ Millions - 13.2 35.8 79.5 

Capital Conversion Costs 2010$ Millions - 0.0 6.1 6.8 

Total Investment Required 2010$ Millions - 13.2 41.9 86.3 

Table V-41 Cash Flow Results – Product Class 8 – Pass Through Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 5,703 6,064 5,730 5,663 

Change in INPV 2010$ Millions - 361 27 (40) 

(%) - 6.3% 0.5% -0.7% 

Product Conversion Costs 2010$ Millions - 13.2 35.8 79.5 

Capital Conversion Costs 2010$ Millions - 0.0 6.1 6.8 

Total Investment Required 2010$ Millions - 13.2 41.9 86.3 

Table V-42 Cash Flow Results – Product Class 8 – Constant Price Markup Scenario 

Units Base Case Trial Standard Level 

1 2 3 

INPV 2010$ Millions 5,703 7,002 5,781 5,642 

Change in INPV 2010$ Millions - 1,300 78 (61) 

(%) - 22.8% 1.4% -1.1% 

Product Conversion Costs 2010$ Millions - 13.2 35.8 79.5 

Capital Conversion Costs 2010$ Millions - 0.0 6.1 6.8 

Total Investment Required 2010$ Millions - 13.2 41.9 86.3 

339 
Product class 8 includes 14 applications, mostly consumer electronics. MP3 players and 

mobile phones make up the vast majority of product class 8 shipments (58 percent and 31 

percent, respectively). Approximately 50 percent of MP3 players meet CSL 1 or higher and 73 

percent of mobile phones already incorporate best-in-market battery chargers that exceed CSL 2. 

For most other applications in this product class, roughly two-thirds of the incorporated battery 

chargers already meet or exceed CSL 1. Furthermore, because the manufacturer selling prices of 

these dominant applications dwarf the incremental product costs associated with increasing the 

efficiency—even at max-tech—the overall industry impacts are projected to be minor for all 

TSLs for product class 8. 

Product Class 9 

Table V-43 Applications in Product Class 9 

Product Class 9 

Flashlights/Lanterns 

In-Vehicle GPS 

Medical Nebulizers 

Portable O2 Concentrators 

DOE did not examine any TSLs for product class 9 and did not conduct any downstream 

analyses for this product class. For product class 9, DOE is not proposing any energy 

conservation standards. Section V.B.2.fof this NOPR provides a more detailed reason for this 

decision. 

Product Class 10 

The following tables (Table V-44 through Table V-47) summarize information related to 

the analysis performed to project the potential impacts on manufacturers of devices falling into 

product class 10. 

340 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-44 Applications in Product Class 10 

Product Class 10 

Uninterruptible Power Supplies 

Table V-45 Cash Flow Results – Product Class 10 – Flat Markup Scenario 

Units Base 

Case* 

Trial Standard Level 

1 2 3 

INPV 2010$ Millions 614 614 612 609 

Change in INPV 2010$ Millions - (0) (2) (5) 

(%) - -0.1% -0.4% -0.9% 

Product Conversion Costs 2010$ Millions - 0.7 2.2 4.5 

Capital Conversion Costs 2010$ Millions - 0.0 0.4 1.5 

Total Investment Required 2010$ Millions - 0.7 2.6 6.0 

* The reason the Base Case INPV value varies for this product class grouping is because of the uncertainty of how 

manufacturers will markup their products sold in California due to the CEC standard. The markup scenario used in 

each table for the DOE standard is also applied to those products sold in California. Therefore in the Flat Markup 

table above a flat markup is applied to all products sold in California after the CEC standard goes into effect. 

Table V-46 Cash Flow Results – Product Class 10 – Pass Through Markup Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 

INPV 2010$ Millions 614 593 586 577 

Change in INPV 2010$ Millions - (21) (28) (37) 

(%) - -3.5% -4.5% -5.9% 

Product Conversion Costs 2010$ Millions - 0.7 2.2 4.5 

Capital Conversion Costs 2010$ Millions - 0.0 0.4 1.5 

Total Investment Required 2010$ Millions - 0.7 2.6 6.0 

Table V-47 Cash Flow Results – Product Class 10 – Constant Price Markup Scenario 

Units Base 

Case 

Trial Standard Level 

1 2 3 

INPV 2010$ Millions 612 532 512 487 

Change in INPV 2010$ Millions - (81) (100) (126) 

(%) - -13.2% -16.4% -20.5% 

Product Conversion Costs 2010$ Millions - 0.7 2.2 4.5 

Capital Conversion Costs 2010$ Millions - 0.0 0.4 1.5 

Total Investment Required 2010$ Millions - 0.7 2.6 6.0 

Product class 10 has only one application: uninterruptible power supplies. The vast 

majority of models on the market have sealed lead-acid battery chemistries. The efficiency 

distribution for product class 10 assumes all shipments are at the baseline CSL. Compared to the 

341 
average application MSP of approximately $289, the incremental costs of meeting the higher 

CSLs remain relatively low, despite increasing substantially on a percentage basis. Therefore, 

even in the constant price scenario, INPV impacts are projected to be limited. 

b. Impacts on Employment 

As part of the direct employment impact analysis, DOE attempted to quantify the number 

of domestic workers involved in EPS manufacturing. Based on manufacturer interviews and 

DOE’s research, DOE believes that all major EPS ODMs are foreign owned and operated. DOE 

did identify a few smaller niche EPS ODMs based in the U.S. and attempted to contact these 

companies. All of the companies DOE reached indicated their EPS manufacturing takes place 

abroad. During manufacturer interviews, large manufacturers also indicated the vast majority, if 

not all, EPS production takes place overseas. Due to DOE’s inability to identify any EPS ODMs 

with domestic manufacturing, DOE has tentatively concluded that there are no EPSs currently 

manufactured domestically. However, in recognition of the fragmented nature of this market, 

DOE seeks comment and input as to whether there are EPS manufacturers that have domestic 

production. 

DOE also recognizes there are several OEMs or their domestic distributors that have 

employees in the U.S. that work on design, technical support, sales, training, certification, and 

other requirements. However, in interviews manufacturers generally did not expect any negative 

changes in the domestic employment of the design, technical support, or other departments of 

EPS OEMs located in the U.S. in response to new or amended energy conservation standards. 

342 
For battery chargers, DOE similarly attempted to quantify the number of domestic 

workers involved in battery charger production. Based on manufacturer interviews and DOE’s 

research, DOE believes that the vast majority of all small appliance and consumer electronic 

applications are manufactured abroad. When looking specifically at the battery charger 

component, which is typically designed by the application manufacturer but sourced for 

production, the same dynamic holds to an even greater extent. That is, in the rare instance when 

an application’s production occurs domestically, it is very likely that the battery charger 

component is still produced and sourced overseas. For example, DOE identified several power 

tool applications with some level of domestic manufacturing. However, based on more detailed 

information obtained during interviews, DOE believes the battery charger components for these 

applications are sourced from abroad. 

Also, DOE was able to find a few manufacturers of medium and high power applications 

with facilities in the U.S. However, only a limited number of these companies produce battery 

chargers domestically for these applications. Therefore, based on manufacturer interviews and 

DOE’s research, DOE believes that golf cars are the only application with U.S.-based battery 

charger manufacturing. Any change in U.S. production employment due to new battery charger 

energy conservation standards is likely to come from changes involving these particular 

products. DOE seeks comment on the presence of any domestic battery charger manufacturing 

outside of the golf car industry and beyond prototyping for R&D purposes. 

At the proposed efficiency levels, domestic golf car manufacturers will face a difficult 

decision on whether to attempt to manufacture more efficient battery chargers in-house and try to 

343 
compete with a greater level of vertical integration than their competitors, move production to 

lower-wage regions abroad, or source their battery charger manufacturing. DOE believes one of 

the latter two strategies would be more likely for domestic golf car manufacturers. DOE 

describes the major implications for golf car employment in the regulatory flexibility section 

VI.B below because the major domestic manufacturer is also a small business manufacturer. 

Similar to EPSs, DOE does not anticipate any negative changes in the domestic employment of 

the design, technical support, or other departments of battery charger application manufacturers 

located in the U.S. in response to new energy conservation standards. Standards may require 

some companies to redesign their battery chargers, change marketing literature, and train some 

technical and sales support staff. However, during interviews, manufacturers generally agreed 

these changes would not lead to positive or negative changes in employment. 

c. Impacts on Manufacturing Capacity 

DOE does not anticipate that the standards proposed in today’s rule would adversely 

impact manufacturer capacity. For EPSs, EISA has set a statutory compliance date. The EPS 

industry is characterized by rapid product development lifecycles. Most battery charger 

applications have similar design cycles. While there is no statutory compliance date for battery 

chargers, DOE believes the compliance date proposed in today’s rule provides sufficient time for 

manufacturers to ramp up capacity to meet the proposed standards for battery chargers and EPSs. 

DOE requests comment on the appropriate compliance date for battery charger (see section I). 

344 
d. Impacts on Sub-Group of Manufacturers 

Using average cost assumptions to develop an industry cash-flow estimate is not adequate 

for assessing differential impacts among manufacturer subgroups. Small manufacturers, niche 

equipment manufacturers, and manufacturers exhibiting a cost structure substantially different 

from the industry average could be affected disproportionately. DOE addressed manufacturer 

subgroups in the battery charger MIA. Because certain applications are disproportionately 

impacted compared to the overall product class, DOE reports those results individually so they 

can be considered as part of the overall MIA. DOE did not identify any EPS manufacturer 

subgroups that would require a separate analysis in the MIA. 

DOE also identified small businesses as a subgroup that could potentially be 

disproportionally impacted. DOE discusses the impacts on the small business subgroup in the 

regulatory flexibility analysis (section VI.B). 

e. Cumulative Regulatory Burden 

While any one regulation may not impose a significant burden on manufacturers, the 

combined effects of several impending regulations may have serious consequences for some 

manufacturers, groups of manufacturers, or an entire industry. Assessing the impact of a single 

regulation may overlook this cumulative regulatory burden. In addition to energy conservation 

standards, other regulations can significantly affect manufacturers’ financial operations. Multiple 

regulations affecting the same manufacturer can strain profits and can lead companies to 

abandon product lines or markets with lower expected future returns than competing products. 

For these reasons, DOE conducts an analysis of cumulative regulatory burden as part of its 

345 
 

rulemakings pertaining to appliance efficiency. DOE received many comments about the 

potential cumulative regulatory burden (see section IV.I.4.a) that may result from a standard for 

battery chargers and EPSs. The regulatory burdens described in those comments, however, 

generally fall outside of the scope of the cumulative regulatory burden analysis, which generally 

focuses on the impacts related to Federal regulations with a compliance date within three years 

of the anticipated compliance date of today’s proposal. DOE notes that the potential for 

duplicative testing requirements raised by some commenters were addressed above. 

i. Impact Due to CEC Battery Charger Standard 

Table V-48 presents the range of impacts on all battery charger product classes due to the 

CEC battery charger standards. 

Table V-48 – Base Case Manufacturer Impact Analysis for All Battery Charger Product 

Classes Due to the CEC Standard 

Units 

No 

California 

Standard 

With California Standard* 

Flat Markup 

Pass 

Through 

Markup 

Constant 

Price 

Markup 

INPV 2010$ Millions 53,780 53,918 53,660 53,205 

Change in INPV 2010$ Millions - 137 -120 -575 

(%) - 0.3 (0.2) (1.1) 

Product Conversion Costs 2010$ Millions - 12.6 12.6 12.6 

Capital Conversion Costs 2010$ Millions - 3.8 3.8 3.8 

Total Investment Required 2010$ Millions - 16.4 16.4 16.4 

* The reason the Base Case INPV value varies for battery chargers is because of the uncertainty of how 

manufacturers will markup their products sold in California due to the CEC standard. The markup scenario used in 

each column is applied to those products sold in California. Therefore in the Constant Price column a constant price 

markup is applied to all products sold in California after the CEC standard goes into effect. 

DOE quantitatively assessed the impact of the CEC battery charger standard on battery 

charger application manufacturers. This standard affects applications using a battery charger that 

are sold in California beginning in 2013. DOE estimates the impacts on manufacturers to range 

from $137 million to -$575 million, or a change in INPV of 0.3 percent to -1.1 percent. This 

346 
range depends on manufacturers’ ability to pass on the incremental price increases to consumers 

in the California markets caused by the CEC standard. DOE also estimated manufacturers will 

have to invest $12.6 million in product conversion costs and $3.8 million in capital conversion 

costs in order to have all battery charger applications sold in California meet the CEC standard 

by 2013. 

3. National Impact Analysis 

a. Significance of Energy Savings 

To estimate the energy savings during the analysis period attributable to potential 

standards for battery chargers and EPSs, DOE compared the energy consumption of these 

products in the base case to their anticipated energy consumption with standards set at each TSL. 

Table V-49 and Table V-50 present DOE’s forecasts of the national energy savings at 

each TSL for battery chargers and EPSs. The savings were calculated using the approach 

described in section IV.G. Chapter 10 of the NOPR TSD presents tables that also show the 

magnitude of the energy savings if the savings are discounted at rates of 3 and 7 percent. 

Discounted energy savings represent a policy perspective in which energy savings realized 

farther in the future are less significant than energy savings realized in the nearer term. 

Table V-49 External Power Supplies: Cumulative National Energy Savings in Quads 

Product Class Trial Standard Level 

1 2 3 

B 0.458 0.725 1.316 

B,C,D, E 0.585 0.916 1.604 

X 0.063 0.072 0.147 

H 0.001 0.001 0.002 

347 
 

Table V-50 Battery Chargers: Cumulative National Energy Savings in Quads 

Product Class Trial Standard Level 

1 2 3 4 

1 0.056 0.130 0.178 N/A 

2, 3, 4 0.309 0.759 1.797 1.997 

5, 6 0.268 0.596 0.781 N/A 

7 0.007 0.021 N/A N/A 

8 0.010 0.041 0.045 N/A 

10 0.231 0.268 0.312 N/A 

b. Net Present Value of Consumer Costs and Benefits 

DOE estimated the cumulative NPV to the Nation of the total costs and savings for 

consumers that would result from potential standard levels for battery chargers and EPSs. In 

accordance with the OMB’s guidelines on regulatory analysis (OMB Circular A-4, section E, 

September 17, 2003), DOE calculated NPV using both a 3-percent and a 7-percent real discount 

rate. 

Table V-51 and Table V-52 show the consumer NPV results for each TSL DOE 

considered for EPSs, using both a 3-percent and a 7-percent discount rate. Table V-53 and Table 

V-54 show the corresponding results for battery chargers. In each case, the impacts cover the 

lifetime of products purchased in 2013–2042. See chapter 10 of the TSD for more detailed NPV 

results. 

Table V-51 Cumulative Net Present Value of Consumer Benefits for External Power 

Supplies, 3-Percent Discount Rate (2010$ millions) 

Product Class Trial Standard Level 

1 2 3 

B 1,227.7 1,138.4 (3,292.3) 

B,C,D, E 1,542.2 1,525.4 (2,982.9) 

X 329.2 330.3 (533.2) 

H 9.4 9.7 7.6 

348 
Table V-52 Cumulative Net Present Value of Consumer Benefits for External Power 

Supplies, 7-Percent Discount Rate (2010$ millions) 

Product Class Trial Standard Level 

1 2 3 

B 596.2 463.3 (2,356.8) 

B,C,D, E 729.7 613.5 (2,301.4) 

X 177.7 175.5 (363.5) 

H 4.8 5.0 3.6 

Table V-53 Cumulative Net Present Value of Consumer Benefits for Battery Chargers, 3-

Percent Discount Rate (2010$ millions) 

Product Class Trial Standard Level 

1 2 3 4 

1 294.0 605.6 (781.2) N/A 

2, 3, 4 1,255.1 (366.9) (14,159.0) (38,442.7) 

5, 6 1,627.9 4,647.7 (11,122.7) N/A 

7 119.4 (493.2) N/A N/A 

8 2,780.5 (1,654.5) (2,001.1) N/A 

10 1,192.4 1,354.4 1,549.5 N/A 

Table V-54 Cumulative Net Present Value of Consumer Benefits for Battery Chargers, 7-

Percent Discount Rate (2010$ millions) 

Product Class Trial Standard Level 

1 2 3 4 

1 156.8 317.9 (527.2) N/A 

2, 3, 4 663.8 (434.7) (8,973.2) (23,542.1) 

5, 6 867.3 2,539.4 (6,961.4) N/A 

7 69.8 (299.5) N/A N/A 

8 1,659.3 (999.9) (1,208.3) N/A 

10 611.3 691.9 788.9 N/A 

DOE conducted NPV sensitivity analysis using three alternative price trends. The NPV 

results from the associated sensitivity cases are described in appendix 10-X of the NOPR TSD. 

349 
c. Indirect Impacts on Employment 

DOE develops estimates of the indirect employment impacts of potential standards on the 

economy in general. As discussed above, DOE expects energy conservation standards for battery 

chargers and EPSs to reduce energy bills for consumers of these products, and the resulting net 

savings to be redirected to other forms of economic activity. These expected shifts in spending 

and economic activity could affect the demand for labor. As described in section IV.J, to 

estimate these effects DOE used an input/output model of the U.S. economy. DOE understands 

that there are uncertainties involved in projecting employment impacts generated by an 

input/output model, especially changes in the later years of the analysis. Therefore, DOE 

generated results for near-term timeframes, such as 2015, where these uncertainties are reduced. 

The results suggest the proposed standards are likely to have negligible impact on the net 

demand for labor in the economy. The net change in jobs is so small that it would be 

imperceptible in national labor statistics and might be offset by other, unanticipated effects on 

employment. Chapter 13 of the NOPR TSD presents more detailed results. 

4. Impact on Utility or Performance of Products 

As presented in section III.B of this notice, DOE has tentatively concluded that none of 

the TSLs considered in this notice would reduce the utility or performance of the products under 

consideration in this rulemaking. Furthermore, manufacturers of these products currently offer 

EPSs and battery chargers that meet or exceed the proposed standards. (42 U.S.C. 

6295(o)(2)(B)(i)(IV)) 

350 
5. Impact of Any Lessening of Competition 

DOE has also considered any lessening of competition that is likely to result from 

amended standards. The Attorney General determines the impact, if any, of any lessening of 

competition likely to result from a proposed standard, and transmits such determination to the 

Secretary, together with an analysis of the nature and extent of such impact. (42 U.S.C. 

6295(o)(2)(B)(i)(V) and (B)(ii)) 

To assist the Attorney General in making such determination, DOE will provide DOJ 

with copies of this NOPR and the TSD for review. DOE will consider DOJ’s comments on the 

proposed rule in preparing the final rule, and DOE will publish and respond to DOJ’s comments 

in that document. 

6. Need of the Nation to Conserve Energy 

An improvement in the energy efficiency of the products subject to today’s NOPR is 

likely to improve the security of the Nation’s energy system and reduce the costs of energy 

production. Reduced electricity demand may also improve the reliability of the electricity 

system, particularly during peak-load periods. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) 

Energy savings from amended standards for Class A EPSs and new standards for nonClass A EPSs and battery chargers could also produce environmental benefits in the form of 

reduced emissions of air pollutants and greenhouse gases associated with electricity production. 

Table V-55 and Table V-56 provide DOE’s estimate of cumulative CO2, NOX, and Hg emissions 

reductions that would be expected to result from each of the TSLs considered in this rulemaking 

351 
 

for EPSs and battery chargers, respectively. In the environmental assessment (chapter 15 in the 

NOPR TSD), DOE reports annual CO2, NOX, and Hg emissions reductions for each considered 

TSL. 

As discussed in section IV.L, DOE has not reported SO2 emissions reductions from 

power plants, because there is uncertainty about the effect of energy conservation standards on 

the overall level of SO2 emissions in the United States due to SO2 emissions caps. DOE also did 

not include NOX emissions reduction from power plants in States subject to CAIR because an 

amended energy conservation standard would not affect the overall level of NOX emissions in 

those States due to the emissions caps mandated by CAIR. 

Table V-55 Cumulative Emissions Reduction for 2013- 2042 Under External Power Supply 

TSLs 

TSL 1 TSL 2 TSL 3 

Product Class B 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

21.7 

17.9 

0.115 

34.3 

28.4 

0.182 

62.5 

51.6 

0.331 

Product Classes B, C, 

D, and E 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

27.5 

22.7 

0.145 

43.0 

35.5 

0.227 

75.4 

62.3 

0.398 

Product Class X 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

2.95 

2.43 

0.015 

3.38 

2.79 

0.018 

6.92 

5.71 

0.036 

Product Class H 

CO2 (Mt) 

NOX (kt) 

Hg(t) 

0.054 

0.045 

0.000 

0.058 

0.048 

0.000 

0.065 

0.053 

0.000 

Table V-56 Cumulative Emissions Reduction for 2013- 2042 Under Battery Charger TSLs 

TSL 1 TSL 2 TSL 3 TSL 4 

Product Class 1 

CO2 (Mt) 

NOX (kt) 

2.62 

2.17 

6.11 

5.05 

8.36 

6.90 

N/A 

N/A 

352 
Hg(t) 0.014 0.032 0.044 N/A 

Product Classes 2, 3, 4 

CO2 (Mt) 14.7 35.9 85.1 94.6 

NOX (kt) 12.1 29.7 70.3 78.1 

Hg(t) 0.078 0.191 0.452 0.502 

Product Classes 5, 6 

CO2 (Mt) 12.4 27.4 35.9 N/A 

NOX (kt) 10.2 22.6 29.6 N/A 

Hg(t) 0.065 0.143 0.187 N/A 

Product Class 7 

CO2 (Mt) 0.312 0.975 N/A N/A 

NOX (kt) 0.259 0.808 N/A N/A 

Hg(t) 0.002 0.006 N/A N/A 

Product Class 8 

CO2 (Mt) 0.457 1.95 2.16 N/A 

NOX (kt) 0.378 1.61 1.78 N/A 

Hg(t) 0.002 0.010 0.011 N/A 

Product Class 10 

CO2 (Mt) 10.3 11.9 13.9 N/A 

NOX (kt) 8.46 9.81 11.5 N/A 

Hg(t) 0.068 0.079 0.092 N/A 

DOE also estimated monetary benefits likely to result from the reduced emissions of CO2 

and NOX that DOE estimated for each of the TSLs considered for battery chargers and EPSs. In 

order to make this calculation similar to the calculation of the NPV of consumer benefits, DOE 

considered the reduced emissions expected to result over the lifetime of products shipped in the 

forecast period for each TSL. 

As discussed in section IV.M, a Federal interagency group selected four SCC values for 

use in regulatory analyses, which DOE used in the NOPR analysis. The four SCC values 

(expressed in 2007$) are $4.7/ton (the average value from a distribution that uses a 5-percent 

discount rate), $21.4/ton (the average value from a distribution that uses a 3-percent discount 

rate), $35.1/ton (the average value from a distribution that uses a 2.5-percent discount rate), and 

$64.9/ton (the 95th-percentile value from a distribution that uses a 3-percent discount rate). These 

353 
 

 

values correspond to the value of CO2 emission reductions in 2010; the values for later years are 

higher due to increasing damages as the magnitude of climate change increases. For each of the 

four cases, DOE calculated a present value of the stream of annual values using the same 

discount rate as was used in the studies upon which the dollar-per-ton values are based. 

