CHAPTER 2. ANALYTICAL FRAMEWORK, COMMENTS FROM
 

INTERESTED PARTIES, AND DOE RESPONSES
 

TABLE OF CONTENTS

2.1 INTRODUCTION ........................................................................................................... 2­1
 

2.2 MARKET AND TECHNOLOGY ASSESSMENT........................................................ 2­3
 

2.2.1 Definitions...................................................................................................... 2­3
 

2.2.2 Product Classes and Scope of Coverage........................................................ 2­5
 

2.2.2.1 Residential Clothes Dryers ............................................................................ 2­5
 

2.2.2.2 Room Air Conditioners.................................................................................. 2­7
 

2.2.3 Test Procedures.............................................................................................. 2­7
 

2.2.3.1 Residential Clothes Dryers ............................................................................ 2­7
 

2.2.3.2 Room Air Conditioners................................................................................ 2­13
 

2.2.3.3 Standby and Off Mode Energy Use............................................................. 2­15
 

2.2.4 Technology Assessment............................................................................... 2­15
 

2.2.4.1 Residential Clothes Dryers .......................................................................... 2­16
 

2.2.4.2 Room Air Conditioners................................................................................ 2­18
 

2.3 SCREENING ANALYSIS ............................................................................................ 2­18
 

2.3.1 Geographic Boundaries of “Commercially Available Products” ................ 2­19
 

2.3.2 Residential Clothes Dryers .......................................................................... 2­19
 

2.3.2.1 Dryer Control or Drum Upgrades................................................................ 2­20
 

2.3.2.2 Methods of Exhaust Heat Recovery ............................................................ 2­20
 

2.3.2.3 Heat Generation Options.............................................................................. 2­21
 

2.3.3 Room Air Conditioners................................................................................ 2­22
 

2.3.3.1 Heat Exchanger Surface Area Design Options............................................ 2­22
 

2.3.3.2 Heat Exchanger Improvement in Heat Transfer.......................................... 2­23
 

2.3.3.3 Component Improvements........................................................................... 2­24
 

2.4 ENGINEERING ANALYSIS........................................................................................ 2­25
 

2.4.1 Technologies Unable to be Analyzed .......................................................... 2­26
 

2.4.1.1 Residential Clothes Dryers .......................................................................... 2­27
 

2.4.1.2 Room Air Conditioners................................................................................ 2­27
 

2.4.2 Product Classes Analyzed............................................................................ 2­27
 

2.4.3 Analysis Approach....................................................................................... 2­28
 

2.4.3.1 Residential Clothes Dryers .......................................................................... 2­28
 

2.4.3.2 Room Air Conditioners................................................................................ 2­29
 

2.4.4 Efficiency Metrics........................................................................................ 2­29
 

2.4.5 Baseline Efficiency Levels .......................................................................... 2­30
 

2.4.5.1 Residential Clothes Dryers .......................................................................... 2­30
 

2.4.5.2 Room Air Conditioners................................................................................ 2­31
 

2.4.6 Efficiency Levels......................................................................................... 2­32
 

2.4.6.1 Residential Clothes Dryers .......................................................................... 2­32
 

2.4.6.2 Room Air Conditioners................................................................................ 2­33
 

2.4.7 Maximum Technology Efficiency Levels ................................................... 2­34
 

2.4.7.1 Residential Clothes Dryers .......................................................................... 2­34
 

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2.4.7.2 Room Air Conditioners................................................................................ 2­35
 

2.4.8 Cost­Efficiency Relationships ..................................................................... 2­36
 

2.5 MARKUPS TO DETERMINE PRODUCT PRICES ................................................... 2­36
 

2.6 ENERGY USE CHARACTERIZATION ..................................................................... 2­37
 

2.6.1 Residential Clothes Dryers .......................................................................... 2­37
 

2.6.2 Room Air Conditioners................................................................................ 2­38
 

2.7 LIFE­CYCLE COST AND PAYBACK PERIOD ANALYSES .................................. 2­39
 

2.7.1 Energy Prices............................................................................................... 2­40
 

2.7.2 Installation, Maintenance and Repair Costs................................................. 2­40
 

2.7.3 Product Lifetime .......................................................................................... 2­41
 

2.7.4 Energy Efficiency in the Base Case............................................................. 2­41
 

2.8 NATIONAL IMPACT ANALYSIS.............................................................................. 2­42
 

2.8.1 Shipments Analysis...................................................................................... 2­42
 

2.8.2 Efficiency Trends......................................................................................... 2­43
 

2.8.3 National Energy Savings.............................................................................. 2­43
 

2.8.4 Net Present Value of Consumer Benefit...................................................... 2­43
 

2.8.5 Other Impacts............................................................................................... 2­44
 

2.9 PRELIMINARY MANUFACTURER IMPACT ANALYSIS ..................................... 2­45
 

2.9.1 Industry Cash­Flow Analysis....................................................................... 2­45
 

2.9.2 Manufacturer Subgroup Analysis................................................................ 2­45
 

2.9.3 Competitive Impacts Assessment ................................................................ 2­46
 

2.9.4 Cumulative Regulatory Burden ................................................................... 2­46
 

2.9.4.1 HCFC Phaseout............................................................................................ 2­46
 

2.9.4.2 Underwriters Laboratory Fire Safety Regulation ........................................ 2­47
 

2.9.4.3 Clothes Washer Energy Conservation Standards ........................................ 2­48
 

2.9.4.4 Other Regulatory Burden Comments........................................................... 2­48
 

2.9.5 Preliminary Results for the Manufacturer Impact Analysis ........................ 2­49
 

2.10 LIFE­CYCLE COST SUBGROUP ANALYSIS .......................................................... 2­49
 

2.11 UTILITY IMPACT ANALYSIS................................................................................... 2­49
 

2.12 ENVIRONMENTAL IMPACT ANALYSIS................................................................ 2­50
 

2.13 EMPLOYMENT IMPACT ANALYSIS....................................................................... 2­54
 

2.14 REGULATORY IMPACT ANALYSIS ....................................................................... 2­55
 

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CHAPTER 2. ANALYTICAL FRAMEWORK, COMMENTS FROM
 

INTERESTED PARTIES, AND DOE RESPONSES
 

2.1 INTRODUCTION

Section 6295(o)(3)(B) of 42 United States Code (U.S.C.) requires the U.S. Department of

Energy (DOE) to set forth energy conservation standards that are technologically feasible and

economically justified, and would achieve the maximum improvement in energy efficiency. This

chapter provides a description of the general analytical framework that DOE uses in developing

such standards, and in particular, amended energy conservation standards for residential clothes

dryers and room air conditioners. The analytical framework is a description of the methodology,

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

For example, the methodology that addresses the statutory requirement for economic justification

includes analyses of life­cycle cost (LCC); economic impact on manufacturers and users;

national benefits; impacts, if any, on utility companies; and impacts, if any, from lessening

competition among manufacturers.

The analyses performed as part of the preliminary notice of proposed rulemaking (PreNOPR) stage and reported in this preliminary technical support document (preliminary TSD) are

listed below.

•	 A market and technology assessment to characterize the relevant product markets and

existing technology options, including prototype designs.

•	 A screening analysis to review each technology option and determine if it is

technologically feasible; is practical to manufacture, install, and service; would adversely

affect product utility or product availability; or would have adverse impacts on health and

safety.

•	 An engineering analysis to develop cost­efficiency relationships that show the
 

manufacturer’s cost of achieving increased efficiency.
 

•	 A markups analysis to develop distribution channel markups that relate the manufacturer

production cost to the cost to the consumer.

•	 An energy use analysis to determine the annual energy use in the field of the considered

products.

•	 LCC and payback period (PBP) analyses to calculate, at the consumer level, the

discounted savings in operating costs throughout the estimated average life of the covered

products, compared to any increase in the installed cost for the products likely to result

directly from imposition of the standard.

•	 A shipments analysis to forecast product shipments, which then are used to calculate the

national impacts of standards on energy, consumer net present value (NPV), and future

manufacturer cash flows.

•	 A national impact analysis (NIA) to assess the aggregate impacts at the national level of

potential energy conservation standards for each of the considered products, as measured

by the net present value (NPV) of total consumer economic impacts and the national

energy savings (NES).

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•	 A preliminary manufacturer impact analysis to assess the potential impacts of energy

conservation standards on manufacturers, such as impacts on capital conversion

expenditures, marketing costs, shipments, and research and development costs.

The analyses DOE will perform in the subsequent notice of proposed rulemaking

(NOPR) stage include those listed below. In addition, DOE will revise the analyses it performed

in the Pre­NOPR stage based on comments and new information received.

•	 An LCC subgroup analysis to evaluate variations in customer characteristics that might

cause a standard to affect particular consumer sub­populations, such as low­income

households, differently than the overall population.

•	 A manufacturer impact analysis to estimate the financial impact of standards on

manufacturers and to calculate impacts on competition, employment, and manufacturing

capacity.

•	 A utility impact analysis to estimate the effects of proposed standards on electric and gas

utilities.

•	 An employment impact analysis to assess the aggregate impacts of amended energy

conservation standards on national employment.

•	 An environmental impact analysis to provide estimates of the effects of amended energy

conservation standards on emissions of carbon dioxide (CO2), sulfur dioxide (SO2),

nitrogen oxides (NOx), and mercury (Hg).

•	 A regulatory impact analysis to present major alternatives to proposed amended energy

conservation standards that could achieve substantially the same regulatory goal at a

lower cost.

DOE developed this analytical framework and documented its findings in the Energy

Conservation Standards Rulemaking Framework Document for Residential Clothes Dryers and

Room Air Conditioners (the framework document). DOE announced the availability of the

framework document in a Notice of Public Meeting and Availability of a Framework Document

published in the Federal Register on October 9, 2007. 72 FR 57254. DOE presented the

analytical approach to interested parties during a public meeting held on October 24, 2007. The

framework document is available at

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/dryer_roomac_fram

ework.pdf

In response to the publication of the framework document and the framework public

meeting, DOE received numerous comments from interested parties regarding DOE’s analytical

approach. In this chapter (chapter 2) of the preliminary TSD, DOE: (1) summarizes the key

comments received from interested parties and describes DOE’s responses to those comments;

(2) summarizes any significant changes in analytical approach made since publishing the

framework document that DOE used in its Pre­NOPR analyses; and (3) explains in further detail

each of the issues for which DOE seeks public comment identified in the executive summary.

