CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT
 

TABLE OF CONTENTS

3.1 INTRODUCTION ........................................................................................................... 3­5
 

3.2 PRODUCT DEFINITIONS............................................................................................. 3­5
 

3.3 PRODUCT CLASSES..................................................................................................... 3­5
 

3.4 PRODUCT TEST PROCEDURES ................................................................................. 3­8
 

3.5 MANUFACTURER TRADE GROUPS ....................................................................... 3­12
 

3.5.1 Association of Home Appliance Manufacturers............................................................ 3­12
 

3.5.2 Air Conditioning and Refrigeration Institute................................................................. 3­12
 

3.6 MANUFACTURER INFORMATION ......................................................................... 3­13
 

3.6.1 Manufacturers and Market Shares................................................................................. 3­13
 

3.6.2 Mergers and Acquisitions.............................................................................................. 3­18
 

3.6.3 Small Business Impacts ................................................................................................. 3­20
 

3.6.4 Distribution Channels.................................................................................................... 3­21
 

3.7 REGULATORY PROGRAMS ..................................................................................... 3­22
 

3.7.1 Current Federal Energy Conservation Standards........................................................... 3­22
 

3.7.2 Energy Independence and Security Act of 2007............................................................ 3­23
 

3.7.3 State Energy Conservation Standards............................................................................ 3­24
 

3.7.4 Canadian Energy Conservation Standards..................................................................... 3­24
 

3.7.5 International Standby Power Regulatory Programs....................................................... 3­25
 

3.8 VOLUNTARY PROGRAMS........................................................................................ 3­28
 

3.8.1 Consortium for Energy Efficiency................................................................................. 3­28
 

3.8.2 ENERGY STAR............................................................................................................ 3­28
 

3.8.3 Federal Energy Management Program .......................................................................... 3­29
 

3.8.4 Rebates for Highly Energy­Efficient Products.............................................................. 3­30
 

3.9 HISTORICAL SHIPMENTS......................................................................................... 3­31
 

3.9.1 New Home Starts........................................................................................................... 3­31
 

3.9.2 Unit Shipments............................................................................................................... 3­32
 

3.9.3 Value of Shipments........................................................................................................ 3­34
 

3.9.4 Imports and Exports....................................................................................................... 3­36
 

3.10 HISTORICAL EFFICIENCIES..................................................................................... 3­38
 

3.11 MARKET SATURATION............................................................................................ 3­39
 

3.12 PRODUCT RETAIL PRICES ....................................................................................... 3­40
 

3.13 INDUSTRY COST STRUCTURE................................................................................ 3­48
 

3.14 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES.......................... 3­53
 

3.15 TECHNOLOGY ASSESSMENT.................................................................................. 3­55
 

3.15.1 Product Operations and Components............................................................................. 3­55
 

3.15.1.1 Residential Clothes Dryers .......................................................................... 3­55
 

3.15.1.2 Room Air Conditioners................................................................................ 3­56
 

3.15.2 Technology Options....................................................................................................... 3­58
 

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3.15.2.1 Residential Clothes Dryers .......................................................................... 3­58
 

3.15.2.2 Room Air Conditioners................................................................................ 3­69
 

3.15.3 Energy Efficiency .......................................................................................................... 3­81
 

3.15.3.1 Residential Clothes Dryers .......................................................................... 3­81
 

3.15.3.2 Room Air Conditioners................................................................................ 3­84
 

LIST OF TABLES
 

Table 3.3.1 Residential Clothes Dryer Product Classes .............................................................. 3­6
 

Table 3.3.2 Room Air Conditioner Product Classes.................................................................... 3­7
 

Table 3.6.1 Major and Other Residential Clothes Dryer Manufacturers................................... 3­14
 

Table 3.6.2 2000­2007 Electric Clothes Dryer Manufacturer Market Share ............................ 3­15
 

Table 3.6.3 2000­2007 Gas Clothes Dryer Manufacturer Market Share .................................. 3­16
 

Table 3.6.4 Major and Other Room Air Conditioner Manufacturers........................................ 3­16
 

Table 3.6.5 2000­2007 Room Air Conditioner Manufacturer Market Share ........................... 3­17
 

Table 3.6.6 Core Appliance Manufacturers............................................................................... 3­18
 

Table 3.6.7 Major Appliance Sales by Channel (Purchased between 2001 and 2005) ............. 3­21
 

Table 3.7.1 Federal Energy Conservation Standards for Residential Clothes Dryers............... 3­22
 

Table 3.7.2 Federal Energy Conservation Standards for Room Air Conditioners .................... 3­23
 

Table 3.7.3: Canada’s Proposed Efficiency Requirements for Room Air Conditioners........... 3­25
 

Table 3.8.1 CEE Criteria for Room Air Conditioners............................................................... 3­28
 

Table 3.8.2 ENERGY STAR Criteria for Room Air Conditioners........................................... 3­29
 

Table 3.8.3 FEMP Recommendations for Room Air Conditioners........................................... 3­30
 

Table 3.8.4 Rebates Offered for Highly Energy Efficient Room Air Conditioners in 2008 ..... 3­31
 

Table 3.9.1 Industry Shipments of Residential Clothes Dryers (Domestic and Import, in
 

Thousands of Units)........................................................................................... 3­33

Table 3.9.2 Industry Shipments of Room Air Conditioners (Domestic and Import, in

Thousands of Units)........................................................................................... 3­33

Table 3.9.3 2005 ENERGY STAR Shipments for Room Air Conditioners (Domestic and

Import) ............................................................................................................... 3­34

Table 3.9.4 Household Laundry Equipment Value of Shipments by Year ............................... 3­35

Table 3.9.5 “Room Air­Conditioners and Dehumidifiers, Except Portable Dehumidifiers”

Product Class Value of Shipments by Year....................................................... 3­35
 

Table 3.9.6 Disposition of Previous Appliance (Percentage).................................................... 3­36
 

Table 3.9.7 2006­2007 Imports of Appliances Covered by this Rulemaking ........................... 3­37
 

Table 3.9.8 2006­2007 Exports of Appliances Covered by this Rulemaking ........................... 3­38
 

Table 3.10.1 Room Air Conditioner Energy Efficiency and Consumption Trends
 

(Shipment Weighted Averages)......................................................................... 3­39

Table 3.11.1 Appliance Saturation (Number in Millions and Percentage of U.S.

Households with Product).................................................................................. 3­40
 

Table 3.12.1 Residential Appliance Retail Prices...................................................................... 3­40
 

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Table 3.13.1 Household Appliance Industry Employment and Earnings ................................. 3­49

Table 3.13.2 Household Laundry Industry Employment and Earnings .................................... 3­49

Table 3.13.3 Air­Conditioning & Warm Air Heating & Commercial/Industrial

Refrigeration Equipment Industry Employment and Earnings ......................... 3­50

Table 3.13.4 Household Appliance Industry Census Data ........................................................ 3­50

Table 3.13.5 Household Laundry Industry Census Data .......................................................... 3­51

Table 3.13.6 Air Conditioning & Warm Air Heating & Commercial/Industrial

Refrigeration Equipment Industry Census Data ................................................ 3­51
 

Table 3.13.7 Industry Cost Structure Using SEC Data.............................................................. 3­52
 

Table 3.14.1 Household Appliance Industry Census Data ........................................................ 3­53
 

Table 3.14.2 Household Laundry Industry Census Data ........................................................... 3­54
 

Table 3.14.3 Air Conditioning & Warm Air Heating & Commercial/Industrial
 

Refrigeration Equipment Industry Census Data ................................................ 3­54
 

Table 3.14.4 Full Production Capacity Utilization Rates.......................................................... 3­55
 

Table 3.15.1 Technology Options for Residential Clothes Dryers............................................ 3­59
 

Table 3.15.2 Technology Options for Room Air Conditioners................................................. 3­70
 

Table 3.15.3 Manufacturer Test Results from 1997 TSD Analysis: Performance
 

Improvements due to Subcoolers....................................................................... 3­73

Table 3.15.4 Residential Clothes Dryer Market Share Efficiency Data for Electric

Standard Dryers ................................................................................................. 3­83
 

Table 3.15.5 Residential Clothes Dryer Market Share Efficiency Data for Gas Dryers........... 3­84
 

LIST OF FIGURES
 

Figure 3.6.1 2007 Market Shares for the Domestic Electric Clothes Dryer Market ................. 3­14
 

Figure 3.6.2 2007 Market Shares for the Domestic Gas Clothes Dryer Market........................ 3­15
 

Figure 3.6.3 2007 Market Shares for the Domestic Room Air Conditioner Market ................. 3­17
 

Figure 3.6.4 2007 Core Appliance Market Shares..................................................................... 3­19
 

Figure 3.9.1 New Privately Owned Single­Family and Multi­Family Housing Unit Starts
 

in the United States from 1998–2007 ............................................................... 3­32
 

Figure 3.12.1 Retail Prices for Room Air Conditioners, Product Classes 1 through 5 ............. 3­41
 

Figure 3.12.2 Retail Prices for Room Air Conditioners, Product Classes 6 through 10 ........... 3­42
 

Figure 3.12.3 Retail Price versus EER for Product Class 1....................................................... 3­43
 

Figure 3.12.4 Retail Price versus EER for Product Class 2....................................................... 3­44
 

Figure 3.12.5 Retail Price versus EER for Product Class 3....................................................... 3­45
 

Figure 3.12.6 Retail Price versus EER for Product Class 4....................................................... 3­46
 

Figure 3.12.7 Retail Price versus EER for Product Class 5....................................................... 3­47
 

Figure 3.12.8 Retail Price versus EER for Product Class 8....................................................... 3­48
 

Figure 3.13.1 Industry Gross Margin Derived from SEC Data ................................................. 3­52
 

Figure 3.15.1 Room Air Conditioner Operation Schematic ...................................................... 3­58
 

Figure 3.15.2 Electric Standard Capacity Clothes Dryers in the CEC Directory...................... 3­81
 

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Figure 3.15.3 Electric Compact Capacity Clothes Dryers in the CEC Directory...................... 3­82

Figure 3.15.4 Gas Clothes Dryers in the CEC Directory........................................................... 3­83

Figure 3.15.5 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners

without Reverse Cycle and with Louvered Sides (Product Classes 1–5).......... 3­85

Figure 3.15.6 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners

without Reverse Cycle and without Louvered Sides (Product Classes 6–

10) ..................................................................................................................... 3­86

Figure 3.15.7 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners with

Reverse Cycle (Product Classes 11–14) ........................................................... 3­87

Figure 3.15.8 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners

Casement­Only and Casement­Slider (Product Classes 15, 16) ....................... 3­88

Figure 3.15.9 Distribution of Room Air Conditioner Models in the CEC, AHAM, and

ENERGY STAR Databases .............................................................................. 3­89
 

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CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT
 

3.1 INTRODUCTION
 

This chapter provides a profile of the residential clothes dryer and room air conditioner

industries in the United States. The U.S. Department of Energy (DOE) developed the preliminary

market and technology assessment presented in this chapter primarily from publicly available

information. This assessment is helpful in identifying the major manufacturers and their product

characteristics, which form the basis for the engineering and the life­cycle cost (LCC) analyses.

Present and past industry structure and industry financial information help DOE in the process of

conducting the manufacturer impact analysis.

3.2 PRODUCT DEFINITIONS

DOE defines “electric clothes dryer” under the Energy Policy and Conservation Act

(EPCA) of 1975, Pub. L. 94­163, (42 United States Code (U.S.C.) 6291–6309) as “a cabinet­like

appliance designed to dry fabrics in a tumble­type drum with forced air circulation. The heat

source is electricity and the drum and blower(s) are driven by an electric motor(s).” Similarly,

EPCA defines “gas clothes dryer” as “a cabinet­like appliance designed to dry fabrics in a

tumble­type drum with forced air circulation. The heat source is gas and the drum and blower(s)

are driven by an electric motor(s).” (10 Code of Federal Regulation (CFR) 430.2)

DOE defines “room air conditioner” under EPCA as “a consumer product, other than a

“packaged terminal air conditioner”, which is powered by a single phase electric current and

which is an encased assembly designed as a unit for mounting in a window or through the wall

for the purpose of providing delivery of conditioned air to an enclosed space. It includes a prime

source of refrigeration and may include a means for ventilating and heating.” (10 CFR 430.2)

3.3 PRODUCT CLASSES

DOE intends to separate each product (residential clothes dryers and room air

conditioners) into product classes. Because DOE will formulate a separate energy conservation

standard for each product class, the criteria for separation into different classes are: (1) type of

energy used, and (2) capacity or other performance­related features such as those that provide

utility to the consumer or others deemed appropriate by the Secretary that would justify the

establishment of a separate energy conservation standard. (42 U.S.C. 6295 (q) and 6316(a))

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For residential clothes dryers, DOE plans to consider four product classes for vented and

two product classes for vent­less dryers, as shown in Table 3.3.1. This is a new analytical

structure for clothes dryers, recognizing the unique utility that vent­less clothes dryers offer to

consumers.a Another new entry with unique utility is the combination washer/dryer (i.e., a device

which washes and then dries clothes in the same basket/cavity in a combined cycle).

Combination washer/dryers are very popular in space­constrained environments (e.g.,

apartments, recreational vehicles), and all products of this type appear to utilize vent­less

operation. Thus, like other vent­less dryers, such combination washer/dryers can be installed in

locations where venting dryers would be precluded due to venting restrictions.

DOE notes that it proposed an alternate test procedure for condenser clothes dryers in its

“Energy Conservation Program for Consumer Products: Publication of the Petition for Waiver

and Denial of the Application for Interim Waiver of LG Electronics from the Department of

Energy Clothes Dryer Test Procedures.” (LG Petition for Waiver) 71 FR 49437, 49439 (August

23, 2006). As discussed in section 3.4, DOE intends to publish a test procedure notice of

proposed rulemaking (NOPR) to propose amendments to the DOE test procedure for clothes

dryers to include provisions for testing of vent­less clothes dryers. DOE believes that the current

DOE test procedure can be used to test condenser clothes dryers (and, by extension, other ventless clothes dryers) by eliminating the requirement of an exhaust simulator and adding a number

of simple clarifications. Therefore, DOE plans to include product classes for vent­less clothes

dryers in this rulemaking analysis.

Table 3.3.1 Residential Clothes Dryer Product Classes

Vented dryers

1. Electric, Standard (4.4 cubic feet (ft3) or greater capacity)

2. Electric, Compact (120 volts (V)) (less than 4.4 ft3 capacity)

3. Electric, Compact (240 V) (less than 4.4 ft3 capacity)

4. Gas

Vent­less dryers

5. Electric, Compact (240 V) (less than 4.4 ft3 capacity)

6. Electric, Combination Washer/Dryer

For room air conditioners, amendments to EPCA in the National Appliance Energy

Conservation Act of 1987 (NAECA), Pub. L. 100­12, initially specified 12 product classes which

were applicable to units designed for single­ or double­hung window installation or through­thewall installation and based on the following criteria: (1) cooling capacity; (2) the presence of

louvered sides (LS); and (3) the capability of reverse cycle (i.e., the unit can function as a heat

pump). (42 U.S.C. 6295(c)(1)) Capacity is measured in British Thermal Units (Btu) per hour (h).

a Previously, DOE has described vent­less dryers as condensing dryers. The new designation reflects the actual

consumer utility (i.e., no external vent required) and the market availability of vented dryers that also condense.

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In the final rule published in the Federal Register on September 24, 1997, DOE established an

updated set of performance standards (effective October 1, 2000) which included four additional

product classes.b Table 3.3.2 lists the existing 16 product classes for room air conditioners. Based

on DOE’s estimate that higher­capacity units may be constrained by space limitations in their

ability to incorporate design options that could raise energy efficiency, and the assumption that

the increments in energy efficiency among the other product classes are well­defined by the

increments in their associated minimum efficiency standards, DOE intends to conduct a full

analysis of product classes 1, 3, 5, and 8. The first three of these product classes span the range

of capacities of room air conditioners without reverse cycle and with louvered sides. The fourth

product class is the intermediate capacity product class for room air­conditioners without reverse

cycle and without louvered sides. DOE plans to then extend this analysis numerically to the

remaining 13 product classes. This approach is discussed in more detail in the engineering

analysis in chapter 5 of this preliminary technical support document (preliminary TSD).

Table 3.3.2 Room Air Conditioner Product Classes

Without reverse cycle and with louvered sides

1. Less than 6,000 Btu/h

2. 6,000 to 7,999 Btu/h

3. 8,000 to 13,999 Btu/h

4. 14,000 to 19,999 Btu/h

5. 20,000 Btu/h or more

Without reverse cycle and without louvered sides

6. Less than 6,000 Btu/h

7. 6,000 to 7,999 Btu/h

8. 8,000 to 13,999 Btu/h

9. 14,000 to 19,999 Btu/h

10. 20,000 Btu/h or more

With reverse cycle

11. With louvered sides and less than 20,000 Btu/h

12. Without louvered sides and less than 14,000 Btu/h

13. With louvered sides and 20,000 Btu/h or more

14. Without louvered sides and 14,000 Btu/h or more

Casement

15. Casement­Only

16. Casement­Slider

b DOE divided the product class covering units with reverse cycle and with louvered sides into units of capacity less

than 20,000 Btu/h and units 20,000 Btu/h or more. DOE split the product class covering units with reverse cycle and

without louvered sides into units of capacity less than 14,000 Btu/h and units 14,000 Btu/h or more. In addition,

DOE established two new product classes for units that are designed to be installed in casement­slider and casementonly windows. Due to the size constraints imposed by casement windows, casement units are small in size and

typically deliver 5,000 to 10,000 Btu/h in cooling capacity.

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3.4 PRODUCT TEST PROCEDURES

Test procedures exist for both products covered by this rulemaking to determine energy

efficiency and annual energy use as the basis for representation and determination of compliance

with energy conservation standards. DOE established test procedures for residential clothes

dryers and room air conditioners through the rulemaking process, in both cases over 25 years

ago. The Energy Independence and Security Act of 2007 (EISA 2007), Pub. L. 110­140, amends

EPCA to require DOE to review these test procedures at least every 7 years and to amend them if

such amended test procedures would more accurately or fully comply with the requirements of

producing test results which measure energy efficiency, energy use, or estimated annual

operating cost during a representative average use cycle or period of use without being unduly

burdensome to conduct. (42 U.S.C. 6293(b)(1))

DOE established its test procedure for residential clothes dryers in a final rule published

in the Federal Register on May 19, 1981. (46 FR 27324; 10 CFR part 430, subpart B, appendix

D) Although DOE has updated its test procedure for residential clothes washers since that time,c

it has not updated its residential clothes dryer test procedure since it was first established in

1981. In the revised residential clothes washer test procedure, a new parameter, the remaining

moisture content (RMC) of the test cloth, was introduced. In addition, the average number of use

cycles in a year was revised to reflect current consumer use patterns. The RMC of typical clothes

loads and the average number of use cycles in the residential clothes washer test procedure

should be consistent with the values defined in the clothes dryer test procedure. However, after

the clothes washer test procedure revision, the assumed RMC in the clothes dryer test procedure

did not reflect typical RMCs of actual clothes loads and the average number of use cycles was

inconsistent between the clothes washer and dryer test procedures.

In the case of the RMC, the revision to the clothes washer test procedure established a

method for crediting the performance of clothes washers that lower the RMC and, thereby,

reduce clothes drying energy use. Although most clothes washers today yield clothes loads with

maximum RMCs of just over 60 percent, the clothes dryer test procedure still requires that test

loads have average RMCs of 70 percent. Therefore, the clothes dryer test procedure does not

reflect the RMCs of actual clothes loads.

The energy factor (EF) for clothes dryers is determined by measuring the total energy

required to dry a standard test load of laundry to a “bone dry” state. As mentioned above, the test

load currently is specified to have an RMC of 70 percent, and its weight is either seven or three

pounds for standard and compact dryers, respectively. Therefore, revisions to the residential

clothes dryer test procedure to reflect more realistic (i.e., lower) RMCs would result in the

current EF rating increasing for a given clothes dryer, since the clothes dryer would have less

water to remove.

c See 62 FR 45484 (August 27, 1997); 68 FR 62198 (Oct. 31, 2003).

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In the case of the average residential clothes washer annual use cycles, the DOE clothes

washer test procedure revision lowered annual clothes washer to 392 cycles per year, a value

which DOE determined to be more representative of current usage patterns.d Further, the revised

DOE clothes washer test procedure assumes that 84 percent of all clothes washer loads are dried

in clothes dryers. Thus, based upon the parameters in the current residential clothes washer test

procedure, the annual usage pattern for clothes dryers is calculated to be 329 cycles per year. In

contrast, the current DOE residential clothes dryer test procedure assumes an average annual

clothes dryer use of 416 cycles per year, which is 21 percent higher than the number of cycles

per year derived from the current clothes washer test procedure.