Table V-57 to Table V-60 and Table V-61 to Table V-66 present the global values of 

CO2 emissions reductions at each TSL considered for energy efficiency for EPSs and battery 

chargers, respectively. As explained in section IV.M.1, DOE calculated domestic values as a 

range from 7 percent to 23 percent of the global values, and these results are presented in Table 

V-67to Table V-70 and Table V-71 to Table V-76 for EPSs and battery chargers, respectively. 

Table V-57 External Power Supply Product Class B: Estimates of Global Present Value of 

CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 91 448 752 1,369 

2 145 710 1,190 2,166 

3 263 1,289 2,162 3,936 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-58 External Power Supply Product Classes B, C, D, and E: Estimates of Global 

Present Value of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 116 572 960 1,746 

2 182 895 1,501 2,731 

3 319 1,568 2,631 4,785 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

354 
 

 

 

Table V-59 External Power Supply Product Class X: Estimates of Global Present Value of 

CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 12 61 103 187 

2 14 70 118 215 

3 29 144 242 440 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-60 External Power Supply Product Class H: Estimates of Global Present Value of 

CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 0 1 2 4 

2 0 1 2 4 

3 0 1 2 4 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-61 Battery Charger Product Class 1: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 11 55 92 167 

2 26 127 213 388 

3 35 174 292 531 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-62 Battery Chargers Product Classes 2, 3, 4: Estimates of Global Present Value of 

CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 62 302 506 921 

355 
 

 

 

 

2 151 740 1,242 2,260 

3 358 1,753 2,940 5,352 

4 398 1,949 3,268 5,949 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-63 Battery Chargers Product Classes 5, 6: Estimates of Global Present Value of 

CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 53 261 438 795 

2 118 580 974 1,770 

3 154 760 1,276 2,318 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-64 Battery Chargers Product Class 7: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 1 6 11 19 

2 4 20 33 61 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-65 Battery Chargers Product Class 8: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 2 9 16 29 

2 8 40 67 122 

3 9 44 74 136 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

356 
 

 

 

Table V-66 Battery Chargers Product Class 10: Estimates of Global Present Value of CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, average* 

3% discount rate, 

95th percentile* 

1 45 220 370 672 

2 52 256 430 780 

3 60 298 501 910 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-67 External Power Supply Product Class B: Estimates of Domestic Present Value 

of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 6 to 21 31 to 103 53 to 173 96 to 315 

2 10 to 33 50 to 163 83 to 274 152 to 498 

3 18 to 60 90 to 297 151 to 497 275 to 905 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-68 External Power Supply Product Classes B, C, D, E: Estimates of Domestic 

Present Value of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 8 to 27 40 to 132 67 to 221 122 to 402 

2 13 to 42 63 to 206 105 to 345 191 to 628 

3 22 to 73 110 to 361 184 to 605 335 to 1,101 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-69 External Power Supply Product Class X: Estimates of Domestic Present Value 

of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 3% discount 2.5% discount 3% discount rate, 

357 
 

 

 

rate, average* rate, average* rate, 

average* 

95th percentile* 

1 1 to 3 4 to 14 7 to 24 13 to 43 

2 1 to 3 5 to 16 8 to 27 15 to 49 

3 2 to 7 10 to 33 17 to 56 31 to 101 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-70 External Power Supply Product Class H: Estimates of Domestic Present Value 

of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 0.017 to 0.056 0.085 to 0.280 0.144 to 0.472 0.260 to 0.854 

2 0.018 to 0.060 0.092 to 0.301 0.154 to 0.507 0.279 to 0.918 

3 0.020 to 0.067 0.102 to 0.334 0.172 to 0.564 0.310 to 1.020 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-71 Battery Charger Product Class 1: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 1 to 3 4 to 13 6 to 21 12 to 38 

2 2 to 6 9 to 29 15 to 49 27 to 89 

3 2 to 8 12 to 40 20 to 67 37 to 122 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-72 Battery Charger Product Classes 2, 3, 4: Estimates of Domestic Present Value 

of CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 4 to 14 21 to 69 35 to 116 64 to 212 

358 
 

 

 

 

2 11 to 35 52 to 170 87 to 286 158 to 520 

3 25 to 82 123 to 403 206 to 676 375 to 1,231 

4 28 to 91 136 to 448 229 to 752 416 to 1,368 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-73 Battery Charger Product Classes 5, 6: Estimates of Domestic Present Value of 

CO2 Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 4 to 12 18 to 60 31 to 101 56 to 183 

2 8 to 27 41 to 133 68 to 224 124 to 407 

3 11 to 35 53 to 175 89 to 293 162 to 533 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-74 Battery Charger Product Class 7: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 0.091 to 0.300 0.446 to 1 1 to 2 1 to 4 

2 0 to 1 1 to 5 2 to 8 4 to 14 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-75 Battery Charger Product Class 8: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 0.135 to 0.442 0.658 to 2 1 to 4 2 to 7 

2 1 to 2 3 to 9 5 to 15 9 to 28 

3 1 to 2 3 to 10 5 to 17 9 to 31 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

359 
 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

Table V-76 Battery Charger Product Class 10: Estimates of Domestic Present Value of CO2 

Emissions Reduction Under TSLs 

TSL 

Million 2010$ 

5% discount 

rate, average* 

3% discount 

rate, average* 

2.5% discount 

rate, 

average* 

3% discount rate, 

95th percentile* 

1 3 to 10 15 to 51 26 to 85 47 to 155 

2 4 to 12 18 to 59 30 to 99 55 to 179 

3 4 to 14 21 to 69 35 to 115 64 to 209 

* Columns are labeled by the discount rate used to calculate the SCC and whether it is an average value or drawn 

from a different part of the distribution. Values presented in the table are based on escalating the SCC values in 

2007$ to 2010$ for consistency with other values presented in this notice, and incorporate the escalation of the SCC 

over time. 

DOE is well aware that scientific and economic knowledge about the contribution of CO2 

and other GHG emissions to changes in the future global climate and the potential resulting 

damages to the world economy continues to evolve rapidly. Thus, any value placed in this 

rulemaking on reducing CO2 emissions is subject to change. DOE, together with other Federal 

agencies, will continue to review various methodologies for estimating the monetary value of 

reductions in CO2 and other GHG emissions. This ongoing review will consider any comments 

on this subject that are part of the public record for this and other rulemakings, as well as other 

methodological assumptions and issues. However, consistent with DOE’s legal obligations, and 

taking into account the uncertainty involved with this particular issue, DOE has included in this 

NOPR the most recent values and analyses resulting from the ongoing interagency review 

process. 

DOE also estimated a range for the cumulative monetary value of the economic benefits 

associated with NOX emissions reductions anticipated to result from amended standards for Class 

A EPSs and new standards for non-Class A EPSs and battery chargers. The dollar-per-ton values 

360 
that DOE used are discussed in section IV.M. Table V-77 presents the cumulative present values 

for each TSL considered for EPSs, calculated using 7-percent and 3-percent discount rates. Table 

V-78 presents similar results for the TSLs considered for battery chargers. 

Table V-77 Estimates of Present Value of NOX Emissions Reduction Under External Power 

Supply TSLs 

TSL 1 TSL 2 TSL 3 

Million 2010$ 

Product Class B 

3% discount rate 

7% discount rate 

5 to 53 

3 to 29 

8 to 83 

5 to 47 

15 to 151 

8 to 85 

Product Classes B, C, D, E 

3% discount rate 

7% discount rate 

6 to 67 

4 to 37 

10 to 104 

6 to 58 

18 to 183 

10 to 102 

Product Class X 

3% discount rate 

7% discount rate 

1 to 7 

0 to 4 

1 to 8 

0 to 5 

2 to 17 

1 to 9 

Product Class H 

3% discount rate 

7% discount rate 

0.013 to 0.135 

0.007 to 0.069 

0.014 to 0.145 

0.007 to 0.074 

0.016 to 0.161 

0.008 to 0.082 

361 
 

Table V-78 Estimates of Present Value of NOX Emissions Reduction Under Battery 

Charger TSLs 

TSL 1 TSL 2 TSL 3 TSL 4 

Million 2010$ 

Product Class 1 

3% discount rate 

7% discount rate 

1 to 6 

0.344 to 4 

1 to 15 

1 to 8 

2 to 20 

1 to 11 

N/A. 

N/A. 

Product Classes 2, 3, 4 

3% discount rate 

7% discount rate 

3 to 35 

2 to 20 

8 to 87 

5 to 49 

20 to 206 

11 to 116 

22 to 229 

13 to 129 

Product Classes 5, 6 

3% discount rate 

7% discount rate 

3 to 30 

2 to 16 

7 to 67 

4 to 37 

9 to 88 

5 to 48 

N/A. 

N/A. 

Product Class 7 

3% discount rate 

7% discount rate 

0.073 to 1 

0.042 to 0.431 

0.229 to 2 

0.131 to 1 

N/A. 

N/A. 

N/A. 

N/A. 

Product Class 8 

3% discount rate 

7% discount rate 

0.108 to 1 

0.061 to 1 

0.459 to 5 

0.260 to 3 

1 to 5 

0.288 to 3 

N/A 

N/A. 

Product Class 10 

3% discount rate 

7% discount rate 

2 to 25 

1 to 14 

3 to 29 

2 to 16 

3 to 34 

2 to 18 

N/A 

N/A. 

The NPV of the monetized benefits associated with emissions reductions can be viewed 

as a complement to the NPV of the consumer savings calculated for each TSL considered in this 

rulemaking. Table V-79 shows an example of the calculation of the combined NPV, including 

benefits from emissions reductions for the case of TSL 1 for battery chargers product classes 2, 

3, 4. Table V-80 and Table V-81 present the NPV values that result from adding the estimates of 

the potential economic benefits resulting from reduced CO2 and NOX emissions in each of four 

valuation scenarios to the NPV of consumer savings calculated for each TSL considered for 

EPSs, at both a 7-percent and a 3-percent discount rate. The CO2 values used in the columns of 

each table correspond to the four scenarios for the valuation of CO2 emission reductions 

362 
 

 

 

 

 

presented in section IV.M. Table V-82 and Table V-83 present similar results for the TSLs 

considered for battery chargers. 

Table V-79 Adding Net Present Value of Consumer Savings to Present Value of Monetized 

Benefits from CO2 and NOX Emissions Reductions Under TSL 1 for Battery Chargers 

Product Classes 2, 3, 4 

Category Present Value 

billion 2010$ 

Discount 

Rate 

Benefits 

Operating Cost Savings 1.132 7% 

2.038 3% 

CO2 Reduction Monetized Value 

(at $4.9/Metric Ton)* 

0.062 5% 

CO2 Reduction Monetized Value 

(at $22.3/Metric Ton)* 

0.302 3% 

CO2 Reduction Monetized Value 

(at $36.5/Metric Ton)* 

0.506 2.5% 

CO2 Reduction Monetized Value 

(at $67.6/Metric Ton)* 

0.921 3% 

NOX Reduction Monetized Value 

(at 2,537 /Ton)* 

0.011 7% 

0.019 3% 

Total Monetary Benefits ** 

1.445 7% 

2.360 3% 

Costs 

Incremental Installed Costs‡ 

0.468 7% 

0.783 3% 

Net Benefits/Costs 

Including CO2 and NOX** 0.977 7% 

1.576 3% 

* These values represent global values (in 2010$) of the social cost of CO2 emissions in 2010 under several 

scenarios. The values of $4.9, $22.3 and $36.5 per ton are the averages of SCC distributions calculated using 5%, 

3%, and 2.5% discount rates, respectively. The value of $67.6 per ton represents the 95th percentile of the SCC 

distribution calculated using a 3% discount rate. See section IV.M for details. The value for NOX (in 2010$) is the 

average of the low and high values used in DOE’s analysis. 

** Total Monetary Benefits and Net Benefits/Costs for both the 3% and 7% cases utilize the central estimate of 

social cost of CO2 emissions calculated at a 3% discount rate, which is equal to $22.3/ton in 2010 (in 2010$). 

‡ Incremental Product Costs represent the total present value (in 2010$) of costs borne by consumers due to 

increased manufacturing costs from efficiency improvements. 

363 
 

 

 

 

Table V-80 Results of Adding Net Present Value of Consumer Savings (at 7% Discount 

Rate) to Net Present Value of Monetized Benefits from CO2 and NOX Emissions 

Reductions Under External Power Supply TSLs 

Product 

Class 

TSL 

Consumer NPV at 7% Discount Rate added to: 

SCC Value of 

$4.9/metric ton CO2* 

and Low Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$22.3/metric ton CO2* 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$36.5/metric ton CO2* 

and Medium Value 

for NOX ** 

billion 2010$ 

SCC Value of 

$67.6/metric ton CO2* 

and High Value for 

NOX ** 

billion 2010$ 

B 1 0.6905 1.0608 1.3645 1.9944 

2 0.6126 1.1986 1.6792 2.6761 

3 (2.0855) (1.0208) (0.1477) 1.6637 

B, C, D, 

and E 1 0.8498 1.3222 1.7100 2.5128 

2 0.8013 1.5402 2.1467 3.4026 

3 (1.9722) (0.6775) 0.3851 2.5857 

X 1 0.1905 0.2411 0.2826 0.3686 

2 0.1903 0.2483 0.2960 0.3947 

3 (0.3333) (0.2144) (0.1167) 0.0854 

H 1 0.0051 0.0061 0.0069 0.0086 

2 0.0052 0.0063 0.0072 0.0090 

3 0.0039 0.0051 0.0061 0.0081 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been calculated 

with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per ton of NOX 

emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

364 
 

 

 

 

 

 

 

 

 

Table V-81 Results of Adding Net Present Value of Consumer Savings (at 3% Discount 

Rate) to Net Present Value of Monetized Benefits from CO2 and NOX Emissions 

Reductions External Power Supply TSLs 

Product 

Class 

TSL 

Consumer NPV at 3% Discount Rate added to: 

SCC Value of 

$4.9/metric ton CO2 * 

and Low Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$22.3/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$36.5/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$67.6/metric ton CO2 * 

and High Value for 

NOX ** 

billion 2010$ 

B 1 1.3243 1.7050 2.0087 2.6490 

2 1.2912 1.8937 2.3743 3.3876 

3 (3.0146) (1.9199) (1.0469) 0.7944 

B, C, D, 

and E 

1 1.6651 2.1509 2.5387 3.3549 

2 1.7177 2.4775 3.0840 4.3607 

3 (2.6459) (1.3146) (0.2519) 1.9852 

X 1 0.3423 0.3943 0.4359 0.5233 

2 0.3454 0.4051 0.4527 0.5531 

3 (0.5022) (0.3799) (0.2823) (0.0768) 

H 1 0.0096 0.0106 0.0115 0.0132 

2 0.0100 0.0111 0.0120 0.0139 

3 0.0079 0.0091 0.0101 0.0122 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been calculated 

with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per ton of NOX 

emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

365 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table V-82 Results of Adding Net Present Value of Consumer Savings (at 7% Discount 

Rate) to Net Present Value of Monetized Benefits from CO2 and NOX Emissions 

Reductions Under Battery Charger TSLs 

Product 

Class 

TSL 

Consumer NPV at 7% Discount Rate added to: 

SCC Value of 

$4.9/metric ton CO2 * 

and Low Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$22.3/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$36.5/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$67.6/metric ton CO2 * 

and High Value for 

NOX ** 

billion 2010$ 

1 1 0.1682 0.2133 0.2503 0.3269 

2 0.3445 0.4496 0.5358 0.7143 

3 (0.4907) (0.3471) (0.2292) 0.0148 

2, 3, 4 1 0.7274 0.9767 1.1810 1.6052 

2 (0.2789) 0.3325 0.8337 1.8741 

3 (8.6041) (7.1561) (5.9692) (3.5054) 

4 (23.1317) (21.5222) (20.2029) (17.4641) 

5, 6 1 0.9217 1.1370 1.3141 1.6792 

2 2.6605 3.1394 3.5334 4.3456 

3 (6.8028) (6.1757) (5.6596) (4.5960) 

7 1 0.0712 0.0764 0.0807 0.0897 

2 (0.2953) (0.2788) (0.2654) (0.2375) 

8 1 1.6613 1.6690 1.6754 1.6886 

2 (0.9914) (0.9584) (0.9313) (0.8750) 

3 (1.1989) (1.1622) (1.1322) (1.0697) 

10 1 0.6571 0.8390 0.9890 1.2971 

2 0.7451 0.9561 1.1301 1.4874 

3 0.8509 1.0971 1.3001 1.7170 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been calculated 

with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per ton of NOX 

emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

366 
 

 

 

 

 

 

 

Table V-83 Results of Adding Net Present Value of Consumer Savings (at 3% Discount 

Rate) to Net Present Value of Monetized Benefits from CO2 and NOX Emissions 

Reductions Under Battery Charger TSLs 

Product 

Class 

TSL 

Consumer NPV at 3% Discount Rate added to: 

SCC Value of 

$4.9/metric ton CO2 * 

and Low Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$22.3/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$36.5/metric ton CO2 * 

and Medium Value for 

NOX ** 

billion 2010$ 

SCC Value of 

$67.6/metric ton CO2 * 

and High Value for 

NOX ** 

billion 2010$ 

1 1 0.3057 0.3521 0.3891 0.4669 

2 0.6329 0.7409 0.8271 1.0086 

3 (0.7438) (0.5962) (0.4783) (0.2301) 

2, 3, 4 1 1.3202 1.5765 1.7808 2.2120 

2 (0.2073) 0.4212 0.9224 1.9799 

3 (13.7811) (12.2925) (11.1057) (8.6012) 

4 (38.0226) (36.3680) (35.0488) (32.2648) 

5, 6 1 1.6837 1.9051 2.0822 2.4535 

2 4.7717 5.2643 5.6584 6.4842 

3 (10.9602) (10.3152) (9.7991) (8.7176) 

7 1 0.1207 0.1261 0.1304 0.1395 

2 (0.4889) (0.4720) (0.4586) (0.4302) 

8 1 2.7825 2.7905 2.7969 2.8103 

2 (1.6458) (1.6118) (1.5847) (1.5275) 

3 (1.9915) (1.9538) (1.9238) (1.8603) 

10 1 1.2394 1.4266 1.5765 1.8898 

2 1.4089 1.6260 1.8000 2.1635 

3 1.6131 1.8664 2.0693 2.4933 

* These label values represent the global SCC of CO2 in 2010, in 2010$. Their present values have been calculated 

with scenario-consistent discount rates. See section IV.M for a discussion of the derivation of these values. 

** Low Value corresponds to $450 per ton of NOX emissions. Medium Value corresponds to $2,537 per ton of NOX 

emissions. High Value corresponds to $4,623 per ton of NOX emissions, in $2010. 

Parentheses indicate negative (-) values. 

Although adding the value of consumer savings to the values of emission reductions 

provides a valuable perspective, two issues should be considered. First, the national operating 

savings are domestic U.S. consumer monetary savings that occur as a result of market 

transactions, while the value of CO2 reductions is based on a global value. Second, the 

assessments of operating cost savings and CO2 savings are performed with different methods that 

367 
 

 

use quite different time frames for analysis. The national operating cost savings is measured for 

the lifetime of products shipped in the 30-year period after the compliance date. The SCC values, 

on the other hand, reflect the present value of all future climate-related impacts resulting from 

the emission of one ton of carbon dioxide in each year. These impacts go well beyond 2100. 

7. Other Factors 

In determining whether a standard is economically justified, DOE may consider any other 

factors that it deems relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VI))) The California IOUs asked that 

DOE consider adopting the standard levels proposed by the State of California. (California IOUs, 

No. 43 at p. 2) In January 2012, the CEC finalized its battery charger energy conservation 

standards and published energy conservation standards for battery chargers. Prior to finalizing 

these standards, CEC published a draft staff report outlining the requirements that were 

ultimately adopted.68 The standards consist of two metrics; one is a maximum allowance for 24­

hour charge and maintenance energy, while the other is a maximum allowance for the 

combination of maintenance and no battery mode power. DOE analyzed the CEC's proposal and 

determined, for each of DOE's product classes, which CSL aligns most closely with the CEC's 

proposed standards, as explained in section IV.C.2.d above. Table shows this mapping and the 

national energy savings and net benefits that could be expected to result from federal standards at 

these levels. Additional results for these CSLs are presented elsewhere in section V.B and in the 

TSD. 

68 Singh, Harinder; Rider, Ken. 2011. Staff Report Staff Analysis of Battery Chargers and Self-Contained Lighting 

Controls. 2011 California Energy Commission, Efficiency and 

Renewable Energy Division, Appliances and Process Energy Office. CEC-400-2011-001-SF. 

368 
 

Table V-84 Selected National Impacts of Aligning Federal Standards with California 

Standards 

Product CSL that Best NES NPV 3% NPV 7% NPV 3% added NPV 7% added 

Class Approximates 

the CEC 

Standard 

(Quad) (Million 2010$) (Million 2010$) to SCC Value 

of $22.3/metric 

ton CO2* and 

Medium Value 

for NOX at 

3%** 

(Million 2010$) 

to SCC Value 

of $22.3/metric 

ton CO2* and 

Medium Value 

for NOX at 

7%** 

(Million 2010$) 

1 CSL 0 0 0 0 0 0 

2 CSL 2 0.585 (855) (679) (247) (88) 

3 CSL 2 0.169 (966) (628) (791) (457) 

4 CSL 2 0.301 (3,909) (2,415) (3,595) (2,110) 

5 CSL 3 0.668 (10,000) (6,230) (-9,308) (5,557) 

6 CSL 3 0.113 (1,123) (731) (1,007) (618) 

7 CSL 1 0.007 119 70 126 76 

8 CSL 0 0 0 0 0 0 

10 CSL 3 0.312 1,550 789 1,866 1,097 

* Social Cost of CO2 (SCC) in 2010, in 2010$. 

** Medium value corresponds to $2,537 per ton of NOX emissions, in 2010$. 

DOE incorporated the CEC's battery charger standards into its analysis by adjusting its 

base case efficiency distributions, as explained in section IV.G.4 above. It did not choose 

proposed standard levels with the explicit intention of aligning its standards with the CEC's. 

Rather, as in all such rulemakings, the proposed levels were selected to meet a number of criteria 

specified in EPCA. These decisions for each product class grouping are explained in detail in the 

following section. 

C. Proposed Standards 

When considering proposed standards, the new or amended energy conservation standard 

that DOE adopts for any type (or class) of covered product shall be designed to achieve the 

maximum improvement in energy efficiency that the Secretary determines is technologically 

feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In determining whether a 

369 
standard is economically justified, the Secretary must determine whether the benefits of the 

standard exceed its burdens by considering, to the greatest extent practicable, the seven statutory 

factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i)) The new or amended standard must 

also result in the significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) 

For today’s NOPR, DOE considered the impacts of standards at each TSL, beginning 

with the maximum technologically feasible level, to determine whether that level was 

economically justified. Where the max-tech level was not justified, DOE then considered the 

next most efficient level and undertook the same evaluation until it reached the most efficient 

level that is both technologically feasible and economically justified and saves a significant 

amount of energy. 

DOE separately discusses the benefits and burdens of each TSL for each group of 

products. To aid the reader in its discussion of the benefits and burdens of each TSL, DOE 

presents summary tables containing the results of DOE’s quantitative analysis for each TSL. 

In addition to the quantitative results presented in the tables, DOE also considers other 

burdens and benefits that impact whether a given efficiency level is economically justified. 