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2.2 MARKET AND TECHNOLOGY ASSESSMENT

When DOE begins an energy conservation standards rulemaking, it develops information

that provides an overall picture of the market for the products considered, including the nature of

the products, the industry structure, and market characteristics for the products. This activity

consists of both quantitative and qualitative efforts based primarily on publicly available

information. The subjects addressed in the market assessment included manufacturers, trade

associations, and the quantities and types of products sold and offered for sale. DOE examined

residential clothes dryer and room air conditioner manufacturers. DOE examined both large and

small and foreign and domestic manufacturers. DOE also examined publicly available

information from trade associations, including the Association of Home Appliance

Manufacturers (AHAM) and the Air Conditioning, Heating, and Refrigeration Institute (AHRI).a

DOE also reviewed shipment data collected by AHAM and the U.S. Census Bureau to evaluate

annual shipment trends. Finally, DOE also reviewed other energy efficiency programs from

utilities, individual states, and other organizations. Chapter 3 of the preliminary TSD provides

additional details on the market and technology assessment.

DOE reviewed relevant literature and interviewed manufacturers to develop an overall

picture of the residential clothes dryer and room air conditioner industries in the United States.

Industry publications and trade journals, government agencies, and trade organizations provided

the bulk of the information, including (1) manufacturers and their market shares; (2) shipments

by product type (i.e., residential clothes dryers and room air conditioners); (3) product

information; and (4) industry trends. The analysis developed as part of the market and

technology assessment is described in chapter 3 of the preliminary TSD.

2.2.1 Definitions

DOE defines “electric clothes dryer” in regulations promulgated under the Energy Policy

and Conservation Act (EPCA) of 1975, Pub. L. 94­163, (42 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).” 10 CFR

430.2. Similarly, DOE 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).” Id.

DOE presented these clothes dryer definitions in the framework document, and, in

response, received comments regarding the coverage of certain new drying technologies under

this rulemaking. Edison Electric Institute (EEI) stated that some microwave clothes dryers do not

meet the definition of a covered product as having a tumble­type drum and questioned whether

such dryers would be covered. EEI also questioned whether heat pump clothes dryers would be

a On January 1, 2008, the Air­Conditioning and Refrigeration Institute (ARI) and the Gas Appliance Manufacturers

Association (GAMA) merged to become AHRI. Consequently, comments from GAMA have been attributed to

AHRI in this document.

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considered covered products. (EEI, Public Meeting Transcript, No. 4.6 at pp. 37–38)b EEI stated

that DOE may want to update and expand the definition of clothes dryers to account for new

technologies that are in use or will be in use, such as "cabinet" clothes dryers and microwave

units that would not include a "tumble type drum". (EEI, No. 5 at p. 2)c The American Council

for an Energy­Efficient Economy (ACEEE), Appliance Standards Awareness Project (ASAP),

Natural Resources Defense Council (NRDC), and the Northeast Power Coordinating Council

(NPCC), submitted a joint comment to DOE, hereafter referred to as the “Joint Comment,”

stating that DOE should remove "tumbling" from definition of clothes dryers. (Joint Comment,

No. 9 at p. 12) AHAM commented that it is not opposed to changes in the product definitions

that make them more descriptive. However, AHAM also commented that microwave technology

is not a valid technology at this time, so at this time is does not support changing the clothes

dryer definitions. (AHAM, Public Meeting Transcript, No. 4.6 at p. 45)

Natural Resources Defense Council (NRDC) stated that DOE has authority to regulate

additional products regardless of whether a product is covered according to the current legal

definition. NRDC commented it does not want to create loopholes or foreclose the opportunity

that the test procedure could cover completely different dryer technologies that are more

efficient, as not only the standards analysis but market transformation programs could be

affected as well. According to NRDC, the utility of product clothes dryer is to dry wet clothes,

and whether that is achieved through tumble action or the addition of heat are technical issues

with which consumers are not concerned. (NRDC, Public Meeting Transcript, No. 4.6 at pp. 38–

39)

DOE is unaware of any commercially available microwave dryers that are currently for

sale in the United States or any other country. Because of research conducted on such dryers in

the past, however, DOE considered microwave drying as a technology option for improving

efficiency in electric clothes dryers. As discussed in chapters 3 and 4 of the preliminary TSD,

significant technical challenges are associated with microwave drying technology and DOE

screened this technology out due to safety issues. As a result, DOE does not believe that changes

to the clothes dryer definitions to cover microwave drying would be warranted. DOE notes that

heat pump dryers commercially available in Europe and Japan include a tumbling action and, as

such, would be included under the DOE definition of a clothes dryer. DOE has included heat

pump drying as a technology option evaluated as part of the preliminary analyses, as discussed in

chapter 5 of the preliminary TSD.

b A notation in the form “EEI, Public Meeting Transcript, No. 4.6 at pp. 37–38” identifies an oral comment that

DOE received during the October 24, 2007, framework public meeting and which was recorded in the public

meeting transcript in the docket for the standards rulemaking for clothes dryers and room air conditioners (Docket

No. EE­2007­STD­0010), maintained in the Resource Room of the Building Technologies Program. This particular

notation refers to a comment (1) made by the Edison Electric Institute (EEI) during the public meeting, (2) recorded

in document number 4.6, which is the public meeting transcript that is filed in the docket of this rulemaking, and (3)

which appears on pages 37 through 38 of document number 4.6. c A notation in the form “EEI, No. 5 at p. 2” identifies a written comment that DOE has received and has included in

the docket of the standards rulemaking for clothes dryers and room air conditioners (Docket No. EE­2007­STD0010). This particular notation refers to a comment (1) Submitted by the EEI, (2) in document number 5 in the

docket of that rulemaking, and (3) appearing on page 2 of document number 5.

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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.

DOE did not receive any comments on this definition.

2.2.2 Product Classes and Scope of Coverage

When evaluating and establishing energy conservation standards, DOE generally divides

covered products into product classes by the type of energy used or by capacity or other

performance­related features that affect efficiency. Different energy conservation standards may

apply to different product classes. (42 U.S.C. 6295(q))

DOE received several comments from interested parties regarding the product classes and

their organization. Specifically, DOE received comments regarding the inclusion of additional

clothes dryer product classes, particularly for vent­less clothes dryers, the room air conditioner

product classes, and potential inclusion of portable air conditioners in the rulemaking.

2.2.2.1 Residential Clothes Dryers

In the framework document, DOE proposed to analyze six product classes for residential

clothes dryers (for details on these product classes, see chapter 3 of the preliminary TSD). In

particular, DOE proposed four product classes for vented clothes dryers, which are already the

subject of existing DOE energy conservation standards, and proposed two new product classes

for vent­less clothes dryers, including vent­less electric compact (240 V) and combination

washer/dryers. This is a new analytical structure for clothes dryers, recognizing the unique utility

that vent­less clothes dryers offer to consumers.d

AHAM, Whirlpool Corporation (Whirlpool), and Alliance Laundry Systems (ALS)

supported the proposed product classes, but added that DOE should include vent­less electric

standard (240 V) (4.4 cubic feet or greater capacity) clothes dryers as a product class to address

the waiver that was granted on this unit several years ago. (AHAM, No. 8 at p. 3; Whirlpool, No.

7 at p.3; ALS, No. 6 at p.1) AHAM added that this product class is currently a very small part of

the market, but perhaps will become a larger portion in the future. (AHAM, Public Meeting

Transcript, No. 4.6 at pp. 43–44) The Joint Comment supported DOE’s inclusion of vent­less

clothes dryers in this rulemaking, even though the long drying cycle time suggests market uptake

in the United States will be slow, adding that the best time to establish coverage and test methods

for emerging product types is before they gain market share. (Joint Comment, No. 9 at p. 12) In

its data requests and research, DOE was unable to identify any information indicating that ventd 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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less electric standard (240 V) clothes dryers are on the market in the United States. Therefore,

DOE is not proposing an additional product class covering such dryers.

In addition, the Joint Comment stated that DOE should add a new product class for

clothes dryers with 240 V, greater than 4.4 cubic feet. The Joint Comment also questioned

whether this product class should include 3­phase equipment, since this type of product is not

generally available for residential service. According to the Joint Comment, it is important that

this "supersize" class have high efficiency (moisture removed per kilowatt­hour (kWh)). (Joint

Comment, No. 9 at p. 12) The Joint Comment did not support separate classes for non­vented

(condensing) dryers, microwave dryers, heat pump dryers, or other advanced technologies. (Joint

Comment, No. 9 at pp. 12–13) DOE notes that the vented electric standard product class already

includes 240 V clothes dryers with capacities greater than 4.4 cubic feet; therefore, DOE intends

to maintain this product class. DOE agrees that microwave and heat pump dryers do not warrant

a separate product class and, as noted in the framework document, is considering these as

technologies options for electric clothes dryers. For vent­less clothes dryers, including

condensing dryers, DOE maintains its position stated in the framework document that vent­less

clothes dryers provide unique utility to consumers in that they do not require an external vent and

can be installed in locations where venting dryers would be precluded due to venting restrictions.

Thus according to the EPCA criteria, such unique utility warrants a separate product class. (42

U.S.C. 6295 (q) and 6316(a))

EEI questioned whether DOE should include combination washer/dryers in this

rulemaking. EEI stated it would support this expansion of product classes from the product

classes defined in past energy conservation rulemakings if combination units obtained a

significant (4–5 percent) share of new sales. EEI also supported the addition of other vent­less

clothes dryer products. (EEI, No. 5 at pp. 2–3) Whirlpool commented that combination

washer/dryers would require a unique test procedure and that DOE should weigh the effort to

create such a procedure against the potential for energy savings from a product category with

very modest annual unit sales. (Whirlpool, No. 7 at p. 3) In the framework document, DOE

proposed to analyze a separate product class for combination washer/dryers based upon their

unique utility of washing and drying in a single combined cycle and the flexibility in installation

locations. DOE notes it has initiated a separate test procedure rulemaking concurrent with this

rulemaking to address active mode test procedures for clothes dryers and room air conditioners.

As part of this test procedure rulemaking, DOE is considering provisions for testing vent­less

clothes dryers, which include combination washer/dryers. DOE notes that this energy

conservation standards rulemaking addresses the drying cycle energy consumption of a

combination washer/dryer and would not regulate the washing cycle, which is covered under the

clothes washer energy conservation standards. DOE is unaware of any market share data for

combination washer/dryers, but would consider such data if it is made available.