In addition to the above­discussed disconnect between the DOE test procedures for

residential clothes washers and clothes dryers, a potential limitation of the clothes dryer test

procedure for vent­less dryers (commonly referred to as “condensing dryers”) has been

suggested. Manufacturers of vent­less clothes dryers have informed DOE that the current clothes

dryer test procedure is unable to test this type of clothes dryer. Vent­less clothes dryers do not

vent exhaust air to the outside as a conventional dryer does; instead, they typically use ambient

air in a heat exchanger to cool the hot, humid air inside the appliance, thereby condensing out the

moisture. Alternatively, cold water can be used in the heat exchanger to condense the moisture

from the air in the drum.e In either case, the dry air exiting the drum is reheated and recirculated

in a closed loop. Thus, there is no moisture­laden exhaust air to vent outside, only a wastewater

stream that can either be collected in an included water container or discharged down the

household drain. However, the process of condensing out the moisture in the recirculated air

results in higher energy consumption than a conventional dryer, and it can significantly increase

the ambient room temperature.

To address the potential limitation of the clothes dryer test procedure for vent­less dryers,

DOE proposed an alternate test procedure for vent­less dryers in the LG Petition for Waiver. 71

FR 49439. The revisions under consideration consist of adding separate definitions for a

“conventional clothes dryer” (which is vented) and a “condensing clothes dryer” (which is a

vent­less design). Further, the proposed alternate test procedure qualified the requirement for an

exhaust simulator so that it would only apply to conventional clothes dryers. In the notice, DOE

stated that it is seeking comment on this proposed modification to the test procedure. At present,

a final determination on such a revision has not yet been made.

Finally, DOE believes that the clothes dryer test procedure may not adequately measure

the benefits of automatic termination, in which a sensor monitors either the exhaust air

temperature or moisture in the drum to determine the length of the drying cycle. Currently, the

d The original clothes washer annual use cycles were 416.

e This is a typical approach for combination clothes washer and dryer units that wash and dry a load in the same

drum.

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test procedure credits the enhanced performance of clothes dryers equipped with automatic

termination but does not distinguish between the type of sensing control system (e.g.,

temperature­sensing or moisture­sensing controls) and the sophistication of the control system.

DOE redesignated and amended its test procedure for room air conditioners on June 29,

1979. (44 FR 37938; 10 CFR part 430, subpart B, appendix F) The room air conditioner test

procedure cites two test standards that are each at least 25 years old: (1) American National

Standards (since renamed American National Standards Institute (ANSI)) Z234.1­1972, Room

Air Conditioners and (2) American Society of Heating, Refrigerating and Air­Conditioning

Engineers (ASHRAE) Standard 16­69, Method of Testing for Rating Room Air Conditioners.

Both the ANSI and ASHRAE standards have been updated since DOE last redesignated its room

air conditioner test procedure. The current standards are ANSI/Association of Home Appliance

Manufacturers (AHAM) RAC­1­2003, Room Air Conditioners, and ANSI/ASHRAE 16­1983

(RA 99), Method of Testing for Rating Room Air Conditioners and Packaged Terminal Air

Conditioners, respectively. Because it is likely that any manufacturer rating it products is using

the most recent test standards, DOE may consider updating its test procedure to incorporate by

reference the most recent test standards.

There are two other limitations of the room air conditioner test procedure: (1) the

inability of the test procedure to measure the benefits of technologies that improve part­load

performance, and (2) the assumed annual operational hours.

The current room air conditioner test procedure measures only the full­load performance

at outdoor ambient conditions of 95 degrees Fahrenheit (oF) dry­bulb and 75 oF wet­bulb.

Therefore, technologies that improve part­load performance, such as multiple­speed compressors

and variable­opening expansion devices, will not improve the rated performance of a room air

conditioner under the current test procedure. In contrast, central air conditioners and heat pumps

are rated with a seasonal energy efficiency ratio (SEER) descriptor, but the test procedure

consists of multiple rating points that add time and expense when rating the product.

In order to allow calculation of annual energy use, the DOE test procedure for room air

conditioners currently assumes 750 annual hours of operation. DOE’s TSD from September

1997, issued in support of the most recent previous room air conditioner rulemaking, provides

estimates for average annual operating hours closer to 500,1 which would yield 33 percent lower

annual energy consumption than currently calculated by the test procedure. Similar assessment

of room air conditioner hours of operation conducted for the current rulemaking, described in

chapter 8 of this preliminary TSD, suggest that the annual hours of operation have since risen.

DOE is considering clothes dryer and room air conditioner test procedure amendments to

address the aforementioned issues in a separate rulemaking.

Standby power measurement is not currently incorporated into DOE test procedures for

residential clothes dryers or room air conditioners. Section 310 of EISA 2007 amended Section

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325 of EPCA to require that the test procedures for clothes dryers and room air conditioners be

amended to include measurement of standby mode and off mode power, taking into

consideration the most current version of International Electrotechnical Commission (IEC)

Standard 62301 Household electrical appliances – Measurement of standby power (IEC

Standard 62301).f EPCA, as amended by EISA 2007, also required that the final rule for this test

procedure be published no later than March 31, 2009. (42 U.S.C. 6295(gg)) DOE initiated a

separate test procedure rulemaking to modify the test procedures for clothes dryers and room air

conditioners to provide procedures for the measurement of standby and off modes. DOE

published a NOPR for this rule on December 9, 2008 (December 2008 NOPR). 73 FR 74639.

DOE determined after the December 2008 NOPR was published that it would continue

the clothes dryer and room air conditioner test procedure rulemaking to allow for consideration

of a revised version of IEC Standard 62301, which at that time was expected in July 2009. DOE

anticipated, based on review of drafts of the updated IEC Standard 62301, that the revisions

could include different mode definitions. DOE expected to publish a supplemental NOPR

(SNOPR) for the test procedure rulemaking in which the new mode definitions are considered.

However, more recently, DOE received information that the revised IEC Standard 62301 would

not be available until mid­2010. Hence, DOE expects to issue a final rule addressing standby and

off mode energy use for these products based on the NOPR and comments received during the

NOPR public meeting and comment period.

DOE also notes that EISA 2007 amended EPCA to require that standby mode and off

mode energy consumption be integrated into the overall energy efficiency, energy consumption,

or other energy descriptor unless the Secretary determines that – (i) the current test procedures

for a covered product already fully account for and incorporate standby mode and off mode

energy consumption of the covered product; or (ii) such an integrated test procedure is

technically infeasible for a particular covered product, in which case the Secretary shall prescribe

a separate standby mode and off mode energy use test procedure for the covered product, if

technically feasible. (42 U.S.C. 6295(gg)(2)(A))

As indicated, the test procedure rulemaking to incorporate standby mode and off mode

energy consumption in the energy descriptors for residential clothes dryers and room air

conditioners was initiated in parallel with the current rulemaking. A final rule for the test

procedures will be published before the publication of a final rule on energy conservation

standards.

f DOE notes that EPCA as amended by EISA 2007, also requires DOE to consider IEC Standard 62087, which

specifies methods of measurement for the power consumption of TV receivers, VCRs, set top boxes, audio

equipment and multi­function equipment for consumer use. IEC Standard 62087 does not, however, include

measurement for the power consumption of electrical appliances such as clothes dryers and room air conditioners.

Therefore, DOE determined that IEC Standard 62087 was not suitable for amendments to the clothes dryer and

room air conditioner test procedures.

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For both clothes dryers and room air conditioners, DOE has determined that it is

technically feasible to incorporate standby mode and off mode energy consumption into overall

energy consumption. Accordingly, DOE expects to develop the amended energy conservation

standards for residential clothes dryers and room air conditioners based on the integrated metrics

whose definitions will be finalized in the expected final rule for the test procedure addressing

standby and off mode energy use.

3.5 MANUFACTURER TRADE GROUPS

DOE recognizes the importance of trade groups in disseminating information and

promoting the interests of the industry that they support. To gain insight into the residential

clothes dryer and room air conditioner industries, DOE researched various associations available

to manufacturers, suppliers, and users of such equipment. DOE also used the member lists of

these groups in the construction of an exhaustive database containing domestic manufacturers.

DOE identified several trade groups that support, or have an interest in, the residential

clothes dryer and/or room air conditioner industries, including AHAM and the Air Conditioning

and Refrigeration Institute.

3.5.1 Association of Home Appliance Manufacturers

The Association of Home Appliance Manufacturersg (AHAM), formed in 1967, aims to

enhance the value of the home appliance industry through leadership, public education and

advocacy. AHAM provides services to its members including government relations; certification

programs for room air conditioners, dehumidifiers and room air cleaners; an active

communications program; and technical services and research. In addition, AHAM conducts

other market and consumer research studies and publishes a biennial Major Appliance Fact

Book. AHAM also develops and maintains technical standards for various appliances to provide

uniform, repeatable procedures for measuring specific product characteristics and performance

features.

3.5.2 Air Conditioning and Refrigeration Institute

The Air Conditioning and Refrigeration Institute (ARI) is the trade organization that

represents manufacturers of over 90 percent of the air conditioning and refrigeration equipment

that is currently installed in the United States. ARI develops and published technical standards,

often in conjunction with ANSI, the IEC, and the International Organization for Standardization

(ISO). ARI maintains a certification program and certified product database, and supports

legislation, regulations, and codes favorable to the HVACR industry. While ARI does not certify

g For more information, please visit www.aham.org.

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room air conditioners, it represents a number of manufacturers which produce multiple types of

air conditioning systems, including room air conditioners, and is involved with regulatory issues

affecting all types of refrigeration­based systems.

3.6 MANUFACTURER INFORMATION

The following section details information regarding manufacturers of residential clothes

dryers and room air conditioners for sale in the United States, including estimated market shares

(section 3.6.1), industry mergers and acquisitions (section 3.6.2), potential small business

impacts (section 3.6.3), and product distribution channels (section 3.6.4).

3.6.1 Manufacturers and Market Shares

Using publicly available data (e.g. Appliance Magazine and market assessments done by

third parties), DOE estimates the market shares for domestic manufacturers of each of the two

products contained in this standards rulemaking. Manufacturers may offer multiple brand names.

Some of the brand names come from independent appliance manufacturers which have been

acquired over time, and domestic manufacturers may put their brand on a product manufactured

overseas. Companies included in this analysis may also be off­shore manufacturers that maintain

a significant domestic presence via a U.S. entity.

For residential clothes dryers, DOE estimates that there are 14 manufacturers selling into

the domestic market, of which several are foreign­owned companies with manufacturing

facilities outside of the United States. The majority of market share is held by four major

domestic manufacturers, including Whirlpool Corporation (Whirlpool), Maytag Corporation

(Maytag), GE Consumer & Industrial (GE), and AB Electrolux (Frigidaire).2 As will be

discussed in section 3.6.2, Maytag and Whirlpool merged in 2006 but have continued to maintain

both product lines to this date. The combined Maytag­Whirlpool entity accounts for 70 ­ 74

percent of the residential clothes dryer market. Other manufacturers include Alliance Laundry

Systems LLC (Alliance), AM Appliance Group (formerly ASKO, Inc.), BSH Home Appliances

Corporation (Bosch­Siemens), Fisher & Paykel Appliances Limited (Fisher & Paykel), Haier

America Trading, LLC (Haier), Indesit Company (Indesit), LG Electronics, Inc. (LG), Miele,

Inc. (Miele), Samsung Electronics America, Inc. (Samsung), and Felix Storch, Inc. (Summit).

Table 3.6.1 lists these manufacturers. Figure 3.6.1 and Figure 3.6.2 illustrate the 2008 market

shares for the domestic residential electric and gas clothes dryer markets, respectively.

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Table 3.6.1 Major and Other Residential Clothes Dryer Manufacturers
 

Major Manufacturers Other Manufacturers

Whirlpool Alliance

Maytag ASKO

GE Bosch­Siemens

Frigidaire Fisher & Paykel

Haier

Indesit

LG

Miele

Samsung

Summit

Figure 3.6.1 2008 Market Shares for the Domestic Electric Clothes Dryer Market3

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Figure 3.6.2 2008 Market Shares for the Domestic Gas Clothes Dryer Market4

Table 3.6.2 and Table 3.6.3 show the market share for electric and gas clothes dryer

manufacturers, respectively, between 2000 and 2008. The market shares for the top three clothes

dryer manufacturers have remained relatively stable since 2000; however, the market share for

Electrolux gas dryers has decreased by 5 percent since 2000.

Table 3.6.2 2000­2008 Electric Clothes Dryer Manufacturer Market Share 5

Company

Market Share (%)

2008 2007 2006 2005 2004 2003 2002 2001 2000

Whirlpool 70* 56 56 56 56 56 55 54 54

Maytag ­ 16 17 18 19 18 20 20 19

GE 16 15 15 14 14 15 17 18 16

Electrolux (Frigidaire) 8 8 9 10 10 11 8 8 8

Others 6 5 3 2 1 0 0 0 3

*Whirlpool share of market in 2008 includes Maytag.

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Table 3.6.3 2000­2008 Gas Clothes Dryer Manufacturer Market Share 6

Company

Market Share (%)

2008 2007 2006 2005 2004 2003 2002 2001 2000

Whirlpool 74 55 55 55 55 55 57 58 56

Maytag ­ 22 23 25 25 26 23 23 21

GE 10 11 11 11 11 11 13 13 13

Electrolux (Frigidaire) 5 5 6 7 7 8 7 6 10

Others 11 7 5 3 2 0 0 0 0

*Whirlpool share of market in 2008 includes Maytag.

For room air conditioners, DOE estimates that there are less than 10 key manufacturers

supplying the U.S. market. Based on data published by Appliance Magazine,

7 nearly three

quarters of the domestic market, 70 percent, in 2008 was controlled by four manufacturers: LG,

Fedders Corporation (Fedders), Frigidaire, and Whirlpool. The remaining market share was

divided among companies including Haier, Samsung, Sharp Electronics Corporation (Sharp),

Friedrich Air Conditioning Company (Friedrich) and others. Table 3.6.4 lists these

manufacturers. Figure 3.6.3 illustrates the 2008 market shares for the domestic room air

conditioner market.

Table 3.6.4 Major and Other Room Air Conditioner Manufacturers

Major Manufacturers Other Manufacturers

LG Haier

Fedders Samsung

Frigidaire Sharp

Whirlpool Matsushita

Friedrich

Carrier

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Figure 3.6.3 2008 Market Shares for the Domestic Room Air Conditioner Market7

Table 3.6.5 shows the market share for room air conditioner manufacturers between 2000

and 2008. The market share for LG increased 12 percent since 2000, whereas the market share

for Fedders and Electrolux dropped by 10 and 5 percent, respectively, over the same period.

Whirlpool’s market share remained relatively stable between 2000 and 2008.

8 Table 3.6.5 2000­2007 Room Air Conditioner Manufacturer Market Share

Company

Market Share (%)

2008 2007 2006 2005 2004 2003 2002 2001 2000

LG Electronics 32 32 30 30 29 32 28 26 20

Fedders 12 12 14 14 22 21 22 20 22

Electrolux (Frigidaire) 13 13 14 14 11 13 11 13 17

Whirlpool 13 13 14 14 11 9 11 12 12

Haier 8 8 6 5 6 9 12 11 6

Samsung 5 5 5 5 6 5 2 1 3

Sharp 4 4 5 4 4 3 4 3 2

Friedrich 4 4 4 4 2 2 3 3 3

UTC/Carrier 3 3 3 0 0 2 2 3 2

Matsushita 2 2 1 2 2 3 2 2 3

Others 4 4 4 8 7 5 3 6 10

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Since 2007 there have been significant changes to the market. Fedders and Whirlpool left

the market in 2008, and the status of other manufacturers including Sharp and Matsushita is

unclear. Also not reflected in the market share data is the distinction between brand share and

manufacturer share. GE, for example, is an active brand that is not listed in the Appliance

Magazine data, while some of the brands listed do not currently manufacture their room air

conditioners. The manufacture of room air conditioners has, in recent years, entirely moved

offshore. There is some limited manufacturing still occurring in North America, but most of the

production is currently in Asia, primarily in China.

3.6.2 Mergers and Acquisitions

Due to mergers and acquisitions, the home appliance industry continues to consolidate.

While this phenomenon varies from product to product within the industry, the large market

shares of a few companies provide evidence in support of this characterization.

According to the September 2009 issue of Appliance Magazine, four manufacturers

comprise 85 percent of the core appliance market share. “Core appliances” include dishwashers,

dryers, freezers, ranges, refrigerators, and clothes washers. Table 3.6.6 lists these core appliance

manufacturers, and Figure 3.6.4 illustrates the breakdown of 2008 market shares in the core

appliance category.

Table 3.6.6 Core Appliance Manufacturers

Core Appliance Manufacturers

Whirlpool

GE

Frigidaire

Maytag

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Figure 3.6.4 2008 Core Appliance Market Shares9

On August 22, 2005, Whirlpool, headquartered in Benton Harbor, Michigan, and Maytag,

based in Newton, Iowa, announced plans to merge in a deal worth $2.7 billion.10 Maytag

shareholders approved the merger on December 22, 2005. Shortly after announcing the merger,

Whirlpool submitted a pre­merger notification to the U.S. Department of Justice (DOJ). The DOJ

Antitrust Division initiated an investigation, scheduled to end February 27, 2006, into the effects

of the merger, including potential lessening of competition or the creation of a monopoly.

Following this initial review, the DOJ asked for additional materials from each company and

extended the review to March 30, 2006.

Opponents of the merger asserted that the combined companies would control as much as

70 percent of the residential laundry market and as much as 50 percent of the residential

dishwasher market.11 Whirlpool claimed that their large potential residential laundry market

share was skewed because the company produces washing machines for Sears, which sells them

under their Kenmore in­house brand. Whirlpool went on to say that they must periodically bid

with other manufacturers to keep the Kenmore contract and that Sears controls the pricing of the

Kenmore units.12

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In early January 2006, U.S. Senator Tom Harkin and U.S. Representative Leonard

Boswell, both of Iowa, called upon the DOJ to block the merger, claiming it would give

Whirlpool an unfair advantage in the home appliance industry. The Congressmen wrote, that if

the DOJ does not block the deal, the agency should at least “require that Whirlpool divest the

washer and dryer portions of Maytag to a viable purchaser who will have the financial capability

and desire to continue to operate that business.”13

On March 29, 2006, DOJ closed its investigation and approved the merger. DOJ claims

“that the proposed transaction is not likely to reduce competition substantially. The combination

of strong rival suppliers with the ability to expand sales significantly and large cost savings and

other efficiencies that Whirlpool appears likely to achieve indicates that this transaction is not

likely to harm consumer welfare.”14

The DOJ Antitrust Division focused its investigation on residential laundry, although it

considered impacts across all products offered by the two companies. DOJ determined that the

merger would not give Whirlpool excessive market power in the sale of its products and that any

attempt to raise prices would likely be unsuccessful. In support of this claim, DOJ noted: (1)

other U.S. brands, including Kenmore, GE, and Frigidaire, are well established; (2) foreign

manufacturers, including LG and Samsung, are gaining market share; (3) existing U.S.

manufacturers are below production capacity; (4) the large home appliance retailers have

alternatives available to resist price increase attempts; and (5) Whirlpool and Maytag

substantiated large cost savings and other efficiencies that would benefit consumers.15

Whirlpool and Maytag completed the merger on March 31, 2006. This large merger

follows several other mergers and acquisitions in the home appliance industry. For example,

Maytag acquired Jenn­Air Corporation (Jenn­Air) in 1982, Magic Chef, Inc. (Magic Chef) in

1986, and Amana Appliances (Amana) in 2001. Whirlpool acquired the KitchenAid division of

Hobart Corporation (KitchenAid) in 1986. White Consolidated Industries (WCI) acquired the

Frigidaire division of General Motors Corporation in 1979, and AB Electrolux acquired WCI

(and therefore Frigidaire) in 1986.

3.6.3 Small Business Impacts

DOE considers the possibility of small businesses being impacted by the promulgation of

energy conservation standards for residential clothes dryers and room air conditioners. The Small

Business Association (SBA) considers an entity to be a small business if, together with its

affiliates, it employs less than a threshold number of workers specified in 13 CFR part 121,

which relies on size standards and codes established by the North American Industry

Classification System (NAICS). The threshold number for NAICS classification for 335224,

which applies to household laundry equipment manufacturers and includes clothes dryer

manufacturers, is 1,000 employees. The threshold number for NAICS classification for 333415,

which applies to air conditioning and warm air heating equipment and commercial and industrial

refrigeration equipment manufacturers and includes room air conditioner manufacturers, is 750

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employees. Searches of the SBA websiteh to identify manufacturers within these NAICS codes

that manufacture clothes dryers and/or room air conditioners revealed only Staber Industries, Inc.

(Staber) of Groveport, Ohio, as a producer or laundry equipment. However, DOE notes that the

Staber website indicates that their clothes dryer is manufactured by Whirlpool and rebranded.

Therefore, DOE believes that there are no clothes dryer manufacturers that are considered a

small business. Further, DOE is aware that at least one room air conditioner manufacturer supply

the U.S. market is a small business, although this manufacturer is not listed on the SBA website

under the NAICS classification number 333415. For any small business manufacturers of the two

appliance products that DOE identifies, DOE will study the potential impacts on the small

businesses in greater detail during the manufacturer impact analysis (MIA), which it will conduct

as a part of the NOPR analysis.