These factors include the impacts on identifiable subgroups of consumers, such as low-income 

households and seniors, who may be disproportionately affected by a national standard. Section 

V.B.1 presents the estimated impacts of each TSL on these subgroups. DOE also considers 

impacts on employment stemming from the manufacture of the products subject to standards (see 

370 
section V.B.2.b), as well as potential indirect impacts in the national economy (see section 

V.B.3.c). 

DOE notes that the economics literature provides a wide-ranging discussion of how 

consumers trade off upfront costs and energy savings in the absence of government intervention. 

Much of this literature attempts to explain why consumers appear to undervalue energy 

efficiency improvements. This undervaluation suggests that regulation that promotes energy 

efficiency can produce significant net private gains (as well as producing social gains by, for 

example, reducing pollution). There is evidence that consumers undervalue future energy savings 

as a result of (1) a lack of information; (2) a lack of sufficient salience of the long-term or 

aggregate benefits; (3) a lack of sufficient savings to warrant delaying or altering; (4) excessive 

focus on the short term, in the form of inconsistent weighting of future energy cost savings 

relative to available returns on other investments; (5) computational or other difficulties 

associated with the evaluation of relevant tradeoffs; and (6) a divergence in incentives (that is, 

renter versus owner; builder vs. purchaser). Other literature indicates that with less than perfect 

foresight and a high degree of uncertainty about the future, consumers may trade off these types 

of investments at a higher than expected rate between current consumption and uncertain future 

energy cost savings. 

In DOE’s current regulatory analysis, potential changes in the benefits and costs of a 

regulation due to changes in consumer purchase decisions are included in two ways. First, if 

consumers forego a purchase of a product in the standards case, this decreases sales for product 

manufacturers and the cost to manufacturers is included in the MIA. Second, DOE accounts for 

371 
 

energy savings attributable only to products actually used by consumers in the standards case; if 

a regulatory option decreases the number of products used by consumers, this decreases the 

potential energy savings from an energy conservation standard. DOE provides detailed estimates 

of shipments and changes in the volume of product purchases in chapter 9 of the NOPR TSD. 

However, DOE’s current analysis does not explicitly control for heterogeneity in consumer 

preferences, preferences across subcategories of products or specific features, or consumer price 

sensitivity variation according to household income. 

While DOE is not prepared at present to provide a fuller quantifiable framework for 

estimating the benefits and costs of changes in consumer purchase decisions due to an energy 

conservation standard, DOE is committed to developing a framework that can support empirical 

quantitative tools for improved assessment of the consumer welfare impacts of appliance 

standards. DOE has posted a paper that discusses the issue of consumer welfare impacts of 

appliance energy efficiency standards, and potential enhancements to the methodology by which 

these impacts are defined and estimated in the regulatory process.69 DOE welcomes comments 

on approaches for improved assessment of the consumer welfare impacts of appliance standards. 

1. External Power Supplies 

a. Product Class B -- Direct Operation External Power Supplies 

Table V-85 presents a summary of the quantitative impacts estimated for each TSL for 

EPSs in product class B. As outlined in section V.A.1, DOE is extending the TSLs for product 

69 Alan Sanstad. Notes on the Economics of Household Energy Consumption and Technology Choice. Lawrence 

Berkeley National Laboratory. 2010. Available online at: 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf 

372 
 

 

 

 

 

 

 

 

 

 

class B to product classes C, D, and E since product class B was the only one directly analyzed 

and interested parties supported this approach because of the technical similarities among these 

products. The efficiency levels contained in each TSL are described in section V.A.1. 

Table V-85 Summary of Results for Product Class B External Power Supplies 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.4579 0.7246 1.3164 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 1,228 1,138 (3,292) 

7% discount rate 596 463 (2,357) 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium Assumptions i (2010$ 

million) 

3% discount rate 1,705 1,894 (1,920) 

7% discount rate 1,061 1,199 (1,021) 

Industry Impacts 

2.5 W, 18 W, 60 W, and 120 W Rep Units* 

Industry NPV Change (2010$ million) (62.5) - (38.9) (81.4) - (35.2) (123.5) – 17.9 

Industry NPV (% change) (26.9) - (16.8) (35.1) - (15.2) (53.2) – 7.7 

Cumulative Emissions Reduction 

CO2 (Mt) 21.7 34.3 62.5 

NOX (kt) 17.9 28.4 51.6 

Hg (t) 0.115 0.182 0.331 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)** 0.091 to 1.369 0.145 to 2.166 0.263 to 3.936 

NOX – 3% discount rate (2010$ million) 5 to 53 8 to 83 15 to 151 

NOX – 7% discount rate (2010$ million) 3 to 29 5 to 47 8 to 85 

Mean LCC Savings*** (2010$) 

2.5 W rep unit 0.10 0.04 0.02 

18 W rep unit 0.68 0.69 (1.19) 

60 W rep unit (0.33) (0.45) (1.38) 

120 W rep unit 0.60 0.61 (5.49) 

Median PBP (years) 

2.5 W rep unit 3.5 4.3 4.3 

18 W rep unit 1.2 3.1 8.1 

60 W rep unit 6.3 5.4 6.4 

120 W rep unit 1.4 1.9 9.1 

Distribution of Consumer LCC Impacts 

2.5 W rep unit 

Net Cost (%) 45.9 59.1 61.3 

No Impact (%) 8.3 2.4 0.0 

Net Benefit (%) 45.8 38.6 38.7 

18 W rep unit 

Net Cost (%) 16.7 37.5 74.4 

No Impact (%) 28.5 10.2 0.0 

Net Benefit (%) 54.9 52.3 25.6 

60 W rep unit 

Net Cost (%) 73.7 85.2 92.8 

373 
 

 

 

 

 

Category TSL 1 TSL 2 TSL 3 

No Impact (%) 18.0 1.3 0.0 

Net Benefit (%) 8.3 13.6 7.2 

120 W rep unit 

Net Cost (%) 0.1 8.6 100.0 

No Impact (%) 21.2 3.0 0.0 

Net Benefit (%) 78.7 88.4 0.0 

Generation Capacity Reduction (GW) 0.255 0.404 0.734 † 

Parentheses indicate negative (-) values. 

* For the MIA impacts, DOE conservatively presents the impacts for product classes B, C, D, and E as a group 

versus only the results for product class B for the other analyses. Because there are no technical differences between 

product class B and the scaled product classes C, D, and E from a manufacturing perspective, there is no product 

class B “industry” that would be impacted differently than product classes C, D, and E. 

** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

*** For LCCs, a negative value means an increase in LCC by the amount indicated. i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value for NOx 

corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 3 

would save 1.316 quads of energy, an amount DOE considers significant. Under TSL 3, the NPV 

of consumer benefits would be -$2.357 billion, using a discount rate of 7 percent, and -$3.292 

billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 62.5 Mt of CO2, 51.6 kt of NOX, and 

0.331 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

3 ranges from $0.263 billion to $3.936 billion. 

At TSL 3, the average LCC impact is a gain (consumer savings) of $0.02 for the 2.5W 

unit and a cost (LCC savings decrease) of $1.19 for the 18W unit, $1.38 for the 60W unit, and 

$5.49 for the 120W unit. The median payback period is 4.3 years for the 2.5W unit, 8.1 years for 

the 18W unit, 6.4 years for the 60W unit, and 9.1 years for the 120W unit. The fraction of 

consumers experiencing an LCC benefit is 38.7 percent for the 2.5W unit, 25.6 percent for the 

374 
18W unit, 7.2 percent for the 60W unit, and 0 percent for the 120W unit. The fraction of 

consumers experiencing an LCC cost is 61.3 percent for the 2.5W unit, 74.4 percent for the 18W 

unit, 92.8 percent for the 60W unit, and 100 percent for the 120W unit. 

At TSL 3, the projected change in INPV for direct operation product classes B, C, D, and 

E as a group ranges from a decrease of $123.5 million to an increase of $17.9 million. At TSL 3, 

DOE recognizes the risk of very large negative impacts if manufacturers’ expectations 

concerning reduced profit margins are realized. If the high end of the range of impacts is 

reached, as DOE expects, TSL 3 could result in a net loss of 53.2 percent in INPV to 

manufacturers of EPSs in these product classes. However, as DOE has not identified any 

domestic manufacturers of direct operation EPSs, it does not project any immediate negative 

impacts on direct domestic jobs. 

The Secretary tentatively concludes that at TSL 3 for EPSs in product class B, the 

negative NPV of consumer benefits, the economic burden on a significant fraction of consumers 

due to the large increases in product cost, and the capital conversion costs and profit margin 

impacts that could result in a very large reduction in INPV, outweigh the benefits of energy 

savings, emission reductions, and the estimated monetary value of the CO2 emissions reductions. 

Consequently, the Secretary has tentatively concluded that TSL 3 is not economically justified. 

DOE then considered TSL 2. TSL 2 would save 0.7246 quads of energy, an amount DOE 

considers significant. Under TSL 2, the NPV of consumer benefits would be $463 million, using 

a discount rate of 7 percent, and $1.138 billion, using a discount rate of 3 percent. Additionally, 

375 
 

TSL 2 yields the maximum NPV of consumer benefits added to the social cost of carbon and 

monetized NOx emissions reductions70 with a value of $1.199 billion at a 7-percent discount rate 

and $1.894 billion at a 3-percent discount rate. 

The cumulative emissions reductions at TSL 2 are 34.3 Mt of CO2, 28.4 kt of NOX, and 

0.182 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

2 ranges from $0.145 billion to $2.166 billion. 

At TSL 2, the average LCC impact is a gain (consumer savings) of $0.04 for the 2.5W 

unit, $0.69 for the 18W unit, $0.61 for the 120W unit, and a cost (LCC savings decrease) of 

$0.45 for the 60W unit. The median payback period is 4.3 years for the 2.5W unit, 3.1 years for 

the 18W unit, 5.4 years for the 60W unit, and 1.9 years for the 120W unit. The fraction of 

consumers experiencing an LCC benefit is 38.6 percent for the 2.5W unit, 52.3 percent years for 

the 18W unit, 13.6 percent for the 60W unit, and 88.4 percent for the 120W unit. The fraction of 

consumers experiencing an LCC cost is 59.1 percent for the 2.5W unit, 37.5 percent for the 18W 

unit, 85.2 percent for the 60W unit, and 8.6 percent for the 120W unit. 

At TSL 2, the projected change in INPV for product classes B, C, D, and E as a group 

ranges from a decrease of $81.4 million to a decrease of $35.2 million. DOE recognizes the risk 

of large negative impacts if manufacturers’ expectations concerning reduced profit margins are 

realized. If the high end of the range of impacts is reached, as DOE expects, TSL 2 could result 

in a net loss of 35.1 percent in INPV to manufacturers of EPSs in these product classes. 

70 Assuming the social cost of carbon equal to $21.4 per metric ton and NOx calculated with a medium value of 

$2,514 per short ton. These values are applied throughout the TSL discussion that follows. 

376 
 

The Secretary tentatively concludes that at TSL 2 for EPSs in product class B, the 

benefits of energy savings, positive NPV of consumer benefits, emission reductions, and the 

estimated monetary value of the CO2 emissions reductions outweigh the economic burden on a 

significant fraction of consumers due to the increases in product cost and the capital conversion 

costs and profit margin impacts that could result in a reduction in INPV to manufacturers. 

After considering the analysis, comments to the preliminary analysis and TSD, and the 

benefits and burdens of TSL 2, the Secretary tentatively concludes that this TSL will offer the 

maximum improvement in efficiency that is technologically feasible and economically justified 

and will result in the significant conservation of energy. Therefore, DOE today proposes to adopt 

TSL 2 for EPSs in product class B and, by extension, for EPSs in product classes C, D, and E 

because of the technical similarities among all of these devices. The proposed new and amended 

energy conservation standards for these EPSs, expressed as equations for minimum average 

active-mode efficiency and maximum no-load input power, are shown in Table V-86. 

Table V-86 Proposed Standards for EPSs in Product Classes B, C, D, and E 

External Power Supplies – Product Class B: AC-DC, Basic-Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.100 

> 49 watts ≥ 0.880 ≤ 0.210 

377 
External Power Supplies – Product Class C: AC-DC, Low-Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.100 

> 49 watts ≥ 0.870 ≤ 0.210 

External Power Supplies – Product Class D: AC-AC, Basic-Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.210 

> 49 watts ≥ 0.880 ≤ 0.210 

External Power Supplies – Product Class E: AC-AC, Low-Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.210 

> 49 watts ≥ 0.870 ≤ 0.210 

b. Product Class X -- Multiple-Voltage External Power Supplies 

Table V-87 presents a summary of the quantitative impacts estimated for each TSL for 

multiple-voltage EPSs. The efficiency levels contained in each TSL are described in section V.A. 

378 
 

 

 

 

 

 

 

 

 

 

Table V-87 Proposed Standards for Product Class X External Power Supplies 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.0625 0.0718 0.1470 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 329 330 (533) 

7% discount rate 178 176 (364) 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium Assumptioni (2010$ 

million) 

3% discount rate 394 405 (380) 

7% discount rate 241 248 (214) 

Industry Impacts 

Product Class X 

Industry NPV Change (2010$ million) (0.7) - (0.4) (12.8) - (12.0) (17.9) - (4.6) 

Industry NPV (% change) (1.7) - (1.0) (28.9) - (27.1) (40.5) - (10.3) 

Cumulative Emissions Reduction 

CO2 (Mt) 2.95 3.38 6.92 

NOX (kt) 2.43 2.79 5.71 

Hg (t) 0.015 0.018 0.036 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.012 to 0.187 0.014 to 0.215 0.029 to 0.440 

NOX – 3% discount rate (2010$ million) 1 to 7 1 to 8 2 to 17 

NOX – 7% discount rate (2010$ million) 0 to 4 0 to 5 1 to 9 

Mean LCC Savings** (2010$) 2.05 2.07 (3.09) 

Median PBP (years) 0.4 4.7 13.2 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 51.0 95.0 

No Impact (%) 95.0 0.0 0.0 

Net Benefit (%) 5.0 49.0 5.0 

Generation Capacity Reduction (GW)

† 0.035 0.040 0.082 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value for NOx 

corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 3 

would save 0.147 quads of energy, an amount DOE considers significant. Under TSL 3, the NPV 

of consumer benefits would be -$364 million, using a discount rate of 7 percent, and -$533 

million, using a discount rate of 3 percent. 

379 
The cumulative emissions reductions at TSL 3 are 6.92 Mt of CO2, 5.71 kt of NOX, and 0.036 t 

of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 3 

ranges from $0.029 billion to $0.440 billion. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $3.09. The 

median payback period is 13.2 years. The fraction of consumers experiencing an LCC benefit is 

5 percent while the fraction of consumers experiencing an LCC cost is 95 percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $17.9 million to a 

decrease of $4.6 million. At TSL 3, DOE recognizes the risk of very large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high range of 

impacts is reached, as DOE expects, TSL 3 could result in a net loss of 40.5 percent in INPV to 

manufacturers of multiple-voltage EPSs. However, as DOE has not identified any domestic 

manufacturers of multiple-voltage EPSs, it does not project any immediate negative impacts on 

direct domestic jobs. 

The Secretary tentatively concludes that at TSL 3 for multiple-voltage EPSs, the negative 

NPV of consumer benefits, the economic burden on a significant fraction of consumers due to 

the large increases in product cost, and the capital conversion costs and profit margin impacts 

that could result in a very large reduction in INPV outweigh the benefits of energy savings, 

emission reductions, and the estimated monetary value of the CO2 emissions reductions. 

Consequently, the Secretary has tentatively concluded that TSL 3 is not economically justified. 

380 
DOE then considered TSL 2. TSL 2 would save 0.0718 quads of energy, an amount DOE 

considers significant. Under TSL 2, the NPV of consumer benefits would be $176 million, using 

a discount rate of 7 percent, and $330 million, using a discount rate of 3 percent. Additionally, 

TSL 2 yields the maximum NPV of consumer benefits added to the social cost of carbon and 

monetized NOx emissions reductions with a value of $248 million at a 7-percent discount rate 

and $405 million at a 3-percent discount rate. 

At TSL 2, the average LCC impact is a gain (consumer savings) of $2.07. The median 

payback period is 4.7 years. The fraction of consumers experiencing an LCC benefit is 49 

percent while the fraction of consumers experiencing an LCC cost is 51 percent. 

The cumulative emissions reductions at TSL 2 are 3.38 Mt of CO2, 2.79 kt of NOX, and 

0.018 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

2 ranges from $0.014 billion to $0.215 billion. 

At TSL 2, the projected change in INPV ranges from a decrease of $12.8 million to a 

decrease of $12.0 million. At TSL 2, DOE recognizes the risk of large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 2 could result in a net loss of 28.9 percent 

in INPV to manufacturers of multiple-voltage EPSs. 

The Secretary tentatively concludes that at TSL 2 for multiple-voltage EPSs, the benefits 

of energy savings, positive NPV of consumer benefits, emission reductions, and the estimated 

381 
monetary value of the CO2 emissions reductions outweigh the economic burden on a significant 

fraction of consumers due to the increases in product cost and the capital conversion costs and 

profit margin impacts that could result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the preliminary analysis and TSD, and the 

benefits and burdens of TSL 2, the Secretary tentatively concludes that this TSL will offer the 

maximum improvement in efficiency that is technologically feasible and economically justified 

and will result in the significant conservation of energy. Therefore, DOE today proposes to adopt 

TSL 2 for multiple-voltage EPSs. The proposed new and amended energy conservation standard 

for multiple-voltage EPSs, expressed as an equation for minimum average active-mode 

efficiency and maximum no-load input power, is shown in Table V-88. 

Table V-88 Proposed Standards for Multiple-Voltage External Power Supplies 

External Power Supplies – Product Class X: Multiple Voltage 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.497 * Pout + 0.067 ≤ 0.300 

> 1 to ≤ 49 watts ≥ 0.075 * ln (Pout) + 0.561 ≤ 0.300 

> 49 watts ≥ 0.860 ≤ 0.300 

c. Product Class H – High-Power External Power Supplies 

Table V-89 presents a summary of the quantitative impacts estimated for each TSL for 

high-power EPSs. The efficiency levels contained in each TSL are described in section V.A. 

382 
 

 

 

 

 

 

 

 

 

 

 

Table V-89 Proposed Standards for High-Power External Power Supplies 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.0013 0.0014 0.0015 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 9.4 9.7 7.6 

7% discount rate 4.8 5.0 3.6 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium Assumptioni (2010$ 

million) 

3% discount rate 10.6 11.1 9.1 

7% discount rate 6.1 6.3 5.1 

Industry Impacts 

Product Class H 

Industry NPV Change (2010$ million) (0.05) - (0.04) (0.05) - (0.04) (0.05) - (0.03) 

Industry NPV (% change) (45.5) - (32.7) (44.0) - (33.8) (47.3) - (24.4) 

Cumulative Emissions Reduction 

CO2 (Mt) 0.054 0.058 0.065 

NOX (kt) 0.045 0.048 0.053 

Hg (t) 0.000 0.000 0.000 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.000 to 0.004 0.000 to 0.004 0.000 to 0.004 

NOX – 3% discount rate (2010$ million) 0.013 to 0.135 0.014 to 0.145 0.016 to 0.161 

NOX – 7% discount rate (2010$ million) 0.007 to 0.069 0.007 to 0.074 0.008 to 0.082 

Mean LCC Savings** (2010$) 124.82 129.08 92.96 

Median PBP (years) 0.0 0.2 2.5 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 0.0 16.9 

No Impact (%) 0.0 0.0 0.0 

Net Benefit (%) 100.0 100.0 83.1 

Generation Capacity Reduction (GW)

† 0.001 0.001 0.001 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value for NOx 

corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 3 

would save 0.0015 quads of energy, an amount DOE considers significant. Under TSL 3, the 

NPV of consumer benefits would be $3.6 million, using a discount rate of 7 percent, and $7.6 

million, using a discount rate of 3 percent. 

383 
The cumulative emissions reductions at TSL 3 are 0.065 Mt of CO2, 0.053 kt of NOX, and less 

than 0.0001 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions 

at TSL 3 ranges from less than $0.0001 to $0.004 billion. 

At TSL 3, the average LCC impact is a gain (consumer savings) of $92.96. The median 

payback period is 2.5 years. The fraction of consumers experiencing an LCC benefit is 83.1 

percent while the fraction of consumers experiencing an LCC cost is 16.9 percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $0.05 million to a 

decrease of $0.03 million. At TSL 3, DOE recognizes the risk of very large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 3 could result in a net loss of 47.3 percent 

in INPV to manufacturers of high-power EPSs. However, as DOE has not identified any 

domestic manufacturers of high power EPSs, it does not project any immediate negative impacts 

on direct domestic jobs. 

The Secretary tentatively concludes that at TSL 3 for high-power EPSs, the additional 

considerations of the potential negative impacts of a standard at this max-tech TSL outweigh the 

benefits of energy savings, emission reductions, and the estimated monetary value of the CO2 

emissions reductions. DOE notes that it scaled results for product class B to estimate the cost and 

efficiency of this max-tech CSL. Consequently, DOE is unaware of any product that can achieve 

this CSL in either product class B or H. Thus, although DOE’s analysis indicates that the max384 
tech efficiency level is achievable, there is a risk that unforeseen obstacles remain to creating an 

EPS at this TSL. 

Additionally, setting a standard at TSL 3 would create a discontinuity in the average 

efficiency standards for EPSs. For product class B devices, the average efficiency standard is 

constant for nameplate output power ratings greater than 49 watts up to 250 watts. At 250 watts, 

where product class H begins, the average efficiency standard would increase by 4 percent if 

DOE set standards for this product class at the max-tech TSL. This discontinuity in efficiency 

between the two product classes would be the result of the proposed standards for product class 

B EPSs being equivalent to the best-in-market CSL equation while the proposed standards for 

product class H would be equivalent to the max-tech CSL equation for high-power EPSs. DOE 

believes that setting a standard with a large discontinuity between these product classes is not 

consistent with EPS design trends. 

In contrast, by applying the same level of stringency, scaled for the representative unit 

voltage, to all EPSs with output power greater than 250 watts, the achievable efficiency in EPS 

designs that have an output power above 49 watts remains nearly constant. This result occurs 

because the switching and conduction losses associated with the EPS remain proportionally the 

same with the increase in output power, which creates a relatively flat achievable efficiency 

above 49 watts. If DOE were to adopt a level that created a discontinuity in the efficiency levels, 

it would ignore this trend and set a higher efficiency standard between two product classes 

despite numerous technical similarities. Consequently, the Secretary has tentatively concluded 

that TSL 3 is not justified. 

385 
DOE then considered TSL 2. TSL 2 would save 0.0014 quads of energy, an amount DOE 

considers significant. Under TSL 2, the NPV of consumer benefits would be $5.0 million, using 

a discount rate of 7 percent, and $9.7 million, using a discount rate of 3 percent. 

At TSL 2, the average LCC impact is a gain (consumer savings) of $129.08. The median 

payback period is 0.2 years. The fraction of consumers experiencing an LCC benefit is 100 

percent while the fraction of consumers experiencing an LCC cost is 0 percent. 