ACEEE questioned which product classes would cover microwave dryers and heat pump

dryers in light of the definition of tumbling action. These technologies are not now a factor in the

U.S. market, but represent a reference point of what could be implemented. (ACEEE, Public

Meeting Transcript, No. 4.6 at p. 44) DOE has considered both microwave drying and heat pump

dryers as technology options for all electric clothes dryers for the preliminary analyses. As noted

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above, DOE screened out microwave drying due to safety issues. In addition, DOE analyzed heat

pump technology for both vented and vent­less product classes in the engineering analysis.

Whirlpool opposes adding a product class for non­tumbling (i.e., cabinet) clothes dryers,

since the unit volume of such products is de­minimus and the relatively high cost and significant

space requirements for these products would be expected to keep the volume low. (Whirlpool,

No. 7 at p. 3) DOE believes that non­tumbling dryers represent a very small portion of the U.S.

market. DOE also notes that non­tumbling cabinet dryers are not covered under the definition of

a clothes dryer under EPCA. (10 CFR 430.2) For these reasons, DOE did not include an

additional product class for non­tumbling cabinet dryers.

2.2.2.2 Room Air Conditioners

In the framework document, DOE proposed to consider amended energy conservation

standards for the same 16 room air conditioner product classes that are the basis of the existing

DOE energy conservation standards. (For details on these product classes, see chapter 3 of this

TSD). AHAM commented that the 16 proposed room air conditioner product classes are

appropriate. (AHAM, No. 8 at p. 3) DOE did not receive any comments objecting to these

product class definitions or proposing alternative product classes. Therefore, DOE will continue

to consider in the preliminary analysis the 16 product classes for room air conditioners proposed

in the framework document.

The Consortium for Energy Efficiency (CEE) commented that portable air conditioners

should be included in the rulemaking. (CEE, No. 10 at p. 2) Portable air conditioners are

products with cooling capacities similar to those of room air conditioners. Unlike room air

conditioners, they rest on the floor, often on wheels, with a short ducted connection to a window

or other access to the outside to vent warm condenser air and, for some of these products, to

provide condenser cooling air from the outside. Because portable air conditioners are intended to

be readily moved to different locations, they are not currently covered by the DOE definition of

room air conditioners, which specifies that the unit be designed for mounting in a window or

through the wall. In addition, there is currently no DOE test procedure applicable to portable air

conditioners. Therefore, portable air conditioners will not be considered in this rulemaking.

2.2.3 Test Procedures

In response to the framework document, DOE received several comments from interested

parties regarding potential amendments to the DOE test procedures for residential clothes dryers

and room air conditioners.

2.2.3.1 Residential Clothes Dryers

In the framework document, DOE identified the following potential issues for the DOE

test procedure for residential clothes dryers: (1) the remaining moisture content (RMC) specified

for the start of the clothes dryer test is inconsistent with the RMC at the end of the residential

clothes washer test procedure and may not be representative of current clothes dryer loads; (2)

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the average residential clothes dryer annual use cycles has likely decreased since the test

procedure was developed and may not be representative of current consumer usage habits, (3)

the test procedure is currently unable to measure vent­less clothes dryers; and (4) the test

procedure may not adequately measure the benefits of automatic termination.

ACEEE supported changes to the DOE clothes dryer test procedure, but was concerned

that the changes would slow down the implementation of a new standard. ACEEE added that

they would work with all interested parties to address this concern. (ACEEE, Public Meeting

Transcript, No. 4.6, pp. 19­20) AHAM questioned how DOE would proceed with a clothes dryer

test procedure change at the same time that it needed to collect data for the standards rulemaking.

AHAM stated that the best case would be if the test procedure change is done first. (AHAM,

Public Meeting Transcript, No. 4.6, p. 20) AHAM indicated that they would be committed to try

and provide inputs for the clothes dryer test procedure changes within a period of months.

(AHAM, Public Meeting Transcript, No. 4.6, p. 22) EEI added that if the clothes dryer test

procedure change is not ready before the Pre­NOPR stage, it could cause a lot of confusion

because the Pre­NOPR might be based on the previous test procedure while the NOPR might be

based on a new one. (EEI, Public Meeting Transcript, No. 4.6, p. 21)

DOE believes that concurrent development of test procedures and energy conservation

standards is appropriate. EPCA requires that DOE determine “to what extent, if any, the

proposed test procedure would alter the measured energy efficiency . . . of any covered product

as determined under the existing test procedure.” (42 U.S.C. 6293(e)(1)) If DOE determines that

the amended test procedure would alter the measured efficiency of a covered product, DOE must

amend the applicable energy conservation standard during the rulemaking carried out with

respect to such test procedure. (42 U.S.C. 6293(e)(2))

Remaining Moisture Content

The current DOE clothes dryer test procedure specifies that the clothes load have an

initial RMC of 70 ± 3.5 percent. DOE indicated in the framework document that the RMC of

typical clothes loads in the residential clothes washer test procedure should be consistent with

values defined in the clothes dryer test procedure. DOE also noted that it believes that the initial

RMC in the clothes dryer test procedure may not reflect typical RMCs of actual clothes dryer

loads. DOE suggested in the framework document that an initial RMC of 56 percent would be

more representative of actual clothes dryer loads based on DOE’s estimate from the most recent

clothes washer energy conservation standards rulemaking of the weighted­average RMC for

clothes washers at the time most recent standards became effective (January 1, 2007).

AHAM commented that an RMC of 56 percent is realistic and stated that it will collect

additional information to validate this. (AHAM, No. 8 at p. 1) Whirlpool added that the

weighted­average RMC from clothes washers that Whirlpool sells in North America is

approximately 56 percent and concurred that a revised test procedure should use that value.

(Whirlpool, No. 7 at pp. 1–2) CEE, EEI, and ALS all supported revising the clothes dryer test

procedure to account for lower RMC. (CEE, No. 10 at p. 1; EEI, No. 5 at p. 2; ALS, No. 6 at p.1)

CEE further commented that this reduced RMC for clothes dryers is likely due to recent

improvements in clothes washers, particularly the entrance of horizontal­axis washers with high

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spin speeds and significantly reduced RMC. (CEE, No. 10 at p. 1) ALS stated that the clothes

washer test procedure is a regulation that greatly influences residential clothes dryer efficiency,

since RMC is tied to energy and the time required for drying. According to ALS, in previous

rulemakings, all stakeholders realized it is more efficient to remove water in the clothes washer

than in the dryer. (ALS, No. 6 at p. 5)

The Joint Comment also agreed that a lower RMC for the clothes dryer test procedure is

justified. The Joint Comment referenced California Energy Commission (CEC) data for the

relationship between clothes washer modified energy factor (MEF) and RMC, which shows that

models just meeting current energy conservation standards have an average RMC of 55 percent.

The Joint Comment also noted that a regression fit through the entire CEC data set shows a

clothes washer with an MEF of 0.817 (which approximates pre­2001 standards) would have an

estimated RMC of 72 percent, which is comparable to the value in the existing clothes dryer test

procedure. (Joint Comment, No. 9 at pp. 12–13)

DOE agrees that a review of clothes washer models in the CEC database suggests that the

average RMC is less than the nominal 70 percent which is currently provided for in the DOE

clothes dryer test procedure. Therefore, DOE is considering amendments to the clothes dryer test

procedure to address RMC in a separate active mode test procedure rulemaking.

Average Clothes Dryer Annual Use Cycles

DOE noted in the framework document that the average number of use cycles assumed in

the revised clothes washer test procedure is inconsistent with the use cycles in the clothes dryer

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

published a final rule on August 27, 1997, amending the DOE clothes washer test procedure to

lower the annual clothes washer use cycle value from 416 to 392 cycles per year, a value DOE

determined to be more representative of current usage patterns. 62 FR 45484 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.

AHAM supported changing the DOE clothes dryer test procedure to decrease the use

cycles from 416 to 329 cycles per year, as proposed by DOE, based on usage patterns for

residential clothes washers. (AHAM, No. 8 at p.1) CEE also supported decreasing the number of

use cycles to be more consistent with the clothes washer test procedure. CEE noted that in the

amendments to the DOE test procedure for clothes washers adopted in 1997, the clothes dryer

utilization factor (i.e. percentage of clothes washer loads dried in clothes dryers) was set to 84

percent. However, CEE was unsure whether 392 cycles or 329 (84 percent of 392) is the correct

number of annual clothes dryer cycles, and recommended that DOE re­examine the clothes dryer

utilization factor. (CEE, No. 10 at p. 1) EEI believes that the test procedure should have fewer

annual use cycles based on the Energy Information Administration’s (EIA’s) Residential Energy

Consumption Survey (RECS) data and demographic projections. (EEI, No. 5 at p. 2)

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Whirlpool commented that 392 annual clothes washer cycles is generally accepted as

valid; however, the assumption of 84 percent of clothes washer loads being machined dried is

high. Whirlpool cited data from Proctor & Gamble, which indicates that consumers average 5.72

loads per week, or 297 annually, and that line drying and blocking are a common alternative to

machine drying. Whirlpool noted other surveys suggest that annual laundry (wash) loads are

closer to 343 than 392, which, if the 84 percent was applied, would give 288 annual clothes dryer

loads. Whirlpool believes that the annual number of clothes dryer cycles should be 298 (or 76%

of the 392 washer loads). (Whirlpool, No. 7 at p. 2)

The Joint Comment believes that DOE should request manufacturers to verify that the

ratio of clothes dryer cycles to washer cycles is 84 percent. The Joint Comment believes that

DOE should establish the number of annual clothes dryer cycles independent of the number of

annual clothes washer cycles because some laundry is washed but not dried in a dryer, while

some dryer loads have not been washed. The Joint Comment also noted that many recently

manufactured clothes dryers have software that logs the number of cycles, and manufacturers

could provide cycle count data for clothes dryers with at least 1 full year of operation (to account

for month­to­month variations). The Joint Comment stated that another potential data source is

the California Measurement Advisory Council (CALMAC), which documents appliance energy

use in California. (Joint Comment, No. 9 at pp. 10–11)

DOE is reviewing available data on the number of annual clothes dryer cycles, and will

consider amendments to its test procedure in the active mode test procedure rulemaking to

accurately reflect the number of annual clothes dryer cycles for the clothes dryer tests.

Test Procedure for Vent­less Clothes Dryers

DOE noted in the framework document that a potential limitation of the clothes dryer test

procedure had been identified for vent­less dryers, which includes condensing clothes dryers and

combination washer/dryers. Manufacturers of vent­less clothes dryers commented 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. 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.