3.6.4 Distribution Channels

Understanding the distribution channels of products covered by this rulemaking is an

important facet of the market assessment. DOE gathered information regarding the distribution

channels for residential clothes dryers and room air conditioners from publicly available sources.

This section contains distribution channel information for residential appliances.

For residential appliances, including room air conditioners and clothes dryers, the

majority of consumers purchase their appliances directly from retailers. Table 3.6.7 identifies the

types of retail stores through which major appliances, including residential clothes washers, are

sold, based on data from the AHAM Fact Book 2005.16

Table 3.6.7 Major Appliance Sales by Channel (Purchased between 2001 and 2005)17

Type of Store Percentage of Appliance Purchases (%)

Department Store (such as Sears or Kohls) 34.7

Appliance Store or Consumer Electronics Store 30.9

Home Improvement Store (such as Lowe’s or Home Depot) 23.8

Discount Store (such as Wal­Mart or K­Mart) 2.0

Membership Warehouse Club/Store (such as Sam’s or Costco) 1.8

Another type of store 6.8

Home appliance retailers generally obtain products directly from manufacturers. The

AHAM Fact Book 2003 shows that over 93 percent of residential appliances are distributed from

the manufacturer directly to a retailer.18 A 2000 Consortium for Energy Efficiency (CEE) report

determined that 5–10 percent of major appliance sales were made to commercial consumers such

as builders, contractors, government sales, and property managers through

distributors/wholesalers.19

h A searchable database of certified small businesses is available online at:

http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm.

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3.7 REGULATORY PROGRAMS

The following section details current regulatory programs mandating energy conservation

standards for residential clothes dryers and room air conditioners. Section 3.7.1 discusses current

Federal energy conservation standards, while section 3.7.2 discusses the requirements of EISA

2007 and section 3.7.3 provides an overview of existing State standards. In addition, section

3.7.4 reviews standards in Canada that may impact the companies servicing the North American

market.

3.7.1 Current Federal Energy Conservation Standards

Current Federal standards exist for residential clothes dryers. NAECA amended EPCA

to establish prescriptive standards for clothes dryers, requiring that gas dryers manufactured on

or after January 1, 1988 not be equipped with a constant burning pilot and further requiring that

DOE conduct two cycles of rulemakings to determine if more stringent standards are justified.

(42 U.S.C. 6295 (g)(3) and (4)) On May 14, 1991, DOE published a final rule in the Federal

Register (FR) establishing the first set of performance standards for residential clothes dryers (56

FR 22250); the new standards became effective on May 14, 1994. (10 CFR 430.32(h)) Table

3.7.1 presents these standards for residential clothes dryers, expressed as EF in terms of pounds

(lb) of clothes washed per kilowatt­hour (kWh). DOE initiated a second standards rulemaking for

residential clothes dryers by publishing an advance notice of proposed rulemaking (ANOPR) in

the Federal Register on November 14, 1994 (hereafter “November 1994 ANOPR). 59 FR 56423.

However, pursuant to the priority­setting process outlined in its Procedures for Consideration of

New or Revised Energy Conservation Standards for Consumer Products (the “Process Rule”)

(61 FR 36974 (July 15, 1996); establishing 10 CFR part 430, subpart C, appendix A), DOE

classified the standards rulemaking for residential clothes dryers as a low priority for its fiscal

year 1998 priority­setting process. As a result, DOE suspended the standards rulemaking

activities for them.

Table 3.7.1 Federal Energy Conservation Standards for Residential Clothes Dryers

Clothes Dryer Classification Minimum EF

(lb/kWh))

Electric, Standard (4.4 ft3 or greater capacity) 3.01

Electric, Compact (120 V) (less than 4.4 ft3 capacity) 3.13

Electric, Compact (240 V) (less than 4.4 ft3 capacity) 2.90

Gas 2.67

NAECA established performance standards for room air conditioners that became

effective on January 1, 1990, and directed DOE to conduct two cycles of rulemakings to

determine if more stringent standards are justified. (42 U.S.C. 6295 (c)(1) and (2)) On March 4,

1994, DOE published in the Federal Register a NOPR for several products, including room air

conditioners. 59 FR 10464. As a result of the Process Rule, DOE suspended activities to finalize

standards for room air conditioners. DOE subsequently resumed rulemaking activities related to

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room air conditioners, and, on September 24, 1997, DOE published a final rule establishing an

updated set of performance standards, with an effective date of October 1, 2000. (62 FR 50122;

10 CFR 40.32(b)). Table 3.7.2 presents these standards for room air conditioners in terms of

energy efficiency ratio (EER), which is expressed as cooling capacity in Btu/h per watt (W) of

input power.

Table 3.7.2 Federal Energy Conservation Standards for Room Air Conditioners

Room Air Conditioner Classification

Minimum EER (Btu/h­W),

effective as of

Jan. 1, 1990 Oct. 1, 2000

1. Without reverse cycle, with LS, and less than 6,000 Btu/h 8.0 9.7

2. Without reverse cycle, with LS and 6,000 to 7,999 Btu/h 8.5 9.7

3. Without reverse cycle, with LS and 8,000 to 13,999 Btu/h 9.0 9.8

4. Without reverse cycle, with LS and 14,000 to 19,999 Btu/h 8.8 9.7

5. Without reverse cycle, with LS and 20,000 Btu/h or more 8.2 8.5

6. Without reverse cycle, without LS, and less than 6,000 Btu/h 8.0 9.0

7. Without reverse cycle, without LS and 6,000 to 7,999 Btu/h 8.5 9.0

8. Without reverse cycle, without LS and 8,000 to 13,999 Btu/h 8.5 8.5

9. Without reverse cycle, without LS and 14,000 to 19,999 Btu/h 8.5 8.5

10. Without reverse cycle, without LS and 20,000 Btu/h or more 8.2 8.5

11. With reverse cycle, with LS, and less than 20,000 Btu/h 8.5 9.0

12. With reverse cycle, without LS, and less than 14,000 Btu/h 8.0 8.5

13. With reverse cycle, with LS, and 20,000 Btu/h or more 8.5 8.5

14. With reverse cycle, without LS, and 14,000 Btu/h or more 8.0 8.0

15. Casement­Only * 8.7

16. Casement­Slider * 9.5

* Casement­only and casement­slider room air conditioners were not separate product classes under standards

effective January 1, 1990. These units were subject to the applicable standards in classes 1 through 14 based on unit

capacity and the presence or absence of louvered sides and a reverse cycle.

3.7.2 Energy Independence and Security Act of 2007

There is currently no prescriptive Federal energy conservation standard for standby

power consumption for either residential clothes washers or room air conditioners, nor is standby

power incorporated into the existing Federal energy conservation standard metric for either

product. On December 19, 2007, the President signed into law EISA 2007, which contains

numerous amendments to EPCA. Section 310 of EISA 2007 amends section 325 of EPCA to

require any final rule establishing or revising a standard for a covered product, adopted after July

10, 2010, shall incorporate standby mode and off mode energy use into a single amended or new

standard. (42 U.S.C. 6295(gg)(3)(A)) If not feasible, the Secretary shall prescribe within the final

rule a separate standard for standby mode and off mode energy consumption, if justified. (42

U.S.C. 6295(gg)(3)(B))

Off mode is defined by EISA 2007 as “the condition in which an energy­using product –

(I) is connected to a main power source; and (II) is not providing any standby or active mode

function.” (42 U.S.C. 6295(gg)(1)(A)(ii)) Active mode refers to the one or more main functions,

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while standby is defined by EISA 2007 as “the condition in which an energy­using product (I) is

connected to a main power source; and (II) offers 1 or more of the following user­oriented or

protective functions: (aa) To facilitate the activation or deactivation of other functions (including

active mode) by remote switch (including remote control), internal sensor, or timer. (bb)

Continuous functions, including information or status displays (including clocks) or sensor­based

functions.” (Id.; 42 U.S.C. 6295(gg)(1)(A)(iii))

The final rule for this rulemaking is scheduled to be published in the Federal Register by

June 30, 2011. Thus, according to EISA 2007, energy conservation standards for residential

clothes dryers and room air conditioners that would be put forth from this rulemaking are

required to incorporate standby mode and off mode energy consumption.

As noted above in section 3.4, the test procedure rulemaking to incorporate standby mode

and off mode energy consumption in the energy descriptors for residential clothes dryers and

room air conditioners was initiated in parallel with the current rulemaking. For both clothes

dryers and room air conditioners, DOE has determined that it is technically feasible to

incorporate standby mode and off mode energy consumption into overall energy consumption.

Therefore, DOE expects to propose test procedure amendments which integrate standby mode

and off mode energy use with the existing energy use metrics into new overall energy use

descriptors. DOE anticipates that integrated metrics “integrated energy factor” (IEF) and

“integrated energy efficiency ratio” (IEER) will be established for clothes dryers and room air

conditioners, respectively. These metrics will have energy use of standby and off modes

integrated into the overall efficiency metrics for the products. Accordingly, DOE expects to

develop the amended energy conservation standards for residential clothes dryers and room air

conditioners based on these integrated metrics.

3.7.3 State Energy Conservation Standards

For those States which currently regulate residential clothes dryers and/or room air

conditioners, no State energy conservation standards differ from Federal standards.

3.7.4 Canadian Energy Conservation Standards

Canada’s Energy Efficiency Regulations (hereafter Regulations) mandate minimum

energy conservation standards for residential clothes dryers and room air conditioners.

Canadian Regulations stipulate minimum efficiency levels and definitions for electric

residential clothes dryers which are identical to U.S. Federal standards, mandating an EF of at

least 3.01 for standard clothes dryers, an EF of at least 3.13 for compact (120 V) clothes dryers,

and an EF of at least 2.90 for compact (240 V) clothes dryers. There are no Canadian

Regulations covering gas clothes dryers.

3­24

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For room air conditioners, Canada’s Regulations are currently identical to U.S. Federal

standards for all product classes. Canada’s Regulations, however, provide a stipulation in the

definition of covered products that limits cooling capacity to 36,000 Btu/h. U.S. Federal

standards do not specify a maximum cooling capacity.

Canada has proposed increasing the required efficiency levels of room air conditioners,

with an effective date of January 1, 2011. For many of the product classes, the proposed

standards are the same as the current ENERGY STAR efficiency levels, which are roughly 10

percent higher than the minimum standard levels. The current and proposed efficiency levels are

summarized in Table 3.7.3 below. The proposal also calls for measurement and reporting of

standby and off mode energy use, anticipating future regulation of the energy use of these

modes.

Table 3.7.3: Canada’s Proposed Efficiency Requirements for Room Air Conditioners

Room Air Conditioner Classification

Minimum EER (Btu/h­W)

Current

Standard

Proposed

1. Without reverse cycle, with LS, and less than 6,000 Btu/h 9.7 10.7

2. Without reverse cycle, with LS and 6,000 to 7,999 Btu/h 9.7 10.7

3. Without reverse cycle, with LS and 8,000 to 13,999 Btu/h 9.8 10.8

4. Without reverse cycle, with LS and 14,000 to 19,999 Btu/h 9.7 10.7

5. Without reverse cycle, with LS and 20,000 Btu/h or more 8.5 9.4

6. Without reverse cycle, without LS, and less than 6,000 Btu/h 9.0 9.9

7. Without reverse cycle, without LS and 6,000 to 7,999 Btu/h 9.0 9.9

8. Without reverse cycle, without LS and 8,000 to 13,999 Btu/h 8.5 9.4

9. Without reverse cycle, without LS and 14,000 to 19,999 Btu/h 8.5 9.4

10. Without reverse cycle, without LS and 20,000 Btu/h or more 8.5 8.5

11. With reverse cycle, with LS, and less than 20,000 Btu/h 9.0 9.9

12. With reverse cycle, without LS, and less than 14,000 Btu/h 8.5 9.2

13. With reverse cycle, with LS, and 20,000 Btu/h or more 8.5 9.5

14. With reverse cycle, without LS, and 14,000 Btu/h or more 8.0 8.8

15. Casement­Only 8.7 9.5

16. Casement­Slider 9.5 9.5

3.7.5 International Standby Power Regulatory Programs

The International Energy Agency (IEA) has raised awareness of standby power through

publications, international conferences, and policy advice to governments. In 1999, the IEA

developed the “1­Watt Plan,” which proposed reducing standby power internationally in

electronic devices and which advocates that all countries harmonize energy policies and adopt

the same definition and test procedure. The IEA has advocated a 1 W requirement for all

consumer electrical products (unless specifically excluded) in standby mode. The IEA also stated

3­25

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that IEC Standard 62301 provides an internationally sanctioned definition and test procedure for

standby power which is now widely specified and used.i

Australia has announced plans to implement a mandatory horizontal 1 W requirement for

all consumer electrical products by 2012, including room air conditioners and clothes dryers.20

The European Union (EU) recently enacted the Commission Regulation (EC) No.

1275/2008 of December 17, 2008, implementing design requirements for standby and off mode

power for electrical and electronic household and office equipment, including clothes dryers.

Annex II of the regulation specifies the following maximum power requirements:

1. One year after this Regulation has come into force:

(a) Power consumption in ‘off mode’:

Power consumption of equipment in any off­mode condition shall not exceed

[1.00] W.

(b) Power consumption in ‘standby mode(s)’:

The power consumption of equipment in any condition providing only a

reactivation function, or providing only a reactivation function and a mere

indication of enabled reactivation function, shall not exceed [1.00] W.

The power consumption of equipment in any condition providing only

information or status display, or providing only a combination of reactivation

function and information or status display, shall not exceed [2.00] W.

(c) Availability of off mode and/or standby mode

Equipment shall, except where this is inappropriate for the intended use, provide

off mode and/or standby mode and/or another condition which does not exceed

the applicable power consumption requirements for off mode and/or standby

mode when the equipment is connected to the mains power source.

2. Four years after this Regulation has come into force:

(a) Power consumption in ‘off mode’:

For more information visit http://www.iea.org/.

3­26

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Power consumption of equipment in any off­mode condition shall not exceed

[0.50] W.

(b) Power consumption in ‘standby mode(s)’:

The power consumption of equipment in any condition providing only a
 

reactivation function, or providing only a reactivation function and a mere
 

indication of enabled reactivation function, shall not exceed [0.50] W.
 

The power consumption of equipment in any condition providing only

information or status display, or providing only a combination of reactivation

function and information or status display, shall not exceed [1.00] W.

(c) Availability of off mode and/or standby mode

Equipment shall, except where this is inappropriate for the intended use, provide

off mode and/or standby mode and/or another condition which does not exceed

the applicable power consumption requirements for off mode and/or standby

mode when the equipment is connected to the mains power source.

(d) Power management

When equipment is not providing the main function, or when other energy­using

product(s) are not dependent on its functions, equipment shall, unless

inappropriate for the intended use, offer a power management function, or a

similar function, that switches equipment after the shortest possible period of time

appropriate for the intended use of the equipment, automatically into:

— standby mode, or

— off mode, or

—	 another condition which does not exceed the applicable power consumption

requirements for off mode and/or standby mode when the equipment is

connected to the mains power source. The power management function shall

be activated before delivery.

3­27

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3.8 VOLUNTARY PROGRAMS

DOE reviewed several voluntary programs promoting energy­efficient residential

appliances in the United States. Many programs, including the CEE, ENERGY STAR, and the

Federal Energy Management Program (FEMP), establish voluntary energy conservation

standards for these products.

3.8.1 Consortium for Energy Efficiency

The CEEj

develops initiatives for its North American members to promote the

manufacture and purchase of energy efficient products and services. The goal of the organization

is to induce lasting structural and behavioral changes in the marketplace, resulting in the

increased adoption of energy­efficient technologies.

CEE issues voluntary specifications for room air conditioners. Qualifying units must

use at least 15 percent less electricity, based on EER, than the Federal standard. Table 3.8.1

presents the room air conditioner efficiency specifications, effective January 2003, under its

Super­Efficient Home Appliance Initiative (SEHA). Unlike for Federal standards, no distinction

is made among the features present on a qualifying unit (i.e., louvered sides, reverse cycle, etc.).

The classes are differentiated only by cooling capacity.

Table 3.8.1 CEE Criteria for Room Air Conditioners

Product Class (Btu/h) Tier 1 (EER, Btu/h­W) Tier 2 (EER, Btu/h­W)

< 8,000 11.2 11.6

8,000 to 13,999 11.3 11.8

14,000 to 19,999 11.2 11.6

≥ 20,000 9.8 10.2

3.8.2 ENERGY STAR

ENERGY STAR, a voluntary labeling program jointly administered by the U.S.

Environmental Protection Agency (EPA) and DOE, identifies energy efficient products through a

qualification processk

. To qualify, a product must exceed Federal minimum standards by a

specified amount, or if no Federal standard exists, exhibit selected energy­saving features. The

ENERGY STAR program works to recognize the top quartile of products on the market,

meaning that approximately 25 percent of the models on the market at the time the qualifying

criteria are specified meet or exceed the ENERGY STAR levels. ENERGY STAR specifications

exist for several products, including room air conditioners.

j

For more information, please visit www.cee1.org.

k For more information, please visit www.energystar.gov.

3­28

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Prior to November, 2005, ENERGY STAR room air conditioner criteria existed for

only cooling­only units; i.e., those without a reverse cycle or electric resistance heating. New

criteria which became effective November 16, 2005 added ENERGY STAR specifications for

room air conditioners with reverse cycle operation. The current ENERGY STAR criteria for

room air conditioners are listed in Table 3.8.2. According to the ENERGY STAR program, 54

percent of room air conditioners sold in 2006 were ENERGY STAR­qualified.

Table 3.8.2 ENERGY STAR Criteria for Room Air Conditioners

Without reverse cycle and with louvered sides Required EER

(Btu/h­W)

1. Less than 6,000 Btu/h ≥ 10.7

2. 6,000 to 7,999 Btu/h ≥ 10.7

3. 8,000 to 13,999 Btu/h ≥ 10.8

4. 14,000 to 19,999 Btu/h ≥ 10.7

5. 20,000 Btu/h or more ≥ 9.4

Without reverse cycle and without louvered sides

6. Less than 6,000 Btu/h ≥ 9.9

7. 6,000 to 7,999 Btu/h ≥ 9.9

8. 8,000 to 13,999 Btu/h ≥ 9.4

9. 14,000 to 19,999 Btu/h ≥ 9.4

10. 20,000 Btu/h or more ≥ 9.4

With reverse cycle and with louvered sides

11. Less than 20,000 Btu/h ≥ 9.9

12. 20,000 Btu/h or more ≥ 9.4

With reverse cycle and without louvered sides

13. Less than 14,000 Btu/h ≥ 9.4

14. 14,000 Btu/h or more ≥ 8.8

Casement

15. Casement­Only ≥ 9.6

16. Casement­Slider ≥ 10.5

3.8.3 Federal Energy Management Program

DOE’s Federal Energy Management Programl(FEMP) works to reduce the cost and

environmental impact of the Federal government by advancing energy efficiency and water

conservation, promoting the use of distributed and renewable energy, and improving utility

management decisions at Federal sites. FEMP helps Federal buyers identify and purchase energy

efficient equipment, including certain residential appliances.

l

For more information, please visit www.eere.energy.gov/femp.

3­29

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FEMP issues energy efficiency recommendations for room air conditioners. Table 3.8.3

presents the room air conditioner recommendations.

Table 3.8.3 FEMP Recommendations for Room Air Conditioners

Air Conditioner Type and Capacity Required EER (Btu/h­W)

With louvered sides, < 20,000 Btu/h ≥ 10.7

With louvered sides, ≥ 20,000 Btu/h ≥ 9.4

Without louvered sides, < 8,000 Btu/h ≥ 9.9*

Without louvered sides, ≥ 8,000 Btu/h ≥ 9.4

* FEMP states that currently there are no models that can meet this recommendation, and

suggests purchasing a unit with the best available EER.

FEMP estimates that a typical household using a louvered­side model room air

conditioner with a cooling capacity of 10,000 Btu/h and 750 operating hours per year with an

EER of 9.8 (DOE minimum standard) can save $40 in energy costs over the lifetime of the unit

(assuming Federal average energy prices) by upgrading to a unit with an EER of 10.7 (FEMP

recommendation). The lifetime energy savings increase to $80 by purchasing a unit with an EER

of 11.5.

Executive Order 13221 Energy Efficient Standby Power Devices, signed July 31, 2001,

requires that Federal agencies purchase commercially available products with low standby

power. In addition, Executive Order 13221 of July 31, 2001, directs Federal agencies, when

purchasing a product that contains an internal standby power function or that uses an external

standby power device, to purchase such a product that consumes no more than 1 W in standby

power mode or, if such a product is not available, to select a product with the lowest available

standby power consumption. These requirements shall apply only if the lower­wattage eligible

product is lifecycle cost effective and practicable, and the utility and performance of the product

is not compromised by the lower wattage requirement. 66 FR 40571.