The cumulative emissions reductions at TSL 2 are 0.058 Mt of CO2, 0.048 kt of NOX, 

and less than 0.0001 t of Hg. The estimated monetary value of the cumulative CO2 emissions 

reductions at TSL 2 ranges from less than $0.0001 to $0.004 billion. Additionally, TSL 2 yields 

the maximum NPV of consumer benefits added to the social cost of carbon and monetized NOx 

emissions reductions with a value of $6.3 million at a 7-percent discount rate and $11.1 million 

at a 3-percent discount rate. 

At TSL 2, the projected change in INPV ranges from a decrease of $0.04 million to a 

decrease of $0.04 million. At TSL 2, DOE recognizes the risk of large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 2 could result in a net loss of 44.0 percent 

in INPV to manufacturers of high-power EPSs. 

386 
The Secretary tentatively concludes that at TSL 2 for high-power EPSs, the benefits of 

energy savings, positive NPV of consumer benefits, positive LCC savings for all consumers, 

emission reductions, and the estimated monetary value of the CO2 emissions reductions outweigh 

the economic burden of the capital conversion costs and profit margin impacts that could result 

in a reduction in INPV for manufacturers. The Secretary also tentatively concludes that this TSL 

will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, DOE 

today proposes to adopt TSL 2 for high-power EPSs. The proposed new and amended energy 

conservation standards for high-power EPSs, expressed as a discrete standard for minimum 

average active-mode efficiency and maximum no-load input power, are shown in Table V-90. 

Table V-90 Proposed Standards for High-Power External Power Supplies 

External Power Supplies – Product Class H: High-Power 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

> 250 watts 0.875 0.500 

d. Product Class N -- Indirect-Operation External Power Supplies 

Product class N consists of indirect-operation EPSs, which are EPSs that serve only as 

battery charger components and do not operate an end-use consumer product or power any 

auxiliary functions of an end-use consumer product on their own. See section IV.A.3 above. The 

applications that use these EPSs consist of applications using motors and detachable batteries, 

which correspond to MADB non-Class A EPSs and other applications that use Class A EPSs. 

DOE believes that the Class A and non-Class A devices in product class N are technically 

equivalent. Because of this technical equivalency, DOE believes that EPSs of both types can 

achieve the same efficiency level for the same cost and, thus, grouped these EPSs into one 

387 
product class for analysis. DOE is not aware of any capacity- or performance-related features of 

the non-Class A devices in product class N that would enable DOE to create a separate class for 

this group of devices. 42 U.S.C. 6295(q) 

Of the estimated 75 million EPSs in this product class sold annually, 46 percent are Class 

A and are already subject to the Federal standards prescribed by EISA 2007. The remaining 54 

percent are non-Class A EPSs, which are not currently subject to Federal standards. Table V-91 

lists those applications that DOE has identified as product class N EPSs and indicates how many 

of each are subject to the current Federal standard for Class A EPSs and how many are non-Class 

A devices. DOE seeks comment on the accuracy of its estimates regarding the proportions of 

these applications that ship with indirect-operation EPSs versus direct-operation EPSs. (See Issue 

17 under “Issues on Which DOE Seeks Comment” in Section VII.E of this notice.) 

Table V-91 Applications of Indirect Operation External Power Supplies 

Status Application Estimated EPS Shipment 

Volume in 2009 

(thousands of units) 

Indirect 

Operation 

(Product 

Class N) 

Direct 

Operation 

(Other 

Product 

Classes) 

Currently 

Subject to 

Federal 

Standards 

(Class A) 

MP3 Players 3,609 401 

Personal Digital Assistants 525 1,225 

In-Vehicle GPS 2,845 316 

Handheld GPS 136 15 

Bluetooth Headsets 13,900 0 

Mobile Phones 4,712 42,408 

Smartphones 6,174 14,407 

Digital Cameras 2,470 1,567 

Not Currently RC Toys 350 0 

388 
Subject to 

Federal 

Standards 

(Non-Class A) 

Handheld Vacuums 4,000 0 

Stick Vacuums 1,000 0 

Robotic Vacuums 2,615 0 

Air Mattress Pumps 250 0 

Flashlights/Lanterns 100 0 

Rechargeable Garden Care 

Products 

8 0 

Lawn Mowers 15 0 

Rechargeable Toothbrushes 15,000 0 

Rechargeable Water Jets 100 0 

Beard and Moustache 

Trimmers 

1,763 5,288 

Hair Clippers 3,413 1,138 

Shavers 6,492 2,164 

DIY Power Tools (Integral) 4,675 0 

DIY Power Tools (External) 351 0 

Electric Scooters 175 0 

Motorized Bicycles 105 0 

First, DOE considered setting standards for EPSs in product class N at an efficiency level 

greater than the level prescribed by EISA for all Class A EPSs. While such a standard would 

theoretically yield energy savings, DOE tentatively believes that these savings would not be cost 

justified. In the case of these particular devices, DOE believes that a more effective way to 

obtain additional energy savings is to regulate the battery chargers of which product class N 

EPSs are a part, since all of the power flowing through an indirect-operation EPS flows to the 

battery charger. In contrast, a direct-operation EPS's output power flows to both a battery charger 

and an end-use consumer product, which means that regulating only the battery charger would 

not adequately address the entire system. Thus, by not setting new standards for product class N 

EPSs beyond the existing EISA standard level, DOE believes that manufacturers will have 

greater flexibility in designing more efficient battery chargers without adversely impacting their 

389 
utility and performance. This approach would help ensure that consumers and the Nation as a 

whole will realize cost-effective savings either through improvements to the EPS or other 

components in the battery charger. Thus, DOE tentatively believes that any cost-effective energy 

savings for these products will be realized through the battery charger standard itself. 

Next, DOE considered standards equivalent to the current EISA standards for Class A 

EPSs. This approach would represent no change in standards for Class A devices and a new 

standard for non-Class A devices in product class N. (Note that all Class A EPSs, including those 

in product class N, cannot, by virtue of EPCA’s anti-backsliding provision, be subject to a 

standard less stringent than the current Class A standard prescribed by EISA 2007 (see 42 U.S.C. 

6295(o)(1)).) 

As indicated in section IV.A.1 above, DOE has not identified any non-Class A EPSs in 

product class N that are not already subject to the California EPS standard. As a result, all of 

these non-Class A EPSs that fall into product class N must already comply with the California 

standard. The California standard for non-Class A EPSs is at the same efficiency level as the 

Federal Class A EPS standard. California also relies on the Federal test procedure to verify 

compliance with its EPS standards. Since California requires identical standards and test 

methods for non-Class A EPSs as DOE does for Class A, DOE considers these standards to be 

equivalent. 

Additionally, manufacturers have alluded informally to DOE that the California standard 

is the "de facto" national standard for their non-Class A EPSs because they typically sell the 

390 
same EPS for a given product line throughout the country. The California IOUs concurred with 

this view. (California IOUs, No. 43 at p. 9) Thus, DOE believes that the non-Class A EPSs in 

product class N already meet the Federal standards currently in place for Class A EPSs and seeks 

comment on the accuracy of this belief. (See Issue 18 under “Issues on Which DOE Seeks 

Comment” in section VII.E of this notice.) 

Under the assumption that all non-Class A EPSs in product class N already meet the 

Federal standards currently in place for Class A EPSs, a new standard at the EISA level for these 

products would not yield significant energy savings and, therefore, would not be cost-justified. 

Therefore, DOE is not proposing new standards for indirect operation EPSs today. If DOE 

receives new information indicating that this assumption is incorrect, i.e., that manufacturers are 

not producing all indirect operation EPSs at or above the EISA efficiency levels, DOE will 

reconsider this decision and evaluate potential new standards for this product class. 

2. Battery Chargers 

a. Low-Energy, Inductive Charging Battery Chargers, Product Class 1 

Table V-92 presents a summary of the quantitative impacts estimated for each TSL for 

low-energy, inductive charging battery chargers. The efficiency levels contained in each TSL are 

described in section V.A. 

391 
 

 

 

 

 

 

 

 

 

 

Table V-92 Summary of Results for Battery Charger Product Class 1 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.0557 0.1298 0.1775 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 294 606 (781) 

7% discount rate 157 318 (527) 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium Assumptioni (2010$ 

million) 

3% discount rate 352 741 (596) 

7% discount rate 213 450 (347) 

Industry Impacts 

Battery Charger-Product Class 1 

Industry NPV Change (2010$ million) (41) - 1 (101) – 1 (441) – 29 

Industry NPV (% change) (8.4) - 0.1 (20.6) – 0.3 (89.7) – 5.9 

Cumulative Emissions Reduction 

CO2 (Mt) 2.62 6.11 8.36 

NOX (kt) 2.17 5.05 6.9 

Hg (t) 0.014 0.032 0.044 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.011 to 0.167 0.026 to 0.388 0.035 to 0.531 

NOX – 3% discount rate (2010$ million) 1 to 6 1 to 15 2 to 20 

NOX – 7% discount rate (2010$ million) 0 to 4 1 to 8 1 to 11 

Mean LCC Savings** (2010$) 0.76 1.52 (2.87) 

Median PBP (years) 1.2 1.7 8.5 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 0.0 98.2 

No Impact (%) 22.2 11.1 0.0 

Net Benefit (%) 77.8 88.9 1.8 

Generation Capacity Reduction (GW)

† 0.031 0.072 0.099 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value for NOx 

corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 3 

would save 0.178 quads of energy, an amount DOE considers significant. Under TSL 3, the NPV 

of consumer benefits would be -$527 million, using a discount rate of 7 percent, and -$781 

million, using a discount rate of 3 percent. 

392 
The cumulative emissions reductions at TSL 3 are 8.36 Mt of CO2, 6.90 kt of NOX, and 

0.044 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

3 ranges from $0.035 billion to $0.531 billion. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $2.87 for lowenergy inductive charging battery chargers. The median payback period is 8.5 years. The fraction 

of consumers experiencing an LCC benefit is 1.8 percent and the fraction of consumers 

experiencing an LCC cost is 98.2 percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $441 million to an 

increase of $29 million. At TSL 3, DOE recognizes the risk of very large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 3 could result in a net loss of 89.7 percent 

in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for low-energy, inductive charging 

battery chargers, the benefits of energy savings, emission reductions, and the estimated monetary 

value of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

benefits, the economic burden on a significant fraction of consumers due to the large increases in 

product cost, and the capital conversion costs and profit margin impacts that could result in a 

very large reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 3 is not economically justified. 

393 
DOE then considered TSL 2. TSL 2 would save 0.130 quads of energy, an amount DOE 

considers significant. Under TSL 2, the NPV of consumer benefits would be $318 million, using 

a discount rate of 7 percent, and $606 million, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 2 are 6.11 Mt of CO2, 5.05 kt of NOX, and 

0.032 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

2 ranges from $0.026 billion to $0.388 billion. Additionally, the NPV of consumer benefits 

added to the social cost of carbon and monetized NOx emissions reductions is maximized with a 

value of $741 million at a 3-percent discount rate and $450 million at a 7-percent discount rate at 

TSL 2. 

At TSL 2, the average LCC impact is a savings of $1.52 for low-energy inductive 

charging battery chargers. The median payback period is 1.7 years. The fraction of consumers 

experiencing an LCC benefit is 88.9 percent and the fraction of consumers experiencing an LCC 

cost is 0 percent. 

At TSL 2, the projected change in INPV ranges from a decrease of $101 million to an 

increase of $1 million. DOE recognizes the risk of large negative impacts if manufacturers’ 

expectations concerning reduced profit margins are realized. If the high end of the range of 

impacts is reached, as DOE expects, TSL 2 could result in a net loss of 20.6 percent in INPV to 

manufacturers of low-energy inductive charging battery chargers. 

394 
The Secretary tentatively concludes that at TSL 2 for low-energy, inductive charging 

battery chargers, the benefits of energy savings, positive NPV of consumer benefits, positive 

mean LCC savings, emission reductions, and the estimated monetary value of the CO2 emissions 

reductions outweigh the economic burden of the capital conversion costs and profit margin 

impacts that could result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 2, the Secretary tentatively concludes that 

this TSL will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, DOE 

today proposes to adopt TSL 2 for low-energy inductive charging battery chargers. The proposed 

new energy conservation standard for low-energy inductive charging battery chargers is shown 

in Table V-97. 

Table V-93 Proposed Standard for Product Class 1 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

1 (Low-Energy, Inductive) 3.04 

b. Low-Energy, Non-Inductive Charging Battery Chargers, Product Classes 2, 3, and 4 

Table presents a summary of the quantitative impacts estimated for each TSL for lowenergy, non-inductive charging battery chargers. The efficiency levels contained in each TSL are 

described in section V.A. 

395 
 

 

 

 

 

 

 

 

Table V-94 Summary of Results for Battery Charger Product Classes 2, 3, and 4 

Category TSL 1 TSL 2 TSL 3 TSL 4 

National Energy Savings (quads) 0.3091 0.7588 1.7967 1.9971 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 1,255 (367) (14,159) (38,442.72) 

7% discount rate 664 (435) (8,973) (23,542.09) 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium Assumptionsi (2010$ 

million) 

3% discount rate 1,576 421 (12,293) (36,368) 

7% discount rate 977 333 (7,156) (21,522) 

Industry Impacts 

Battery Charger -Product Classes 2, 3, and 4 

Industry NPV Change (2010$ million) (4,897) – 15 (6,055) – 

134 

(10,863) – 

528 

(14,562) ­

975 

Industry NPV (% change) (11.2) - 0.0 (13.8) – 0.3 (24.8) – 1.2 (33.2) – 2.2 

Cumulative Emissions Reduction 

CO2 (Mt) 14.7 35.9 85.1 94.6 

NOX (kt) 12.1 29.7 70.3 78.1 

Hg (t) 0.078 0.191 0.452 0.502 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.062 to 

0.921 

0.151 to 

2.260 

0.358 to 

5.352 

0.398 to 

5.949 

NOX – 3% discount rate (2010$ million) 3 to 35 8 to 87 20 to 206 22 to 229 

NOX – 7% discount rate (2010$ million) 2 to 20 5 to 49 11 to 116 13 to 129 

Mean LCC Savings** (2010$) 

PC2 – Low-Energy, Low-Voltage 0.16 (0.12) (1.81) (4.54) 

PC3 – Low-Energy, Medium-Voltage 0.35 0.35 (2.12) (2.15) 

PC4 – Low-Energy, High-Voltage 0.43 0.43 (2.73) (10.14) 

Median PBP (years) 

PC2 – Low-Energy, Low-Voltage 0.5 5.2 8.5 16.9 

PC3 – Low-Energy, Medium-Voltage 3.9 3.9 21.9 21.5 

PC4 – Low-Energy, High-Voltage 3.0 3.0 13.8 37.6 

Distribution of Consumer LCC Impacts 

PC2 – Low-Energy, Low-Voltage 

Net Cost (%) 1.0 26.8 87.1 96.8 

No Impact (%) 82.0 60.1 2.9 0.0 

Net Benefit (%) 17.0 13.1 10.0 3.2 

PC3 – Low-Energy, Medium-Voltage 

Net Cost (%) 8.9 8.9 65.8 85.8 

No Impact (%) 82.8 82.8 20.9 0.0 

Net Benefit (%) 8.3 8.3 13.3 14.2 

PC4 – Low-Energy, High-Voltage 

Net Cost (%) 3.4 3.4 46.4 98.2 

No Impact (%) 90.7 90.7 51.5 0.0 

Net Benefit (%) 5.8 5.8 2.2 1.8 

Generation Capacity Reduction (GW)

† 0.17 0.42 1.00 1.11 

396 
 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value for NOx 

corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 4, which represents the max-tech efficiency level. TSL 4 

would save 1.9971 quads of energy, an amount DOE considers significant. Under TSL 4, the 

NPV of consumer benefits would be -$23.54 billion, using a discount rate of 7 percent, and ­

$38.44 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 4 are 94.6 Mt of CO2, 78.1 kt of NOX, and 

0.502 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

4 ranges from $0.398 billion to $5.949 billion. 

At TSL 4, the average LCC impact is a cost (LCC savings decrease) of $4.54, $2.15, and 

$10.14 for low-energy non-inductive charging battery charger product classes 2, 3, and 4 

respectively. The median payback period is 16.9, 21.5, and 37.6 years for product classes 2, 3, 

and 4 respectively. The fraction of consumers experiencing an LCC benefit is 3.2, 14.2, and 1.8 

percent for each product class and the fraction of consumers experiencing an LCC cost is 96.8, 

85.8, and 98.2 percent for each product class. 

At TSL 4, the projected change in INPV ranges from a decrease of $14.56 billion to an 

increase of $0.98 billion. At TSL 4, DOE recognizes the risk of very large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

397 
the range of impacts is reached, as DOE expects, TSL 4 could result in a net loss of 33.2 percent 

in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 4 for low-energy, non-inductive charging 

battery chargers, the benefits of energy savings, emission reductions, and the estimated monetary 

value of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

benefits, the economic burden on a significant fraction of consumers due to the large increases in 

product cost, and the capital conversion costs and profit margin impacts that could result in a 

very large reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 4 is not economically justified. 

DOE then considered TSL 3, which represents the best-in-market efficiency level. TSL 3 

would save 1.797 quads of energy, an amount DOE considers significant. Under TSL 3, the NPV 

of consumer benefits would be -$8.97 billion, using a discount rate of 7 percent, and -$14.16 

billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 85.1 Mt of CO2, 70.3 kt of NOX, and 

0.452 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

3 ranges from $0.358 billion to $5.352 billion. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $1.81, $2.12, and 

$2.73 for low-energy non-inductive charging battery charger product classes 2, 3, and 4 

respectively. The median payback period is 8.5, 21.9, and 13.8 years for product classes 2, 3, and 

4 respectively. The fraction of consumers experiencing an LCC benefit is 10.0, 13.3, and 2.2 

398 
percent for each product class and the fraction of consumers experiencing an LCC cost is 87.1, 

65.8, and 46.4 percent for each product class. 

At TSL 3, the projected change in INPV ranges from a decrease of $10.86 billion to an 

increase of $0.53 billion. At TSL 3, DOE recognizes the risk of large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 3 could result in a net loss of 24.8 percent 

in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for low-energy, non-inductive charging 

battery chargers, the benefits of energy savings, emission reductions, and the estimated monetary 

value of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

benefits, the economic burden on a significant fraction of consumers due to the large increases in 

product cost, and the capital conversion costs and profit margin impacts that could result in a 

very large reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 3 is not economically justified. 

DOE then considered TSL 2, which represents an intermediate efficiency level. TSL 2 

would save 0.759 quads of energy, an amount DOE considers significant. Under TSL 2, the NPV 

of consumer benefits would be -$435 million, using a discount rate of 7 percent, and ­

$367million, using a discount rate of 3 percent. 

399 
The cumulative emissions reductions at TSL 2 are 35.9 Mt of CO2, 29.7 kt of NOX, and 

0.191 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

2 ranges from $0.151 billion to $2.260 billion. 

At TSL 2, the average LCC impact is a cost (LCC savings decrease) of $0.12 for product 

class 2 and a savings (LCC savings increase) of $0.35 and $0.43 product classes 3 and 4 

respectively. The median payback period is 5.2, 3.9, and 3.0 years for product classes 2, 3, and 4 

respectively. The fraction of consumers experiencing an LCC benefit is 17.0, 8.3, and 5.8 percent 

for each product class and the fraction of consumers experiencing an LCC cost is 26.8, 8.9, and 

3.4 percent for each product class. 

At TSL 2, the projected change in INPV ranges from a decrease of $6.06 billion to an 

increase of $0.13 billion. At TSL 2, DOE recognizes the risk of large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 2 could result in a net loss of 13.8 percent 

in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 2 for low-energy, non-inductive charging 

battery chargers, the benefits of energy savings, emission reductions, and the estimated monetary 

value of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

benefits, the economic burden on a significant fraction of consumers due to the increases in 

product cost, and the capital conversion costs and profit margin impacts that could result in a 

400 
large reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 2 is not economically justified. 

DOE then considered TSL 1, which represents another intermediate efficiency level. 

Relative to TSL 2, the efficiency level for product class 2 has decreased, while the efficiency 

levels for product classes 3 and 4 are the same. TSL 1 would save 0.309 quads of energy, an 

amount DOE considers significant. Under TSL 1, the NPV of consumer benefits would be $664 

million, using a discount rate of 7 percent, and $1.255 billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 1 are 14.7 Mt of CO2, 12.1 kt of NOX, and 

0.078 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

1 ranges from $0.062 billion to $0.921 billion. Additionally, the NPV of consumer benefits 

added to the social cost of carbon and monetized NOx emissions reductions is maximized with a 

value of $1.576 billion at a 3-percent discount rate and $0.977 billion at a 7-percent discount rate 

at TSL 1. 

At TSL 1, the average LCC impact is a savings (LCC savings increase) of $0.16, $0.35, 

and $0.43 for low-energy non-inductive charging battery charger product classes 2, 3, and 4 

respectively. The median payback period is 0.5, 3.9, and 3.0 years for product classes 2, 3, and 4 

respectively. The fraction of consumers experiencing an LCC benefit is 17.0, 8.3, and 5.8 percent 

for each product class and the fraction of consumers experiencing an LCC cost is 1.0, 8.9, and 

3.4 percent for each product class. 

401 
At TSL 1, the projected change in INPV ranges from a decrease of $4.90 billion to an 

increase of $0.02 billion. DOE recognizes the risk of negative impacts if manufacturers’ 

expectations concerning reduced profit margins are realized. If the high end of the range of 

impacts is reached, TSL 1 could result in a net loss of 11.2 percent in INPV to manufacturers of 

low-energy non-inductive charging battery chargers. 

The Secretary tentatively concludes that at TSL 1 for low-energy, non-inductive charging 

battery chargers, the benefits of energy savings, positive NPV of consumer benefits, positive 

mean LCC savings, emission reductions, and the estimated monetary value of the CO2 emissions 

reductions outweigh the economic burden of the capital conversion costs and profit margin 

impacts that could result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 1, the Secretary tentatively concludes that 

this TSL will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, DOE 

today proposes to adopt TSL 1 for low-energy non-inductive charging battery chargers. The 

proposed new energy conservation standards for low-energy, non-inductive charging battery 

chargers, expressed as equations for minimum unit energy consumption, are shown in Table V99. 

402 
Table V-95 Proposed Standard for Product Classes 2, 3, and 4 

Product Class Maximum Unit Energy Consumption(kWh/yr) 

2 (Low-Energy, Low-Voltage) = 0.2095(Ebatt*) + 5.87 

3 (Low-Energy, Medium-Voltage For Ebatt < 9.74 Wh, = 4.68 

For Ebatt ≥ 9.74 Wh, = 0.0933(Ebatt) + 3.77 

4 (Low-Energy, High-Voltage) For Ebatt < 9.71 Wh, = 9.03 

For Ebatt ≥ 9.71 Wh, = 0.2411(Ebatt) + 6.69 

c. Medium-Energy Battery Chargers, Product Classes 5 and 6 

Table V-96 presents a summary of the quantitative impacts estimated for each TSL for 

medium-energy battery chargers. The efficiency levels contained in each TSL are described in 

section V.A. 