DOE also noted in the framework document, to address the potential limitation of the

clothes dryer test procedure for vent­less dryers, DOE proposed an alternate test procedure for

vent­less dryers in in LG Electronics, Inc.’s (LG’s) Petition for Waiver and Denial of the

Application for Interim Waiver. 71 FR 49437, 49439 (Aug. 23, 2006). The proposed revisions

consisted 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

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procedure qualified the requirement for an exhaust simulator so that it would only apply to

conventional clothes dryers.

ALS and CEE both supported revising the DOE clothes dryer test procedure to test ventless clothes dryers. (ALS, No. 6 at p. 1; CEE, No. 10 at pp. 1–2) AHAM also supported

including a provision to test vent­less clothes dryers, but added that a single procedure for vented

and vent­less clothes dryers may not be applicable. (AHAM, No. 8 at p. 1) AHAM commented

that adding ventless clothes dryers to the test procedure is not as simple as closing a vent off, but

may require a more significant change to the test procedure methods to appropriately measure

energy use. AHAM added that it would work on developing such a procedure for DOE to

measure energy use. (AHAM, Public Meeting Transcript, No. 4.6 at pp. 18–19) AHAM

commented that the energy calculation for vent­less clothes dryers should take a more “holistic”

approach than those for vented clothes dryers, because vent­less clothes dryers can have an effect

on energy use outside of their system (i.e., impacts on HVAC loads). (AHAM, Public Meeting

Transcript, No. 4.6 at p. 51; AHAM, No. 8 at p. 3) Whirlpool commented that, in light of

increasing interest by manufacturers in offering vent­less clothes dryers in North America, it

would work through AHAM to propose an appropriate test procedure for measuring such units.

(Whirlpool, No. 7 at p. 2) Whirlpool also noted that combination washer/dryers would require a

unique test procedure, and that DOE should weigh the effort to create such a test procedure

against the potential for energy savings from a product with very modest annual unit sales.

(Whirlpool, No. 7 at p. 3)

DOE believes that the availability of vent­less clothes dryers on the market warrants the

definition of a separate product class for these units in this rulemaking, as discussed in chapter 3

of this TSD. For DOE to analyze potential energy conservation standards for vent­less clothes

dryers, provisions must be added to the DOE clothes dryer test procedure to measure the energy

efficiency performance in vent­less clothes dryers. DOE is, therefore, considering amendments

to its clothes dryer test procedure to allow for the measurement of the energy efficiency of ventless clothes dryers in its active mode test procedure rulemaking. As part of this rulemaking, DOE

will consider the methodology it proposed in an alternate test procedure for condenser clothes

dryers in LG’s Petition for Waiver and Denial of the Application for Interim Waiver discussed

above, as well as other methodologies suggested by interested parties.

AHAM also commented that for water­cooling clothes dryers, the energy­use calculation

should include water­use cost. (AHAM, No. 8 at p. 4) Based upon its review of products on the

U.S. market, DOE is unaware of any vent­less electric compact (240V) condensing dryers that

use water in a heat exchanger to condense moisture in the air exiting the drum, and instead use

an air­to­air heat exchanger. DOE review of dryers on the U.S. market showed that only ventless combination washer/dryers use water to condense moisture in the air exiting the drum. DOE

intends to address the issue of water consumption for combination washer/dryers in the

concurrent clothes dryer active mode test procedure rulemaking.

Automatic Termination

In the framework document, DOE stated that it believes that the clothes dryer test

procedure may not adequately measure the benefits of automatic cycle termination, in which a

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sensor monitors either the exhaust air temperature or moisture in the drum to determine the

length of the drying cycle. Currently, the test procedure provides a single credit for 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 and accuracy of the control system.

AHAM, EEI, ALS, and CEE commented that the clothes dryer test procedure should be

changed to better account for the use of automatic cycle termination. (AHAM, No. 8 at p. 2; EEI,

No. 5 at p. 2; ALS, No. 6 at p. 1; CEE, No. 10 at p. 2) Whirlpool commented that automatic

termination reduces over­drying or under­drying. Over­drying wastes energy directly and underdrying leads to consumer use of a second clothes drying cycle. Whirlpool believes that the test

procedure should credit both temperature sensing and moisture sensing automatic termination,

and, because moisture sensing is less subject to over­ or under­drying, this approach should

receive greater credit. Whirlpool added that they would need additional time to evaluate a

specific recommendation on the nature of the credit. (Whirlpool, No. 7 at p. 2)

The Joint Comment stated that DOE should verify the benefits of automatic cycle

termination for clothes dryers and that testing should be conducted on new and accelerated­use

models to verify long­term effectiveness. The Joint Comment added that the test procedure

should not provide any “default” efficiency credit for reduced cycle time unless such benefits

have been verified through actual testing. (Joint Comment, No. 9 at p. 13) ACEEE questioned

whether the current test procedure allows for ambiguity or less­than­optimum results in terms of

cycle termination when the clothes are defined to be dry. (ACEEE, Public Meeting Transcript,

No. 4.6 at p. 36)

DOE agrees that the benefit of automatic cycle termination should be more accurately

credited in its clothes dryer test procedure, and that this credit should properly account for any

over­ or under­drying. Thus, DOE is considering clothes dryer test procedure amendments to

address automatic cycle termination in the active mode test procedure rulemaking.

Test Load Sizes

Currently the DOE test procedure for clothes dryers requires a 7.00 lb ± .07 lb test load

for standard size dryers and a 3.00 lb ± .03 lb test load for compact size dryers. The Joint

Comment stated that DOE should determine whether the average test load weight for standard

capacity dryers is consistent with the current generation of washer capacities. The Joint

Commented noted that, according to AHAM data, the average tub volume of washers has been

increasing. The Joint Comment indicated that between 1981 when the dryer testing protocol was

established in 2004, the average washer tub volume increased by more than 20 percent (2.52 ft.3

to 3.05 ft.3) The Joint Comment also pointed out that in the current DOE clothes washer test

procedure the maximum test load weight of a 2.52 ft.3 machine is 10.5 lbs, while the maximum

test load weight of a 3.05 ft.3 machine is 12.5 lbs. The Joint Comment stated that if the ratio of

the maximum test load weights is applied to the test load weight in the clothes dryer test

procedure, this would imply that the current 7 lb test load weight should be adjusted upward by

about 20 percent to 8.3 lbs. The Joint Comment added that DOE should request that

manufacturers provide field data to document that the current test load weight for standard

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capacity dryers should not be adjusted upward to account for the increased capacity of clothes

washers. The Joint Comment also stated that DOE should interview detergent manufacturers

since they are among the most knowledgeable parties in the laundry industry. (Joint Comment,

No. 9 at pp. 11–12)

DOE is reviewing available data to determine the current representative clothes dryer

load size, and will consider amendments to its test procedure in the active mode test procedure

rulemaking to accurately reflect the current clothes dryer test load size for the clothes dryer tests.

Additional Test Procedure Issues

ACEEE requested that DOE consider whether the induced infiltration associated with

vented clothes dryers has an energy impact that's worth considering on an annual basis, and

whether the consumer value would be proportional to the difficulties in doing it. (ACEEE, Public

Meeting Transcript, No. 4.6 at pp. 51­52) DOE is unaware of any data indicating induced

infiltration associated with vented clothes dryers has an energy impact; therefore, DOE does not

intend to analyze this at this time, but welcomes data showing such energy impacts.

Whirlpool noted that the DOE clothes washer test procedure defines a modified energy

factor (MEF) which includes RMC, pointing out that this created a “laundry system” efficiency

measure, as much of the work of clothes drying is a function of the moisture extraction which

takes place in the clothes washer. Whirlpool believes this laundry system measure invalidates the

need for any measure of dryer efficiency. (Whirlpool, No. 7 at p. 1) As noted above, DOE

intends to address the issue of initial RMC as part of the clothes dryer active mode test procedure

rulemaking. DOE believes that using a representative initial RMC will produce measures of

clothes dryer efficiency that do not overlap with the efficiency metric of clothes washers.

2.2.3.2 Room Air Conditioners

In response to the framework document, DOE received comments from interested parties

on its room air conditioner test procedure addressing: (1) the annual hours of operation; (2)

consideration of part­load performance; (3) an update of the references to commercial test

procedure standards; and (4) the test procedure ambient temperature.

Annual Operating Hours

DOE pointed out in the framework document that the 1997 TSD supporting the previous

room air conditioner rulemaking indicated average room air conditioner operating hours per year

of nearly 500, in contrast to the 750 hours per year specified in the current DOE test procedure.

CEE commented that it doesn’t believe the annual hours of operation have decreased from 750 to

500, citing information from the Northwest Power & Planning Council’s Regional Technical

Forum, which is claimed to represent a low­usage area. Such information suggests a 628­hour

average annual usage. (CEE, No. 10 at p. 2) AHAM also commented that the room air

conditioner test procedure should be changed to account for fewer annual operating hours.

(AHAM, No. 8 at p. 2) The Joint Comment stated that DOE should update the room air

conditioner test procedure for annual operating hours to reflect the best available information and

to seek justification other than manufacturer assertions. The Joint Comment suggested checking

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the New York State Energy Research and Development Authority or the New York Department

of Public Service, which have considerable ratepayer investments in upgrading room air

conditioners to more efficient models, and analysis to support this program may include data on

hours of operation. (Joint Comment, No. 9 at p. 8)

DOE recognizes the uncertainty regarding room air conditioner usage patterns, and has

initiated a test procedure rulemaking that will address room air conditioner active mode issues,

including annual hours of usage. While there are limited data available on this issue, DOE is

investigating a range of information sources to develop as accurate an estimate of annual

operating hours as possible. The analysis for the active mode test procedure rulemaking will take

into consideration the life­cycle cost (LCC) analysis for room air conditioners conducted as part

of this energy conservation standards rulemaking, which included a separate investigation of this

issue. This analysis, described in chapter 8 of the preliminary TSD, suggests that the annual

hours of operation have increased since this issue was investigated in the previous rulemaking.