3.8.4 Rebates for Highly Energy­Efficient Products

Electric utilities and other organizations promote the purchase of highly energy efficient

residential clothes washers through consumer rebates. Typically, these programs offer rebates for

products meeting existing ENERGY STAR efficiency levels. Table 3.8.4 lists some rebates that

were offered in 2008. Some utilities also offer incentives to retire old and inefficient appliances.

3­30

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Table 3.8.4 Rebates Offered for Highly Energy Efficient Room Air Conditioners in 200821

Utility/Organization* Rebate Level ($)

Alliant Energy (Iowa and Minnesota) 50 (ENERGY STAR)

Efficiency Vermont 25 (ENERGY STAR)

40 (CEE Tier 1)

Los Angeles Department of Water and Power (CA) 50 (ENERGY STAR)

Pacific Gas and Electric Company (Northern California) 50 (ENERGY STAR)

Sacramento Municipal Utility District (CA) 50 (ENERGY STAR)

San Diego Gas & Electric (CA) 50 (ENERGY STAR)

* The table includes a survey of a limited number of rebate programs. Additional programs may exist.

3.9 HISTORICAL SHIPMENTS

Awareness of annual product shipment trends is an important aspect of the market

assessment and in the development of the standards rulemaking. DOE reviewed data collected by

the U.S. Census Bureau, EPA, and AHAM to evaluate residential appliance product shipment

trends and the value of these shipments. Knowledge of such trends will be used during the

shipments analysis (chapter 9 of this preliminary TSD).

3.9.1 New Home Starts

Trends in new home starts may directly affect shipments of certain home appliances.

While there is certainly both a replacement and remodeling market for some appliances

including residential clothes dryers, these products are also fixtures in many new homes. Room

air conditioner shipments are not as greatly impacted by new home starts, as they are often

purchased for use in existing construction.

Figure 3.9.1 presents the number of new single­family and multi­family housing units

started in the United States from 1998–2008. Over the 5­year period from 2000–2005, singlefamily home starts increased 39.4 percent, to 1,716,000 units annually. However, between 2005

and 2008, single­family home starts decreased 63.7 percent, to 622,000 units annually. Multifamily unit starts remained relatively flat between 1998 and 2005, hovering around 350,000 units

annually. However, between 2005 and 2008, multi­family unit starts decreased by 19.6 percent,

to around 284,000 units annually.22

3­31

EERE-2007-BT-STD-0010 COMMENT 20.3
                       

            

   

                       

                     

                             

                               

                           

                               

                                 

                         

Figure 3.9.1 New Privately Owned Single­Family and Multi­Family Housing Unit Starts in

23 the United States from 1998–2008

3.9.2 Unit Shipments

AHAM submitted data for the annual unit shipments for residential clothes dryers, and

DOE obtained additional shipments data from Appliance Magazine. Table 3.9.1 presents the

annual shipments of clothes dryers for the 13­year period from 1994 to 2008. The shipments of

electric clothes dryers increased 73 percent from 1993 to 2006, to about 6.4 million units in

2006. However, between 2006 and 2008, shipments of electric clothes dryers decreased by 11.6

percent, to 5.6 million units in 2008. The shipments of gas dryers increased 40 percent from

1993 to 2006, to about 1.6 million units in 2006. Again, between 2006 and 2008, shipments of

gas clothes dryers decreased by about 16 percent, to about 1.4 million in 2008.

3­32

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Table 3.9.1 Industry Shipments of Residential Clothes Dryers (Domestic and Import, in

Thousands of Units)24

Year

Clothes Dryers (Thousands)

Electric Standard

Electric

Compact

Electric Gas Total

2008** 5,620 1,353 6,973

2007** 6,035 1,530 7,565

2006 6,360 6,246 114 1,614 7,974

2005 6,408 6,330 78 1,707 8,115

2004 6,262 6,159 103 1,660 7,922

2003 5,718 5,622 96 1,616 7,334

2002 5,402 1,490 6,892

2001 5,117 1,384 6,501

2000 5,095 1,480 6,575

1999 4,865 1,444 6,309

1998 4,482 1,307 5,789

1997 4,115 1,195 5,310

1996 3,947 1,193 5,140

1995 3,823 1,169 4,992

1994 3,838 1,239 5,077

1993 3,674 1,156 4,830

*AHAM did not provide data for standard and compact electric clothes dryers prior to 2003, nor any clothes dryer
 

shipments data for 2007 and 2008.
 

**Source: September 2008 and 2009 Appliance Magazine “Share­of­Market Picture”.
 

AHAM’s Fact Book 2003 and 2005, as well as Appliance Magazine, provide annual unit

shipments for room air conditioners. Table 3.9.2 presents the annual shipments of room air

conditioners for the 14­year period from 1994 to 2008. Shipments of room air conditioners

increased sharply in 1999 and again in 2003 and 2006.

Table 3.9.2 Industry Shipments of Room Air Conditioners (Domestic and Import, in

Thousands of Units) 25

Year Room Air Conditioners

(Thousands)

2008* 9,086

2007* 9,550

2006* 10,055

2005 8,032

2004 8,082

2003 8,216

2002 6,153

2001 5,575

2000 6,496

1999 6,114

1998 4,403

1997 4,123

1996 4,825

3­33

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1995 4,300

1994 3,853

*Shipments data for 2006 through 2008 were obtained from the September 2007­2009 Appliance Magazine “Shareof­Market Picture”.

ENERGY STAR market share data are an indicator of the demand for energy efficient

products. Table 3.9.3 shows the ENERGY STAR­qualified room air conditioner shipments and

market share from 1997 to 2006 provided in the ENERGY STAR Room Air Conditioner 2007

Product Snapshot. Sales of ENERGY STAR qualified room air conditioners have grown faster

than the overall total sales of clothes washers over the 10­year period, with market share

increasing more than 40 percent.

Table 3.9.3 ENERGY STAR Shipments for Room Air Conditioners (Domestic and Import)

Year

Shipments % ENERGY

STAR of

Total

ENERGY 26 STARQualified Other Total27

2006 5,429,862 4,625,438 10,055,300* 54

2005 4,176,640 3,855,360 8,032,000 52

2004 2,828,700 5,253,300 8,082,000 35

2003 2,382,640 5,833,360 8,216,000 29

2002 2,215,080 3,937,920 6,153,000 36

2001 669,000 4,906,000 5,575,000 12

2000 1,234,240 5,261,760 6,496,000 19

1999 794,820 5,319,180 6,114,000 13

1998 572,390 3,830,610 4,403,000 13

1997 494,760 3,628,240 4,123,000 12

*Total shipments data for 2006 from the September 2007 Appliance Magazine “Share­of­Market Picture for 2006”.

3.9.3 Value of Shipments

Table 3.9.4 provides the value of household laundry equipment shipments, which

includes residential clothes dryer and clothes washer shipments, from 1994 to 2006 based upon

data from the U.S. Census Bureau’s Annual Survey of Manufacturers (ASM)m. The ASM

expresses all dollar values in nominal dollars; i.e., 2006 data are expressed in 2006 dollars, and

2005 data are expressed in 2005 dollars. Using the Gross Domestic Product Implicit Price

Deflator, DOE converted each year’s value of shipments to 2006 dollars. In constant dollars, the

value of household laundry shipments increased 9 percent over the 13­year period. During the

same period, however, unit shipments of residential clothes dryers increased about 60 percent,

suggesting that the U.S. laundry appliance industry is very competitive.

m Available online at www.census.gov/mcd/asm­as1.html.

3­34

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Table 3.9.4 Household Laundry Equipment Value of Shipments by Year28

Year Value of Shipments in Nominal

Dollars ($million)

Value of Shipments in 2006

Dollars ($million)

2006 5,129 5,129

2005 5,222 5,375

2004 4,987 5,288

2003 4,658 5,080

2002 4,352 4,847

2001 4,549 5,155

2000 4,420 5,129

1999 4,365 5,175

1998 4,249 5,111

1997 3,710 4,513

1996 3,699 4,574

1995 3,541 4,462

1994 3,671 4,719

Table 3.9.5 provides the value of shipments for the NAICS product class which includes

room air conditioners and dehumidifiers, other than portable dehumidifiers (NAICS product

class code 3334156). The value of shipments for these products has decreased 64 percent from

1994 to 2006 while unit shipments of room air conditioners have increased about 108 percent

during the same time period, indicating significant industry competition.

Table 3.9.5 “Room Air­Conditioners and Dehumidifiers, Except Portable Dehumidifiers”

Product Class Value of Shipments by Year29

Year Value of Shipments in Nominal

Dollars ($million)

Value of Shipments in 2006

Dollars ($million)

2006 542 542

2005 572 589

2004 598 634

2003 820 894

2002 839 934

2001 944 1,070

2000 984 1,142

1999 1,177 1,396

1998 1,034 1,243

1997 979 1,191

1996 1,367 1,690

1995 1,300 1,637

1994 1,183 1,521

According to data presented in the AHAM 2003 Fact Book, many old appliances are still

being used after consumers purchase new units of same product. Table 3.9.6 presents the various

methods by which consumers dispose of their older appliances.

3­35

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Table 3.9.6 Disposition of Previous Appliance (Percentage)30

Product

Kept It

(%)

Left with

Previous

Home (%)

Sold / Gave

Away (%)

Recycling

Facility (%)

Left at

Curb for

Disposal

(%)

Retailer

Took Away

(%)

Clothes Dryers 5 19 25 18 10 23

Room Air Conditioners 16 21 40 9 9 4

3.9.4 Imports and Exports

There is a large market for the import and export of home appliances. Each month

AHAM publishes import and export data for certain home appliances. This data is released by

the U.S. Census Bureau and aggregated by a third party. On the whole, major appliance unit

imports decreased 13.5 percent in 2008 as compared to 2007. Major appliance unit exports

decreased 14.0 percent over the same period.

Table 3.9.7 shows selected import data from AHAM’s Import/Export Trade Report –

December 2008 (preliminary year end).31 For non­coin­operated clothes dryers with a capacity

less than 10 kilograms (kg) (i.e., residential clothes dryers), the number of units imported

decreased by 11 percent from 2007 to 2008, while the value of units imported remained the same

over that same period. For room air conditioners with a capacity less than 2.93 kW (10,000

Btu/h), both the number and value of units imported decreased by more than 22 percent from

2007 to 2008. For room air conditioners with a capacity between 2.93 to 4.98 kW (10,000 to

17,000 Btu/h) both the number and value of units imported decreased slightly. For room air

conditioners with a capacity greater than 4.98 kW (17,000 Btu/h), the number of units imported

decreased slightly, while the value of units imported increased slightly over the same period.

3­36

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Table 3.9.7 2007­2008 Imports of Appliances Covered by this Rulemaking32

Appliance Description

Jan. – Dec.

2008

Jan. – Dec.

2007 % Change

Jan. – Dec.

2008

Jan. – Dec.

2007 % Change

Units $ Mil (Nominal)

Drying machines, except

coin­operated, capacity ≤

10 kg

1,159,511 1,302,758 ­11.0 242.635 242.602 0.0

Air conditioners,

window/wall, capacity <

2.93 kW

(<10,000 Btu/h)

4,959,412 6,354,996 ­22.0 518.186 731.984 ­29.2

Air conditioners,

window/wall, selfcontained, capacity 2.93­

4.98 kW

(10,000 to 17,000 Btu/h)

2,109,417 2,141,643 ­1.5 378.011 379.856 ­0.5

Air conditioners,

window/wall, selfcontained, capacity

≥4.98 kW

(≥17,000 Btu/h)

636,125 666,129 ­4.5 178.275 176.571 1.0

Table 3.9.8 shows selected export data from AHAM’s Import/Export Trade Report –

December 2008 (preliminary year end).

33 For the 1­year period from 2007 to 2008, the number

and value of unit exports of non­coin­operated clothes dryers and all room air conditioners

decreased significantly.

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Table 3.9.8 2007­2008 Exports of Appliances Covered by this Rulemaking34

Appliance Description

Jan. – Dec.

2008

Jan. – Dec.

2007 % Change

Jan. – Dec.

2008

Jan. – Dec.

2007 % Change

Units $ Mil (Nominal)

Drying machines, except

coin­operated, capacity ≤

10 kg

158,537 344,864 ­54.0 34.681 75.792 ­54.0

Air conditioners,

window/wall, capacity <

2.93 kW/h

(<10,000 Btu/h)

104,044 117,036 ­11.1 33.547 35.400 ­11.1

Air conditioners,

window/wall, selfcontained, capacity 2.93­

4.98 kW/h

(10,000 to 17,000 Btu/h)

73,726 79,858 ­7.7 30.551 32.870 ­7.7

Air conditioners,

window/wall, selfcontained, capacity

≥4.98 kW/h

(≥17,000 Btu/h)

52,031 58,046 ­10.4 36.666 34.610 ­10.4

3.10 HISTORICAL EFFICIENCIES

Table 3.10.1 shows the historical efficiency trends and the percentage of domestic

shipments by EER classification for room air conditioners from 1980 to 2004, as provided in the

AHAM Fact Book 2005. New coil designs, increased motor and compressor efficiencies, and

better air circulation systems have all contributed to the 11­percent efficiency increase from 1990

through 2004. The percentage of domestic shipments by EER classification also shows a trend

towards high efficiency room air conditioners. The increases in EER and percent of shipments of

higher efficiency room air conditioners in 2000 and 2001 were a result of the new energy

conservation standards which became effective in October 1, 2000.

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Table 3.10.1 Room Air Conditioner Energy Efficiency and Consumption Trends (Shipment

Weighted Averages)35

Year EER (Btu/h)

Percentage of Domestic Shipments (%)

Less than 8.5 EER 8.5 ­ 9.4 EER 9.5 EER and Higher

2004 9.71 0.04 11.2 88.8

2003 9.75 0.03 9.0 91.0

2002 9.75 0.02 12.4 87.6

2001 9.63 0.1 13.8 86.0

2000 9.3 14.2 34.2 51.5

1999 9.07 26.9 41.4 31.7

1998

1997 9.09 16.7 47.3 36.0

1996 9.08 16.0 49.3 34.7

1995 9.03 19.3 51.9 28.8

1994 8.97 24.1 50.9 25.0

1993 9.05 24.8 55.3 19.9

1992 8.88 24.6 58.1 17.3

1991 8.8 27.5 57.2 15.3

1990 8.73 28.9 58.3 12.8

1980 7.02 88.6 9.3 2.1

3.11 MARKET SATURATION

AHAM’s Fact Book 2005 presents the market saturation for residential clothes dryers and

room air conditioners. Table 3.11.1 presents the appliance saturation and percentage of U.S.

households with each product as reported in the AHAM Fact Book 2005. The number of U.S.

households with each product is based on U.S. Census Bureau projections of occupied units in

the relevant year. The saturation of gas dryers as a percentage of households has remained

constant since 2001, while the saturation of electric dryers has increased. Conversely, the

saturation of room air conditioners as a percentage of households has decreased somewhat since

1990.

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Table 3.11.1 Appliance Saturation (Number in Millions and Percentage of U.S. Households

with Product) 36

Product

1970 1982 1990 2001 2005

# % # % # % # % # %

Dryers, Electric 18.6 29.3 42.3 50.6 56.1 60.1 61.8 59.3 67.6 62.1

Dryers, Gas 7.8 12.3 12.3 14.7 19.1 20.5 19.8 19 20.7 19

Room Air

Conditioners 16.9 25 22.6 27 30.2 32.4 26.9 25.8 27.4 25.2

3.12 PRODUCT RETAIL PRICES

Table 3.12.1 presents the average retail prices of residential clothes dryers and room air

conditioners for select years between 1980 and 2002. The retail prices presented in nominal

dollars are obtained from the AHAM Fact Book 2003. To adjust these prices to constant 2002

dollars, the values are scaled by the annual U.S. city average Consumer Price Index (CPI),

published by the U.S. Department of Labor’s Bureau of Labor Statistics (BLS). Although retail

prices in nominal dollars for electric and gas clothes dryers have increased since 1980, the

increase has been at a slower rate than the CPI, so that in constant 2002 dollars the retail prices

have decreased. Prices of room air conditioners in both nominal and 2002 dollars have

decreased in the same time period.

Table 3.12.1 Residential Appliance Retail Prices37

Product

Average Retail Prices

(Nominal $)

Average Retail Prices

(2002$)

1980 1994 2002 1980 1994 2002

Electric Clothes Dryers 286 327 396 624 397 396

Gas Clothes Dryers 315 325 467 688 395 467

Room Air Conditioners 372 351 322 812 426 322

DOE used the consolidated room air conditioner database developed for the energy

efficiency analysis in section 3.15.3.2 to produce a more recent overview of the retail prices. The

prices shown represent retail prices offered by a wide variety of retailers and internet

distributors. The prices reflected information collected in August 2008.

Figure 3.12.1 and Figure 3.12.2 show the retail price versus cooling capacity of each

room air conditioner listed in the databases, shown separately for product class groups 1­5 and 6­

10. There is a definite positive trend in cost for both of the graphs, however, the range of prices

at a given capacity is much wider for product classes 1 through 5. The second graph shows that

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there are a limited number of products in the product class 6 through 10 group with capacities

higher than 15,000 Btu/h. This represents primarily product classes 9 and 10.

Figure 3.12.1 Retail Prices for Room Air Conditioners, Product Classes 1 through 5
 

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Figure 3.12.2 Retail Prices for Room Air Conditioners, Product Classes 6 through 10

Figure 3.12.3 through Figure 3.12.8 show the retail price as a function of EER for the

room air conditioners in the consolidated database, specifically for the product classes analyzed

in detail in the engineering analysis (product classes 1, 3, 5, and 8). The figures show

concentrations of products at the baseline and ENERGY STAR efficiency levels. Figure 3.12.3

shows an approximate $50 price increment for those units in product class 1 with an ENERGY

STAR rating. However, there are not strong trends of price as a function of EER observed for

product classes 3, 5, and 8.

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Figure                    3.12.3 Retail Price versus EER for Product Class 1
 

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Figure                  3.12.4 Retail Price versus EER for Product Class 2
 

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Figure 3.12.5 Retail              Price versus EER for Product Class 3
 

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Figure 3.12.6 Retail              Price versus EER for Product Class 4
 

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Figure 3.12.7 Retail              Price versus EER for Product Class 5
 

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Figure 3.12.8 Retail Price versus EER for Product Class 8

3.13 INDUSTRY COST STRUCTURE

DOE developed the household appliance, household laundry, and air­conditioning and

warm air heating and commercial/industrial refrigeration equipment industries cost structures

from publicly available information from the ASM (Table 3.13.1 through Table 3.13.6) and from

the Securities and Exchange Commission (SEC) 10­K reports filed by publicly owned

manufacturers (summarized in Table 3.13.7). Table 3.13.1 presents the home appliance industry

employment levels and earnings from 1994–2006. The statistics illustrate a steady decline in the

number of production and non­production workers in the industry.

Because the ASM expresses all dollar values in constant 2006 dollars, the following table

shows that as industry employment levels decline, the industry payroll is also decreasing. The

percent decrease in total industry employees tracks closely with the percent decrease in payroll

for all employees.

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Table 3.13.1 Household Appliance Industry Employment and Earnings 38

Year

Production Workers

(‘000)

All Employees

(‘000)

Payroll for All Employees

(2006$ Mil)

2006 60.0 69.7 2,644.0

2005 64.3 76.9 2,788.3

2004 69.4 83.7 3,068.8

2003 71.0 85.3 3,146.5

2002 73.5 88.8 3,334.1

2001 76.6 92.6 3,497.5

2000 82.7 99.5 3,815.2

1999 82.3 97.9 3,691.2

1998 82.4 99.5 3,716.3

1997 79.8 97.2 3,547.4

1996 87.1 108.1 3,798.1

1995 88.9 110.8 3,860.6

1994 90.4 110.4 3,846.0

Table 3.13.2 presents the employments levels and earnings for just the household laundry

portion of the appliance industry. Statistics for both employment levels and payroll show a

steady fluctuation over the past 13 years, with payroll and employment levels again showing a

positive correlation.

Table 3.13.2 Household Laundry Industry Employment and Earnings 39

Year

Production Workers

(‘000)

All Employees

(‘000)

Payroll for All Employees

(2006$ Mil)

2006 12.4 14.1 571.5

2005 12.6 14.5 532.3

2004 12.9 15.1 586.4

2003 13.1 15.5 623.9

2002 13.5 15.9 687.6

2001 12.8 14.9 613.0

2000 13.3 15.5 660.1

1999 14.0 15.9 657.0

1998 14.3 16.7 679.8

1997 12.9 14.8 583.9

1996 12.9 15.7 619.5

1995 12.9 16.3 656.4

1994 12.9 16.2 690.7

Table 3.13.3 shows the employment levels and payroll for the air conditioning and warm

air heating and commercial/industrial refrigeration equipment industry. Industry statistics show a

steady decrease in the levels of employment and payroll, and the same correlation between these

parameters as seen in the appliance industry.