403 
 

 

 

 

 

 

 

Table V-96 Summary of Results for Battery Charger Product Classes 5 and 6 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.2679 0.5962 0.7809 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 1,628 4,648 (11,123) 

7% discount rate 867 2,539 (6,961) 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium Assumptionsi (2010$ 

million) 

3% discount rate 1,905 5,264 (10,315) 

7% discount rate 1,137 3,139 (6,176) 

Industry Impacts 

Battery Charger -Product Classes 5 and 6 

Industry NPV Change (2010$ million) (327) – 6 (225) – (40) (1,314) – 692 

Industry NPV (% change) (21.0) – 0.3 (14.5) – (2.5) (84.8) – 43.7 

Cumulative Emissions Reduction 

CO2 (Mt) 12.4 27.4 35.9 

NOX (kt) 10.2 22.6 29.6 

Hg (t) 0.065 0.143 0.187 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.053 to 0.795 0.118 to 1.770 0.154 to 2.318 

NOX – 3% discount rate (2010$ million) 3 to 30 7 to 67 9 to 88 

NOX – 7% discount rate (2010$ million) 2 to 16 4 to 37 5 to 48 

Mean LCC Savings** (2010$) 

PC5 – Medium-Energy, Low-Voltage 9.69 33.79 (104.58) 

PC6 – Medium-Energy, High-Voltage 9.96 40.78 (86.76) 

Median PBP (years) 

PC5 – Medium-Energy, Low-Voltage 1.7 0.0 53.4 

PC6 – Medium-Energy, High-Voltage 1.2 0.0 20.8 

Distribution of Consumer LCC Impacts 

PC5 – Medium-Energy, Low-Voltage 

Net Cost (%) 1.3 0.0 78.6 

No Impact (%) 72.0 20.1 13.0 

Net Benefit (%) 26.8 79.9 8.4 

PC6 – Medium-Energy, High-Voltage 

Net Cost (%) 0.0 0.0 85.4 

No Impact (%) 64.6 35.2 13.0 

Net Benefit (%) 35.4 64.8 1.6 

Generation Capacity Reduction (GW)

† 0.15 0.33 0.43 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value for NOx 

corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 3 

would save 0.781 quads of energy, an amount DOE considers significant. Under TSL 3, the NPV 

404 
of consumer benefits would be -$6.96 billion, using a discount rate of 7 percent, and -$11.12 

billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 3 are 35.9 Mt of CO2, 29.6 kt of NOX, and 

0.187 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

3 ranges from $0.154 billion to $2.318 billion. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $104.58 and 

$86.76 for medium-energy battery charger product classes 5 and 6 respectively. The median 

payback period is 53.4 and 20.8 years for product classes 5 and 6 respectively. The fraction of 

consumers experiencing an LCC benefit is 8.4 and 1.6 percent for product classes 5 and 6, 

respectively, and the fraction of consumers experiencing an LCC cost is 78.6 and 85.4 percent 

for product classes 5 and 6, respectively. 

At TSL 3, the projected change in INPV ranges from a decrease of $1.31 billion to an 

increase of $0.69 billion. At TSL 3, DOE recognizes the risk of very large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 3 could result in a net loss of 84.8 percent 

in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for medium-energy battery chargers, 

the benefits of energy savings, emission reductions, and the estimated monetary value of the CO2 

emissions reductions would be outweighed by the negative NPV of consumer benefits, the 

405 
economic burden on a significant fraction of consumers due to the large increases in product 

cost, and the capital conversion costs and profit margin impacts that could result in a very large 

reduction in INPV for manufacturers. Consequently, the Secretary has tentatively concluded that 

TSL 3 is not economically justified. 

DOE then considered TSL 2, which represents the best-in-market efficiency level. TSL 2 

would save 0.596 quads of energy, an amount DOE considers significant. Under TSL 2, the NPV 

of consumer benefits would be $2.54 billion, using a discount rate of 7 percent, and $4.65 

billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 2 are 27.4 Mt of CO2, 22.6 kt of NOX, and 

0.143 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

2 ranges from $0.118 billion to $1.770 billion. Additionally, the NPV of consumer benefits 

added to the social cost of carbon and monetized NOx emissions reductions is maximized with a 

value of $5.264 billion at a 3-percent discount rate and $3.139 billion at a 7-percent discount rate 

at TSL 2. 

At TSL 2, the average LCC impact is a savings (LCC savings increase) of $33.79 and 

$40.78 for medium-energy battery charger product classes 5 and 6, respectively. The median 

payback period is 0.0 and 0.0 years for product classes 5 and 6, respectively. The fraction of 

consumers experiencing an LCC benefit is 79.9 and 64.8 percent for each product class and the 

fraction of consumers experiencing an LCC cost is 0.0 and 0.0 percent for each product class. 

406 
At TSL 2, the projected change in INPV ranges from a decrease of $225 million to a 

decrease of $40 million. DOE recognizes the risk of negative impacts if manufacturers’ 

expectations concerning reduced profit margins are realized. If the high end of the range of 

impacts is reached, TSL 2 could result in a net loss of 14.5 percent in INPV to manufacturers of 

medium-energy battery chargers. 

The Secretary tentatively concludes that at TSL 2 for medium-energy battery chargers, 

the benefits of energy savings, positive NPV of consumer benefits, positive mean LCC savings, 

emission reductions, and the estimated monetary value of the CO2 emissions reductions outweigh 

the economic burden of the capital conversion costs and profit margin impacts that could result 

in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 2, the Secretary tentatively concludes that 

this TSL will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, DOE 

today proposes to adopt TSL 2 for medium-energy battery chargers. The proposed new energy 

conservation standards for medium-energy battery chargers, expressed as equations for minimum 

unit energy consumption, are shown in Table V-101. 

Table V-97 Proposed Standard for Product Classes 5 and 6 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

5 (Medium-Energy, Low-Voltage) For Ebatt < 355.18 Wh, = 20.06 

For Ebatt ≥ 355.18 Wh, = 0.0219(Ebatt) + 12.28 

6 (Medium-Energy, High-Voltage) For Ebatt < 239.48 Wh, = 30.37 

For Ebatt ≥ 239.48 Wh, = 0.0495(Ebatt) + 18.51 

407 
 

 

 

 

 

 

 

 

d. High-Energy Battery Chargers, Product Class 7 

Table V-98 presents a summary of the quantitative impacts estimated for each TSL for 

high-energy battery chargers. The efficiency levels contained in each TSL are described in 

section V.A. 

Table V-98 Summary of Results for Battery Charger Product Class 7 

Category TSL 1 TSL 2 

National Energy Savings (quads) 0.0067 0.0209 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 119 (493) 

7% discount rate 70 (299) 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium 

Assumptionsi (2010$ million) 

3% discount rate 126 (472) 

7% discount rate 76 (279) 

Industry Impacts 

Battery Charger-Product Class 7 

Industry NPV Change 

(2010$ million) (4) – 47 (136) – 23 

Industry NPV 

(% change) (0.4) – 4.5 (13.1) – 2.2 

Cumulative Emissions Reduction 

CO2 (Mt) 0.312 0.975 

NOX (kt) 0.259 0.808 

Hg (t) 0.002 0.006 

Value of Cumulative Emissions Reduction

 CO2 (2010$ billion)* 0.001 to 0.019 0.004 to 0.061

 NOX – 3% discount rate (2010$ million) 0.073 to 1 0.229 to 2

 NOX – 7% discount rate (2010$ million) 0.042 to 0.431 0.131 to 1 

Mean LCC Savings** (2010$) 38.26 (127.30) 

Median PBP (years) 0.0 27.2 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 100.0 

No Impact (%) 56.6 0.0 

Net Benefit (%) 43.5 0.0 

Generation Capacity Reduction (GW)

† 0.003 0.010 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of 

reduced CO2 emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a 

medium value for NOx corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 2, which represents the max-tech efficiency level. TSL 2 

would save 0.021 quads of energy, an amount DOE considers significant. Under TSL 2, the NPV 

408 
of consumer benefits would be -$299 million, using a discount rate of 7 percent, and -$493 

million, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 2 are 0.975 Mt of CO2, 0.808 kt of NOX, 

and 0.006 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at 

TSL 2 ranges from $0.004 billion to $0.061 billion. 

At TSL 2, the average LCC impact is a cost (LCC savings decrease) of $127.30 for highenergy battery chargers. The median payback period is 27.2 years. The fraction of consumers 

experiencing an LCC benefit is 0.0 percent and the fraction of consumers experiencing an LCC 

cost is 100.0 percent. 

At TSL 2, the projected change in INPV ranges from a decrease of $136 million to an 

increase of $23 million. At TSL 2, DOE recognizes the risk of large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 2 could result in a net loss of 13.1 percent 

in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 2 for high-energy battery chargers, the 

benefits of energy savings, emission reductions, and the estimated monetary value of the CO2 

emissions reductions would be outweighed by the negative NPV of consumer benefits, the 

economic burden on a significant fraction of consumers due to the large increases in product 

cost, and the capital conversion costs and profit margin impacts that could result in a large 

409 
reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively concluded 

that TSL 2 is not economically justified. 

DOE then considered TSL 1, which is the best-in-market efficiency level. TSL 1 would 

save 0.007 quads of energy, an amount DOE considers significant. Under TSL 1, the NPV of 

consumer benefits would be $70 million, using a discount rate of 7 percent, and $119 million, 

using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 1 are 0.312 Mt of CO2, 0.259 kt of NOX, 

and 0.002 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at 

TSL 1 ranges from $0.001 billion to $0.019 billion. Additionally, the NPV of consumer benefits 

added to the social cost of carbon and monetized NOx emissions reductions is maximized with a 

value of $126 million at a 3-percent discount rate and $76 million at a 7-percent discount rate at 

TSL 1. 

At TSL 1, the average LCC impact is a savings of $38.26 for high-energy battery 

chargers. The median payback period is 0.0 years. The fraction of consumers experiencing an 

LCC benefit is 43.5 percent and the fraction of consumers experiencing an LCC cost is 0.0 

percent. 

At TSL 1, the projected change in INPV ranges from a decrease of $4 million to an 

increase of $47 million. DOE recognizes the risk of negative impacts if manufacturers’ 

expectations concerning reduced profit margins are realized. If the high end of the range of 

410 
impacts is reached, as DOE expects, TSL 1 could result in a net loss of 0.4 percent in INPV to 

manufacturers of high-energy battery chargers. 

The Secretary tentatively concludes that at TSL 1 for high-energy battery chargers, the 

benefits of energy savings, positive NPV of consumer benefits, positive mean LCC savings, 

emission reductions, and the estimated monetary value of the CO2 emissions reductions outweigh 

the economic burden associated with the potential direct employment losses, capital conversion 

costs and profit margin impacts that could result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 1, the Secretary tentatively concludes that 

this TSL will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, DOE 

today proposes to adopt TSL 1 for high-energy battery chargers. The proposed new energy 

conservation standard for high-energy battery chargers, expressed as an equation for minimum 

unit energy consumption, is shown in Table V-103. 

Table V-99 Proposed Standard for Product Class 7 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

7 (High-Energy) = 0.502(Ebatt) + 4.53 

e. Battery Chargers with a DC Input of Less than 9 V, Product Class 8 

Table V-100 presents a summary of the quantitative impacts estimated for each TSL for 

battery chargers with a DC input less than 9 V. The efficiency levels contained in each TSL are 

described in section V.A. 

411 
 

 

 

 

 

 

 

 

 

Table V-100 Summary of Results for Battery Charger Product Class 8 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.0096 0.0408 0.0453 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 2,780 (1,654) (2,001) 

7% discount rate 1,659 (1,000) (1,208) 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium Assumptionsi (2010$ 

million) 

3% discount rate 2,790 (1,612) (1,954) 

7% discount rate 1,669 (958) (1,162) 

Industry Impacts 

Battery Charger -Product Class 8 

Industry NPV change (2010$ million) (75) - 1,300 4 – 78 (61) - (30) 

Industry NPV (% change) (1.3) - 22.8 0.1 – 1.4 (1.1) - (0.5) 

Cumulative Emissions Reduction 

CO2 (Mt) 0.46 1.95 2.16 

NOX (kt) 0.38 1.61 1.78 

Hg (t) 0.002 0.010 0.011 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.002 to 0.029 0.008 to 0.122 0.009 to 0.136 

NOX – 3% discount rate (2010$ million) 0 to 1 0 to 5 1 to 5 

NOX – 7% discount rate (2010$ million) 0 to 1 0 to 3 0 to 3 

Mean LCC Savings** (2010$) 3.04 (1.96) (2.31) 

Median PBP (years) 0.0 0.0 24.9 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 40.0 55.4 

No Impact (%) 50.0 10.0 0.0 

Net Benefit (%) 50.0 50.0 44.6 

Generation Capacity Reduction (GW)

† 0.005 0.023 0.025 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value for NOx 

corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which represents the max-tech efficiency level. TSL 3 

would save 0.045 quads of energy, an amount DOE considers significant. Under TSL 3, the NPV 

of consumer benefits would be -$1.21 billion, using a discount rate of 7 percent, and -$2.00 

billion, using a discount rate of 3 percent. 

412 
The cumulative emissions reductions at TSL 3 are 2.16 Mt of CO2, 1.78 kt of NOX, and 

0.011 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

3 ranges from $0.009 billion to $0.136 billion. 

At TSL 3, the average LCC impact is a cost (LCC savings decrease) of $2.31 for battery 

chargers with a DC input of less than 9 V. The median payback period is 24.9 years. The fraction 

of consumers experiencing an LCC benefit is 44.6 percent and the fraction of consumers 

experiencing an LCC cost is 55.4 percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $61 million to a 

decrease of $30 million. At TSL 3, DOE recognizes the risk of large negative impacts if 

manufacturers’ expectations concerning reduced profit margins are realized. If the high end of 

the range of impacts is reached, as DOE expects, TSL 3 could result in a net loss of 1.1 percent 

in INPV to manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 3 for battery chargers with a DC input of 

less than 9 V, the benefits of energy savings, emission reductions, and the estimated monetary 

value of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

benefits and the economic burden on a significant fraction of consumers due to the large 

increases in product cost, and the capital conversion costs and profit margin impacts that could 

result in a reduction in INPV for the manufacturers. Consequently, the Secretary has tentatively 

concluded that TSL 3 is not economically justified. 

413 
DOE then considered TSL 2, which represents the best-in-market efficiency level. TSL 2 

would save 0.041 quads of energy, an amount DOE considers significant. Under TSL 2, the NPV 

of consumer benefits would be -$1.00 billion, using a discount rate of 7 percent, and -$1.65 

billion, using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 2 are 1.95 Mt of CO2, 1.61 kt of NOX, and 

0.010 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

2 ranges from $0.008 billion to $0.122 billion. 

At TSL 2, the average LCC impact is a cost (LCC savings decrease) of $1.96 for battery 

chargers with a DC input of less than 9 V. The median payback period is 0.0 years. The fraction 

of consumers experiencing an LCC benefit is 50.0 percent and the fraction of consumers 

experiencing an LCC cost is 40.0 percent. 

At TSL 2, the projected change in INPV ranges from an increase of $4 million to an 

increase of $78 million. At TSL 2, DOE believes there are minimal risks of negative impacts on 

manufacturers and expects that TSL 2 could result in a net gain of 0.1 percent in INPV to 

manufacturers of battery chargers. 

The Secretary tentatively concludes that at TSL 2 for battery chargers with a DC input of 

less than 9 V, the benefits of energy savings, emission reductions, and the estimated monetary 

value of the CO2 emissions reductions would be outweighed by the negative NPV of consumer 

benefits and the economic burden on a significant fraction of consumers due to the large 

414 
increases in product cost. Consequently, the Secretary has tentatively concluded that TSL 2 is not 

economically justified. 

DOE then considered TSL 1, which is an intermediate efficiency level. TSL 1 would save 

0.010 quads of energy, an amount DOE considers significant. Under TSL 1, the NPV of 

consumer benefits would be $1.66 billion, using a discount rate of 7 percent, and $2.78 billion, 

using a discount rate of 3 percent. 

The cumulative emissions reductions at TSL 1 are 0.46 Mt of CO2, 0.38 kt of NOX, and 

0.002 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

1 ranges from $0.002 billion to $0.029 billion. Additionally, the NPV of consumer benefits 

added to the social cost of carbon and monetized NOx emissions reductions is maximized with a 

value of $2.790 billion at a 3-percent discount rate and $1.669 billion at a 7 percent discount rate 

at TSL 1. 

At TSL 1, the average LCC impact is a savings of $3.04 for battery chargers with a DC 

input of less than 9 V. The median payback period is 0.0 years. The fraction of consumers 

experiencing an LCC benefit is 50.0 percent and the fraction of consumers experiencing an LCC 

cost is 0.0 percent. 

At TSL 1, the projected change in INPV ranges from a decrease of $75 million to an 

increase of $1,300 million. DOE recognizes the risk of negative impacts if manufacturers’ 

expectations concerning reduced profit margins are realized. If the high end of the range of 

415 
impacts is reached, as DOE expects, TSL 1 could result in a net loss of 1.3 percent in INPV to 

manufacturers of battery chargers with a DC input less than 9 V. 

The Secretary tentatively concludes that at TSL 1 for battery chargers with a DC input of 

less than 9 V, the benefits of energy savings, positive NPV of consumer benefits, positive mean 

LCC savings, emission reductions, and the estimated monetary value of the CO2 emissions 

reductions outweigh the economic burden associated with the capital conversion costs and profit 

margin impacts that could result in a reduction in INPV for manufacturers. 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 1, the Secretary tentatively concludes that 

this TSL will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, DOE 

today proposes to adopt TSL 1 for battery chargers with a DC input less than 9 V. The proposed 

new energy conservation standard for battery chargers with a DC input less than 9 V is shown in 

Table V-105. 

Table V-101 Proposed Standard for Product Class 8 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

8 (Low-Voltage DC Input) 0.66 

DOE is also considering an alternative approach for product class 8 because of the 

considerations expressed in section IV.C.2.i above. This approach is same as the proposal that 

DOE has for product class 9, discussed in the following section. 

416 
f. Battery Chargers with a DC Input Greater than 9 V, Product Class 9 

DOE ran a number of analyses in an attempt to ascertain whether an appropriate 

efficiency level could be created for product class 9. A battery charger is in product class 9 if it 

operates using a DC input source greater than 9 V, it is unable to operate from a universal serial 

bus (USB) connector, and a manufacturer does not package, recommend, or sell a wall adapter 

for the device. Such products would be in-vehicle battery chargers that can operate outside of a 

vehicle. After completing its engineering analysis for these products, DOE ran the LCC analysis. 

These analyses projected that no efficiency level would be likely to exhibit a positive LCC 

savings. The LCC results showed a cost (LCC savings decrease) of $0.08 and $0.24 for CSLs 1 

and 2 respectively. That fact, combined with the minimal UECs found for products in this 

category, leads DOE to tentatively believe that there would be no economically justifiable TSLs 

that correspond to the efficiency levels found in the engineering analysis for this product class. 

g. AC Output Battery Chargers, Product Class 10 

Table V-102 presents a summary of the quantitative impacts estimated for each TSL for 

battery chargers with an AC output. The efficiency levels contained in each TSL are described in 

section V.A. 

417 
 

 

 

 

 

 

 

 

 

 

 

Table V-102 Summary of Results for Battery Charger Product Class 10 

Category TSL 1 TSL 2 TSL 3 

National Energy Savings (quads) 0.2308 0.2678 0.3124 

NPV of Consumer Benefits (2010$ million) 

3% discount rate 1,192 1,354 1,550 

7% discount rate 611 692 789 

NPV of Consumer Benefits added to the Value of Emissions Reductions Using Medium Assumptionsi (2010$ 

million) 

3% discount rate 1,427 1,626 1,866 

7% discount rate 839 956 1,097 

Industry Impacts 

Battery Charger-Product Class 10 

Industry NPV Change (2010$ million) (81) - (0) (100) - (2) (126) - (5) 

Industry NPV (% change) (13.2) - (0.1) (16.4) - (0.4) (20.5) - (0.9) 

Cumulative Emissions Reduction 

CO2 (Mt) 10.3 11.9 13.9 

NOX (kt) 8.46 9.81 11.5 

Hg (t) 0.068 0.079 0.092 

Value of Cumulative Emissions Reduction 

CO2 (2010$ billion)* 0.045 to 0.672 0.052 to 0.780 0.060 to 0.910 

NOX – 3% discount rate (2010$ million) 2 to 25 3 to 29 3 to 34 

NOX – 7% discount rate (2010$ million) 1 to 14 2 to 16 2 to 18 

Mean LCC Savings** (2010$) 6.41 7.26 8.30 

Median PBP (years) 1.3 1.4 1.5 

Distribution of Consumer LCC Impacts 

Net Cost (%) 0.0 0.0 0.0 

No Impact (%) 13.0 13.0 13.0 

Net Benefit (%) 87.0 87.0 87.0 

Generation Capacity Reduction (GW)

† 0.11 0.12 0.14 

Parentheses indicate negative (-) values. 

* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 

emissions. 

** For LCCs, a negative value means an increase in LCC by the amount indicated.

i

 Calculations based on the SCC series corresponding to a value of $22.3/ton in 2010, and a medium value for NOx 

corresponding to $2,537/t in 2010$† Changes in 2042. 

DOE first considered TSL 3, which is the max-tech efficiency level. TSL 3 would save 

0.312 quads of energy, an amount DOE considers significant. Under TSL 3, the NPV of 

consumer benefits would be $789 million, using a discount rate of 7 percent, and $1.55 billion, 

using a discount rate of 3 percent. 

418 
The cumulative emissions reductions at TSL 3 are 13.9 Mt of CO2, 11.5 kt of NOX, and 

0.092 t of Hg. The estimated monetary value of the cumulative CO2 emissions reductions at TSL 

3 ranges from $0.060 billion to $0.910 billion. Additionally, the NPV of consumer benefits 

added to the social cost of carbon and monetized NOx emissions reductions is maximized with a 

value of $1.866 billion at a 3-percent discount rate and $1.097 billion at a 7-percent discount rate 

at TSL 3. 

At TSL 3, the average LCC impact is a savings of $8.30 for AC battery output battery 

chargers. The median payback period is 1.5 years. The fraction of consumers experiencing an 

LCC benefit is 87.0 percent and the fraction of consumers experiencing an LCC cost is 13.0 

percent. 

At TSL 3, the projected change in INPV ranges from a decrease of $126 million to a 

decrease of $5 million. DOE recognizes the risk of large negative impacts if manufacturers’ 

expectations concerning reduced profit margins are realized. If the high end of the range of 

impacts is reached, as DOE expects, TSL 3 could result in a net loss of 20.5 percent in INPV to 

manufacturers of AC output battery chargers. 

The Secretary tentatively concludes that at TSL 3 for AC output battery chargers, the 

benefits of energy savings, positive NPV of consumer benefits, positive mean LCC savings, 

emission reductions, and the estimated monetary value of the CO2 emissions reductions outweigh 

the economic burden associated with the capital conversion costs and profit margin impacts that 

could result in a reduction in INPV for manufacturers. 

419 
 

After considering the analysis, comments to the September 2010 notice and the 

preliminary TSD, and the benefits and burdens of TSL 3, the Secretary tentatively concludes that 

this TSL will offer the maximum improvement in efficiency that is technologically feasible and 

economically justified and will result in the significant conservation of energy. Therefore, DOE 

today proposes to adopt TSL 3 for AC output battery chargers. The proposed new energy 

conservation standards for AC output battery chargers is shown in Table V-108. 