Part­Load Performance

DOE noted in the framework document that the current DOE room air conditioner test

procedure measures full­load performance, and is not able to assess energy savings associated

with technologies that improve part­load performance. AHAM commented that the room air

conditioner test procedure should not include part­load performance or SEER ratings, stating that

it is not realistic or applicable to room air conditioners. According to AHAM, room air

conditioners are a commodity item with a compressor that operates only in on/off mode, and that

consumers historically have not been willing to pay for part­load performance options. (AHAM,

No. 8 at p. 2; AHAM, Public Meeting Transcript, No. 4.6 at p. 24) CEE commented that peak

load is of greater significance for room air conditioners than part load. CEE recommended a twopart reporting requirement based on both EER and SEER. CEE believes that including part­load

operation in the test procedure would have more relevance for milder climates. (CEE, No. 10 at

p. 2) NRDC commented that if just one energy use metric is used, it should be EER, since peak

load is most important for room air conditioners, and because it is difficult to develop a SEER

test procedure which accurately reflects real­world performance. However, NRDC recommended

the use of two energy­use metrics, one for peak load and one for part load. (NRDC, Public

Meeting Transcript, No. 4.6 at pp. 25–26) ACEEE commented that a SEER rating is not

appropriate for room air conditioners due to their impact on utility peak demand. (ACEEE,

Public Meeting Transcript, No. 4.6 at p. 25) Finally, the Joint Comment indicated that there is no

compelling reason to change from an EER rating, and that if a SEER rating is considered, it

should be used in addition to EER. (Joint Comment, No. 9 at p. 8)

DOE notes that 42 U.S.C. 6292(22)(B) requires the efficiency descriptor for room air

conditioners to be reported as EER. DOE also concludes that widespread use of part­load

technology in room air conditioners would probably not occur as a result of development of a

SEER rating, and hence the significant effort of development of an accurate SEER rating is not

likely to be warranted by the expected minimal energy savings. Therefore, DOE does not plan to

consider amendments to its room air conditioner test procedure to measure part­load

performance.

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Referenced Test Standards

AHAM and EEI both commented that the room air conditioner test procedure should be

amended to reference the latest American National Standards Institute (ANSI) and American

Society of Heating, Refrigerating and Air­Conditioning Engineers (ASHRAE) test standards.

(AHAM, No. 8 at p.2; EEI, No. 5 at p. 2) DOE has reviewed the most recent versions of the

referenced test procedures, and has determined that incorporation by reference of these versions

would not negatively impact EER measurement. Therefore, DOE expects to update these

references as part of the room air conditioner active mode test procedure rulemaking.

Ambient Test Temperature

The Joint Comment recommended increasing the ambient temperature of the DOE

energy test procedure from 95 °F to 115 °F, stating that room air conditioners are generally

operated when the outdoor temperatures are the highest, and that they are often located on the

south or west side of residences where the sun can shine on them during operation. (Joint

Comment, No. 9 at p. 9) DOE did not receive further information to support the specification of

the higher temperature, and therefore is not considering amending the ambient test conditions

specified in the room air conditioner test procedure at this time.

2.2.3.3 Standby and Off Mode Energy Use

Section 310 of the Energy Independence and Security Act of 2007 (EISA 2007), Pub. L.

110­140, amended section 325 of EPCA to mandate that test procedures for all covered products

be amended to include standby mode and off mode energy consumption, and that this energy

consumption be integrated into the overall energy efficiency or other energy descriptor for the

product, unless the current test procedure already incorporates the energy use of these modes or

such an integrated test procedure is technically infeasible. (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 notice of proposed rulemaking (NOPR) for this rule on December 9, 2008. 73 FR

74639. This topic is discussed in greater length in chapter 3. 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.

The clothes dryer and room air conditioner energy conservation standards framework

meeting and the framework comment period took place prior to enactment of EISA 2007.

Stakeholders made no comments regarding standby and off mode energy use.

2.2.4 Technology Assessment

As part of the market and technology assessment, DOE develops a list of technologies for

consideration for improving the efficiency of residential clothes dryers and room air

conditioners. Initially, these technologies encompass all those DOE believes are technologically

feasible. Chapter 3 of the preliminary TSD includes the detailed list of all technology options

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identified for residential clothes dryers and room air conditioners. DOE received several

comments in response to the technologies proposed in the framework document to be analyzed

for residential clothes dryers and room air conditioners.

2.2.4.1 Residential Clothes Dryers

AHAM commented that the clothes dryer technology options list is very long and will be

a difficult analysis. AHAM recommended cutting the list down, particularly because, for the

design­option approach, industry will need to provide manufacturing costs for each, which could

be a very difficult process. (AHAM, Public Meeting Transcript, No. 4.6 at pp. 55–56) EPCA

requires DOE to establish energy conservation standards that achieve the maximum

improvement in energy efficiency that are technologically feasible and economically justified.

As a result, eliminating options on the basis articulated by AHAM is inappropriate. Based on the

limited availability of aggregated manufacturing cost­efficiency data and discussions with

manufacturers, however, DOE determined that multiple design changes and approaches were

used by various manufacturers to meet the different efficiency levels. As a result, and as

discussed further in chapter 5 of this preliminary TSD, DOE intends to use an efficiency­level

approach for the clothes dryer engineering analysis instead of the design­option approach

proposed in the framework document. Therefore, DOE retains the list of technology options

presented in the framework document in the screening and engineering analyses. DOE also adds

two technology options as a result of the individual review discussed below.

ASAP commented that using only the prior rulemaking to come up with technology

options could lead to erroneous results. (ASAP, Public Meeting Transcript, No. 4.6 at p. 59)

Whirlpool commented that it is unaware of any proprietary designs for clothes dryers.

(Whirlpool, No. 7 at p. 6) Although DOE used the technologies identified from the previous

rulemakings as a starting point, DOE conducted extensive reviews of literature and research

reports as well as reviews of the latest product literature in order to develop a comprehensive list

of technology options. DOE also solicited feedback from interested parties on additional

technologies to consider as part of the framework document. DOE acknowledges Whirlpool’s

comment and has also not identified any proprietary designs for clothes washers. For a complete

list of the technology options identified, see chapter 3 of this preliminary TSD.

Technologies Proposed in the Framework Document

AHAM commented that the industry feels that increased insulation for clothes dryers

would have little impact on energy efficiency for current models, although the impact could be

greater for other heat generation options. (AHAM, Public Meeting Transcript, No. 4.6 at p. 56)

Based on its review of this technology option and discussions with manufacturers, DOE believes

that increased insulation provides an opportunity for improving efficiency and should continue to

be considered as part of the preliminary analyses.

AHAM and ALS requested clarification on the "modified operating conditions" and

"improved drum design" technology options for clothes dryers, particularly in terms of cost

information. (AHAM, Public Meeting Transcript, No. 4.6 at p. 56; ALS, Public Meeting

Transcript, No. 4.6 at p. 58) ALS added that "improved drum design" would already be offered

2­16

EERE-2007-BT-STD-0010 COMMENT 20.3
                           

                                 

                           

                             

                                     

           

                   

                             

                           

                         

                       

                                 

                                   

                             

                               

                       

                         

               

                         

                             

                           

                             

                               

                             

                             

                         

                             

                           

                               

                               

                           

                           

   

                       

                           

                                 

                   

                           

                       

                               

by manufacturers if it improved efficiency. ALS is not aware of any other clothes dryer

technologies besides the ones identified by DOE. (ALS, No. 6 at p. 2) AHAM stated that the

energy effects of clothes dryer improved drum design depend upon the specific design. AHAM

and Whirlpool stated that this item needs to be clarified before commenting further. (AHAM No.

8 at p. 4; Whirlpool No. 7 at p. 4) DOE has included descriptions of these technology options in

chapter 3 of this preliminary TSD.

AHAM stated that microwave clothes drying technology was investigated thoroughly

many years ago. According to AHAM, there has not been much successful work on this

technology since then, and therefore microwave drying would not be relevant as a heat

generation technology. (AHAM, Public Meeting Transcript, No. 4.6 at p. 57) EEI commented

that the Electric Power Research Institute (EPRI) conducted much research on microwave

clothes dryers in the 1990s, and the results were not favorable. The last research EEI was aware

of was on a portable, countertop unit for drying small loads. EEI is not familiar with more recent

research, and recommended contacting EPRI to find out if there is current research. (EEI, Public

Meeting Transcript, No. 4.6 at p. 58) For this rulemaking, DOE investigated the current state of

microwave clothes drying technology, noting that it has been demonstrated in working

prototypes and continues to offer the potential to improve efficiency. Therefore, DOE considered

microwave clothes drying technology for the screening analysis.

ALS and Whirlpool requested that "reverse tumble" be removed as a clothes dryer

technology option because it has been looked at for commercial clothes dryers, and it is

considered useful mostly for removal of wrinkling. (ALS, Public Meeting Transcript, No. 4.6 at

p.58; Whirlpool, No. 7 at p. 4) ALS added that if reverse tumbling increased efficiency,

manufacturers would be incorporating it in their clothes dryers. (ALS, No. 6 at p. 2) Whirlpool

also commented that testing has shown that reverse tumble has no impact on energy efficiency

(Whirlpool, No. 7 at p.4) DOE investigated this technology option and agreed with ALS and

Whirlpool that reverse tumble is a consumer­related feature used primarily for removal of

wrinkling, and its effect on efficiency is uncertain. DOE believes that, in some circumstances, it

could actually decrease efficiency according to the DOE test procedure, because the motor must

come to a stop and then reverse direction, increasing cycle time and energy consumption by the

motor. Because, however, it is possible that a small energy savings could be associated with this

technology option under certain conditions, even though that is not the primary motivation for

manufacturers to incorporate it in clothes dryers, DOE retained this technology option for the

screening analysis.

AHAM stated that for indirect heating technology option for clothes dryers, calculations

would need to include water use cost and other information. (AHAM, Public Meeting Transcript,

No. 4.6 at pp. 56–57) DOE considers energy and water usage costs in the LCC analysis, and

retained this technology option for consideration in the screening analysis.

ASAP suggested that, because the moisture content of air leaving a clothes dryer is

typically at about 100 percent, any technology affecting exhaust temperature would cause

moisture to begin to condense. Thus, it would be difficult to remove much heat without affecting

2­17

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the system. (ASAP, Public Meeting Transcript, No. 46 at p. 60) Issues of safety are considered in

the screening analysis, so DOE retained this technology in its list of technology options.