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Table 3.13.3 Air­Conditioning & Warm Air Heating & Commercial/Industrial

Refrigeration Equipment Industry Employment and Earnings 40

Year

Production Workers

(‘000)

All Employees

(‘000)

Payroll for All Employees

(2006$ Mil)

2006 74.9 98.1 4,021.1

2005 75.9 102.2 4,053.1

2004 73.1 99.0 3,914.2

2003 77.5 104.7 4,118.5

2002 80.4 108.3 4,249.9

2001 89.0 118.9 4,476.8

2000 98.0 127.4 4,952.5

1999 95.9 124.0 4,793.9

1998 92.0 120.0 4,624.6

1997 91.0 119.4 4,474.4

1996 104.0 134.9 5,539.7

1995 103.2 134.8 5,419.2

1994 99.1 130.6 5,275.2

Table 3.13.4 presents the costs of materials and industry payroll as a percentage of value

of shipments from 1994–2006. The cost of materials as a percentage of value of shipments has

fluctuated slightly over the 13­year period. DOE notes that fluctuations in raw material costs are

common from year to year. The cost of payroll for production workers as a percentage of value

of shipments has declined since 2000. Similarly, the cost of total payroll as a percentage of value

of shipments has declined since 2000.

Table 3.13.4 Household Appliance Industry Census Data41

Year

Cost of Materials as a

Percentage of Value of

Shipments (%)

Cost of Payroll for

Production Workers as a

Percentage of Value of

Shipments (%)

Cost of Total Payroll

(Production + Admin.) as a

Percentage of Value of

Shipments (%)

2006 57.9 8.4 10.9

2005 56.9 8.3 11.0

2004 57.2 9.0 12.1

2003 55.9 9.2 12.5

2002 54.9 9.7 13.4

2001 56.8 10.1 13.8

2000 55.8 10.2 14.0

1999 54.7 10.2 13.9

1998 56.0 10.0 13.7

1997 52.8 9.9 13.6

1996 56.8 9.9 13.9

1995 57.7 9.4 13.7

1994 55.5 9.2 13.1

Table 3.13.5 shows the cost of materials and industry payroll as a percentage of value of

shipments for the household laundry industry. DOE observed a decline in both the cost of

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materials and payroll as a percentage of value of shipments from 1996–2006. Table 3.13.6 shows

similar statistical trends for the air conditioning and warm air heating and commercial/industrial

refrigeration equipment industry, with decreases in percentages of both cost of material and

payroll.

Table 3.13.5 Household Laundry Industry Census Data 42

Year

Cost of Materials as a

Percentage of Value of

Shipments (%)

Cost of Payroll for

Production Workers as a

Percentage of Value of

Shipments (%)

Cost of Total Payroll

(Production + Admin.) as a

Percentage of Value of

Shipments (%)

2006 61.2 9.0 11.1

2005 52.5 7.8 9.9

2004 52.5 8.5 11.1

2003 56.0 9.4 12.3

2002 56.6 10.4 14.2

2001 56.2 9.2 11.9

2000 54.2 9.7 12.9

1999 51.4 10.0 12.7

1998 54.5 10.3 13.3

1997 56.1 10.6 12.9

1996 64.4 10.6 13.5

1995 62.3 10.5 14.7

1994 63.4 10.4 14.6

Table 3.13.6 Air Conditioning & Warm Air Heating & Commercial/Industrial

Refrigeration Equipment Industry Census Data43

Year

Cost of Materials as a

Percentage of Value of

Shipments (%)

Cost of Payroll for

Production Workers as a

Percentage of Value of

Shipments (%)

Cost of Total Payroll

(Production + Admin.) as a

Percentage of Value of

Shipments (%)

2006 53.2 8.9 13.8

2005 55.3 8.7 14.1

2004 53.3 9.2 14.8

2003 52.5 9.9 16.0

2002 51.3 10.2 16.5

2001 54.8 10.3 16.5

2000 56.3 10.7 17.0

1999 55.9 10.2 16.1

1998 58.1 10.5 16.3

1997 56.7 10.6 16.8

1996 62.0 12.0 17.6

1995 62.7 12.3 18.1

1994 59.5 12.4 18.3

Table 3.13.7 presents the industry cost structure derived from SEC 10­K reports of

publicly­owned home appliance manufacturers which produce residential clothes dryers and

room air conditioners. DOE averaged the financial data from 2002–2007 of several companies to

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obtain an industry average. Each financial statement entry is presented as a percentage of total

revenues.

Table 3.13.7 Industry Cost Structure Using SEC Data

Financial Statement Entry Percent of Revenues

(%)

Cost of sales 81.3

Net income 1.7

Selling, general and administrative 12.8

Capital expenditure 3.3

Research and development 2.3

Depreciation and amortization 3.3

Net plant, property and equipment 18.7

Working capital 1.6

Figure 3.13.1 presents the industry­average gross margin over the period from 2002–

2007 for the same manufacturers from which the industry cost structure is derived. The slope of

the curve indicates the downward cost pressure facing manufacturers.

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

Industry Average Gross Margin

2002 2003 2004 2005 2006 2007

Figure 3.13.1 Industry Gross Margin Derived from SEC Data

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3.14 INVENTORY LEVELS AND CAPACITY UTILIZATION RATES

Table 3.14.1 through Table 3.14.3 shows the year­end inventory for the household

appliance, household laundry, and air conditioning and warm air heating and

commercial/industrial refrigeration equipment industries, according to the ASM. Both in dollars

and as a percentage of value of shipments, the end­of­year inventory for these industries has

steadily declined since 1995. This data illustrates that domestic manufacturers are retaining less

of their inventories each consecutive year.

Table 3.14.1 Household Appliance Industry Census Data44

Year

End­of­Year Inventory

(2006$ Mil)

End­of­Year Inventory as a

Percentage of Value

of Shipments (%)

2006 1,688.5 7.0

2005 1,681.3 6.6

2004 1,853.4 7.3

2003 1,857.9 7.4

2002 1,997.2 8.1

2001 2,223.1 8.8

2000 2,511.9 9.2

1999 2,503.3 9.4

1998 2,698.4 10.0

1997 2,592.9 10.0

1996 2,842.7 10.4

1995 3,139.5 11.1

1994 3,252.8 11.1

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Table 3.14.2 Household Laundry Industry Census Data45

Year

End­of­Year Inventory

(2006$ Mil)

End­of­Year Inventory as a

Percentage of Value

of Shipments (%)

2006 304.9 5.9

2005 223.3 4.2

2004 204.1 3.9

2003 229.5 4.5

2002 258.1 5.3

2001 300.4 5.8

2000 279.5 5.4

1999 427.1 8.3

1998 435.4 8.5

1997 447.7 9.9

1996 428.9 9.4

1995 410.0 9.2

1994 439.2 9.3

Table 3.14.3 Air Conditioning & Warm Air Heating & Commercial/Industrial

Refrigeration Equipment Industry Census Data46

Year

End­of­Year Inventory

(2006$ Mil)

End­of­Year Inventory as a

Percentage of Value

of Shipments (%)

2006 2,887.7 9.9

2005 2,755.1 9.6

2004 2,627.2 10.0

2003 2,586.8 10.0

2002 2,564.2 9.9

2001 2,928.2 10.8

2000 3,480.5 11.9

1999 3,497.2 11.8

1998 3,172.9 11.2

1997 3,137.0 11.8

1996 3,795.0 12.0

1995 3,821.6 12.8

1994 3,627.5 12.6

DOE obtained full production capacity utilization rates from the U.S. Census Bureau,

Survey of Plant Capacity from 1994 to 2006. Table 3.14.4 presents utilization rates for various

sectors of the household appliance industry. Full production capacity is defined as the maximum

level of production an establishment could attain under normal operating conditions. In the

Survey of Plant Capacity report, the full production utilization rate is a ratio of the actual level of

operations to the full production level. The full production capacity utilization rate for household

appliances in aggregate, along with the rates for household laundry appliances, show a decrease

in utilization from 1994 to 2006, although trends in subsets of that time period have fluctuated.

Full production capacity utilization rates for air conditioning and warm air heating and

commercial/industrial refrigeration equipment have remained relatively steady over the period

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from 1996 to 2006. Prior to 1996, reported data did not disaggregate these types of equipment

from more general heating and refrigeration equipment.

Table 3.14.4 Full Production Capacity Utilization Rates47

Year

Rates (%)

Household

Appliances Household Laundry

Air Conditioning & Warm Air Heating &

Commercial/Industrial Refrig. Equip.

2006 77 80 63

2005 74 79 66

2004 76 77 60

2003 78 85 62

2002 72 87 60

2001 70 90 59

2000 70 88 66

1999 75 87 67

1998 73 75 67

1997 73 80 66

1996 76 81 NA*

1995 79 83 NA*

1994 82 89 NA*

* Data not available at this level of disaggregation

3.15 TECHNOLOGY ASSESSMENT

This section provides a technology assessment for residential clothes dryers and room air

conditioners. Contained in this technology assessment are details about product characteristics

and operation (section 3.15.1), an examination of possible technological improvements for each

product (section 3.15.2) and a characterization of the product efficiency levels currently

commercially available (section 3.15.3).

3.15.1 Product Operations and Components

In preparation for the screening and engineering analyses, DOE prepared a brief

description of the characteristics and operation of each product covered by this rulemaking.

These descriptions provide a basis for understanding the technologies used to improve product

efficiency.

3.15.1.1 Residential Clothes Dryers

Residential clothes dryers are appliances designed to dry clothes by tumbling the load in

a heated drum to remove moisture by means of evaporation. Because a horizontal axis of rotation

is required to create the tumble action, residential clothes dryers are generally front­loading.

Front­loading clothes dryers have an opening on the front of the unit, covered by a door, which

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gives access to an inner cylindrical drum where the load to be dried is placed. The inner drum is

perforated and is surrounded by a larger outer housing which collects the moisture­laden air. The

clothes dryer uses electricity to power an electric motor that rotates the drum within the housing,

which is contained inside a cabinet. Vanes and/or surface textures may be incorporated into the

inner surface of the drum to facilitate separation of the clothing to expose surface areas for

drying.

Air is drawn through the drum by means of an electrically driven blower. This air stream

is heated prior to entering the drum in order to evaporate the moisture in the clothing with which

the air comes in contact. Heating may be provided by an electrically energized resistive element.

Alternatively, hot air in the drum may be supplied by means of a gas burner system whose

combustion products are directed into the drum by the electrically powered blower.

In the case of vented clothes dryers, the moisture­laden air is exhausted from the drum

through a length of ducting, and as it exits, freshly heated room air is drawn in. The exhaust air is

typically vented to an exterior location due to its high temperature and relative humidity. In

installations where exterior venting is not possible, a vent­less system may be used in which the

moist air in the drum is routed through an air­ or water­cooled heat exchanger. The water vapor

condenses on the heat exchanger surface where it is either collected in a removable container for

disposal by the user or discharged into a drain line. Vent­less systems may either open­loop, in

which the relatively dry air from the drum is exhausted into the room, or closed­loop, in which

the dry air is recirculated back to the heater and subsequently to the drum inlet. With an air­to­air

heat exchanger, the ambient air that was used to provide cooling is also discharged back into the

room at a slightly higher temperature due to the heat transfer from the condensing water.

Because the exhaust products from gas combustion systems contain a significant amount of

moisture and varying levels of hazardous emissions such as carbon monoxide, vent­less clothes

dryers are all electrically heated. Tradeoffs associated with vent­less versus vented dryers

include greater flexibility in installation but longer drying times. In addition, for air­to­air

systems, space conditioning loads may be increased due to the discharge of warm dry air to

ambient. This may be offset, however, by the fact that conditioned ambient air is not being

discharged to the exterior, as would be the case for a vented unit.

Combination washer/dryers combine clothes washing and drying functions in the same

front­loading tub. The wash and dry cycles are performed in sequence. Since the washing

function requires a drain hookup, and because these units are often installed where space is at a

premium and outside access might not be available, all combination washer/dryers currently on

the market utilize condensation drying. In addition, a water­cooled heat exchanger is made

possible due to the water hookup already in place for the washing.

3.15.1.2 Room Air Conditioners

Room air conditioners are portable, refrigeration­based appliances that enable users to

cool or warm an enclosed space, room, or zone. In addition to the primary cooling or warming

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function, room air conditioners also reduce the relative humidity (RH) of the conditioned space.

RH is defined as the amount of water vapor present in the air compared to the maximum amount

of water vapor the air can hold at that temperature. Although they are portable, room air

conditioners are designed for semi­permanent installation in a window opening or opening in an

exterior wall. Room air conditioners are classified according to the amount of heat that can be

removed from the ambient air during a given time period, expressed in Btu/h.

Room air conditioners contain refrigeration systems that remove both sensible and latent

heat, and therefore moisture, from ambient air. The refrigerant­side and air­side components are

all contained within one cabinet. The refrigerant­side components include the evaporator (indoor

conditioning coil), the compressor, the condenser (outdoor coil), and the capillary tube. These

components are all connected via refrigerant tubing. The air­side components consist of the fan

motor, the evaporator blower, and the condenser fan. The cabinet containing both refrigerantside and air­side components is split into an indoor and outdoor side. An insulated divider wall

separates the two sides and reduces the heat transfer between sides. The indoor components are

the evaporator and evaporator blower. The outdoor components are the compressor, condenser,

capillary tube, fan motor, and condenser fan. A single fan motor with a shaft which extends out

both ends is generally used to power both the evaporator blower and the condenser fan. The

motor is located on the outdoor side to isolate motor losses from the indoor side. The evaporator

blower shaft penetrates the insulated dividing wall.

Refrigeration­based room air conditioners operate as follows, illustrated in Figure 3.15.1:

1.	 The fan motor drives the evaporator blower and condenser fan simultaneously;

2.	 Warm ambient air from the room or space is drawn into the indoor side of the unit

across the evaporator coil, where latent and sensible heat is removed, and the cooled,

conditioned air is circulated back into the room by the evaporator fan;

3.	 The heat from the air vaporizes the refrigerant in the evaporator coil. The evaporated

refrigerant is compressed by means of the compressor;

4.	 The heated refrigerant is circulated through the condenser coil on the outside side of

the unit, wherein the vapor is cooled by outside air being drawn across the coil by

means of the condenser fan. This cools the vapor to saturation conditions and then

condenses the refrigerant.

5.	 The cooled liquid passes through the capillary tube, reducing its pressure. The

refrigerant flashes to a liquid/vapor mixture, and the temperature drops, consistent

with the pressure/temperature curve of saturated refrigerant. The two­phase

refrigerant re­enters the evaporator and the cycle is repeated.

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Source: Friedrich CP10E10 Service and Parts Manual48

Figure 3.15.1 Room Air Conditioner Operation Schematic

3.15.2 Technology Options
 

In order to gain a deeper understanding of the technological improvements used to

increase the efficiency of residential clothes dryers and room air conditioners, DOE identified

several possible technologies and examined the most common improvements used in today’s

market.

3.15.2.1 Residential Clothes Dryers

For clothes dryers, DOE will consider technologies identified in the November 1994

ANOPR (59 FR 56423), supplemented by technologies described in recent trade publications,

research reports, and manufacturer product offerings. DOE took the technologies listed below

(Table 3.15.1)—with exceptions noted below—from the November 1994 ANOPR. DOE took the

modulating gas dryer technology from an April 2005 report by TIAX LLC (TIAX).49

Additionally, DOE’s preliminary market research indicated the availability of hydronically

heated clothes dryers, so DOE has decided to include them in the clothes dryer heat generation

technologies, but notes that significant revisions to the clothes dryer test procedure would be

required to accommodate them. Specifically, DOE would have to incorporate a number of

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assumptions about the efficiency of the heat generation source used with these dryers. Improved

air circulation, motor efficiency, and fan efficiency were added as technology options based on

comments received during the Framework Document public meeting for this rulemaking held

October 24, 2007 as well as submitted written comments in response to the framework

document. DOE also added technology options for reducing standby power, including switching

power supplies and transformerless power supplies with auto­powerdown, based on its reverse

engineering analyses.

Table 3.15.1 Technology Options for Residential Clothes Dryers

Dryer Control or Drum Upgrades

1. Improved termination

2. Increased insulation

3. Modified operating conditions

4. Improved air circulation

5. Reverse tumble

6. Improved drum design

Methods of Exhaust Heat Recovery (Vented Models Only)

7. Recycle exhaust heat

8. Inlet air preheat

9. Inlet air preheat, condensing mode

Heat Generation Options

10. Heat pump, electric only

11. Microwave, electric only

12. Modulating Heat

13. Water­cooling, vent­less electric only

14. Indirect heating

Component Improvements

15. Improved motor efficiency

16. Improved fan efficiency

Standby Power Improvements

17. Switching Power Supply

18. Transformerless Power Supply with Auto­Powerdown

The technology options for residential clothes dryers can be broadly grouped into five

main categories: dryer control or drum upgrades, methods of exhaust heat recovery (for vented

models only), heat generation options, improvements to components, and options to reduce

standby power.

Improved termination

The standard dryer is assumed to use a timed drying cycle, which automatically turns off

the dryer after a user­specified time interval. With automatic termination by temperature sensing,

an exhaust air temperature sensor controls the length of the drying cycle. With automatic

termination by moisture sensing, the moisture content of the clothes in the dryer is determined by

sensors that measure conductivity along with an exhaust air temperature sensor. When the

moisture content is reduced to a level at which these sensors cannot measure accurately

(generally around 15 percent RMC) a countdown timer is started. After a pre­specified time

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period that is set by the manufacturer, the cycle terminates. Manufacturers indicated in

discussions with DOE that moisture sensing with electromechanical controls increase the

accuracy above automatic termination using only temperature sensors. Manufacturers stated that

moisture sensing with electronic controls further improves the accuracy of automatic

termination.

One method to improve automatic termination via moisture sensing is to improve the

accuracy of the conductivity sensors at low levels of RMC. This can be done by increasing the

contact area between the sensor and the clothing, as achieved by one manufacturer by including

slip rings in the drum design. An adjustable gain control can also be used in the electronics to

improve the sensitivity; however, this adds significant cost and reliability issues. A second

method to improve automatic termination is to improve the accuracy of end­of­cycle detection.

One manufacturer has indicated preliminary energy savings of up to 17 percent through timer

controls based on new dryer process modeling.50

The test procedure for dryers allows an energy credit of 12 percent for either temperature

or moisture sensing relative to time control to terminate drying. There has been some

controversy as to whether the use of moisture sensors reduces energy consumption relative to

temperature sensors. A number of sources claim that temperature sensing controls provide 10

percent real­world energy savings, whereas moisture sensing controls provide 15 percent energy

savings.51 Based on field measurements conducted by one manufacturer for the previous

rulemaking, it appears that the test procedure credits are appropriate.

Increased insulation

During the drying cycle some parts of the dryer are warmer than the ambient air.

Insulating the dryer drum reduces the heat lost through conduction, convection, and radiation to

the surrounding air. During the previous rulemaking, two dryer manufacturers reported an energy

savings of about 2 percent from the addition of 1 inch of fiberglass insulation around the dryer

drum. Computer simulations performed by other researchers with a thermal model showed a 6

percent energy savings.52 However, in recent discussions with DOE, manufacturers indicated that

there is little to no efficiency improvement associated with adding insulation.

There is concern that the insulation would eventually degrade, resulting in fiberglass

particles being drawn into the drum and onto the clothes because dryer air circulation systems

operate with a negative air pressure in the drum relative to the outside. These particles can cause

skin irritation. Potential material substitutions for fiberglass include polystyrene, polyethylene, or

polyurethane foam insulation. They have similar or lower thermal conductivities and do not

cause skin irritation.

Modified operating conditions

Reducing air flow and/or heat input rate changes the efficiency of the drying process.

Manufacturers may select operating points which match the dryer cycle time to the washer cycle

time. From an efficiency standpoint, these settings do not necessarily lead to optimum dryer

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operation. By decreasing the air flow rate, the air temperature in the drum, and thus the

evaporating rate, increases and results in better energy efficiency. Energy savings of as much as

8 percent have been shown for tests with reduced air flow rates and electric heater inputs, but the

drying time increased from about 40 to 55 minutes. Tests by the same researchers with only

reduced heater input (3.3 kW instead of 4.55 kW) yielded no energy savings and increased the

drying time from 40 to 56 minutes. For a very low heater input (1.25 kW), energy savings of

around 5 percent were achieved, but the drying times were very long (112 minutes).53

Improved air circulation

One manufacturer of commercial clothes dryers has claimed that designing the drum to

improve airflow (i.e,. directing and maintaining heat more efficiently) decreases the energy use

while maintaining the drying performance.n However, DOE is unaware of any data quantifying

the energy savings associated with improved air circulation.

DOE noted that air flow through the drum in conventional dryers is generally directed

from the rear to the front of the drum. Based on discussions with a number of manufacturers, a

small efficiency improvement, between 1 and 2 percent, can be achieved by changing the air

flow in the drum such that the air flows in through one side on the rear of the drum, and exits on

the other side of the rear of the drum.