Table V-103 Proposed Standard for Product Class 10 

Product Class Maximum Unit Energy Consumption (kWh/yr) 

10a (AC Input, AC Output, 

without AVR) 

For Ebatt < 37.2 Wh, = 2.54 

For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt) – 0.18 

10b (AC Input, AC Output, with 

AVR) 

For Ebatt < 37.2 Wh, = 6.18 

For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt) + 3.45 

3. Summary of Benefits and Costs (Annualized) of Proposed Standards for External Power 

Supplies 

The benefits and costs of today’s proposed standards for EPSs can also be expressed in 

terms of annualized values over the 2013-2042 period. The annualized monetary values are the 

sum of: (1) the annualized national economic value (expressed in 2010$) of the benefits from 

operating products that meet the proposed standards (consisting primarily of operating cost 

savings from using less energy, minus increases in equipment purchase costs, which is another 

way of representing consumer NPV); and (2) the monetary value of the benefits of emission 

reductions, including CO2 emission reductions.71 The value of the CO2 reductions, otherwise 

71 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. 

First, DOE calculated a present value in 2011, the year used for discounting the NPV of total consumer costs and 

savings, for the time-series of costs and benefits using discount rates of three and seven percent for all costs and 

420 
 

 

known as the Social Cost of Carbon (SCC), is calculated using a range of values per metric ton 

of CO2 developed by a recent Federal interagency process. The monetary costs and benefits of 

cumulative emissions reductions are reported in 2010$ to permit comparisons with the other 

costs and benefits in the same dollar units. 

Although combining the values of operating savings and CO2 reductions provides a 

useful perspective, two issues should be considered. First, the national operating savings are 

domestic U.S. consumer monetary savings that occur as a result of market transactions, while the 

value of CO2 reductions is based on a global value. Second, the assessments of operating cost 

savings and CO2 savings are performed with different methods that use quite different time 

frames for analysis. The national operating cost savings is measured for the lifetime of products 

shipped in 2013–2042. The SCC values, on the other hand, reflect the present value of future 

climate-related impacts resulting from the emission of one metric ton of carbon dioxide in each 

year. These impacts go well beyond 2100. 

Estimates of annualized benefits and costs of the proposed standards for EPSs are shown 

in Table V-104. Using a 7-percent discount rate and the SCC value of $22.3/ton in 2010 (in 

2010$), the cost of the energy efficiency standards proposed in today’s NOPR is $251.9 million 

per year in increased equipment installed costs, while the annualized benefits are $325.2 per year 

in reduced equipment operating costs, $52.3 in CO2 reductions, and $3.2 million in reduced NOX 

benefits except for the value of CO2 reductions. For the latter, DOE used a range of discount rates. From the present 

value, DOE then calculated the fixed annual payment over a 30-year period, starting in 2013, which yields the same 

present value. The fixed annual payment is the annualized value. Although DOE calculated annualized values, this 

does not imply that the time-series of cost and benefits from which the annualized values were determined would be 

a steady stream of payments. 

421 
emissions. In this case, the net benefit amounts to $128.7 million per year. Using a 3-percent 

discount rate and the SCC value of $22.3/metric ton in 2010 (in 2010$), the cost of the energy 

efficiency standards proposed in today’s NOPR is $247.3 million per year in increased 

equipment installed costs, while the benefits are $348.2 million per year in reduced operating 

costs, $52.3 million in CO2 reductions, and $3.3 million in reduced NOX emissions. At a 3­

percent discount rate, the net benefit amounts to $156.6 million per year. 

422 
 

 

 

 

Table V-104 Annualized Benefits and Costs of Proposed Standards for EPSs 

Discount 

Rate 

Primary 

Estimate* 

Low Net 

Benefits 

Estimate* 

High Net 

Benefits 

Estimate* 

Monetized (million 2010$/year) 

Benefits 

Operating Cost Savings 

7% 325.2 309.1 341.1 

3% 348.2 329.5 367.3 

CO2 Reduction at $4.9/t** 5% 14.1 14.1 14.1 

CO2 Reduction at $22.3/t** 3% 52.3 52.3 52.3 

CO2 Reduction at $36.5/t** 2.5% 81.4 81.4 81.4 

CO2 Reduction at $67.6/t** 3% 159.6 159.6 159.6 

NOX Reduction at $2,537/t** 

7% 3.2 3.2 3.2 

3% 3.3 3.3 3.3 

Total† 

7% plus 

CO2 range 

342.5 to 488.0 326.4 to 471.9 358.4 to 

503.9 

7% 380.7 364.6 396.6 

3% 403.9 385.1 422.9 

3% plus 

CO2 range 

365.7 to 511.2 346.9 to 492.5 384.7 to 

530.3 

Costs 

Incremental Product Costs 

7% 251.9 251.9 251.9 

3% 247.3 247.3 247.3 

Total Net Benefits 

Total† 

7% plus 

CO2 range 

90.5 to 236.1 74.4 to 220.0 106.5 to 

252.0 

7% 128.7 112.6 144.7 

3% 156.6 137.9 175.7 

3% plus 

CO2 range 

118.4 to 264.0 99.7 to 245.2 137.5 to 

283.0 

* The results include benefits to consumers which accrue after 2042 from the products purchased from 2013 through 

2042. Costs incurred by manufacturers, some of which may be incurred prior to 2013 in preparation for the rule, are 

indirectly included as part of incremental equipment costs. The Primary, Low Benefits, and High Benefits Estimates 

utilize forecasts of energy prices from the AEO2010 Reference case, Low Estimate, and High Estimate, respectively 

** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 2010 under 

several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC distributions calculated 

using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.6 per ton represents the 

95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2010$) is 

the average of the low and high values used in DOE’s analysis. 

423 
 

 

 

 

 

 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent 

discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

4. Summary of Benefits and Costs (Annualized) of Proposed Standards for Battery Chargers 

The benefits and costs of today’s proposed standards for battery chargers can also be 

expressed in terms of annualized values over the 2013-2042 period. The annualized monetary 

values are the sum of: (1) the annualized national economic value (expressed in 2010$) of the 

benefits from operating products that meet the proposed standards (consisting primarily of 

operating cost savings from using less energy, minus increases in equipment purchase costs, 

which is another way of representing consumer NPV); and (2) the monetary value of the benefits 

of emission reductions, including CO2 emission reductions.72 The value of the CO2 reductions, 

otherwise known as the Social Cost of Carbon (SCC), is calculated using a range of values per 

metric ton of CO2 developed by a recent Federal interagency process. The monetary costs and 

benefits of cumulative emissions reductions are reported in 2010$ to permit comparisons with 

the other costs and benefits in the same dollar units. 

Although combining the values of operating savings and CO2 reductions provides a 

useful perspective, two issues should be considered. First, the national operating savings are 

domestic U.S. consumer monetary savings that occur as a result of market transactions, while the 

72 DOE used a two-step calculation process to convert the time-series of costs and benefits into annualized values. 

First, DOE calculated a present value in 2011, the year used for discounting the NPV of total consumer costs and 

savings, for the time-series of costs and benefits using discount rates of three and seven percent for all costs and 

benefits except for the value of CO2 reductions. For the latter, DOE used a range of discount rates, as shown in 

Table I.3. From the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in 

2013 that yields the same present value. The fixed annual payment is the annualized value. Although DOE 

calculated annualized values, this does not imply that the time-series of cost and benefits from which the annualized 

values were determined would be a steady stream of payments. 

424 
value of CO2 reductions is based on a global value. Second, the assessments of operating cost 

savings and CO2 savings are performed with different methods that use quite different time 

frames for analysis. The national operating cost savings is measured for the lifetime of products 

shipped in 2013–2042. The SCC values, on the other hand, reflect the present value of future 

climate-related impacts resulting from the emission of one metric ton of carbon dioxide in each 

year. These impacts go well beyond 2100. 

Estimates of annualized benefits and costs of the proposed standards for battery chargers 

are shown in Table V-104. Using a 7-percent discount rate and the SCC value of $22.3/ton in 

2010 (in 2010$), the standards proposed in today’s NOPR result in $110.0 million per year in 

equipment costs savings, and the annualized benefits are $447.2 million per year in reduced 

equipment operating costs, $71.6 million in CO2 reductions, and $4.3 million in reduced NOX 

emissions. In this case, the net benefit amounts to $633.0 million per year. Using a 3-percent 

discount rate and the SCC value of $22.3/metric ton in 2010 (in 2010$), the standards proposed 

in today’s NOPR result in $107.9 million per year in equipment costs savings, and the benefits 

are $485.2 million per year in reduced operating costs, $71.6 in CO2 reductions, and $4.5 million 

in reduced NOX emissions. At a 3-percent discount rate, the net benefit amounts to $669.3 

million per year. 

425 
 

 

 

 

 

 

 

 

Table V-105 Annualized Benefits and Costs of Proposed Standards for Battery Chargers 

Discount 

Rate 

Primary 

Estimate* 

Low Net 

Benefits 

Estimate* 

High Net 

Benefits 

Estimate* 

Monetized (million 2010$/year) 

Benefits 

Operating Cost Savings 

7% 447.2 425.6 468.8 

3% 485.2 459.7 511.2 

CO2 Reduction at $4.9/t** 5% 19.3 19.3 19.3 

CO2 Reduction at $22.3/t** 3% 71.6 71.6 71.6 

CO2 Reduction at $36.5/t** 2.5% 111.5 111.5 111.5 

CO2 Reduction at $67.6/t** 3% 218.5 218.5 218.5 

NOX Reduction at 

$2,537/t** 

7% 4.3 4.3 4.3 

3% 4.5 4.5 4.5 

Total† 

7% plus 

CO2 range 

470.7 to 670.0 449.1 to 648.4 492.4 to 691.6 

7% 523.1 501.5 544.7 

3% 561.3 535.8 587.4 

3% plus 

CO2 range 

509.0 to 708.2 483.5 to 682.7 535.0 to 734.3 

Costs 

Incremental Product Costs 

7% (110.0) (110.0) (110.0) 

3% (107.9) (107.9) (107.9) 

Total Net Benefits 

Total † 

7% plus 

CO2 range 

580.7 to 780.0 559.1 to 758.3 602.3 to 801.6 

7% 633.0 611.4 654.7 

3% 669.3 643.8 695.3 

3% plus 

CO2 range 

616.9 to 816.2 591.4 to 790.7 643.0 to 842.2 

* The results include benefits to consumers which accrue after 2042 from the products purchased from 2013 through 

2042. Costs incurred by manufacturers, some of which may be incurred prior to 2013 in preparation for the rule, are 

indirectly included as part of incremental equipment costs. The Primary, Low Benefits, and High Benefits Estimates 

utilize forecasts of energy prices from the AEO2010 Reference case, Low Estimate, and High Estimate, 

respectively. 

** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 2010 under 

several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC distributions calculated 

using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.6 per ton represents the 

95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NOX (in 2010$) is 

the average of the low and high values used in DOE’s analysis. 

426 
 

 

 

† Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value calculated at a 3-percent 

discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as “7% plus CO2 range” and “3% plus CO2 

range,” the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are 

added to the full range of CO2 values. 

VI. Procedural Issues and Regulatory Review 

A. Review Under Executive Order 12866 and 13563 

Section 1(b)(1) of Executive Order 12866, “Regulatory Planning and Review,” 58 FR 

51735 (Oct. 4, 1993), requires each agency to identify the problem that it intends to address, 

including, where applicable, the failures of private markets or public institutions that warrant 

new agency action, as well as to assess the significance of that problem. The problems that 

today’s standards address are as follows: 

(1) There is a lack of consumer information and/or information processing capability about 

energy efficiency opportunities in the home appliance market. 

(2) There is asymmetric information (one party to a transaction has more and better 

information than the other) and/or high transactions costs (costs of gathering information 

and effecting exchanges of goods and services) in the home appliance market. 

(3) There are external benefits resulting from improved energy efficiency of battery chargers 

and EPSs that are not captured by the users of such equipment. These benefits include 

externalities related to environmental protection and energy security that are not reflected 

in energy prices, such as reduced emissions of greenhouse gases. 

In addition, DOE has determined that today’s regulatory action is an “economically 

significant regulatory action” under section 3(f)(1) of Executive Order 12866. Accordingly, 

section 6(a)(3) of the Executive Order requires that DOE prepare a regulatory impact analysis 

427 
 

(RIA) on today’s rule and that the Office of Information and Regulatory Affairs (OIRA) in the 

Office of Management and Budget (OMB) review this rule. In the RIA, DOE identified and 

analyzed six alternatives to standards, including consumer rebates, consumer tax credits, 

manufacturer tax credits, voluntary energy efficiency targets, an early replacement program, and 

a bulk government purchasing program. DOE quantified the NES and NPV for these alternatives 

and did not find any alternatives to be more beneficial than standards for any BC or EPS product 

class. 

DOE presented to OIRA for review the draft rule and other documents prepared for this 

rulemaking, including the RIA73, and has included these documents in the rulemaking record. 

The assessments prepared pursuant to Executive Order 12866 can be found in the technical 

support document for this rulemaking. They are available for public review in the Resource 

Room of DOE’s Building Technologies Program, 950 L’Enfant Plaza, SW., Suite 600, 

Washington, DC 20024, (202) 586-2945, between 9:00 a.m. and 4:00 p.m., Monday through 

Friday, except Federal holidays. 

DOE has also reviewed this regulation pursuant to Executive Order 13563, issued on 

January 18, 2011 (76 FR 3281 (Jan. 21, 2011)). EO 13563 is supplemental to, and explicitly 

reaffirms the principles, structures, and definitions governing regulatory review established in, 

Executive Order 12866. To the extent permitted by law, agencies are required by Executive 

Order 13563 to: (1) propose or adopt a regulation only upon a reasoned determination that its 

73 The Regulatory Impact Analysis is also available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/battery_external_preliminaryanalysis_tsd.ht 

ml#tsd 

428 
benefits justify its costs (recognizing that some benefits and costs are difficult to quantify); (2) 

tailor regulations to impose the least burden on society, consistent with obtaining regulatory 

objectives, taking into account, among other things, and to the extent practicable, the costs of 

cumulative regulations; (3) select, in choosing among alternative regulatory approaches, those 

approaches that maximize net benefits (including potential economic, environmental, public 

health and safety, and other advantages; distributive impacts; and equity); (4) to the extent 

feasible, specify performance objectives, rather than specifying the behavior or manner of 

compliance that regulated entities must adopt; and (5) identify and assess available alternatives 

to direct regulation, including providing economic incentives to encourage the desired behavior, 

such as user fees or marketable permits, or providing information upon which choices can be 

made by the public. 

We emphasize as well that Executive Order 13563 requires agencies “to use the best 

available techniques to quantify anticipated present and future benefits and costs as accurately as 

possible.” In its guidance, the Office of Information and Regulatory Affairs has emphasized that 

such techniques may include “identifying changing future compliance costs that might result 

from technological innovation or anticipated behavioral changes.” For the reasons stated in the 

preamble, DOE believes that today’s notice of proposed rulemaking is consistent with these 

principles, including that, to the extent permitted by law, agencies adopt a regulation only upon a 

reasoned determination that its benefits justify its costs and select, in choosing among alternative 

regulatory approaches, those approaches that maximize net benefits. 

429 
B. Review Under the Regulatory Flexibility Act 

The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation of an initial 

regulatory flexibility analysis (IRFA) for any rule that by law must be proposed for public 

comment, unless the agency certifies that the rule, if promulgated, will not have a significant 

economic impact on a substantial number of small entities. As required by Executive Order 

13272, “Proper Consideration of Small Entities in Agency Rulemaking,” 67 FR 53461 (August 

16, 2002), DOE published procedures and policies on February 19, 2003, to ensure that the 

potential impacts of its rules on small entities are properly considered during the rulemaking 

process. 68 FR 7990. DOE has made its procedures and policies available on the Office of the 

General Counsel’s website (www.gc.doe.gov ). DOE reviewed the potential standard levels 

considered in today’s NOPR under the provisions of the Regulatory Flexibility Act and the 

procedures and policies published on February 19, 2003. 

As a result of this review, DOE has prepared an IRFA addressing the impacts on small 

manufacturers with respect to the battery charger portion of this proposal. DOE will transmit a 

copy of the IRFA to the Chief Counsel for Advocacy of the Small Business Administration 

(SBA) for review under 5 U.S.C 605(b). As presented and discussed below, the IFRA describes 

potential impacts on small business manufacturers of battery chargers associated with the 

required capital and product conversion costs at each TSL and discusses alternatives that could 

minimize these impacts. Because DOE did not find any small business EPS manufacturers, DOE 

did not prepare an IRFA regarding the impacts on EPS manufacturers from this proposal. 

430 
A statement of the reasons for the proposed rule, and the objectives of, and legal basis 

for, the proposed rule, are set forth elsewhere in the preamble and not repeated here. 

1. Description and Estimated Number of Small Entities Regulated 

a. Methodology for Estimating the Number of Small Entities 

For manufacturers of EPSs and battery chargers, the SBA has set a size threshold, which 

defines those entities classified as “small businesses” for the purposes of the statute. DOE used 

the SBA’s small business size standards to determine whether any small entities would be 

subject to the requirements of the rule. 65 FR 30836, 30850 (May 15, 2000), as amended at 65 

FR 53533, 53545 (Sept. 5, 2000) and codified at 13 CFR part 121. The size standards are listed 

by North American Industry Classification System (NAICS) code and industry description and 

are available at 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf . EPS 

and battery charger manufacturing is classified under NAICS 335999, “All Other Miscellaneous 

Electrical Equipment and Component Manufacturing.” The SBA sets a threshold of 500 

employees or less for an entity to be considered as a small business for this category. 

To estimate the number of companies that could be small business manufacturers of 

products covered by this rulemaking, DOE conducted a market survey using all available public 

information to identify potential small manufacturers. DOE’s research involved industry trade 

association membership directories, product databases, individual company websites, and the 

SBA’s Small Business Database to create a list of every company that could potentially 

manufacture products covered by this rulemaking. DOE also asked stakeholders and industry 

431 
representatives if they were aware of any other small manufacturers during manufacturer 

interviews and at previous DOE public meetings. DOE contacted companies on its list, as 

necessary, to determine whether they met the SBA’s definition of a small business manufacturer 

of covered EPSs and battery chargers. DOE screened out companies that did not offer products 

covered by this rulemaking, did not meet the definition of a “small business,” or are foreignowned and operated. 

Based on this screening, DOE identified 30 companies that could potentially manufacture 

EPSs or battery chargers. DOE eliminated most of these companies from consideration as small 

business manufacturers based on a review of product literature and websites. When those steps 

yielded inconclusive information, DOE contacted the companies directly. As part of these 

efforts, DOE identified Lester Electrical, Inc. (Lincoln, Nebraska), a manufacturer of golf car 

battery chargers, as the only small business that appears to produce covered battery chargers 

domestically. 

DOE did not identify any small business manufacturers of EPSs. DOE also did not 

identify any domestic manufacturers of EPSs, which indicates that all residential EPSs sold in 

the United States are imported. Because there are no small business manufacturers of EPSs, DOE 

certifies that the standards for EPSs set forth in the proposed rule, if promulgated, would not 

have a significant economic impact on a substantial number of small entities. Accordingly, DOE 

has not prepared a regulatory flexibility analysis for the EPS portion of this rulemaking. DOE 

will transmit the certification and supporting statement of factual basis to the Chief Counsel for 

Advocacy of the Small Business Administration for review under 5 U.S.C. 605(b). 

432 
DOE requests comment on the above analysis, as well as any information concerning 

small businesses that could be impacted by this rulemaking and the nature and extent of those 

potential impacts of the proposed energy conservation standards on small EPS manufacturers. 

(See Issue 30 under “Issues on Which DOE Seeks Comment” in section VII.E of this NOPR.) 

The following sections address the IFRA for small business manufacturers of battery 

chargers. 

b. Manufacturer Participation 

Before issuing this NOPR, DOE contacted the potential small business manufacturers of 

battery chargers it had identified. One small business consented to being interviewed during the 

MIA interviews. DOE also obtained information about small business impacts while 

interviewing large manufacturers. 

c. Battery Charger Industry Structure 

With respect to battery chargers, industry structure is typically defined by the 

characteristics of the industry of the application(s) for which the battery chargers are produced. 

In the case of the small business DOE identified, however, the battery charger itself is the 

product the small business produces. That is, the company does not also produce the applications 

with which the battery charger is intended to be used. Specifically, the company manufactures 

battery chargers predominantly intended for golf cars (product class 7) and wheelchairs (product 

classes 5 and 6). 

433 
A high level of concentration exists in both battery charger markets. Two players account 

for the vast majority of the golf car battery charger market and each has a similar share. Both 

competitors in the golf car battery charger market are small businesses: one is foreign-owned and 

operated, while the other is a domestic small business. Despite this concentration, there is 

considerable competition for three main reasons. First, each manufacturer sells into a market that 

is almost as equally concentrated: three golf car manufacturers supply the majority of the golf 

cars sold domestically. Second, while there are currently only two major suppliers of battery 

chargers to the domestic market, the constant prospect of potential entry from other foreign 

countries has ceded substantial buying power to the three golf car OEMs. Third, golf car 

manufacturers have the ever-present option of not building electric golf cars altogether (and thus 

the need for the battery charger) by opting to build gas-powered products. DOE examines a price 

elasticity sensitivity scenario for this in chapter 12 of the TSD to assess this possibility. 

Currently, roughly three-quarters of the golf car market is electric, with the remainder gaspowered. 

The majority of industry shipments flow to the “fleet” segment -- i.e. battery chargers 

sold to golf car manufacturers who then lease the cars to golf courses. Most cars are leased for 

the first few years before being sold to smaller golf courses or other individuals for personal use. 

A smaller portion of golf cars are sold as new through dealer distribution. 

Further upstream, approximately half of the battery chargers intended for golf car use is 

manufactured domestically, while the other half is foreign-sourced. These latter-sourced battery 

434 
chargers are typically high frequency designs, while line frequency designs, which are usually 

less efficient, are made domestically. During the design cycle of the golf car, the battery charger 

supplier and OEM typically work closely together when designing the battery charger. 

The small business manufacturer is also a relatively smaller player in the markets for 

wheelchair and industrial lift battery chargers. Most wheelchair battery chargers and the 

wheelchairs themselves are manufactured overseas. Three wheelchair manufacturers supply the 

majority of the U.S. market, but do not have domestic manufacturing. 

d. Comparison Between Large and Small Entities 

As discussed above, there are two major suppliers in the golf car battery charger market. 

Both are small businesses, although one is foreign-owned and operated. DOE did not identify 

any large businesses with which to compare the projected impacts on small businesses. 

2. Description and Estimate of Compliance Requirements 

The U.S.-owned small business DOE identified manufactures battery chargers for golf 

cars (product class 7) and wheelchairs (product classes 5 and 6), as well as industrial lifts (which 

are not covered by this rulemaking). DOE anticipates the proposed rule will require both capital 

and product conversion costs to achieve compliance. Various combinations of selected TSLs for 

product classes 5 and 6 (which are combined under a single TSL) and product class 7 will drive 

different levels of small business impacts. The compliance costs associated with this 

combination of potential TSLs are present in tables Table VI-1. Compared to the product 

development (R&D) efforts required to achieve the proposed levels, DOE does not expect the 

435 
various potential combinations of TSLs to require significant capital expenditures. Although 

some replacement of fixtures, new assembly equipment and tooling would be required, the 

magnitude of these expenditures would be unlikely to cause significant adverse financial 

impacts. Product class 7 drives the majority of these costs. See Table VI.1 below for the 

estimated capital conversion costs for a typical small business. 