Additional Technology Options

The Joint Comment suggested DOE add "improved air circulation" and “improved fan

efficiency” as clothes dryer technology options. The Joint Comment stated that these improve

commercial dryer efficiency and may be applicable to residential dryers. The Joint Comment

also stated that a critical component of dryer efficiency is the dryer’s ability to exhaust moist

warm air from the drum. According to the Joint Comment, dryer vent lengths in residences vary,

so the static pressure that must be overcome by the dryer fan varies considerably and dryer fans

must be efficient at low static pressures yet maintain air flow at higher static pressures. The Joint

Comment also stated motor efficiency improvements were considered as a design option in

previous clothes washer rulemakings, and because run times are comparable for clothes washers

and dryers, this design option should be evaluated for this rulemaking as well. (Joint Comment,

No. 9 at pp. 13–14)

DOE notes that the current DOE test procedure requires the use of a standard exhaust

simulator which does not capture variations in dryer vent lengths. Because improvements in fan

efficiency would reduce energy consumption even with the standard exhaust simulator, however,

DOE added improved fan efficiency to the list of technology options. DOE agrees with the Joint

Comment that improved air circulation and improved motor efficiency should be considered and

has therefore included them as part of the preliminary analysis.

2.2.4.2 Room Air Conditioners

EEI commented that DOE should consider use of variable­speed drives for evaporator

fans and compressors. (EEI, No. 5 at p. 2) Variable­capacity compressors were on the framework

document list of technology options under consideration. Variable­speed evaporator fans were

not on that list. This is a technology that can improve part­load efficiency but not full­load

efficiency. As discussed in section 2.2.3.2, such technologies have not been analyzed because the

test procedure measures only full­load efficiency and hence cannot measure efficiency

improvement associated with them.

2.3 SCREENING ANALYSIS

After DOE identified the technologies in the technology assessment that could potentially

improve the energy efficiency of residential clothes dryers and room air conditioners, DOE

conducted the screening analysis. The purpose of the screening analysis is to evaluate the

technologies to determine which options to consider further in the rulemaking analysis. DOE

consults with industry, technical experts, and other interested parties in developing a list of

technologies for consideration. DOE then applies the screening criteria to determine which

technologies are unsuitable for further consideration in this preliminary rulemaking. Chapter 4 of

the preliminary TSD, the screening analysis, contains details on the criteria that DOE uses.

2­18

EERE-2007-BT-STD-0010 COMMENT 20.3
                             

                             

                         

                                 

                                 

                               

           

           

                   

                       

                             

                   

                             

                           

                           

                           

                         

                                   

                            

                         

                         

                         

                         

                   

                     

                     

                   

                               

                     

                   

                       

                             

                     

                       

     

                     

                          

In the screening analysis, DOE reviews, in consultation with interested parties, the list of

technology options described in chapter 3 of the preliminary TSD to determine whether they (1)

are technologically feasible; (2) are practicable to manufacture, install, and service; (3) do not

have an adverse impact on product utility or availability; and (4) do not have adverse impacts on

health and safety. (10 CFR part 430, subpart C, appendix A at 4(a)(4)) DOE further considers in

the engineering analysis the technologies that it did not screen out in the screening analysis on

the basis of these criteria.

2.3.1 Geographic Boundaries of “Commercially Available Products”

DOE received several comments on the general screening analysis methodology

presented in the framework document. ACEEE questioned if the geographic boundary of

commercial availability of a technology is considered as part of the criteria of practicability to

manufacture and technological feasibility. ACEEE questioned whether DOE’s criteria for

commercially availability would be met if heat pump clothes dryers have a 10 percent market

share in another country. (ACEEE, Public Meeting Transcript, No. 4.6 at pp. 70–71) ACEEE

also commented on the criterion of practicability for manufacture in the United States. ACEEE

expressed concern that DOE could use arbitrary criteria for screening out technologies that have

been adopted elsewhere and are worthy of consideration. ACEEE stated DOE should consider

what is being done elsewhere as part of the obligation for national energy savings and as part of

the value for manufacturers. (ACEEE, Public Meeting Transcript, No. 4.6 at pp. 70–71) In

response to ACEEE’s comment, AHAM stated that DOE should use caution when considering

technologies that are manufactured and sold in Europe. According to AHAM, Europe is

significantly different from the United States in consumer preferences, home sizes, types of

electricity, and other important aspects that should be carefully considered in the screening

analysis. (AHAM, Public Meeting Transcript, No. 4.6 at p. 73)

In determining whether a technology option is practicable to manufacture and

technologically feasible, DOE considers technologies that are commercially available in other

countries in determining whether products incorporating such technologies could be

manufactured in the United States on the required scale at the time new or amended energy

conservation standards become effective. However, DOE understands that other countries may

have different electrical input requirements, different consumer expectations and utility

requirements, and other factors that may affect the domestic product design and manufacturing.

Therefore, the mere fact that a technology is commercially available in another country in itself

does not constitute technological feasibility or practicability to manufacture. DOE carefully

evaluates each such technology option individually in making such a determination.

2.3.2 Residential Clothes Dryers

DOE received the following specific comments on the residential clothes dryer

technology options shown in the framework document with regard to the screening analysis.

2­19

EERE-2007-BT-STD-0010 COMMENT 20.3
         

                       

                           

                     

           

                       

                               

                             

                       

                             

         

         

                       

                           

                           

                       

                             

                             

                           

                         

                             

                                 

                         

                             

           

                           

                           

                                 

                                   

                           

                             

                      

                     

                           

                           

                     

                           

                     

2.3.2.1 Dryer Control or Drum Upgrades

In the framework document, DOE proposed five technology options for improvement of

clothes dryer efficiency that are associated with dryer control or drum upgrades, including: (1)

improved termination; (2) increased insulation; (3) modified operating conditions; (4) reverse

tumble and (5) improved drum design.

Whirlpool stated that increased insulation is subject to insulation migration into clothing

and is not cost effective. Whirlpool stated that increased insulation should not be considered as a

technology option. (Whirlpool, No. 7 at p. 4) DOE notes that multiple manufacturers indicated in

interviews that they considered increased insulation as part of their submission of manufacturing

cost data, as aggregated by AHAM. For this reason, DOE continued to consider this technology

option for the engineering analysis.

2.3.2.2 Methods of Exhaust Heat Recovery

In the framework document, DOE proposed three technology options for improvement of

clothes dryer efficiency that are associated with methods of exhaust heat recovery, including: (1)

recycling exhaust heat; (2) inlet air preheat; and (3) inlet air preheat, condensing mode.

Whirlpool commented that any decrease in exhaust temperature due to recycling exhaust

heat and inlet air preheat technology options would lead to moisture condensation in the exhaust

tube. Whirlpool commented that water damage to the exhaust tube and dryer, along with water

infiltration into the home, could result, leading to mold and/or mildew. Whirlpool believes that

potential health risks from mold/mildew should be weighed against any potential benefits when

determining whether to pursue these options. (Whirlpool, No. 7 at p. 4) ASAP also suggested

that, because the moisture content of air leaving a clothes dryer is typically at about 100 percent,

any technology affecting exhaust temperature would cause moisture to begin to condense. Thus,

it would be difficult to remove much heat without affecting the system. (ASAP, Public Meeting

Transcript, No. 46 at p. 60)

DOE understands that decreasing the temperature of exhaust air from the drum which has

close to 100 percent relative humidity may raise issues with condensation. However, DOE also

understands that in the later stages of the drying cycle, the moisture content of the exhaust air

from the drum may be lower because less moisture is contained in the load and it becomes more

difficult to remove that moisture. Therefore, DOE believes designs which recycle exhaust heat or

pre­heat inlet air and which do not result in moisture condensation are possible, and will,

therefore, continue to consider these technology options for the engineering analysis.

Whirlpool commented that inlet air pre­heat for condensing mode warrants pursuit,

subject to the definition of standard and compact condensing dryer classes and appropriate test

procedure amendments to measure them. (Whirlpool, No. 7 at p.4) As noted above, DOE has

initiated a test procedure rulemaking to address provisions for testing vent­less (condensing)

clothes dryers and is considering separate product classes for vent­less clothes dryers for the

preliminary analyses. DOE, therefore, considered this technology option for the proposed vent2­20

EERE-2007-BT-STD-0010 COMMENT 20.3
                               

                   

                          

     

      

                       

                         

                       

             

                             

                                 

                                 

                             

                         

                                 

                         

                               

                             

                         

                         

                                 

                               

                               

                         

                             

                               

                               

                                   

                     

                             

                               

                           

                             

                         

                                                

                                 

   

less clothes dryer product class, and determined that designs which pre­heat inlet air and in the

process condense moisture are technologically feasible because vent­less dryers already

incorporate means for managing water removal. DOE thus retained this technology option for

the engineering analysis.

2.3.2.3 Heat Generation Options

In the framework document, DOE proposed five technology options for improvement of

clothes dryer efficiency that are associated with heat generation options, including: (1) heat

pump, electric only; (2) microwave, electric only; (3) modulating, gas only; (4) water­cooling,

vent­less electric only; and (5) indirect heating.

EEI stated that EPRI researched heat pump clothes dryers in the 1990s and the prototypes

did not work as well as expected. EEI stated that DOE should contact EPRI to determine whether

there is more recent research or case studies from other countries. If no new research exists, EEI

believes DOE should consider screening out this technology option. (EEI, No. 5 at p. 3)

DOE is aware of more recent literature and test reports investigating heat pump

technology.e DOE is also aware of at least four manufacturers of heat pump dryers in Europe and

Japan producing multiple models, and at least one of these manufacturers also sells conventional

clothes dryers in the United States. Although DOE is unaware of any heat pump clothes dryers

currently on the market in the United States, DOE believes that commercialization of heat pump

technology is sufficiently mature to retain this technology option for the engineering analysis.