Dryer booster fans can be installed to increase the airflow in clothes dryers, which

conceivably increases the rate of forced convection. In cases of long exhaust ducting where the

static pressure that must be overcome by the dryer fan is increased, incorporating a dryer booster

can increase the airflow and thus increase drying capacity and reduce energy consumption of the

clothes dryer. However, the current DOE clothes dryer test procedure uses an exhaust simulator

with a standard length and geometry and does not account for alternate installation conditions.

DOE is unaware of any data quantifying the energy savings associated with dryer booster fans.

Reverse tumble

Reverse tumble drying spins the drum in both the clockwise and counter­clockwise

directions. This action is typically carried out at the end of the cycle in order to reduce the

amount of wrinkling and tangling of the clothes. However, it is possible to reverse rotational

direction earlier in the cycle to increase the separation of clothing and thus dry the clothes load

more quickly and evenly. In the description of a patented reverse tumbling method, it is claimed

that a 10 percent reduction in drying time, and thus energy consumption, could be achieved.54 In

addition, reversing the drum rotation can prevent “balling” of large items such as sheets, which

restricts air flow to the center of the item and requires longer drying times. Tests conducted by

one manufacturer, however, found that the small size of the test cloths in the DOE test procedure

prevents balling and thus no energy efficiency benefit can be measured.55 Manufacturers also

noted in discussions with DOE that reverse tumble does not improve efficiency, and in some

cases can reduce efficiency when the drum is not rotating while it is changing directions.

n For more information visit www.amdry.com/resources/products/450264%20Solaris%206_06_final.pdf

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Improved drum design

The intrinsic energy efficiency of a clothes dryer can be affected by the design of the

drum, including the internal vane design.56 Optimized vane design promotes clothing separation

during tumbling, which can reduce drying times. According to some manufacturers, the surface

texture of the drum can also enhance clothing separation. Manufacturers noted that such designs

are performance related features to ensure gentle handling of delicate clothing, but conceivably

the improvements in clothes separation and aeration could shorten drying times as well.

However, DOE is unaware of any data quantifying potential energy efficiency improvements

associated with improved drum design.

Recycle exhaust heat

It is estimated that about 20–25 percent of total heat input energy is lost through the dryer

vent. For the recycle exhaust heat technology option, a portion of the exhaust air stream is

reintroduced at the dryer air inlet. This recovers a portion of the energy in the exhaust air stream

and reduces the energy needed to raise the inlet air to drying temperatures. The exhaust air

suitable for direct recovery would be available only late in the drying cycle when most of the

moisture is evaporated and the air temperature rises. Therefore, the realizable energy savings are

significantly less than the theoretical maximum of about 20 percent. The estimated energy use

reduction for this technology option is 6 percent.

Recycling of exhaust air late in the dryer cycle can be accomplished using extra duct

work and mechanical air diverters; however, it presents several technical problems. There is the

potential for lint accumulation in the duct work and on the clothes. Recycling of exhaust air

could present a potential fire hazard since some large pieces of lint could enter the heated area.

For a gas dryer, there is also a potential inability to promote satisfactory combustion.

Experiments performed with a 230 V electric dryer (with a baseline energy use of over

3.0 kWh/cycle) showed that energy savings ranged from 10 to 18 percent, depending on the

fraction of exhaust air recirculated.57 A fine nylon­mesh filter was installed to minimize the

amount of recirculated lint. These energy savings are greater than one would expect given the

large quantity of moisture in the exhaust early in the cycle. Additionally, the National Institute of

Standards and Technology (NIST) testing indicated savings ranged from 3 to 6 percent for this

option.58

Inlet air preheat

For this technology option, a heat exchanger is used to recover exhaust heat energy and to

preheat inlet air. This system should be feasible for both gas and electric dryers since none of the

exhaust air re­enters the dryer. Energy savings are achieved either by a faster drying time or by

reducing the required heater input power. A number of researchers have investigated this

technology option for clothes dryers. One manufacturer has estimated 2 to 3 percent energy

savings, while NIST estimated 3 to 6 percent.59 Both of the above experiments were carried out

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in the non­condensing mode. That is, moisture in the exhaust air was not condensed, which

limited the maximum heat recovery.

A limitation of this technology option is that a large surface area is required to achieve

sufficient heat transfer, and that lint may accumulate on these heat transfer surfaces. Although

every dryer is equipped with a lint filter, considerable lint is still contained in the exhaust air.

This lint can foul the heat exchanger, decreasing its effectiveness. Additionally, to overcome the

increased resistance to air flow, an extra blower is needed at the fresh air inlet or a stronger

blower in the exhaust air duct is required.

Manufacturers have also expressed concern that any decrease in exhaust temperature will

lead to moisture condensation in the exhaust duct, which could result in damage to the exhaust

duct and dryer, as well as water leakage into the home. Water leakage into the home could lead

to the health risks from the development of mildew and/or mold.

Inlet air preheat, condensing mode

Dryers have been manufactured both in the United States and Europe that utilize a

condenser to capture some of the sensible and latent heat in the exhaust air stream. For this

technology option, heat energy from the exiting air is transferred, using a heat exchanger, to the

cooler incoming air. If the effectiveness of the heat exchanger is high enough, the water vapor in

the exhaust air will condense. Therefore, more heat energy is transferred than in a sensible heat

exchanger system as described above. In Europe, condenser dryers have been used in an open

system to supply space heat during the winter. In the United States, they have been used to avoid

the need for vents in apartments. Research has shown that compared to a conventional air vented

dryer, an open­cycle condensing dryer is about 14 percent more efficient and a closed­cycle

condensing dryer is 7 percent more efficient.60 Manufacturers have indicated that only minimal

(1 to 3 percent) efficiency improvement can be achieved with inlet air preheat.

Manufacturers have identified several problems with this technology option: 1) a drain

for the moisture is required; 2) lint accumulation on the heat exchanger reduces the heat transfer

efficiency; and 3) lint can accumulate and clog the drain. Because a drain is required to be

installed, and humid operating conditions require extensive use of stainless steel or glass in the

heat exchanger to avoid corrosion, manufacturer cost for this technology option will be greater

than for the inlet air preheat with a sensible heat exchanger.

An alternative approach to capture heat from the exhaust air stream is to mechanically

compress the exhaust air to extract water vapor and transfer the latent heat to the remaining

gaseous steam. The extracted water is drained from the compression chamber, and the

pressurized gaseous steam is allowed to expand and be superheated before being injected back

into the drum to help preheat the inlet air. Researchers have claimed that such a compression

condenser dryer is as energy efficient as a heat pump dryer, but has almost half the cycle time

and requires fewer specialized components.61

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Heat pump, electric only

Heat pump dryers function by recirculating the exhaust air back to the dryer while

moisture is removed by a refrigeration­dehumidification system. A heat pump dryer is essentially

a dryer and an air conditioner packaged as one appliance. No heating element is needed. The

warm and damp exhaust air of the dryer enters the evaporation coil of the dehumidifier where it

cools down below the dew point, and sensible and latent heat are extracted. The heat is

transferred to the condenser coil by the refrigerant and reabsorbed by the air, which is moving in

a closed air cycle. A drain is required to remove the condensate; however, one is usually

available since clothes washers and dryers are typically located side by side. Heat pump dryers

have been unable to penetrate the market despite showing significant energy savings (in some

cases over 50 percent compared to electric resistance dryers), even in Europe, where they have

been in existence for years. Based on a recent study, heat pump dryers had a market share of only

0.3 percent in Western Europe in 2005.62 The major issue for heat pump dryers has been cost and

performance. Heat pump dryer dry times are typically significantly longer than those associated

with standard U.S. electric dryers.

A heat pump dryer has been developed by a U.S. company which has successfully tested

several prototypes and found energy savings of 68 percent as compared to energy use by a

conventional electric clothes dryer. The estimated retail cost is approximately twice that of a

conventional electric dryer. Drying times were essentially the same as for the conventional dryer,

and the dryer operates on standard 120 V line power. The prototype uses a disposable filter to

reduce lint in the air system. One inch of polyisocyanurate insulation was used to avoid

condensation of water vapor in the recirculated air. In addition, the extension on the back of the

prototype dryer to accommodate the added refrigeration components was estimated to be about

the same depth as a vent duct, so the cabinet may fit in the same space as a conventional dryer.

More maintenance will probably be required for a heat pump dryer than for a

conventional dryer. The heater is replaced by equipment found in a small room air conditioner—

a condenser, evaporator, compressor, expansion valve, etc. Installation costs, though, may be less

than for a conventional electric dryer because the heat pump dryer does not require an exhaust

vent as does a conventional dryer (although some heat pump dryers may still use a vent).

However, heat pump dryers require access to a drain for removal of condensate.

Research conducted on both heat pump dryers and conventional vented dryers on the

European market showed that heat pump dryers consumed about 50 percent less energy than

conventional dryers. The heat pump dryers tested had energy efficiency values between 0.32 and

0.40 kWh/kg laundry (with 70 percent initial moisture, measured according to test standard EN

61121) whereas conventional dryers had values between 0.6 and 0.8 kWh/kg laundry. Another

benefit noted by this research was that the leakage of water vapor into the room was around 20

percent, which is significantly lower than conventional dryers. This research performed a cost

comparison of heat pump dryers versus conventional dryers, which showed that the combined

sale price and electricity costs over 15 years was about 1900 and 2300 Euros, respectively.63

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Research sponsored by TIAX and Whirlpool developed a high efficiency, highperformance heat pump clothes dryer for the U.S. market. This different approach to the heat

pump system maximized the output capacity and temperature from the heat pump. This design

has shown 40 to 50 percent energy savings on large loads along with 35 degree Fahrenheit (°F)

lower fabric temperatures and similar dry times. For delicate loads, the design reduced fabric

temperature by 10–30 °F and provide up to 50 percent energy savings and 30–40 percent drying

time savings. The heat pump dryer designed by TIAX also exhibited improved fabric

temperature uniformity as well as robust performance across a range of vent restrictions in a

partially open­loop design described below.64

In order to maximize the air inlet temperature and airflow into the dryer’s drum, TIAX

replaced the standard refrigerant, R­22, with R­134a in an R­22 air conditioner/heat pump

compressor, shifting evaporating and condensing temperatures by 30 °F while maintaining

similar operating pressures and power input. TIAX was also able to maximize the capacity of the

heat pump system by redesigning the heat exchanger components to optimize space utilization

and increasing the airflow in the system as compared to typical dryers.65

A key issue in the TIAX design was the venting options of the heat pump dryer. The

moisture in the air exiting the drum is removed by the evaporator. This air can then be

recirculated back into the drum, which removes the need for a vent. However, some form of heat

rejection is required since the heat pump generates more heat than cooling in steady state

operation. TIAX used a partially open­loop design in which a portion of the process air is vented

outdoors to remove excess heat. In this design, all of the process air is recirculated through the

dryer until the system has fully warmed, at which point the exhaust is opened and a portion of

the total flow is vented to the outside.66

Microwave, electric only

Microwave energy can be absorbed by water, thereby heating the water enough to cause

evaporation. This would be a direct and efficient manner to remove moisture from clothes.

Prototype microwave dryers have been built and tested. The previous rulemaking determined

that energy savings from the use of a microwave dryer would be approximately 26 percent

compared to a conventional dryers. The data was provided by a company developing a prototype

microwave dryer, and the developers claimed that the system could safely dry clothes with metal

buttons and zippers, although clothes with metallic threads could be damaged. Uniform drying is

also a problem since the microwaves may not reach the interior of the clothing container. The

prototype dryer described above utilized two magnetrons for delivering the microwave energy to

the drum.

Instead of the conventional method of passing warm air over the clothes, microwave

energy can be directly absorbed by water retained in the clothing, thereby heating the water

enough to cause evaporation. Microwave drying uses the principle of dielectric heating, in which

electromagnetic energy is radiated into the dryer drum where it is absorbed by water molecules

which have a higher dielectric loss factor than most common fabric materials. Most fabric

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materials are also relatively transparent to microwave energy, so that the microwaves can

penetrate the fabric’s interior to heat the water molecules directly. This allows the fabric in a

microwave dryer to stay cooler—below 115 °F—as compared to conventional dryers which heat

air to approximately 350 °F, with fabric surfaces reaching 150 °F. Microwave dryer prototypes

have been shown to consume about 17 to 25 percent less energy as well as to dry clothes about

25 percent faster than conventional electric dryers.67

Early conceptualization of this technology began in the mid­1960s; however, product

development was not pursued because of high manufacturing costs and difficulties in

overcoming hazards relating to arcing and overheating of clothing. In 1997, the Electric Power

Research Institute (EPRI) focused on developing a compact countertop dryer based on economic

feasibility and market surveys. EPRI market studies and the development of prototypes for inhouse evaluation have led to negotiations for technology licensing and indications of serious

product development for a residential microwave clothes dryer.68

Because of the interaction between the metallic sensor contacts and the electromagnetic

field, microwave dryers are incapable of using contact moisture sensors as in conventional

dryers. EPRI investigated using sensors to detect the microwave electric field strength and the

fabric temperature, which both correlate well with the moisture content. As evaporation nears

completion, both measured signal slopes begin to rise in a predictable manner, so that the dryer

can be shut off automatically and avoid wasted energy in over­drying clothes.69

Microwave drying also introduces a safety concern related to arcing. Arcing is caused by

an electric field which induces a voltage differential between metal objects, allowing current to

flow within them. The resultant heating and sparking of the metal objects may ignite a fire in the

load. EPRI has developed a rapid­response gas sensor to detect small amounts of gaseous byproducts of combustion in the exhaust stream. Upon detection, the drying cycle can be shut down

immediately, preventing safety hazards and damage. Another technique to avoid arcing is to

switch to electric resistance heaters when the clothes are almost dry.70

Modulating Heat

Most gas dryers on the market operate with a single burner at a fixed input rate and a

fixed airflow rate in an on/off mode based on the cycle chosen and the temperature of the

exhaust flow. Based on a modulating gas dryer design jointly developed by TIAX and

Whirlpool, a reduction of energy consumption of up to 25 percent for small and medium loads

has been shown. For large loads, a reduction in energy consumption of 10–15 percent has been

shown as well as up to 35 percent drying time savings, with no adverse effect on cloth

temperature. For delicate loads, modulating gas dryers are able to reduce fabric temperatures as

well as dry times, achieving an 18 percent reduction of energy consumption. Along with these

performance characteristics, modulating gas dryers would provide robust performance across a

range of vent restrictions.71

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A key consideration in the design of a modulating gas dryer is matching the heat input

rate to the moisture level of the load. The design developed by TIAX used a maximum gas input

rate of 40,000 Btu/h using two inshot burners firing into a combustion chamber that was larger

than in a conventional gas dryer. The gas input rate was able to be modulated to three different

levels: (1) high (40,000 Btu/h), (2) medium (rate similar to conventional gas dryers), and (3) low

(rate less than half of a conventional gas dryer). The burners were positioned so that they fired

into an oval­shaped combustion funnel before turning upwards into the rear duct and entering the

drum. A downstream blower was used to induce airflow into the drum. A new funnel/collar/rear

duct was designed to deliver evenly distributed and improved air flow to increase efficiency,

while being able to be manufactured with minimal modifications to existing plant tooling.72

TIAX utilized a variable speed blower to deliver varying airflow rates to match the

following general dryer cycles: (1) heavy duty, (2) normal, and (3) delicate. In order to account

for airflow changes and resultant pressure drops associated with installation variations, the

system used a pressure switch in the exhaust flow stream from the dryer. The blower speed

would be increased at the beginning of the dry cycle until the pressure switch was tripped,

providing an indication of the level of exhaust restriction.73

Control of this system was achieved via a temperature and humidity sensor in the

exhaust. Since the flow rate would be known, the temperature in the exhaust would be used to

infer the amount of moisture inside the drum. The temperature signal would thus be used to

determine when to perform the first and second modulation steps. In addition, this temperature

signal, combined with the output from a humidity sensor in the exhaust, could be used to

determine the end of the cycle.74

Modulating heat can also be implemented in an electric clothes dryer. The electric

resistance heater could be accurately controlled by an electronic controller that incorporates a

bidirectional triode thyristors (Triacs) or similar solid­state approaches to control the heat output.

Water­cooling, vent­less electric only

For this technology option, an internal water­cooled condenser heat exchanger system

condenses the water vapor in the air exiting the drum. This design is similar to conventional

condenser heat exchanger systems used in clothes dryers in which the exhaust heat is recirculated

back to the dryer, except that the cooling fluid is water, not air. On the market in Australia,

water­cooled condensers are generally used in combination washer/dryers whereas air­cooled

condensers are used in stand­alone dryers. According to a report prepared for the Department of

the Environment and Water Resources in Australia, for combination washer/dryers using watercooled condensers, the amount of water required for condenser cooling can be as much or more

than as is used for the wash cycle.75 In addition, this technology option would require a drain for

the removal of condensate as well as plumbing to the supply water. DOE is unaware of any data

quantifying potential energy efficiency improvements associated with improved drum design.

Indirect heating

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For indirect heating, the clothes dryer heat energy is derived from the home’s heating

system. This technology option uses a residence’s hydronic heater system to heat water which

then flows through a heat exchanger in the dryer, heating the air entering the drum. Significant

plumbing would be required to circulate heated water through the heat exchanger in the dryer.

DOE is unaware of any data quantifying potential energy efficiency improvements associated

with indirect heating.

It is possible that a stand­alone hydronic heater could be implemented as a clothes dryers

heat source. One source claims that water or other heat transfer fluids could be heated using an

immersion element similar to a water heater. The heated fluid passes through a heat exchanger,

where the heat is transferred to the air entering the drum, and is then pumped back to the

hydronic heater. The source claims that a hydronic heating clothes dryer uses 50 percent less

energy and dries the clothing load up to 41 percent faster than conventional clothes dryers.76

Improved motor efficiency

Clothes dryers generally use a single motor which functions to turn the drum as well as to

power the blower in order to draw air through the drum and out the exhaust vent. The typical

clothes dryer uses a 1/3 horsepower four­pole induction motor. Based on DOE testing, about 5

percent of the total electrical energy consumed by a typical clothes dryer is used by the electric

motor to drive the drum and the blower. Manufacturers stated that improving the efficiency of

the motor can increase overall efficiency by 1 to 5 percent. Manufacturers also indicated that

using an electronically­commutated motor (ECM) is very expensive and provides minimal

efficiency improvement.

A number of manufacturers indicated that they use separate motors to drive the drum and

the blower fan with a permanent split capacitor motor or brushless permanent magnet motor in

some models in order to adjust air flow rates based on different exhaust vent installations to

improve performance. However, they indicated that because the DOE test procedure uses a

standard exhaust simulator (as indicated above), there would be no benefit to efficiency. DOE

believes that such a split motor design which can adjust air flow rates implemented designs such

as a modulating heater could conceivably improve efficiency.

Improved fan efficiency

Clothes dryers generally use an electrically driven fan blower to draw air through the

drum. Increasing the efficiency of this blower could reduce the clothes dryer energy

consumption. A blower fan with rear curved blades (as opposed to conventional forward curved

blades) could conceivably provide more consistent air flow and improve efficiency. However,

DOE is unaware of any data quantifying the potential energy efficiency improvements associated

with an improved blower fan, distinct from improvements in its drive motor.

Switching Power Supply

A potential area for standby power improvement is the power supplies on the control

board. A typical clothes dryer may use an unregulated plus regulated control board power supply

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(also referred to as a linear power supply). The unregulated portion consists of a small

transformer, a bridge rectifier, and an electrolytic capacitor. Voltage regulators then step down

the voltage(s) to the level(s) required by the control logic, display, and cooking sensor. This

approach results in a rugged power supply which is reliable, but typically has an efficiency of

about 55 percent.

Switching power supplies offer the highest conversion efficiencies (up to 75 percent) and

lowest no­load standby losses (0.2 W or less), though at a higher cost, higher part count, and

greater complexity. Switching power supplies convert power differently than conventional linear

power supplies. Switching power supplies first rectify the alternating current (AC) mains voltage

to direct current (DC), converting it back to AC by switching the current on and off at high

frequency. The high­frequency AC current passes through the primary winding of a transformer

while the output from the secondary winding of the transformer is rectified, resulting in a lowvoltage DC output. Because the AC current passing through the transformer is at high frequency,

the transformer is smaller and has lower standby losses. Switching power supplies greater

complexity may also result in lower overall reliability and take greater care to implement. For

example, among other issues, a switching power supply can be prone to causing electromagnetic

interference. However, DOE noted in its reverse engineering teardown analysis that there are a

large number of clothes dryers on the U.S. market that incorporate switching power supplies.

Transformerless Power Supply for Auto­Powerdown

DOE’s reverse engineering teardown analysis suggests that very low standby levels can

be achieved by implementing a transformerless power supply for the microprocessor logic, along

with a conventional power supply that is activated when the unit goes into active mode. Such a

power supply design, incorporated with a “soft” power pushbutton and triac to control power

through the transformer, would provide just enough power through the transformerless power

supply to maintain the microcontroller chip while the clothes dryer is not powered on. When the

power button is pressed, current would then be allowed to pass through the transformer of the

conventional power supply to power the remainder of the control board. DOE is unaware of any

data indicating the reliability of such a design.