Table VI-1The product conversion costs associated with standards are more significant 

for the small business manufacturer at issue than the projected capital costs. As discussed in 

section V.B.2.a.ii of this notice, TSL 1 for product class 7 reflects a technology change from a 

linear battery charger at the baseline to a switch-mode or high-frequency design. This change 

would require manufacturers that produce linear battery chargers to invest heavily in the 

development of a new product design, which would require investments in engineering resources 

for R&D, testing, and certification, and marketing and training changes. Again, the level of 

expenditure at each TSL is driven almost entirely by the changes required for product class 7 at 

each TSL. See the table below for estimated product conversion costs for a typical small 

business. 

Table VI-2, and Table VI-3 below, accompanied by a description of these and other 

impacts. 

a. Capital Conversion Costs 

Compared to the product development (R&D) efforts required to achieve the proposed 

levels, DOE does not expect the various potential combinations of TSLs to require significant 

436 
capital expenditures. Although some replacement of fixtures, new assembly equipment and 

tooling would be required, the magnitude of these expenditures would be unlikely to cause 

significant adverse financial impacts. Product class 7 drives the majority of these costs. See 

Table VI.1 below for the estimated capital conversion costs for a typical small business. 

Table VI-1 Estimated Capital Conservation Costs for a Typical Small Business (2010$ 

million) 

Alternatives 1 2* 3 4** 

If the TSL for PC 5 & 6 is... TSL 1 TSL 2 TSL 2 TSL 3 

And the TSL for PC 7 is... TSL 1 TSL 1 TSL 2 TSL 2 

Estimated Capital Conversion Costs $0.1 $0.1 $0.1 $0.1 

*This alternative reflects the combination of TSLs proposed in today’s rulemaking. 

**Reflects max-tech. 

b. Product Conversion Costs 

The product conversion costs associated with standards are more significant for the small 

business manufacturer at issue than the projected capital costs. As discussed in section V.B.2.a.ii 

of this notice, TSL 1 for product class 7 reflects a technology change from a linear battery 

charger at the baseline to a switch-mode or high-frequency design. This change would require 

manufacturers that produce linear battery chargers to invest heavily in the development of a new 

product design, which would require investments in engineering resources for R&D, testing, and 

certification, and marketing and training changes. Again, the level of expenditure at each TSL is 

driven almost entirely by the changes required for product class 7 at each TSL. See the table 

below for estimated product conversion costs for a typical small business. 

437 
Table VI-2 Estimated Product Conversion Costs for a Typical Small Business (2010$ 

million) 

Alternatives 1 2* 3 4** 

If the TSL for PC 5 & 6 is... TSL 1 TSL 2 TSL 2 TSL 3 

And the TSL for PC 7 is... TSL 1 TSL 1 TSL 2 TSL 2 

Estimated Product Conversion Costs $2.5 $2.7 $4.8 $5.1 

*This alternative reflects the combination of TSLs proposed in today’s rulemaking. 

**Reflects max-tech. 

c. Summary of Compliance Impacts 

Table VI-3 Estimated Total Conversion Costs for a Typical Small Business (2010$ million) 

Alternatives 1 2* 3 4** 

If the TSL for PC 5 & 6 is... TSL 1 TSL 2 TSL 2 TSL 3 

And the TSL for PC 7 is... TSL 1 TSL 1 TSL 2 TSL 2 

Estimated Total Conversion Costs $2.6 $2.8 $4.9 $5.2 

*This alternative reflects the combination of TSLs proposed in today’s rulemaking. 

**Reflects max-tech. 

Based on its engineering analysis, manufacturer interviews and public comments, DOE 

believes TSL 1 for product class 7 would establish an efficiency level that standard linear battery 

chargers could not cost-effectively achieve. Not only would the size and weight of such chargers 

potentially conflict with end-user preferences, but the additional steel and copper needs would 

make such chargers cost-prohibitive in the marketplace. Baseline linear designs are already 

significantly more costly to manufacture than the more-efficient switch-mode designs, as DOE’s 

cost efficiency curve shows (see Table IV-22). Because, in this case, the small business 

manufacturer is positioned as a vertically integrated supplier of linear battery chargers, any 

energy conservation standard that effectively required switch-mode technology would likely 

cause significant adverse impacts on that manufacturer. All products currently manufactured inhouse by this manufacturer would likely require complete redesigns. 

438 
The potential impacts of a standard on the small business manufacturer are not entirely 

captured by the conversion costs estimates, however. While standard linear battery chargers 

typically have much higher associated material costs relative to the switch-mode battery 

chargers, the manufacturing process of switch-mode designs is more labor intensive. Therefore, 

in high-wage countries like the United States, a manufacturer is at a relative cost-disadvantage in 

producing switch-mode battery chargers. It is most likely for this reason that DOE was unable to 

identify any domestic manufacturing of switch-mode battery chargers. 

At the proposed efficiency levels, the small business manufacturer will face a difficult 

decision on whether to attempt to manufacture switch-mode battery chargers in-house and likely 

compete on factors other than price, move production to lower-wage regions, or source their 

battery charger manufacturing to a foreign company and rebrand these battery chargers. Given 

the lack of domestic switch-mode battery charger manufacturers, one of the latter two strategies 

would appear the more likely course. 

3. Duplication, Overlap, and Conflict with Other Rules and Regulations 

DOE is not aware of any rules or regulations that duplicate, overlap, or conflict with the 

rule being considered today. 

4. Significant Alternatives to the Proposed Rule 

The discussion above analyzes impacts on small businesses that would result from the 

other TSLs DOE considered. Though TSLs lower than the proposed TSLs are expected to reduce 

the impacts on small entities, DOE is required by EPCA to establish standards that achieve the 

439 
maximum improvement in energy efficiency that are technically feasible and economically 

justified, and result in a significant conservation of energy. Once DOE determines that a 

particular TSL meets those requirements, DOE adopts that TSL in satisfaction of its obligations 

under EPCA. 

In addition to the other TSLs being considered, the NOPR TSD includes a regulatory 

impact analysis in chapter 17. For battery chargers, this report discusses the following policy 

alternatives: (1) no standard, (2) consumer rebates, (3) consumer tax credits, (4) manufacturer tax 

credits, and (5) early replacement. DOE does not intend to consider these alternatives further 

because they are either not feasible to implement, or not expected to result in energy savings as 

large as those that would be achieved by the standard levels under consideration. 

DOE continues to seek input from businesses that would be affected by this rulemaking 

and will consider comments received in the development of any final rule. 

C. Review Under the Paperwork Reduction Act 

Manufacturers of battery chargers and EPSs must certify to DOE that their product 

complies with any applicable energy conservation standard. In certifying compliance, 

manufacturers must test their products according to the DOE test procedure for battery chargers 

and EPSs, including any amendments adopted for that test procedure. DOE has proposed 

regulations for the certification and recordkeeping requirements for all covered consumer 

products and commercial equipment, including EPSs 75 FR 56796 (Sept. 16, 2010). The 

collection-of-information requirement for the certification and recordkeeping is subject to review 

440 
and approval by OMB under the Paperwork Reduction Act (PRA). This requirement has been 

submitted to OMB for approval and only applies to Class A EPSs. As discussed, new reporting 

requirements for battery chargers and non-Class A EPSs will be proposed and a collection-ofinformation requirement for the certification and recordkeeping subject to review and approval 

by OMB under the PRA will be submitted as part of a future certification, compliance, and 

enforcement rule promulgated by DOE. Public reporting burden for the certification is estimated 

to average 20 hours per response, including the time for reviewing instructions, searching 

existing data sources, gathering and maintaining the data needed, and completing and reviewing 

the collection of information. 

Public comment is sought regarding: whether this proposed collection of information is 

necessary for the proper performance of the functions of the agency, including whether the 

information shall have practical utility; the accuracy of the burden estimate; ways to enhance the 

quality, utility, and clarity of the information to be collected; and ways to minimize the burden of 

the collection of information, including through the use of automated collection techniques or 

other forms of information technology. Send comments on these or any other aspects of the 

collection of information to Victor Petrolati (see ADDRESSES) and by e-mail to 

Chad_S_Whiteman@omb.eop.gov. 

Notwithstanding any other provision of the law, no person is required to respond to, nor 

shall any person be subject to a penalty for failure to comply with, a collection of information 

subject to the requirements of the PRA, unless that collection of information displays a currently 

valid OMB Control Number. 

441 
D. Review Under the National Environmental Policy Act of 1969 

Pursuant to the National Environmental Policy Act (NEPA) of 1969, DOE has 

determined that the proposed rule fits within the category of actions included in Categorical 

Exclusion (CX) B5.1 and otherwise meets the requirements for application of a CX. See 10 CFR 

Part 1021, App. B, B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). The proposed rule fits 

within the category of actions because it is a rulemaking that establishes energy conservation 

standards for consumer products or industrial equipment, and for which none of the exceptions 

identified in CX B5.1(b) apply. Therefore, DOE has made a CX determination for this 

rulemaking, and DOE does not need to prepare an Environmental Assessment or Environmental 

Impact Statement for this proposed rule. DOE’s CX determination for this proposed rule is 

available at http://cxnepa.energy.gov/. 

E. Review Under Executive Order 13132 

Executive Order 13132, "Federalism," 64 FR 43255 (August 10, 1999) imposes certain 

requirements on agencies formulating and implementing policies or regulations that preempt 

State law or that have Federalism implications. The Executive Order requires agencies to 

examine the constitutional and statutory authority supporting any action that would limit the 

policymaking discretion of the States and to carefully assess the necessity for such actions. The 

Executive Order also requires agencies to have an accountable process to ensure meaningful and 

timely input by State and local officials in the development of regulatory policies that have 

Federalism implications. On March 14, 2000, DOE published a statement of policy describing 

the intergovernmental consultation process it will follow in the development of such regulations. 

65 FR 13735. EPCA governs and prescribes Federal preemption of State regulations as to energy 

442 
conservation for the products that are the subject of today’s proposed rule. States can petition 

DOE for exemption from such preemption to the extent, and based on criteria, set forth in EPCA. 

(42 U.S.C. 6297) No further action is required by Executive Order 13132. 

F. Review Under Executive Order 12988 

With respect to the review of existing regulations and the promulgation of new 

regulations, section 3(a) of Executive Order 12988, "Civil Justice Reform," imposes on Federal 

agencies the general duty to adhere to the following requirements: (1) eliminate drafting errors 

and ambiguity; (2) write regulations to minimize litigation; and (3) provide a clear legal standard 

for affected conduct rather than a general standard and promote simplification and burden 

reduction. 61 FR 4729 (Feb. 7, 1996). Section 3(b) of Executive Order 12988 specifically 

requires that Executive agencies make every reasonable effort to ensure that the regulation: (1) 

clearly specifies the preemptive effect, if any; (2) clearly specifies any effect on existing Federal 

law or regulation; (3) provides a clear legal standard for affected conduct while promoting 

simplification and burden reduction; (4) specifies the retroactive effect, if any; (5) adequately 

defines key terms; and (6) addresses other important issues affecting clarity and general 

draftsmanship under any guidelines issued by the Attorney General. Section 3(c) of Executive 

Order 12988 requires Executive agencies to review regulations in light of applicable standards in 

section 3(a) and section 3(b) to determine whether they are met or it is unreasonable to meet one 

or more of them. DOE has completed the required review and determined that, to the extent 

permitted by law, this proposed rule meets the relevant standards of Executive Order 12988. 

443 
G. Review Under the Unfunded Mandates Reform Act of 1995 

Title II of the Unfunded Mandates Reform Act of 1995 (UMRA) requires each Federal 

agency to assess the effects of Federal regulatory actions on State, local, and Tribal governments 

and the private sector. Pub. L. No. 104-4, sec. 201 (codified at 2 U.S.C. 1531). For a proposed 

regulatory action likely to result in a rule that may cause the expenditure by State, local, and 

Tribal governments, in the aggregate, or by the private sector of $100 million or more in any one 

year (adjusted annually for inflation), section 202 of UMRA requires a Federal agency to publish 

a written statement that estimates the resulting costs, benefits, and other effects on the national 

economy. (2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to develop an 

effective process to permit timely input by elected officers of State, local, and Tribal 

governments on a proposed “significant intergovernmental mandate,” and requires an agency 

plan for giving notice and opportunity for timely input to potentially affected small governments 

before establishing any requirements that might significantly or uniquely affect small 

governments. On March 18, 1997, DOE published a statement of policy on its process for 

intergovernmental consultation under UMRA. 62 FR 12820; also available at 

http://www.gc.doe.gov. 

Although today’s proposed rule does not contain a Federal intergovernmental mandate, it 

may impose expenditures of $100 million or more on the private sector. Specifically, the 

proposed rule will likely result in a final rule that could impose expenditures of $100 million or 

more. Such expenditures may include (1) investment in research and development and in capital 

expenditures by battery charger and EPS manufacturers in the years between the final rule and 

444 
the compliance date for the new standard, and (2) incremental additional expenditures by 

consumers to purchase higher-efficiency battery chargers and EPSs, starting in 2013. 

Section 202 of UMRA authorizes an agency to respond to the content requirements of 

UMRA in any other statement or analysis that accompanies the proposed rule. 2 U.S.C. 1532(c). 

The content requirements of section 202(b) of UMRA relevant to a private sector mandate 

substantially overlap the economic analysis requirements that apply under section 325(o) of 

EPCA and Executive Order 12866. The SUPPLEMENTARY INFORMATION section of this 

NOPR and the “Regulatory Impact Analysis” section of the TSD for this proposed rule respond 

to those requirements. 

Under section 205 of UMRA, the Department is obligated to identify and consider a 

reasonable number of regulatory alternatives before promulgating a rule for which a written 

statement under section 202 is required. 2 U.S.C. 1535(a). DOE is required to select from those 

alternatives the most cost-effective and least burdensome alternative that achieves the objectives 

of the rule unless DOE publishes an explanation for doing otherwise or the selection of such an 

alternative is inconsistent with law. As required by 42 U.S.C. 6295(u), today’s proposed rule 

would establish energy conservation standards for battery chargers and EPSs that are designed to 

achieve the maximum improvement in energy efficiency that DOE has determined to be both 

technologically feasible and economically justified. A full discussion of the alternatives 

considered by DOE is presented in the “Regulatory Impact Analysis” section of the TSD for 

today’s proposed rule. 

445 
H. Review Under the Treasury and General Government Appropriations Act, 1999 

Section 654 of the Treasury and General Government Appropriations Act, 1999 (Pub. L. 

105-277) requires Federal agencies to issue a Family Policymaking Assessment for any rule that 

may affect family well-being. This proposed rule would not have any impact on the autonomy or 

integrity of the family as an institution. Accordingly, DOE has concluded that it is not necessary 

to prepare a Family Policymaking Assessment. 

I. Review Under Executive Order 12630 

DOE has determined, under Executive Order 12630, “Governmental Actions and 

Interference with Constitutionally Protected Property Rights” 53 FR 8859 (March 18, 1988), that 

this proposed regulation would not result in any takings that might require compensation under 

the Fifth Amendment to the U.S. Constitution. 

J. Review Under the Treasury and General Government Appropriations Act, 2001 

Section 515 of the Treasury and General Government Appropriations Act, 2001 (44 

U.S.C. 3516, note) provides for agencies to review most disseminations of information to the 

public under guidelines established by each agency pursuant to general guidelines issued by 

OMB. OMB’s guidelines were published at 67 FR 8452 (Feb. 22, 2002), and DOE’s guidelines 

were published at 67 FR 62446 (Oct. 7, 2002). DOE has reviewed today’s NOPR under the 

OMB and DOE guidelines and has concluded that it is consistent with applicable policies in 

those guidelines. 

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K. Review Under Executive Order 13211 

Executive Order 13211, “Actions Concerning Regulations That Significantly Affect 

Energy Supply, Distribution, or Use” 66 FR 28355 (May 22, 2001), requires Federal agencies to 

prepare and submit to OIRA at OMB, a Statement of Energy Effects for any proposed significant 

energy action. A “significant energy action” is defined as any action by an agency that 

promulgates or is expected to lead to promulgation of a final rule, and that (1) is a significant 

regulatory action under Executive Order 12866, or any successor order; and (2) is likely to have 

a significant adverse effect on the supply, distribution, or use of energy, or (3) is designated by 

the Administrator of OIRA as a significant energy action. For any proposed significant energy 

action, the agency must give a detailed statement of any adverse effects on energy supply, 

distribution, or use should the proposal be implemented, and of reasonable alternatives to the 

action and their expected benefits on energy supply, distribution, and use. 

DOE has tentatively concluded that today’s proposed regulatory action, which sets forth 

proposed energy conservation standards for battery chargers and EPSs, is not a significant energy 

action because the proposed standards are not likely to have a significant adverse effect on the 

supply, distribution, or use of energy, nor has it been designated as such by the Administrator at 

OIRA. Accordingly, DOE has not prepared a Statement of Energy Effects on the proposed rule. 

L. Review Under the Information Quality Bulletin for Peer Review 

On December 16, 2004, OMB, in consultation with the Office of Science and Technology 

(OSTP), issued its Final Information Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 

(Jan. 14, 2005). The Bulletin establishes that certain scientific information shall be peer reviewed 

447 
by qualified specialists before it is disseminated by the Federal Government, including 

influential scientific information related to agency regulatory actions. The purpose of the bulletin 

is to enhance the quality and credibility of the Government’s scientific information. Under the 

Bulletin, the energy conservation standards rulemaking analyses are “influential scientific 

information,” which the Bulletin defines as “scientific information the agency reasonably can 

determine will have or does have a clear and substantial impact on important public policies or 

private sector decisions.” 70 FR 2667. 

In response to OMB’s Bulletin, DOE conducted formal in-progress peer reviews of the 

energy conservation standards development process and analyses and has prepared a Peer 

Review Report pertaining to the energy conservation standards rulemaking analyses. Generation 

of this report involved a rigorous, formal, and documented evaluation using objective criteria and 

qualified and independent reviewers to make a judgment as to the technical/scientific/business 

merit, the actual or anticipated results, and the productivity and management effectiveness of 

programs and/or projects. The “Energy Conservation Standards Rulemaking Peer Review 

Report” dated February 2007 has been disseminated and is available at the following Web site: 

http://www1.eere.energy.gov/buildings/appliance_standards/peer_review.html. 

VII. Public Participation 

A. Attendance at Public Meeting 

The time, date and location of the public meeting are listed in the DATES and 

ADDRESSES sections at the beginning of this document. If you plan to attend the public 

448 
meeting, please notify Ms. Brenda Edwards at (202) 586-2945 or Brenda.Edwards@ee.doe.gov. 

As explained in the ADDRESSES section, foreign nationals visiting DOE Headquarters are 

subject to advance security screening procedures. 

In addition, you can attend the public meeting via webinar. Webinar registration 

information, participant instructions, and information about the capabilities available to webinar 

participants will be published on DOE’s website 

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

Participants are responsible for ensuring their systems are compatible with the webinar software. 

B. Procedure for Submitting Prepared General Statements For Distribution 

Any person who has plans to present a prepared general statement may request that 

copies of his or her statement be made available at the public meeting. Such persons may submit 

requests, along with an advance electronic copy of their statement in PDF (preferred), Microsoft 

Word or Excel, WordPerfect, or text (ASCII) file format, to the appropriate address shown in the 

ADDRESSES section at the beginning of this notice. The request and advance copy of 

statements must be received at least one week before the public meeting and may be emailed, 

hand-delivered, or sent by mail. DOE prefers to receive requests and advance copies via email. 

Please include a telephone number to enable DOE staff to make a follow-up contact, if needed. 

C. Conduct of Public Meeting 

DOE will designate a DOE official to preside at the public meeting and may also use a 

professional facilitator to aid discussion. The meeting will not be a judicial or evidentiary-type 

449 
public hearing, but DOE will conduct it in accordance with section 336 of EPCA (42 U.S.C. 

6306). A court reporter will be present to record the proceedings and prepare a transcript. DOE 

reserves the right to schedule the order of presentations and to establish the procedures governing 

the conduct of the public meeting. After the public meeting, interested parties may submit further 

comments on the proceedings as well as on any aspect of the rulemaking until the end of the 

comment period. 

The public meeting will be conducted in an informal, conference style. DOE will present 

summaries of comments received before the public meeting, allow time for prepared general 

statements by participants, and encourage all interested parties to share their views on issues 

affecting this rulemaking. Each participant will be allowed to make a general statement (within 

time limits determined by DOE), before the discussion of specific topics. DOE will permit, as 

time permits, other participants to comment briefly on any general statements. 

At the end of all prepared statements on a topic, DOE will permit participants to clarify 

their statements briefly and comment on statements made by others. Participants should be 

prepared to answer questions by DOE and by other participants concerning these issues. DOE 

representatives may also ask questions of participants concerning other matters relevant to this 

rulemaking. The official conducting the public meeting will accept additional comments or 

questions from those attending, as time permits. The presiding official will announce any further 

procedural rules or modification of the above procedures that may be needed for the proper 

conduct of the public meeting. 

450 
A transcript of the public meeting will be included in the docket, which can be viewed as 

described in the Docket section at the beginning of this notice. In addition, any person may buy a 

copy of the transcript from the transcribing reporter. 

D. Submission of Comments 

DOE will accept comments, data, and information regarding this proposed rule before or 

after the public meeting, but no later than the date provided in the DATES section at the 

beginning of this proposed rule. Interested parties may submit comments using any of the 

methods described in the ADDRESSES section at the beginning of this notice. 

Submitting comments via regulations.gov. The regulations.gov web page will require you 

to provide your name and contact information. Your contact information will be viewable to 

DOE Building Technologies staff only. Your contact information will not be publicly viewable 

except for your first and last names, organization name (if any), and submitter representative 

name (if any). If your comment is not processed properly because of technical difficulties, DOE 

will use this information to contact you. If DOE cannot read your comment due to technical 

difficulties and cannot contact you for clarification, DOE may not be able to consider your 

comment. 

However, your contact information will be publicly viewable if you include it in the 

comment or in any documents attached to your comment. Any information that you do not want 

to be publicly viewable should not be included in your comment, nor in any document attached 

451 
to your comment. Persons viewing comments will see only first and last names, organization 

names, correspondence containing comments, and any documents submitted with the comments. 

Do not submit to regulations.gov information for which disclosure is restricted by statute, 

such as trade secrets and commercial or financial information (hereinafter referred to as 

Confidential Business Information (CBI)). Comments submitted through regulations.gov cannot 

be claimed as CBI. Comments received through the website will waive any CBI claims for the 

information submitted. For information on submitting CBI, see the Confidential Business 

Information section. 

DOE processes submissions made through regulations.gov before posting. Normally, 

comments will be posted within a few days of being submitted. However, if large volumes of 

comments are being processed simultaneously, your comment may not be viewable for up to 

several weeks. Please keep the comment tracking number that regulations.gov provides after you 

have successfully uploaded your comment. 