EEI stated that EPRI researched microwave clothes dryers in the 1990s and the

prototypes did not work as well as expected. EEI stated that DOE should contact EPRI to find

more recent research or case studies from other countries. If no new research exists, DOE should

consider screening out these technologies (EEI, No. 5 at p. 3) AHAM and Whirlpool stated that

microwave clothes dryer technology is not a relevant technology for residential dryers, and

should not be included in this analysis. AHAM, Whirlpool, and ALS stated that any clothing

with metal components such as snaps, buckles, zippers, or rings, could not be dried due to

significant fire/safety risks from the possibility of igniting a fire due to sparking from the metal

objects. (AHAM, No. 8 at p. 4; Whirlpool No. 7 at p. 4; ALS, No. 6 p. 2)

DOE investigated this microwave drying and determined significant technical and safety

issues are introduced by the potential arcing from metallic objects. While efforts have been made

to mitigate the conditions that are favorable to arcing, or to detect incipient arcing and terminate

the cycle, the possibility of fabric damage cannot be completely eliminated. Because of these

consumer utility and safety issues, DOE screened out microwave drying. DOE is also unaware of

any commercially available microwave dryer models to date in the United States or elsewhere.

e P. Pescatore and P. Carbone. High Efficiency High Performance Clothes Dryer. Final Report to Department of

Energy. 2005

2­21

EERE-2007-BT-STD-0010 COMMENT 20.3
                           

                             

                               

                             

                             

                           

                     

                     

                           

            

                             

                       

                               

                     

                           

                       

                       

                         

                               

                           

                           

                             

                                 

                               

                           

             

                         

                           

                           

                               

                               

                       

   

           

                       

                           

                           

                         

Whirlpool commented that modulation of the heat input can be incorporated in both gas

and electric dryers. According to Whirlpool, limiting the heat input through some portion of the

drying cycle will increase the dry time, but is expected to reduce total energy consumption by

optimizing the heat input as a function of load conditions. Whirlpool agrees that this option

should be evaluated, but noted that any such evaluation must also consider the consumer tradeoff

in extended drying times. Whirlpool stated that the consumer benefits from having drying times

similar to wash times, allowing “continuous processing” of multiple laundry loads. Additionally,

Whirlpool commented that DOE should consider actual and perceived consumer concerns

regarding whether extended time and tumbling action will increase clothing wear in the dryer.

(Whirlpool, No. 7 at p. 4)

DOE agrees with Whirlpool that modulation can be applied to both gas and electric heat

clothes dryers to reduce energy consumption. DOE notes that a number of manufacturers

interviewed as part of these analyses indicated that they considered this design option as a means

to improve dryer energy efficiency in submitting aggregated cost­efficiency data through

AHAM, and did not have concerns about drying cycles becoming too long for consumer

acceptance. Therefore, DOE believes this design option can be implemented without raising

issues of consumer utility and has considered it for the engineering analysis.

Whirlpool commented that a vent­less electric clothes dryer with water­cooling to aid in

condensation of the moisture in the exhaust air would require a water source to facilitate an airto­water heat exchanger. Whirlpool stated that this would add both cost and complexity to

installation and maintenance of the product and, consequently, would not be a cost effective

option. (Whirlpool, No. 7 at p.4) DOE agrees with Whirlpool that this technology option would

add significant installation requirements to plumb in an inlet water line and a drain, as well as

add to the complexity of maintenance. In addition, the requirement for access to a water supply

and drain would limit flexibility in installation locations. For these reasons DOE screened this

technology option out of the engineering analysis.

Whirlpool stated that indirect heating would also add substantial cost and complexity to

clothes dryer installation and maintenance. Whirlpool stated that indirect heating would not be a

cost­effective technology option. (Whirlpool, No. 7 at p. 4) DOE believes that this technology

option would add complexity to installation by requiring that the dryer be plumbed into the home

heating system to circulate hot air through a heat exchanger in the clothes dryer. For these

reasons, DOE did not consider this technology option for the engineering analysis.

2.3.3 Room Air Conditioners

2.3.3.1 Heat Exchanger Surface Area Design Options

In the framework document, DOE proposed four technology options for improvement of

room air conditioner efficiency that are associated with increasing the surface area of heat

exchangers, including: (1) increased coil frontal area; (2) increased depth of coil; (3) increased

fin density; and (4) the addition of a subcooler to the condenser coil.

2­22

EERE-2007-BT-STD-0010 COMMENT 20.3
                           

                                 

                             

                         

                           

                                 

                                     

                

                           

                                   

                         

                             

                             

                             

                             

                         

                         

                                 

                       

                                 

                         

                       

           

                       

                         

                       

                     

                       

                           

                           

                         

                       

                           

                             

                         

                         

                           

                     

                           

                       

AHAM stated that increased heat exchanger coil frontal area, increased depth of coil, and

increased fin density for room air conditioners each affect the size, weight, and noise of the unit.

According to AHAM, consumers typically buy small units to fit into windows, with weight and

size being substantial purchase factors. Therefore, the use of these technology options would

negatively affect consumer utility. (AHAM, Public Meeting Transcript, No. 4.6 at p. 63; AHAM,

No. 8 at p. 4) GE stated that most room air conditioners are small, lightweight, inexpensive units.

Size and weight makes a big difference in the ability of a person to purchase and install it. (GE,

Public Meeting Transcript, No. 4.6 at p. 65)

DOE examined the range of sizes and weights of room air conditioners for products

designed to be installed in windows (i.e. product classes 1 through 5) and noted that there is a

range of sizes and weights both for baseline­efficiency products and ENERGY STAR products.

DOE concludes that the available data does not provide firm indication of allowable maxima for

physical sizes by product class or capacity. The presence of products within each product class

representing relatively wide ranges of sizes indicates that there is no clear line of demarcation

indicating where there has been excessive loss of utility associated with larger size. The DOE

engineering analysis considered design options that include increase of product size and weight

for product classes for room air conditioners designed for installation in windows. More

information on the assessment of sizes of existing products is presented in chapter 5 of this TSD.

For room air conditioners designed for through­the­wall installation (i.e. product classes 6

through 10, 12, and 14), DOE did not consider size increase, due to the large market for

replacements for these products in existing wall sleeves. DOE requests further information on

this issue, as indicated in the executive summary of the preliminary TSD.

2.3.3.2 Heat Exchanger Improvement in Heat Transfer

DOE proposed in the framework document four technology options for improvement of

room air conditioner efficiency that are associated with improving the heat transfer coefficients

of heat exchangers, including improved fin design, improved tube design, spraying condensate

onto the condenser coil, and the use of microchannel heat exchangers.

AHAM stated that microchannel heat exchangers for room air conditioners would require

very significant production line retooling, and, therefore, perhaps need not be considered as a

technology option. (AHAM, Public Meeting Transcript, No. 4.6 at p. 63–64) AHAM stated in

their written comment that microchannel heat exchangers would require a complete retooling of

the room air conditioner manufacturing process. (AHAM, No. 8 at p. 4)

ACEEE commented that a change to the manufacturing process such as the transition to

microchannel heat exchangers is not in itself a reason not to consider a technology. ACEEE

believes that microchannel heat exchangers are a widely available technology that should be

evaluated. (ACEEE, Public Meeting Transcript, No. 4.6 at p. 64) GE commented that

microchannel heat exchangers make room air conditioners more efficient, but there is a big

difference between a $30,000 automobile [which typically uses microchannel heat exchanger

technology for the air conditioning system condenser] and a $100 room air conditioner. Such

heat exchangers are expensive, and consumers expect room air conditioners to be inexpensive.

2­23

EERE-2007-BT-STD-0010 COMMENT 20.3
                             

                         

                         

                               

                             

                           

                             

                         

                                 

                                 

                     

                   

                       

                         

                       

                       

                         

                     

                         

                             

                         

                         

                             

                                 

                         

                                 

                     

                       

                           

                                 

                       

                       

                             

                             

                                   

                  

(GE, Public Meeting Transcript, No. 4.6 at p. 66) ACEEE suggested that GE was endorsing

microchannel heat exchangers for room air conditioners because the use of such technology

would make the units more efficient, smaller, and lighter. (ACEEE, Public Meeting Transcript,

No. 4.6 at p. 66) GE replied that microchannel heat exchangers are more efficient, but not

smaller and lighter, and they are much more expensive. (GE, Public Meeting Transcript, No. 4.6

at p. 66) ACEEE commented that some centralized air conditioner condenser units become very

small with microchannel heat exchangers, and that the substitution of aluminum for copper in the

heat exchange area might have some effect on take­home weight. (ACEEE, Public Meeting

Transcript, No. 4.6 at p. 66) GE stated that, in the context of microchannel heat exchangers, there

is a big difference between a $5,000 or $10,000 central air conditioning system and a $100 room

air conditioner. (GE, Public Meeting Transcript, No. 4.6 at pp. 66–67)

ACEEE, ASAP, NRDC and NPCC commented that they anticipate widespread

consideration of aluminum microchannel heat exchangers for room air conditioners, which are

ubiquitous and reliable in automotive air conditioning. These interested parties stated that the

compactness and lightness of these components could reduce shipping weight and have

marketing appeal. Lighter and smaller room air conditioner units using microchannel heat

exchangers would appeal to many consumers. (Joint Comment, No. 9 at p. 10)

While use of microchannel heat exchangers may require significant conversion of

production facilities, DOE has not been provided sufficient information to conclude that such

conversion could not be implemented in time for the scheduled effective date of the revised

energy standard. Thus, DOE cannot conclude that such technology would be impracticable to

manufacture, install or service and has retained this technology option in its analysis.

The Joint Comment stated that DOE should consider the use of condensate to assist in

cooling the coils for room air conditioners. (Joint Comment, No. 9 at p. 10) Because all current

room air conditioner designs already use this technology to improve performance, the energy

modeling discussed in chapter 5 of this TSD takes this effect into account, but use of condensate

to enhance condenser cooling is not treated as a design option.

2.3.3.3 Component Improvements

DOE proposed in the framework document three technology options for improvement of

room air conditioner efficiency through use of more efficient components. These include use of

more efficient indoor blowers or outdoor fans, use of more efficient fan motors, and use of more

efficient compressors.

The Joint Comment expressed the belief that amended room air conditioner standards

will prompt compressor and air conditioner manufacturers to develop new designs and

approaches, which enable them to meet amended standards at the lowest cost possible. The Joint

Comment also stated that the current dearth of small, high efficiency compressors on the market

for room air conditioners is not an indication of feasibility for products that will be subject to a

future standard. (Joint Comment, No. 9 at p. 10)

2­24

EERE-2007-BT-STD-0010 COMMENT 20.3
                 

                           

                   

                         

                           

                       

                               

                         

                       

                           

                             

                               

                       

                             

                     

                       

       

                     

                           

                           

                         

                     

                   

                       

                   

                             

                         

                               

                         

                       

                         

                         

                         

       

                         

                     

                           

                           

                       

The consideration of high­efficiency compressors is complicated by the conversion to R410A refrigerant, which is currently ongoing for room air conditioners because the sale or

distribution of air­conditioning and refrigeration appliances containing HCFC­22 is banned

starting January 1, 2010. 74 FR 66450 (Dec. 15, 2009). DOE contacted compressor

manufacturers to obtain performance data for R­410A compressors suitable for use in room air

conditioners. The rating condition EER of the most efficient R­410A compressors currently

available is roughly 1.0 EER less than that of the most efficient HCFC­22 compressors of similar

capacity. This EER difference is also typical for scroll compressors. The development and

commercialization of R­410A models occurred several years earlier for scroll compressors than

for the rotary compressors that room air conditioners use almost exclusively. The persistence of

the difference in EER over the years for scroll compressors suggests that nominal rating point

EER for R­410A will inherently be significantly lower than for HCFC­22. Hence, it is not certain

that rotary R­410A compressors with significantly higher EER levels than currently being

reported by compressor manufacturers will be available in time for the effective date of new

energy conservation standards for room air conditioners. DOE considered in the engineering

analysis compressor efficiency levels of the best R­410A compressors for which compressor

vendors provided performance data.