3.15.2.2 Room Air Conditioners

For room air conditioners, DOE will consider technologies identified in its last

standards rulemaking that culminated in the September 24, 1997, final rule. 62 FR 50122. With

the exception of microchannel heat exchangers and hydrophilic­film coating on fins, DOE has

determined that the technologies listed in Table 3.15.2 have not changed appreciably since

DOE’s TSD was published in September 2007. With regard to microchannel heat exchangers,

research conducted at the University of Illinois has demonstrated that this technology can be

applied to room air conditioner applications.77 Hydrophilic­film coating on fins was identified in

an analysis of energy efficiency in Chinese room air conditioners conducted jointly by Lawrence

Berkeley National Laboratory, the China National Institute of Standardization (CNIS), and the

Beijing Energy Efficiency Center (BECon).78

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Table 3.15.2 Technology Options for Room Air Conditioners
 

Increased Heat Transfer Surface Area

1. Increased frontal coil area

2. Increased depth of coil (add tube rows)

3. Increased fin density

4. Add subcooler to condenser coil

Increased Heat Transfer Coefficients

5. Improved fin design

6. Improved tube design

7. Hydrophilic­film coating on fins

8. Spray condensate onto condenser coil

9. Microchannel heat exchangers

Component Improvements

10. Improved indoor blower and outdoor fan efficiency

11. Improved blower/fan motor efficiency

12. Improved compressor efficiency

Part­Load Technology Improvements

13. Two­speed, variable­speed, or modulating­capacity compressors

14. Thermostatic or electronic expansion valves

15. Thermostatic cyclic controls

Standby Power Improvements

16. Switching Power Supply

As shown in Table 3.15.2, design improvements to improve energy efficiency can be

categorized according the following five methods: increasing heat transfer performance by either

increasing heat transfer surface area or the heat transfer coefficients, improvements upon

individual components, part­load technology improvements, and standby power improvements.

Technology options that are intended to improve efficiency under cycling or part­load

conditions cannot be evaluated under the current DOE test procedure which specifies steadystate test conditions. Technology options such as variable speed compressors, electronic

expansion valves, and cyclic controls have been used in central air­conditioning systems. It has

been argued that the operating conditions central systems perform under are very different than

those experienced by room units. When room units are turned on, the room temperature is likely

to be high, thus reducing the amount of cycling as compared to central systems. In addition,

manufacturers have commented that room air conditioners have become a commodity item that

is typically undersized for the room in which it is installed, and thus operates only in on/off

mode. Therefore, the energy­savings benefits from technology options that reduce energy

consumption on a cyclic basis are less likely to affect the performance of room units.

Increased frontal coil area

One of the most common ways of increasing heat transfer surface area is by using a coil

with a larger frontal area. With a greater amount of coil face area, the heat transfer performance

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of the coil is increased. For the condenser, the required heat can be rejected from the refrigerant

to the outside air stream at a lower condensing temperature. For the evaporator, the specified

cooling capacity can be delivered to the room at a higher evaporator temperature. These changes

reduce the pressure difference between the low pressure and high pressure sides of the system

which the compressor must overcome, thus reducing compressor power input. However, a tradeoff associated with increased evaporating temperature is that the evaporator’s ability to

dehumidify the air may be compromised.

Increase of coil frontal area is limited in many situations by the size constraints for the

room air conditioner, particularly for large­capacity and through­the­wall products (i.e products

without louvered sides).

Increased depth of coil (add tube rows)

Heat transfer surface area may also be increased by adding rows of tubes to the coil. In

the previous rulemaking, manufacturers asserted that each room air conditioner chassis is

designed for a maximum­depth evaporator and condenser. Vertical tube rows may be added up

to that maximum depth, however adding more rows would require an increase in the size of the

chassis, which incurs significant costs beyond just the costs of the larger heat exchanger.

Other issues associated with increase of heat exchanger depth include the need to

minimize weight, the added refrigerant charge, decreasing improvement associated which each

additional tube row, and the airside pressure drop. With regard to weight, manufacturers claimed

that there is a practical limit to the depth of a room air conditioner which is related to weight,

appearance, and strength of the mounting. The increase in refrigerant charge combined with the

increased effectiveness of the heat exchangers can lead to risk of compressor failure. The room

air conditioner may require a smaller­capacity compressor to meet the specified cooling load.

Smaller compressors have lower refrigerant charge limitations to avoid problems such as oil

frothing during startup, so the changes could impact the reliability of the compressor.

Manufacturers asserted in the previous rulemaking that each successive row in a coil is only

about 70 percent as effective as the preceding row, thus adding rows to a three­ or four­row heat

exchanger has a small effect on system efficiency. Finally, increasing heat exchanger depth can

reduce air flow, which can negate any benefit associated with the additional heat exchanger

surface area.

Increased fin density

Another method of increasing the heat transfer surface area is to increase the fin density.

Increased fin density improves the heat transfer; however, its effect on air flow, fan power, water

drainage, and dirt build­up places a limit on how much the density can be increased.

Fin density has a direct effect on the fan power required to draw or blow air over the coil.

Increasing the fin density increases the air­side pressure drop over the coil, resulting in more

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power being used by the fan motor. Any reduction in air flow can negate the improvement in

heat transfer associated with increased fin density. Increased fin density also can increase water

retention in the evaporator. The condensate that forms on the evaporator must flow down to the

drain pan by the effect of gravity. Increased fin density can limit the condensate flow, which can

restrict air flow and lead to entrainment of water droplets in the discharge air flow. The build­up

of dirt on heat exchanger surfaces is accelerated by an increase in fin density. Smaller air

passageways through the coils are more likely to retain dirt which, if allowed to accumulate over

a unit’s life, decrease the system performance. Taking these factors into consideration the

maximum fin density is a function of the type of coil (i.e., evaporator or condenser), the fin type

(i.e., wavy, louvered, or enhanced), the number of tube rows, and the tube diameter.

Add subcooler to condenser coil

Subcoolers are added between the condenser coil outlet and the capillary tube inlet and

are submerged near the condenser in the condensate produced by the evaporator. Adding a

subcooler effectively increases the size of the condenser coil as it further cools the refrigerant

coming out of the condenser. However, finding the space to incorporate a subcooler into a room

air conditioner can be difficult..They are used much more frequently in larger­capacity units,

which have more space for them.

In the previous rulemaking, manufacturers supplied data for evaluating subcoolers as a

design option. The data from the 1997 TSD analysis is recreated in Table 3.15.3, which shows

the manufacturer test results on the performance improvements due to adding a subcooler. Using

a representative baseline for each product class, specifications were given on how large a

subcooler could be to be incorporated into the existing baseline design. In addition,

manufacturers provided test data detailing the effect on capacity, power consumption, and

efficiency due to the addition of a subcooler. For each product class, the percentage change in

efficiency was used to establish the efficiency gain due to adding a subcooler. Test data was not

provided for classes with reverse cycle.

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Table 3.15.3 Manufacturer Test Results from 1997 TSD Analysis: Performance

Improvements due to Subcoolers

Product Class

Before Subcooler Added Percent Change with Subcooler Added

(%)

Capacity

(Btu/h)

EER (Btu/Wh)Capacity

(Btu/h)

Power

(kWh)

EER

(Btu/W­h)

Louvered side w/o reverse cycle

less than 6,000 Btu/h 6,338 9.19 1.0 ­2.0 2.9

Louvered side w/o reverse cycle

6,000 to 7,999 Btu/h 7,461 8.50 1.7 ­1.3 3.0

Louvered side w/o reverse cycle

8,000 to 13,999 Btu/h

9,984 9.20 ­0.8 ­1.1 1.0

11,668 9.00 0.8 ­0.9 1.8

Average Change for Product

Class: 0.0 ­1.0 1.4

Louvered side w/o reverse cycle

14,000 to 19,999 Btu/h

18,351 9.70 2.0 0.0 2.1

18,984 9.70 1.5 ­0.2 1.6

17,954 9.71 1.1 ­0.3 1.4

Average Change for Product

Class: 1.5 ­0.2 1.7

Louvered side w/o reverse cycle

greater than 20,000 Btu/h

24,319 8.00 0.9 ­1.0 1.9

34,947 8.00 0.3 ­0.6 1.0

Average Change for Product

Class: 0.6 ­0.8 1.5

No louvered side w/o reverse

cycle

6,000 to 7,999 Btu/h

6,204 8.91 0.5 ­1.3 1.8

No louvered side w/o reverse

cycle

8,000 to 13,999 Btu/h

11,300 8.51 0.2 ­2.6 2.8

A study for the Directorate­General for Energy (DGXVII) of the Commission of the

European Communities used a simulation model to calculate the impact of individual technology

options on a room air conditioner’s performance. The results of the simulation showed that the

addition of a subcooler to the condenser coil resulted in a 1 percent average increase in EER.79

Improved fin design

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Improvements to the fin design have the effect of improving the coil’s air­side heattransfer coefficient, and thus improving the overall heat­transfer capability of the coil. This

improvement can be due to the increase in air turbulence over the coil caused by the enhanced

fin design. Manufacturers commented in the previous rulemaking that most room air

conditioners use some form of fin enhancement in their coil designs already. This fin

improvement is generally achieved by using louvered, lanced, or slit­type fin surfaces.

Specific attention to evaporator design regarding condensate runoff and fin patterns may

increase room air conditioner energy efficiency. It is useful for the evaporator to be designed

such that condensate runs off effectively and does not adhere to the surface. In addition to

allowing less entrainment of liquid droplets into the air stream, effective condensate runoff

results in higher heat transfer between the evaporator and the air and allows higher air flow, thus

increasing evaporator performance.

Improved tube design

Improvement of the refrigerant­side heat­transfer coefficient is accomplished by

augmenting the inside surface of the refrigerant tubes with spiral grooves. This type of

refrigerant tubing is known as rifled or grooved tubing. Research has shown that the refrigerantside heat­transfer coefficient for grooved tubing is significantly greater than that of conventional

smooth tubing. As seen with fin enhancements, manufacturers of refrigerant tubing have

developed various types of grooved tubing to improve the heat­transfer capability of air

conditioning coils. Improvement to the refrigerant­side heat­transfer coefficient is a function of

width, height, and spacing of the grooves as well as the concentration of lubricant oil being

circulated within the refrigerant. As discussed in the 1997 TSD, statistical equations have been

developed which can predict the benefits of rifling.80

Hydrophilic­film coating on fins

The condensate water that forms on heat exchanger fins may adhere to the surface as

droplets and cause bridging of the fin spacing, resulting in decreased heat transfer performance

and increased air pressure drop. Adding a hydrophilic coating to heat exchanger fins gives them

an affinity for water, which reduces the condensate layer thickness. This helps the water to flow

down the fins and fall off the evaporator quickly, resulting in reduced air­side pressure drops and

increased airflow rates across the heat exchanger.81 Hydrophilic­film coating on heat exchanger

fins have been shown to reduce air­side pressure drop 20 to 50 percent when operating with

high­humidity roomside air. DOE is unaware of any publicly available data quantifying the

energy efficiency improvements associated with hydrophilic­film coating on fins under normal

room air conditioner operating conditions.

Spray condensate onto condenser coil

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The condensate that forms on and drips off of the evaporator coil is collected in a

condensate pan. Part of the pan is positioned near the condenser and is placed directly

underneath the condenser fan. The condenser fan is equipped with a slinger ring, which is

located at the fan blade tips and is able to collect and spray the condensate onto the condenser

coil as the fan rotates. The spray provides evaporative cooling to enhance the performance of the

condenser. Spraying condensate onto the condenser coil is standard practice for all room air

conditioners. Therefore, condensate spray was not analyzed as a design option to improve room

air conditioner efficiency. The effect of condensate spray on room air conditioner performance

was based upon research to determine the effect that water spray had on heat exchanger

performance.82

Microchannel heat exchangers

Unlike a conventional coil tube with an attached plate fin, microchannel heat exchangers

have a rectangular aluminum cross section containing several small channels (typically less than

1mm across) through which refrigerant passes. Aluminum fins are brazed between the

rectangular tubes. Microchannel can increase heat transfer while reducing pressure drop as

compared with conventional coils. Microchannel heat exchangers generally weigh less and hold

significantly less refrigerant than conventional heat exchangers.

Currently there are several manufacturers of microchannel heat exchangers. The

technology was first used in automobile air conditioning systems, where it is used almost

exclusively for condensers. Other air­conditioning applications are adopting the technology,

particularly in applications requiring reduced size and weight. These include military

environmental control units (ECUs), air­cooled chillers for commercial buildings, and some

residential central air conditioning systems. However, microchannel heat exchangers have not

yet been adopted by room air conditioner manufacturers. A key issue for use in room air

conditioner applications is the much higher investment cost required for the equipment needed to

fabricate these heat exchangers (i.e. including brazing ovens) as compared with equipment used

for fabrication of conventional heat exchangers.

Microchannel heat exchangers have traditionally had difficulty in evaporator

applications, because their geometry is less amenable to condensate removal than conventional

heat exchangers. When installed with the headers oriented vertically, the horizontal flat fins

between fin sections block gravity flow of condensate. Also, even distribution of expanded twophase refrigerant into the many parallel flow paths through the tubes is challenging. While these

issues can be alleviated by orienting the evaporator with the headers horizontal, such an

orientation is undesirable for many applications.

Research has compared the performance of a window­mounted room air conditioner with

microchannel condensers to a baseline system with a conventional finned­tube condenser. The

results showed the heat transfer rates per unit core volume of the microchannel heat exchangers

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were 14 to 331 percent higher than the conventional finned­tube heat exchangers. However, the

overall efficiency of two systems using the microchannel condenser heat exchanger were 1 to 3

percent lower than the baseline system. The lower efficiencies attained by this work were

believed to be due in part to the unoptimized condensate slinger ring and smaller subcooling of

the microchannel systems. The results did show reductions in refrigerant charge, condenser core

volume, and weight of 35, 55, and 35 percent, respectively, using microchannel condensers.83

Improved indoor blower and outdoor fan efficiency

The air delivery system of a room air conditioner consists of one motor driving two fans,

the indoor blower (evaporator), and outdoor (condenser) fans. The evaporator blower is typically

a centrifugal blower, while the condenser fan is a propeller­type fan with a slinger ring attached

to it. As mentioned earlier, the slinger ring sprays condensate onto the condenser coil.

Improvements to the fan designs to improve air flow characteristics could increase the overall

efficiency by decreasing the power demands for the fan motor.

Fans and blowers are generally molded plastic parts with fairly advanced geometries as

compared with stamped sheet metal designs of the past. The condenser fan is mounted with

reasonable clearance to the fan orifice, which is typically sheet metal which may have a formed

bell mouth in the region of the fan blade tips. The evaporator blower is generally housed inside a

Styrofoam enclosure which is shaped to provide smooth flow of air into and out of the blower.

The Styrofoam doubles as thermal isolation between the indoor and outdoor sides of the unit.

Air system efficiency could possibly be improved through more advanced fan and blower

design. It could also be improved by reducing the restrictions to air flow. However, the space

limitations within room air conditioners make reduction of flow resistance difficult. Adjustments

to the designs of the heat exchangers can affect air flow, as discussed in the sections addressing

heat exchangers above.

Improved blower/fan motor efficiency

Room air conditioners primarily use permanent split capacitor (PSC) fan/blower motors.

These motors range in efficiency from 45 to 70 percent. While larger motors are generally more

efficient, there is a range of efficiency for any given power level.

Electric motors operate based on the interaction between a field magnet and a magnetic

rotor. However, single­phase motors only produce a rotating magnetic field when the rotor is

rotating, and simply powering the electromagnet is therefore not sufficient to start such a motor.

One of the most significant differences between different types of single­phase motors is the way

in which they handle start­up. In a PSC motor, a small start­up winding is present which is

energized out of phase with the main winding. The start­up winding is electrically connected in

parallel with the main winding and in series with a capacitor. At start­up, the interactions

between the magnetic field generated by the start­up winding and that generated by the main

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winding induce rotation. As the capacitor charges, the current flowing through the start­up

winding decreases, and the start­up winding becomes an auxiliary winding after the motor

reaches running speed. Consequently, the current to the start­up winding is cut off once the

capacitor is fully charged and the motor reaches steady­state speed. PSC motors are produced in

large quantities and are relatively inexpensive.84

Permanent magnet motors have higher efficiencies than PSC motors. For the purposes of

this report, they will be called brushless DC (BLDC) motors. They are also known as ECMs,

brushless permanent magnet (BPM) motors, and electronically­commutated permanent magnet

(ECPM) motors. BLDC motors are more efficient than PSC motors. BLDC motors convert

single­phase AC input power into DC power and achieve the commutation required for operation

of DC motors by electronic switching rather than through use of a conventional mechanical

commutator. The commutation is coordinated through use of sensor technology that determines

when the motor is at the proper angle for switching the power. BLDC motors have efficiencies

approaching 80 percent.85 However, BLDC motors can weigh more than PSC motors of the same

shaft power, potentially necessitating a redesign of the room air conditioner chassis to

accommodate the increased weight. In addition, BLDC motors are more expensive than PSC

motors.

Improved compressor efficiency

Most room air conditioners are now made with hermetic rotary compressors. Rotary

compressors have displaced reciprocating compressors, because they are smaller, weigh less, and

have reduced noise and vibration. Maximum rotary compressor efficiencies for HCFC­22

refrigerant range from 10.7 to 11.2 EER. However, due to the phaseout of HCFC­22 to take

place in 2010, room air conditioners have switched to R­410A refrigerant, which is a blend of

HFC refrigerants that do not contain chlorine. The room air conditioner market has lagged

central air conditioners in the transition to R­410A. Compressor manufacturers have developed

rotary compressors for the new refrigerant, but the product lines currently available do not span

the applicable capacities and efficiency levels for room air conditioners fully. Hence, while room

air conditioner manufacturers may have had multiple compressor options of varying EER to

consider in the design of a unit using HCFC­22, there may be only one option with appropriate

capacity for the design of a unit using R­410A. Also, the thermodynamic efficiency of R­410A is

not as high as that of HCFC­22, with compressors rated for EER levels in the range from 9 to 10.

Scroll compressors require high precision to produce their internal components and are

typically found in higher­efficiency central air­conditioning systems. Scroll compressors

compress gas in a fundamentally different manner from traditional compressors — between two

spirals, one fixed and one orbiting. Scroll compressors EERs for HCFC­22 refrigerant range

from 10.8 to 11.2 for the capacities of interest for larger room air conditioners. Scroll

compressors are generally 1 to 2 inches taller than rotary compressors, and therefore are better

suited for larger units.86 Scroll compressors can be larger and heavier than their rotary

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counterparts. Thus, incorporating these compressors may require larger chassis sizes and bracing

to accommodate the increased size and weight.

Two­speed, variable­speed, or modulating­capacity compressors

Most conventional single speed compressors run at a constant speed and vary their

capacity by cycling on and off in response to the thermostat. The efficiency of systems using

these compressors is typically lower than full­capacity efficiency at part load, due to off­cycle

losses. Variable­speed compressors are typically implemented through the use of an electronic

control that varies the input frequency of the power supply for the compressor motor. Variablespeed compressors enable modulation of the refrigeration­system cooling capacity, allowing the

air conditioner to match the cooling load. This can improve efficiency by eliminating off­cycle

losses and because, when operating with the lower mass flow at part load, the heat exchangers

are more effective. There are non­energy advantages to variable­speed control, including quieter

operation at low speeds, enhanced comfort by eliminating temperature fluctuations in the room,

and potential for improved dehumidification.

The control of variable­speed compressors is accomplished through the use of electronic

adjustable­speed drives (ASDs) at the motor. Because electronic ASDs require no drive­train in

order to be coupled to the motor, they can be used with the sealed refrigeration systems used in

room air conditioners. ASDs can be designed for use with induction motors or with permanentmagnet brushless motors. There are two inverter types that are applicable to induction motors

typically used in room air conditioner compressors: voltage source (VSI) and pulse­width

modulated voltage source (PWM) inverters. In either case, the input AC power supply is first

converted to DC by using a solid­state rectifier. This DC signal is then converted to a variablefrequency AC waveform by the inverter and supplied to the motor. The speed of the motor is

roughly proportional to the frequency.87

A recently developed method for modulating capacity in scroll compressors is

intermittent discharge. This technology utilizes a pressure control system in which a solenoid

valve opens, relieving the pressure on the back side of a piston. This spring­loaded piston is

connected to the rotating scroll, and the scroll­piston system is then displaced once the

backpressure is removed. This displacement disengages the scrolls, leaving the driveshaft free to

rotate without any compression taking place. Modulating the time in which the scrolls are

engaged allows capacity to be varied from 10 to 100 percent of maximum. Intermittent discharge

technology, however, is only applicable to scroll compressors, and is a proprietary approach.o

There are no obvious technical barriers to use of variable­speed compressors in room air

conditioners. ASDs have been demonstrated to perform well with both rotary and scroll

compressors. The heat pump market in Japan is now dominated by split systems equipped with

o For more information, see http://www.digitalscroll.com/digitalweb/english/howitworks.htm

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variable­speed rotary compressors. Based on an initial US market survey, a number of

manufacturers offer split system air conditioners equipped with inverter systems using variable

speed compressors. The most common motor used in this application is an induction motor. But

the HVAC industry is now showing a strong interest in brushless permanent magnet motors due

to their high efficiency.