Submitting comments via email, hand delivery, or mail. Comments and documents 

submitted via email, hand delivery, or mail also will be posted to regulations.gov. If you do not 

want your personal contact information to be publicly viewable, do not include it in your 

comment or any accompanying documents. Instead, provide your contact information on a cover 

letter. Include your first and last names, email address, telephone number, and optional mailing 

address. The cover letter will not be publicly viewable as long as it does not include any 

comments 

452 
 

Include contact information each time you submit comments, data, documents, and other 

information to DOE. Email submissions are preferred. If you submit via mail or hand delivery, 

please provide all items on a CD, if feasible. It is not necessary to submit printed copies. No 

facsimiles (faxes) will be accepted. 

Comments, data, and other information submitted to DOE electronically should be 

provided in PDF (preferred), Microsoft Word or Excel, WordPerfect, or text (ASCII) file format. 

Provide documents that are not secured, written in English and are free of any defects or viruses. 

Documents should not contain special characters or any form of encryption and, if possible, they 

should carry the electronic signature of the author. 

Campaign form letters. Please submit campaign form letters by the originating 

organization in batches of between 50 to 500 form letters per PDF or as one form letter with a 

list of supporters’ names compiled into one or more PDFs. This reduces comment processing and 

posting time. 

Confidential Business Information. According to 10 CFR 1004.11, any person submitting 

information that he or she believes to be confidential and exempt by law from public disclosure 

should submit via email, postal mail, or hand delivery two well-marked copies: one copy of the 

document marked confidential including all the information believed to be confidential, and one 

copy of the document marked non-confidential with the information believed to be confidential 

deleted. Submit these documents via email or on a CD, if feasible. DOE will make its own 

453 
determination about the confidential status of the information and treat it according to its 

determination. 

Factors of interest to DOE when evaluating requests to treat submitted information as 

confidential include: (1) A description of the items; (2) whether and why such items are 

customarily treated as confidential within the industry; (3) whether the information is generally 

known by or available from other sources; (4) whether the information has previously been made 

available to others without obligation concerning its confidentiality; (5) an explanation of the 

competitive injury to the submitting person which would result from public disclosure; (6) when 

such information might lose its confidential character due to the passage of time; and (7) why 

disclosure of the information would be contrary to the public interest. 

It is DOE’s policy that all comments may be included in the public docket, without 

change and as received, including any personal information provided in the comments (except 

information deemed to be exempt from public disclosure). 

E. Issues on Which DOE Seeks Comment 

Although DOE welcomes comments on any aspect of this proposal, DOE is particularly 

interested in receiving comments and views of interested parties concerning the following issues: 

1.	 DOE requests interested party feedback, including any substantive data, regarding 

today’s proposed standard levels and the potential for lessening of utility or performance 

related features. 

454 
 

2.	 DOE requests interested party feedback on whether the standards proposed in today’s 

rule would necessitate the use of any proprietary designs or patented technologies. 

3.	 DOE seeks comment on its analysis of the costs and benefits of the standards proposed in 

this rulemaking, including but not limited to DOE’s analytic assumptions as highlighted 

in the list of issues herein. More specifically, DOE seeks comment on the Agency’s 

estimate that the proposed standard for battery chargers lead to between $92.8 million 

and $98.3 million in cost savings (i.e. negative costs) relative to the assumed baseline. 

Recognizing that the cost models used for this analysis have certain limitations, DOE 

seeks comment on the assumed market failure the agency has identified as the underlying 

reason that private markets have not taken advantage of these cost savings in the absence 

of this proposed rulemaking. DOE also seeks comment on key assumptions that 

contributed to this estimate, including but not limited to assumptions regarding energy 

consumption, shipments, and manufacturer costs, treatment of existing regulatory 

requirements for battery chargers and EPSs, and treatment of Energy Star and other 

emerging technologies in both the baseline and standards cases. Finally, DOE seeks 

comment on the assumption that incremental product costs for battery chargers are 

negative because of a shift in technology from linear power supplies to switch mode 

power for the larger battery chargers in product classes 5, 6, and 7. 

4.	 DOE seeks comment on its estimates of battery charger and EPS shipments, lifetimes, 

and efficiency distributions for each application and product class. DOE is especially 

interested in receiving comment on its assumption that EPSs for mobile phones and 

smartphones are likely to standardize around a common connection standard and, as a 

result, remain in use beyond the lifetimes of their associated applications (an average 

lifetime of 4 years as opposed to an average lifetime of 2 years). 

455 
5.	 DOE seeks comment and related data on which battery charger and EPS applications 

are used in the commercial sector, what fraction of shipments are to the commercial 

sector, and how product lifetimes and usage may differ between residential and 

commercial settings. 

6.	 DOE seeks comment on its proposed approach in classifying EPSs that indirectly 

operate consumer products and whether that approach requires modifications. If 

changes are required, DOE seeks specific suggestions on how the proposed approach 

should be altered. 

7.	 DOE welcomes comment on whether there are any performance-related features 

characteristic of either Class A or non-Class A devices (but not both) in product class 

N that would justify different standard levels for the two groups. DOE also seeks 

comment on the merits of applying a standard to EPSs falling into product class N. 

DOE also welcomes comment on the proposed compliance dates for non-Class A 

EPSs. 

8.	 DOE seeks comment, information, and/or data on whether the proposed standards 

would impact any features in the regulated products or in their associated 

complimentary applications. If so, DOE seeks comment as to whether these impacts 

would impact the utility of either the product or the application, and on whether, how, 

and to what degree consumer welfare might be impacted by the proposed standards. 

9.	 DOE requests any information regarding existing products that may seem to be able 

to be classified in multiple product classes. 

10. DOE seeks comment on possible issues of electromagnetic interference and/or radio 

frequency interference associated with switch-mode power supplies (SMPS) used 

456 
with amateur radios, including design options for reducing or eliminating 

interference. 

11. DOE would like to request any feedback on the proposed approach to determining the 

average efficiency for multiple-voltage EPSs. 

12. DOE seeks comment on its methodology for generating CSL3 and CSL4 for highpower EPSs. 

13. DOE seeks comment on its proposal to set a standard for multiple-voltage EPSs as a 

continuous function of output power. 

14. DOE seeks comment on its proposed approach in calculating unit energy 

consumption for battery chargers and the appropriateness of the various equations to 

calculate this consumption that are presented in today’s proposal. 

15. DOE seeks information, including any substantive data, to help it assess factors of 

durability, reliability, and preference of transformer based battery chargers versus 

those incorporating switch-mode power supplies. 

16. DOE seeks comment on its proposed approach in developing a cost-efficiency 

relationship for battery charger product class 6. 

17. DOE requests comment on the results of its LCC and PBP analyses, particularly with 

respect to the projected results for multiple voltage EPSs (i.e., product class X). In 

addition, DOE requests comment regarding the Agency’s approach of calculating 

LCC by averaging estimated installation costs within subproduct categories. Further, 

DOE requests comment on the household debt equity discount rate applied 

specifically to the LCC cost analysis. Finally, DOE requests comment regarding the 

457 
segregation of the LCC analysis and consumer price impacts, which are separately 

addressed in a shipment-based analysis. 

18. DOE seeks comment on its treatment of the market path, markups, and MSP 

estimates. 

19. DOE seeks comment on its use of a roll-up market response, which projects that only 

those products which fall below a standard will improve in efficiency, and that the 

same products will only improve in efficiency so as to meet, but not exceed, the 

efficiency required by the standard. DOE further seeks comments on the assumptions 

regarding efficiency distributions in the baseline, such as the extent to which the 

worst and best energy performers are and are not represented in the baseline. 

20. DOE seeks comment on whether, and to what extent, battery charger efficiency 

would be likely to improve in the absence of standards, including the assumption that 

battery charger efficiency will not improve between today and the compliance date in 

2013. 

21. DOE seeks comment on its assumptions about the extent to which, if at all, EPS 

efficiency will improve for product classes B, C, D, E, X and H in the absence of 

mandatory standards, both prior to and after 2013. 

22. DOE recognizes that significant variation in use exists for battery chargers, EPSs, and 

the applications they power. In an effort to ensure the accuracy of its assumed usage 

profiles, DOE seeks substantiated estimates, with supporting data, of usage profiles 

for battery chargers, EPSs, and the applications they power. 

23. DOE seeks comment on its EPS loading points, as well as test results that will allow 

it to improve the accuracy of those loading points. 

458 
24. DOE seeks comment on its estimate that shipments of EPSs and battery chargers are 

inelastic and on other elasticity assumptions DOE has made. DOE further seeks 

comment, information, and data regarding DOE’s market assessment of EPSs and 

battery chargers via complimentary applications with which these products are nearly 

always bundled. 

25. DOE seeks comment on its estimate that substitution impacts for EPSs and battery 

chargers are negligible. 

26. DOE seeks comment on the methodology employed for conducting the National 

Impact Analysis, including the calculations of National Inventory, National Energy 

Savings, and Net Present Value. 

27. DOE seeks comment on its estimates regarding the proportions of certain applications 

– including mobile phones, MP3 players, GPS equipment, and personal care products 

– that ship with EPSs designed to directly operate the application versus indirectly 

operate the application. 

28. DOE seeks comment on what level of efficiency EPSs in product class N already 

meet and whether EPSs sold in California are different in terms of their energy 

efficiency than EPSs sold in other States. 

29. DOE seeks comment on the accuracy of its distribution models for battery chargers 

and EPSs, as well as its estimates off battery charger and EPS markups. To the extent 

that these models and estimates can be improved, DOE seeks specific suggestions and 

supporting data. 

30. DOE seeks information concerning small businesses that could be impacted by this 

rulemaking and the nature and extent of those potential impacts. For example, DOE is 

459 
interested in information concerning impacts on the golf cart industry that have not 

been captured in the current rulemaking analysis. Further, DOE seeks further 

information and data regarding the ‘double jeopardy’ EPS and battery charger 

impacts on small businesses as raised by commenters. 

31. DOE seeks comment on whether the proposed standards would lead to lessening of 

market competition in the regulated industries. 

32. DOE seeks comment on whether there are any products on the market that are not 

already subject to California or Federal energy efficiency standards that would be 

covered by the new EPS standards being proposed for product class N today. DOE 

welcomes specific examples of such products, if they exist. 

33. DOE invites comment on solid-state lighting EPSs, specifically on whether there are 

any differences between SSL EPSs and other EPSs that might warrant treating them 

as a separate product class, the size of the market for these products, what proportion 

of SSL luminaires use EPSs, the efficiency of those EPSs, and usage patterns. 

34. DOE seeks comment on whether any battery chargers exist that can only be operated 

on 12V input, whether a device that can be powered only from a 12V power outlet 

can be assumed to be designed solely for use in recreational vehicles (RVs) and other 

mobile equipment, and whether there are battery chargers with DC inputs other than 

5V and 12V. 

35. DOE welcomes comment on any and all issues related to efficiency markings for 

battery chargers and EPSs. 

36. DOE is interested in receiving comments from industry, states, and other interested 

parties on the best ways to ensure a smooth transition from the battery charger 

460 
standards established in California to the national standards addressed in this 

proposed rule. 

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________________________________ 

VIII. Approval of the Office of the Secretary 

The Secretary of Energy has approved publication of today’s proposed rule. 

List of Subjects in 10 CFR Part 430 

Administrative practice and procedure, Confidential business information, Energy conservation, 

Household appliances, Reporting and recordkeeping requirements, Small businesses. 

Issued in Washington, DC, on 

Henry Kelly 

Acting Assistant Secretary of Energy 

Energy Efficiency and Renewable Energy 

462 
For the reasons set forth in the preamble, DOE proposes to amend chapter II, subchapter D, of 

title 10 of the Code of Federal Regulations, as set forth below: 

PART 430 - ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS 

1. The authority for part 430 continues to read as follows: 

Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note. 

2. Section 430.2 is amended byadding new definitions for “AC-AC external power supply”, 

“AC-DC external power supply”, “basic-voltage external power supply”, “direct operation 

external power supply”, “indirect operation external power supply”, “low-voltage external power 

supply”, and “multiple-voltage external power supply”to read as follows: 

§430.2 Definitions. 

* * * * * 

AC-AC external power supply means an external power supply that is used to convert household 

electric current into a single lower-voltage AC current. 

AC-DC external power supply means an external power supply that is used to convert household 

electric current into a single lower-voltage DC current. 

* * * * * 

Basic-voltage external power supply means an external power supply that is not a low-voltage 

power supply. 

* * * * * 

463 
Direct operation external power supply means an external power supply that can operate a 

consumer product that is not a battery charger without the assistance of a battery. 

* * * * * 

Indirect operation external power supply means an external power supply that cannot operate a 

consumer product that is not a battery charger without the assistance of a battery as determined 

by the following steps: 

(1) If a product can be connected to an end-use consumer product and that the consumer product 

can be operated using battery power, the method for determining if an EPS can directly power an 

application is as follows: 

i. Charge the battery in the application via the EPS such that the application can operate 

as intended before taking any additional steps. 

ii. Disconnect the EPS from the application. From an off mode state, turn on the 

application and record the time necessary for it to become operational to the nearest 

five second increment (5 sec, 10 sec, etc.). 

iii. Operate the application using power only from the battery until the application stops 

functioning due to the battery discharging. 

iv. Connect the EPS first to mains and then to the application. Immediately attempt to 

operate the application. Record the time for the application to become operational to 

the nearest five second increment (5sec, 10sec, etc.). 

(2) If the time recorded in (iv) is less than or equal to the summation of the time recorded in (ii) 

and five seconds, the EPS can operate the application directly and is not in product class N. 

464 
Otherwise, it is an indirect operation EPS and is subject to the standards of product class N in 

§430.32 (w). 

* * * * * 

Low-voltage external power supply means an external power supply with a nameplate output 

voltage is less than 6 volts and nameplate output current greater than or equal to 550 milliamps. 

* * * * * 

Multiple-voltage external power supply means an external power supply that is used to convert 

household electric current into multiple simultaneous output currents. 

* * * * * 

3. Section 430.32 is amended by adding new paragraphs (w)(1)(iv), (w)(2), (w)(3), (w)(4), 

(w)(5) and (y)to read as follows: 

§430.32 Energy and water conservation standards and their effective dates. 

* * * * * 

(w) External Power Supplies. (1) * * * 

(iv) Except as provided in this paragraph (w)(1)(iii) of this section, all direct operation external 

power supplies manufactured on or after July 1, 2013, shall meet the following standards: 

AC-DC, Basic-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.100 

> 49 watts to ≤

250 watts ≥ 0.880 ≤ 0.210 

> 250 watts ≥ 0.875 ≤ 0.500 

465 
AC-DC, Low-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.100 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.100 

> 49 watts to ≤

250 watts ≥ 0.870 ≤ 0.210 

> 250 watts ≥ 0.875 ≤ 0.500 

AC-AC, Basic-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.5 * Pout + 0.16 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.071 * ln(Pout) - 0.0014 * 

Pout +0.67 ≤ 0.210 

> 49 watts to ≤

250 watts ≥ 0.880 ≤ 0.210 

> 250 watts ≥ 0.875 ≤ 0.500 

AC-AC, Low-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode 

0 to ≤ 1 watt ≥ 0.517 * Pout + 0.087 ≤ 0.210 

> 1 to ≤ 49 watts ≥ 0.0834 * ln(Pout) - 0.0014 * 

Pout + 0.609 ≤ 0.210 

> 49 watts to ≤

250 watts ≥ 0.870 ≤ 0.210 

> 250 watts ≥ 0.875 ≤ 0.500 

Multiple-Voltage External Power Supply 

Nameplate 

Output Power 

(Pout) 

Minimum Average 

Efficiency in Active Mode 

(expressed as a decimal) 

Maximum Power in 

No-Load Mode [W] 

0 to ≤ 1 watt ≥ 0.497 * Pout + 0.067 ≤ 0.300 

> 1 to ≤ 49 watts ≥ 0.075 * ln (Pout) + 0.561 ≤ 0.300 

466 
r

> 49 watts ≥ 0.860 ≤ 0.300 

(2) The standards described in this paragraph (w)(1)(i) and (w)(1)(iv) shall not c onstitute an 

energy conservation standard for the separate end-use product to which the external power 

supply is connected. 

(3) Any external power supply subject to the standards in this paragraphs (w)(1)(i) and (w)(1)(iv) 

shall be clearly and permanently marked in accordance with the External Power Supply 

International Efficiency Marking Protocol, as referenced in the ‘Energy Star Program 

Requirements for Single Voltage External Ac–Dc and Ac–Ac Power Supplies,’ (incorporated by 

reference; see §430.3), published by the Environmental Protection Agency. 

(4) Any indirect operation external power supply subject to the standards in this paragraph 

(w)(1)(i) and not labeled with a Roman numeral VI in accordance with the marking protocol 

referred to in this paragraph (w)(3): 

(i) Shall be permanently marked with the capital letter "N" as a superscript to the circle that 

contains the Roman numeral, for example, 

and 

467 
r

 

(ii) If sold separately from the battery charger or end-use consumer product with which it is 

intended to be used, shall be marked with the manufacturer and model number of that battery 

charger or end-use consumer product. 

(5) Any indirect operation external power supply not subject to the standards in this paragraph 

(w)(1)(i) and not labeled with a Roman numeral VI in accordance with the marking protocol 

referred to in this paragraph (w)(3): 

(i) Shall be permanently marked with the abbreviation "EPS-N", for example, 

and 

(ii) If sold separately from the battery charger or end-use consumer product with which it is 

intended to be used, shall be marked with the manufacturer and model number of that battery 

charger or end-use consumer product. 

* * * * * 

(y) Battery Chargers. (1) Battery chargers manufactured on or after July 1, 2013, shall have a 

unit energy consumption (UEC) less than or equal to the standard calculated using the equations 

for the appropriate product class and corresp onding measured battery energy as shown below: 

468 
 

 

 

 

 

 

Product Class # Input / Output 

Type 

Battery 

Energy (Wh) 

Special Characteristic 

or Battery Voltage 

Maximum UEC 

(kWh/yr) 

1 

AC In, 

DC Out 

< 100 

Inductive Connection* 3.04 

2 < 4 V = 0.2095(Ebatt**) + 5.87 

3 4 – 10 V 

For Ebatt < 9.74 Wh, 

= 4.68 

For Ebatt ≥ 9.74 Wh, 

= 0.0933(Ebatt) + 3.77 

4 > 10 V 

For Ebatt < 9.71 Wh, 

= 9.03 

For Ebatt ≥ 9.71 Wh, 

= 0.2411(Ebatt) + 6.69 

5 

100–3000 

< 20 V 

For Ebatt < 355.18 Wh, 

= 20.06 

For Ebatt ≥ 355.18 Wh, 

= 0.0219(Ebatt) + 12.28 

6 ≥ 20 V 

For Ebatt < 239.48 Wh 

= 30.37 

For Ebatt ≥ 239.48 Wh 

= 0.0495(Ebatt) + 18.51 

7 > 3000 - = 0.502(Ebatt) + 4.53 

8 DC In, 

DC Out 

- < 9 V Input 0.66 

9 - ≥ 9 V Input No Standard 

10a 

AC In, 

AC Out 

- Basic (i.e. no Automatic 

Voltage Regulation) 

For Ebatt < 37.2 Wh, = 2.54 

For Ebatt ≥ 37.2 Wh, = 

0.0733(Ebatt) – 0.18 

10b - Contains Automatic 

Voltage Regulation 

For Ebatt < 37.2 Wh, = 6.18 

For Ebatt ≥ 37.2 Wh, = 

0.0733(Ebatt) + 3.45 

11 AC In, DC Out < 100 Wh 

Wireless Charging 

Capability (for dry 

environments) 

Reserved 

* Inductive connection and designed for use in a wet environment (e.g. electric toothbrushes) 

**Ebatt = Measured battery energy as determined in section 5.6 of Appendix Y to Subpart B of Part 430. 

(2) Unit energy consumption shall be calculated for a device seeking certification using one of 

the two equations listed below. If a device is tested and its charge test duration as determined in 

section 5.2 of Appendix Y to Subpart B of Part 430 minus 5 hours exceeds the threshold charge 

time listed in the table below, equation (ii) shall be used to calculate UEC; otherwise a device’s 

UEC shall be calculated using equation (i). 

469 
൅ ൫ܲ௠ሺݐ ௠&௔െ ሺݐ௖ௗ െ 5ሻ݊ሻ൯ ൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ଶସ ሻ ܧ24 െ 5ܲ௠ െ ܧ௔௕௧௧ (i) ܷܥܧ ൌ 365ሺ݊ሺ ௧೎೏

൫ܲ௢௙௙ݐ௙௙௢൯ሻ or, 

ଶସ ൅ ሺܲ௦௕ݐ௦௕ሻ ൅ ൫ܲ௢௙௙ݐ௙௙௢൯ሻ ሺ௧೎೏ିହሻ ሻ ܧଶସ െ 5ܲ௠ െ ܧ௔௕௧௧ (ii) ܷܥܧ ൌ 365ሺ݊ሺ

Where: 

E24 = 24-hour energy as determined in section 5.10 of Appendix Y to Subpart B of Part 430, 

Ebatt = Measured battery energy as determined in section 5.6 of Appendix Y to Subpart B of Part 

430, 

Pm = Maintenance mode power as determined in section 5.9 of Appendix Y to Subpart B of Part 

430, 

Psb = Standby mode power as determined in section 5.11 of Appendix Y to Subpart B of Part 

430, 

Poff = Off mode power as determined in section 5.12 of Appendix Y to Subpart B of Part 430, 

tcd = Charge test duration as determined in section 5.2 of Appendix Y to Subpart B of Part 430, 

And 

ta&m, n, tsb, and toff, are constants used depending upon a device’s product class and found in the 

following table: 

Product 

Class 

Active + 

Maintenance 

(ta&m) 

Standby 

(tsb) 

Off 

(toff) 

Charges 

(n) 

Threshold 

Charge 

Time* 

- Hours per Day** Number per Day Hours 

1 20.66 0.10 0.00 0.15 135.41 

2 8.82 4.56 0.00 0.54 19.00 

3 6.85 0.29 0.00 0.10 67.21 

470 
4 16.35 0.95 0.00 0.49 33.04 

5 6.29 1.07 0.00 0.11 56.83 

6 17.17 6.83 0.00 0.34 50.89 

7 8.14 7.30 0.00 0.32 25.15 

8 6.34 6.93 0.00 0.54 19.00 

10 24.00 0.00 0.00 0.00 N/A*** 

*If the du 

Subpart B 

otherwise 

**If the t 

time, wh 

needed. 

***Becau 

uration of th 

B of Part 430 

e use equatio 

total time do 

ich means th 

use n = 0 for 

he charge test 

0 exceeds th 

on (ii). 

oes not sum t 

here is 0 pow 

r PC 10, UE 

t (minus 5 h 

he threshold 

to 24 hour p 

wer consump 

EC should alw 

hours) as dete 

charge time, 

er day, the r 

ption and no 

ways be calc 

ermined in s 

, use equatio 

remaining tim 

changes to t 

culated using 

section 5.2 o 

on (ii) to calc 

me is allocat 

the UEC cal 

g equation (i 

f Appendix 

culate UEC 

ted to unplug 

lculation is 

i). 

Y to 

gged 

(3) Any battery charger subject to the standards in this paragraph (y)(1) shall be clearly and 

permanently marked on the outside of its housing with the encircled upper case letters "BC" 

coupled with the Roman numera l "III" or a Roman numeral having a greater value, for example, 

471