As stated earlier, technology options that primarily improve efficiency on a seasonal

basis will not demonstrate any efficiency improvements according to the current DOE test

procedure which specified steady­state conditions. The greatest benefit of variable speed systems

is to save energy on a seasonal basis. Because tests have not been performed to determine the

amount of cycling in room air­conditioners, the potential magnitude of seasonal energy savings

in room air units is not well understood. Research has demonstrated that energy savings from 15

89 90 to 40 percent are attainable in central air conditioning systems.88, , In the previous rulemaking,

DOE estimated that the implementation of variable­speed compressors in room air­conditioners

could achieve an energy savings of approximately 10 percent.91 However, comments received

from manufacturers subsequent to the Framework Document public meeting of this current

rulemaking indicate that room air conditioners are typically purchased oversized relative to the

conditioned space, indicating that they would operate in on/off mode and thus preclude the

energy savings associated with variable­speed systems.

.

Thermostatic or electronic expansion valves

Manufacturer interviews and DOE’s reverse engineering indicate that the capillary tube is

the flow control device that is currently used by all room air conditioners. The capillary tube is a

pressure­reducing device that consists of a small­diameter tube that connects the outlet of the

condenser to the inlet of the evaporator. The very high pressure drop as refrigerant flows through

the capillary allows the high and low pressures in the system to be maintained. Since it is a fixed

device, the capillary tube provides optimum system operating parameters over a narrow range of

operating conditions.

The thermostatic expansion valve (TXV) — a flow­control alternative to the capillary

tube — is commonly used in higher­efficiency central air­conditioning systems. TXVs regulate

the flow of liquid refrigerant entering the evaporator in response to the superheat of the

refrigerant leaving it. TXVs can adapt better to changes in operating conditions, such as those

due to variations in ambient temperature, which affect the condensing temperature. As a result,

TXVs can control for optimum system operating parameters over a wider range of operating

conditions, and can thus improve seasonal efficiency.

Electronic expansion valves (EEVs) are similar to TXVs, but they operate using

electronic (microprocessor) control. The EEV uses a pulse motor, which rotates based on an

electronic signal from a microcomputer determining the desired valve position from measured

system parameters. While a TXV is limited due to its thermo­mechanical design, there is greater

flexibility for operation of an EEV. Research has demonstrated that, when incorporated into air3­79

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conditioning systems using inverter­driven variable­speed compressors, EEVs improve seasonal

energy efficiency beyond that of systems using conventional TXVs. As with variable speed

compressors, the main benefit of electronic expansion valves is to improve efficiency on a

seasonal basis. DOE is aware of a patent describing a room air conditioner using an electronic

expansion valve92 but is not aware of any publications describing prototype testing to evaluate

the efficiency improvement potential of this technology.

Thermostatic cyclic controls

Remote thermostatic cyclic controls more accurately monitor room temperature than

typical built­in thermostats. Research has been conducted to investigate the use of fuzzy logic

controllers for HVAC applications. These controller types have been shown to improve the

performance of HVAC systems over that of conventional controllers. Thermostatic controls

could offer seasonal energy savings.

As with variable speed compressors and expansion valves, the DOE test procedure can

only measure energy efficiency improvements based on steady­state conditions. In addition, no

data were found or presented that indicated how the performance of room air conditioners could

be enhanced with thermostatic cyclic controls.

Switching Power Supplies

A potential area for standby power improvement for room air conditioners is the power

supply on the control board. As with clothes dryers, a typical room air conditioner may use an

unregulated plus regulated control board power supply, with voltage regulators stepping down

the unregulated voltage(s) to the level(s) required by the control logic, display, and remote

control sensor. As noted previously for clothes dryers, this approach results in a rugged power

supply which is reliable, but typically has an efficiency of about 55 percent. The power supply

accounts for the majority of the energy consumed by the control board in inactive mode. DOE’s

room air conditioner reverse engineering showed that the majority of the inspected units used

this type of power supply.

Power supply efficiency may be improved, at higher cost and complexity, with the use of

switching power supplies. For a complete discussion of switching power supply function and

efficiency, see section 3.15.2.1 for the comparable clothes dryer technology option. Based on

DOE’s reverse engineering, described in chapter 5 of this preliminary TSD, DOE determined

that room air conditioners with switching power supplies consume approximately 0.7 W in

standby mode, a roughly 50 percent power savings as compared with standby power

consumption with linear power supplies.

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3.15.3 Energy Efficiency

In preparation for the screening and engineering analyses, DOE gathered data on the

energy efficiency of residential clothes dryers and room air conditioners currently available in

the marketplace. This data is taken from databases maintained by a variety of regulatory

agencies. While this section is not intended to provide a complete characterization of the energy

efficiency of all appliances currently available and in use, it does provide an overview of the

energy efficiency of each product covered by this rulemaking.

3.15.3.1 Residential Clothes Dryers

The CEC publishes a list of “certified” residential clothes dryers. Figure 3.15.2 through

Figure 3.15.4 display the distribution of clothes dryers in the CEC database that are currently

available on the market as a function of EF for electric standard and compact dryers, gas dryers.

Each graph also shows the current federal energy conservation standard. All of the dryer models

listed in the CEC database meet or are above the current standard level, if one exists for the

product class. There are also no vent­less clothes dryer models listed in the CEC database since

there is no accepted way of rating the performance of such dryers.

Figure 3.15.2 Electric Standard Capacity Clothes Dryers in the CEC Directory93

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Figure 3.15.3 Electric Compact Capacity Clothes Dryers in the CEC Directory94

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Figure 3.15.4 Gas Clothes Dryers in the CEC Directory95

AHAM submitted market share efficiency data for residential clothes dryers. Table 3.15.4

and Table 3.15.5 present the market share efficiency data for electric standard and gas dryers,

respectively. AHAM noted that, in order to maintain confidentiality, market share for electric

standard dryers between EF of 3.20 and 3.29 were incorporated into the EF range between 3.10

and 3.19. Similarly, market share for gas clothes dryers with an EF > 2.94 was incorporated into

the EF > 2.85 efficiency bin.

Table 3.15.4 Residential Clothes Dryer Market Share Efficiency Data for Electric Standard

Dryers96

EF Market Share (%)

2005 2006

3.01 – 3.09 26 33

3.10 – 3.29 74 67

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Table 3.15.5 Residential Clothes Dryer Market Share Efficiency Data for Gas Dryers97

EF Market Share (%)

2005 2006

2.67 – 2.74 25 28

2.75 – 2.84 42 44

> 2.85 32 27

3.15.3.2 Room Air Conditioners

Although not completely representative of the entire current room air conditioner market,

CEC, ENERGY STARp and AHAM publish lists of “certified” room air conditioners. The

AHAM Room Air Conditioner Certification Program verifies the cooling and heating capacity

rating, amperes, and EER of each listed room air conditioner as tested by an independent

laboratory.q DOE consolidated the three databases and reviewed all of the listed room air

conditioners, searching websites of the manufacturers and retailers to verify whether the products

are still active. This investigation was carried out in August 2008.

Figure 3.15.5 through Figure 3.15.8 show the EER versus the capacity of each room air

conditioner listed in the databases which were found in the manufacturer and retailer

investigation. Each graph illustrates the current federal energy conservation standard, which

became effective on October 1, 2000. The screening of products which are no longer available

removed many old products, but some of the products still had reported EER below the current

federal standards. These may have erroneous EER listings, or have model numbers identical to

updated products. In any case the exhaustive screening of the products in the databases clearly

was not sufficiently thorough to eliminate all outdated entries.

p For more information, please visit www.energystar.gov.

q For more information, please visit www.aham.org.

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Figure 3.15.5 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners

98, 99, 100
 without Reverse Cycle and with Louvered Sides (Product Classes 1–5)

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Figure 3.15.6 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners

101, 102, 103
 without Reverse Cycle and without Louvered Sides (Product Classes 6–10)

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Figure 3.15.7 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners with

104, 105, 106
 Reverse Cycle (Product Classes 11–14)

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Figure 3.15.8 CEC, AHAM, and ENERGY STAR Certified Room Air Conditioners

107, 108, 109 Casement­Only and Casement­Slider (Product Classes 15, 16)

Figure 3.15.9 shows the distribution of the models listed in the screened database for each

product class. Nearly 70 percent of the products are room air conditioner models without reverse

cycle and with louvered sides. In addition, there are a significant amount of models in product

class 8, room air conditioners without reverse cycle, without louvered sides, and a capacity

between 8,000 and 13,999 Btu/h. Also of note, there are no models in product class 13 (with

reverse cycle, with louvered sides, capacity greater than 120,000 Btu/h).

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Figure 3.15.9 Distribution of Room Air Conditioner Models in the CEC, AHAM, and

110, 111, 112
 ENERGY STAR Databases

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REFERENCES
 

1	 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy.

Technical Support Document for Energy Conservation Standards for Room Air

Conditioners: Volume 2–Detailed Analysis of Efficiency Levels. September 1997,

Washington, D.C. Available online at:

www.eere.energy.gov/buildings/appliance_standards/residential/room_ac.html

2	 “32nd Annual Portrait of the U.S. Appliance Industry: The Share­of­Market Picture for

2008.” Appliance Magazine, September 2009.

3 Ibid.

4 Ibid.

5	 “Annual Portrait of the U.S. Appliance Industry: The Share­of­Market Picture.”

Appliance Magazine, September 2005–2009.

6 Ibid.

7	 Appliance Magazine, September 2009. Op. cit.

8	 Appliance Magazine, September 2005–2009. Op. cit.

9	 Appliance Magazine, September 2009. Op. cit.

10	 Maytag. 2005. “Whirlpool Corporation and Maytag Corporation Sign Definitive Merger

Agreement.” Maytag Press Release, August 22, 2005.

11	 P. Hussmann. 2006. “Justice to Extend Maytag­Whirlpool Merger Review.” Newton

Daily News Online. February 14, 2006.

12	 W. Ryberg. 2006. “Harkin, Boswell want Maytag sale blocked.” Des Moines Register.

January 13, 2006.

13 Ibid.

14	 U.S. Department of Justice (U.S. DOJ). 2006. Department of Justice Antitrust Division

Statement on the Closing of its Investigation of Whirlpool’s Acquisition of Maytag.

March 29, 2006.

15 Ibid.

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16	 Association of Home Appliance Manufacturers (AHAM) Fact Book 2005.

17 Ibid.

18	 AHAM Fact Book 2003.

19	 CEEE. 2000. National Residential Home Appliance Market Transformation Strategic

Plan. December, 2000.

20	 Tiele, Simone. 2008. “Australia’s Approach to Standby Power.” In Reports of national

standby power consumption and targeted policies. New Delhi, India, April 2. Department

of the Environment, Water, Heritage and the Arts, Australia. Available online at:

www.iea.org/textbase/work/workshopdetail.asp?WS_ID=352. (Last accessed on August

28, 2008.)

21	 Database of State Incentives for Renewables & Efficiency. Incentives for Clothes

Washers/Dryers. 2008. Available online at: www.dsireusa.org. (Last accessed on

September 22, 2008)

22	 U.S. Census Bureau. New Privately Owned Housing Units Started in the United States by

Purpose and Design. 2008.

23 Ibid.

24	 AHAM. 2008. Residential Clothes Dryer Shipments. August 20, 2008. Docket No.

EERE­2007­BT­STD­0010, Comment Number 15.

25	 AHAM Fact Book 2003 and 2005.

26	 ENERGY STAR. Room Air Conditioners 2007 Product Snapshot. Prepared by D&R

International, Ltd. on behalf of the U.S. Department of Energy. 2007. Available online at:

www.energystar.gov/index.cfm?c=manuf_res.pt_appliances (Last accessed on April 21,

2009.)

27	 AHAM Fact Book 2005.

28	 U.S. Census Bureau. Annual Survey of Manufacturers (ASM) – Value of Product

Shipments. 1996–2006, issued annually.

29 Ibid.

30	 AHAM Fact Book 2003.

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31 AHAM. Import/Export Trade Report – December 2008 (preliminary year end). 2009.

32 Ibid.

33 Ibid.

34 Ibid.

35 AHAM Fact Book 2005.

36 Ibid.

37 AHAM Fact Book 2003 and 2005.

38 U.S. Census Bureau. “Table 2 ­ Statistics for Industry Groups and Industries.” Statistics

for Industry Groups and Industries, ASM, 1996–2006, issued annually.

39 Ibid.

40 Ibid.

41 Ibid.

42 Ibid.

43 Ibid.

44 U.S. Census Bureau. ASM ­ Statistics for Industry Groups and Industries. 1996–

2006, issued annually.

45 Ibid.

46 Ibid.

47 U.S. Census Bureau. Survey of Plant Capacity. 2004–2005, issued annually.

48 http://www.friedrich.com/products/ModelDocuments.php?model=CP10E10

49 P. Pescatore and P. Carbone. 2005. High Efficiency High Performance Clothes Dryer.

Final Report to Department of Energy.

3­92

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50	 T Richter. Energy Efficient Laundry Process. 2005. GE Global Research, Final Project

Report for the Department of Energy, DOE Award DE­FC26­01NT41261.

51	 Consumer Energy Center. Clothes Dryers – Buying Smart. 2008. Available online at:

www.consumerenergycenter.org/home/appliances/dryers.html (Last accessed on October

1, 2008.)

52	 Science Applications, Inc. Energy Efficiency Program for Clothes Washers, Clothes

Dryers and Dishwashers. 1977. SAI­77­839, La Jolla, CA.

53	 D. Hekmat ad W.J. Fisk. 1983. Improving the Energy Efficiency of Residential Clothes

Dryers. Lawrence Berkeley Laboratory, LBL­16813 ,July 1983.

54	 D.F. Joslin. 1996. Reversing Clothes Dryer and Method Therefor. U.S. Patent No.

5,555,645, issued September 17, 1996.

55	 T. Richter. 2005. Op. cit.

56	 George Wilkenfeld and Associates Pty. Ltd. and Lawrence Berkeley Laboratory. 1993.

Benefits and Costs of Implementing Minimum Energy Performance Standards for

Household Electrical Appliances in Australia. Final Report Prepared for State Electricity

Commission of Victoria, July, p. 138.

57	 D. Hekmat and W.J. Fisk. 1983. Op. cit.

58	 National Institute of Standards and Technology. Appliance Energy Efficiency

Improvement Target for Clothes Dryers. 1977.

59 Ibid.

60	 P.K. Bansal, J.E. Braun, and E.A. Groll. 2001. “Improving the Energy Efficiency of

Conventional Tumbler Clothes Drying Systems.” International Journal of Energy

Research, Vol. 25, January 2001, pp. 1315–32.

61	 L. Palandre and D. Clodic. 2003. “Comparison of Heat Pump Dryer and Mechanical

Steam Compression Dryer.” Presented at the International Congress of Refrigeration.

Washington, D.C. Ecoles des Mines de Paris, Center for Energy Studies,

62	 E. Bush and J. Nipkow. 2006. Tests and Promotion of Energy­Efficient Heat Pump

Dryers. Report Prepared for International Energy Efficiency in Domestic Appliances &

Lighting Conference ’06.

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63 Ibid.

64	 P. Pescatore and P. Carbone. 2005. Op. cit.

65 Ibid.

66 Ibid.

67	 Ashley, Steven. 1998. “Energy­Efficient Appliances.” Mechanical Engineering. Vol.

120, No. 3, pp. 94–97.

68 Ibid.

69	 J. Gerling. 2003. “Microwave Clothes Drying – Technical Solutions to Fundamental

Challenges.” Appliance Magazine. April 2003.

70 Ibid.

71	 P. Pescatore and P. Carbone. 2005. Op. cit.

72 Ibid.

73 Ibid.

74 Ibid.

75	 George Wilkenfeld and Associates Pty. Ltd. 2007. Extending the Water Efficiency

Labelling and Standards (WELS) Scheme to Washer/Dryers and Condenser Dryers.

Report Prepared for the Department of the Environment and Water Resources, pp. 3–5.

76	 “’Green’ Clothes Dryer Technology to Launch at Builders’ Show.” Appliance Magazine

– Daily News. 2008.

77	 M.H. Kim and C.W. Bullard. 2002. “Performance Evaluation of a Window Room Air

Conditioner with Microchannel Condensers.” Journal of Energy Resources Technology.

Vol. 124, Issue 1, pp. 47–55.

78	 D. Fridley, G. Rosenquist, J. Lin, L. Aixian, X. Dingguo, and C. Jianhong. 2006.

Technical and Economic Analysis of Energy Efficiency of Chinese Room Air

Conditioners. Lawrence Berkeley National Laboratory, China National Institute of

Standardization, and Beijing Energy Efficiency Center, LBNL­45550.

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79	 J. Adnot. 1999. Energy Efficiency of Room Air­Conditioners (EERAC). DirectorateGeneral for Energy (DGXVII) of the European Communities, p. 60.

80	 L.M. Schlager, M.B. Pate, and A.E. Bergles. 1990. “Performance Predictions of

Refrigerant­Oil Mixtures in Smooth and Internally Finned Tubes ­ Part II: Design

Equations.” ASHRAE Transactions. 96(1): pp 170–182.

81	 Mimakim M. 1987. “Effectiveness of Finned­Tube Heat Exchanger Coated HydrophilicType Film”, ASHRAE Transactions, 93(1): pp 62­71.

82	 D.R. Tree, V.W. Goldschmidt, R.W. Garrett, and E. Kach. 1978. “Effect of Water Sprays

on Heat Transfer of a Fin and Tube Heat Exchanger.” Sixth International Heat Transfer

Conference.Vol. 4, pp. 339–44.

83	 M.H. Kim and C. Bullard. 2002. Op. cit.

84	 U.S. DOE. 1997. Op. cit.

85	 Simmons. 2003. Op. cit.

86	 ENERGY STAR. 2003. Expansion of ENERGY STAR Room Air­Conditioner Criteria to

Include Through­the­Wall Units. D&R International, Ltd.

87	 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy.

Technical Support Document for Energy Conservation Standards for Room Air

Conditioners, September 1997. Washington, D.C. Available online at:

www.eere.energy.gov/buildings/appliance_standards/residential/room_ac.html

88	 H.I. Henderson, Jr. 1990. “A Side­by­Side Field Test of Variable­Speed and ConstantSpeed Air Conditioners.” ASHRAE Transactions. 96(1): pp 683–692.

89	 V. Bahel and S.M. Zubair. 1989. “An Assessment of Inverter­Driven Variable­Speed Air

Conditioners: Sample Performance Comparison with a Conventional System.” ASHRAE

Transactions. 95(1): pp 455–464.

90	 M. Hori, I. Akamine, and T. Sakai. 1985. “Seasonal Efficiencies of Residential Heat

Pump Air Conditioners with Inverter­Driven Compressors.” ASHRAE Transactions.

91(2B): pp. 1585–1595.

91 Ibid.

92	 Tezuka, T., K. Isono, “Room Air Conditioner”, U.S. Patent 4,795,089, Assignee

Mitsubishi Denki Kabushiki Kaisha, January 3, 1989.

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93	 CEC Appliance Efficiency Database. April 2009. Available online at:

www.energy.ca.gov/appliances/database/ (Last accessed on April 3, 2009.)

94 Ibid.

95 Ibid.

96	 AHAM. 2008. De­identified Clothes Dryer Data – Collected December 2007 for DOE

Rulemaking. Updated 4/11/2008. April 11, 2008. Docket No. EERE­2007­BT­STD­0010,

Comment Number 14.

97 Ibid.

98 CEC Appliance Efficiency Database. 2008 Op. cit.

99 ENERGY STAR Room Air Conditioner Database. May 2008. Available online at:

www.energystar.gov/index.cfm?c=roomac.pr_room_ac (Last accessed on May 9, 2008).

100 AHAM Certified Product Listing ­ Room Air Conditioners. May 2008. Available online

at: http://207.140.180.12/dirsvc/aham.nsf/fraMain?OpenFrameset (Last accessed on May

9, 2008.)

101 CEC Appliance Efficiency Database. 2008 Op. cit.

102 ENERGY STAR Room Air Conditioner Database. Op. cit.

103 AHAM Certified Product Listing ­ Room Air Conditioners. May 2008. Op. cit.

104 CEC Appliance Efficiency Database. Op. cit.

105 ENERGY STAR Room Air Conditioner Database. Op. cit.

106 AHAM Certified Product Listing ­ Room Air Conditioners. May 2008. Op. cit.

107 CEC Appliance Efficiency Database. Op. cit.

108 ENERGY STAR Room Air Conditioner Database. Op. cit.

109 AHAM Certified Product Listing ­ Room Air Conditioners. May 2008. Op. cit.

110 CEC Appliance Efficiency Database. Op. cit.

111 Energy Star Room Air Conditioner Database. Op. cit.

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                       112 AHAM Certified Product Listing ­ Room Air Conditioners. May 2008. Op. cit.

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