2.4 ENGINEERING ANALYSIS

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

manufacturing production cost and the efficiency for each class of residential clothes dryers and

room air conditioners. This relationship serves as the basis for cost/benefit calculations in terms

of individual consumers, manufacturers, and the nation. Chapter 5 discusses the product classes

DOE analyzed, the representative baseline units, the incremental efficiency levels, the

methodology DOE used to develop the manufacturing production costs, the cost­efficiency

curves, the impact of efficiency improvements on the considered products, and the methodology

DOE used to extend the analysis to low­shipment­volume product classes.

In the engineering analysis, DOE evaluates a range of product efficiency levels and their

associated manufacturing costs. The purpose of the analysis is to estimate the incremental MPCs

for a product that would result from increasing efficiency levels above the level of the baseline

model in each product class. The engineering analysis considers technologies not eliminated in

the screening analysis, although certain technologies were not analyzed due to negligible

incremental efficiency improvements or the inability of the existing DOE test procedures to

measure any reduction in energy use. DOE considers the remaining technologies, designated as

design options, in developing the cost­efficiency curves, which are subsequently used for the

LCC and PBP analyses.

DOE typically structures its engineering analysis around one of three methodologies: (1)

the design­option approach, which calculates the incremental costs of adding specific design

options to a baseline model; (2) the efficiency­level approach, which calculates the relative costs

of achieving increases in energy efficiency levels without regard to the particular design options

used to achieve such increases; and/or (3) the reverse­engineering or cost­assessment approach,

2­25

EERE-2007-BT-STD-0010 COMMENT 20.3
                       

                 

                         

                     

                           

               

                     

                         

                         

                           

                         

                         

                       

                     

                         

                             

            

                         

                       

                           

                       

                     

     

                       

                               

                           

                           

                         

              

                             

                           

                         

                       

     

                     

which involves a “bottom­up” manufacturing cost assessment based on a detailed bill of

materials derived from tear­downs of the product being analyzed.

In the framework document, DOE proposed to use the design­option approach for

residential clothes dryers and the efficiency­level approach room air conditioners, combining

each with the cost­assessment approach to develop a cost for each efficiency level. This

approach involved physically disassembling commercially available products, consulting with

outside experts, reviewing publicly available cost and performance information, and modeling

equipment cost. For the reasons discussed below, DOE determined in the preliminary analysis

that the efficiency­level approach was more appropriate for clothes dryers, and used this

approach for the clothes dryer engineering analysis. The efficiency levels that DOE considered in

the engineering analysis are attainable using technologies currently available on the market in

residential clothes dryers and room air conditioners, or have been demonstrated in working

prototypes. In addition, DOE associated each efficiency level with specific technologies that

manufacturers might use to provide interested parties with additional transparency of

assumptions and results and the ability to perform independent analyses for verification. Chapter

5 of the preliminary TSD describes the methodology and results of the efficiency level analysis

used to derive the cost­efficiency relationships.

In response to the approach outlined in the framework document, DOE received

comments regarding the following issues: (1) technologies not analyzed; (2) additional product

classes for full analysis; (3) the analysis approach; (4) the baseline products for residential

clothes dryers; (5) the maximum technologically feasible (max­tech) efficiency levels; (6) the

identification of efficiency levels for analysis; (7) efficiency metrics; and (8) cost­efficiency

relationships.

2.4.1 Technologies Not Analyzed

In performing the engineering analysis, DOE did not consider for analysis certain

technologies that met the screening criteria but were not evaluated for one or more of the

following reasons: (1) data are not available to evaluate the energy efficiency characteristics of

the technology; (2) available data suggest that the efficiency benefits of the technology are

negligible; and (3) certain technologies cannot be measured according to the conditions and

methods specified in the existing test procedure.

In the first case, DOE is unable to adequately assess how these technologies impact

annual energy consumption. In other cases, available data suggested that some of the design

options resulted in negligible energy savings. Because DOE intends to focus on the technologies

with measurable impact on efficiency, design options with negligible energy savings were

eliminated from further consideration.

DOE received the following comments on technologies unable to be analyzed.

2­26

EERE-2007-BT-STD-0010 COMMENT 20.3
     

                         

                             

                             

                             

                           

                             

                             

                         

                                   

                           

                           

                               

                         

   

                       

                       

             

                       

                             

                         

            

                       

                               

                               

                             

                               

                       

              

                         

                         

                       

         

     

                         

                             

                                   

2.4.1.1 Residential Clothes Dryers

As discussed in section 2.2.4.1, ALS and Whirlpool requested that "reverse tumble" be

removed as a clothes dryer technology option because it is considered useful mostly for removal

of wrinkling, and that testing indicates it has no impact on energy efficiency. (ALS, Public

Meeting Transcript, No. 4.6 at p.58; Whirlpool, No. 7 at p. 4) Manufacturers that DOE

interviewed as part of the preliminary manufacturer impact analysis also indicated that such a

feature is used primarily for fabric care. The benefits of reverse tumbling include prevention of

balling and wrinkling of the clothes load. No manufacturer indicated it use, or would consider,

reverse tumble for increasing efficiency. Tests conducted by one manufacturer, in fact, 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.1 At least one manufacturer stated that reverse tumble

could actually reduce efficiency by stopping the drum rotation while it is changing directions.

For reasons of no demonstrable energy savings and uncertainty as to whether its impacts can be

measured by the existing test procedure, DOE did not further analyze reverse tumble.

2.4.1.2 Room Air Conditioners

DOE included three technology options in the technology discussion of the framework

document that improve performance primarily in part load operation. These include two­speed,

variable­speed, or modulating­capacity compressors; thermostatic or electronic expansion

valves; and thermostatic cyclic controls. These technologies have not been demonstrated to

achieve energy savings in the DOE energy test, which measures EER and involves testing only

for full­load operation. A test procedure modification would be required for these technology

options to achieve measurable energy savings.

AHAM stated that part load technology is not appropriate for room air conditioners.

These products are typically undersized and operate in on/off mode. (AHAM, No. 8 at p. 4;

AHAM, Public Meeting Transcript, No. 4.6 at p.64) GE stated that most units are undersized for

their intended use and run at full capacity, hopefully making the room comfortable enough. (GE,

Public Meeting Transcript, No. 4.6 at p. 65) However, EEI suggested DOE examine the use of

variable speed drives for evaporator fans and compressors for possible energy efficiency

improvements. (EEI, No. 5 at p. 2)

As discussed in section 2.2.3.2, DOE does not plan to incorporate test procedure

modifications that would measure part load efficiency of room air conditioners. Hence, these

technology options, which improve part­load efficiency but not full­load efficiency, are not

considered in the engineering analysis.

2.4.2 Product Classes Analyzed

As noted above, DOE considered conducting the rulemaking for 16 product classes for

room air conditioners. DOE indicated in the framework document that it intended to conduct a

full analysis of product classes 1, 3 and 5 – room air conditioners without reverse cycle and with

2­27

EERE-2007-BT-STD-0010 COMMENT 20.3
                                 

                         

             

                           

                           

                                 

                           

                               

                                   

                                     

                             

                         

                               

           

   

                       

                     

                         

                       

                           

                       

                                 

                               

                                     

                           

                     

                     

                     

                     

                     

                           

                       

                         

                       

     

                       

                           

                               

                                 

louvered sides with a cooling capacity of less than 6,000 Btu per hour (Btu/hr), 8,000 to 13,999

Btu/h, and 20,000 Btu/hr or more, respectively. DOE would then extend this analysis

numerically to the remaining 13 product classes.

AHAM agreed that representative room air conditioner product classes 1, 3, and 5 for

room air conditioners with louvered sides are appropriate, and added that DOE should also

conduct the full analysis for product class 8 because data from units with louvered sides may not

realistically evaluate units without louvered sides. AHAM stated that if DOE can illustrate from

previous analysis that energy use data from units with louvered sides are predictive of energy use

for units without louvered sides, it would not be necessary to add product class 8 to the analysis.

(AHAM, No. 8 at p. 3; AHAM, Public Meeting Transcript, No. 4.6 at pp. 49, 50, and 79) DOE

agrees with AHAM that a full analysis should be conducted for product class 8, the intermediatecapacity product class for room air conditioners without reverse cycle and without louvered

sides, and has therefore included this product class in the preliminary analyses. (See chapter 5 of

this preliminary TSD for more details.)

2.4.3 Analysis Approach

In the framework document, DOE proposed to use the design­option approach for

residential clothes dryers and the efficiency­level approach room air conditioners, combining

each with the cost­assessment approach to develop a cost for each efficiency level.

NRDC stated that DOE should be cautious about using the efficiency­level approach

because existing high efficiency models of almost any product usually offer non­energy as well

as energy benefits, DOE’s methodology should account for these benefits. NRDC commented

that the DOE costing only accounts for energy benefits, and does not add costs for features that

offer additional value that consumers are willing to pay for in products at the ENERGY STAR

level and above. If a new plant has higher labor productivity than the old plant, that is a benefit

that should be considered. (NRDC, Public Meeting Transcript, No. 4.6 at p. 84) DOE

acknowledges NRDC’s assertion that higher efficiency products often incorporate features that

provide non­energy benefits and increase the manufacturing costs. To disaggregate the

manufacturing costs associated with energy and non­energy benefits, DOE conducts reverse

engineering analyses, which include product teardowns, to identify the components associated

with technology options for improving efficiency. Although some consumer­related features may

be attributed to a baseline design and thus a baseline manufacturing cost, DOE’s engineering

analysis is limited to defining incremental manufacturing costs associated with improvements in

energy efficiency. When DOE proposes energy conservation standards in the NOPR, however, it

will consider consumer utility issues at each considered trial standard level (TSL).

2.4.3.1 Residential Clothes Dryers

As noted above, DOE proposed in the framework document to use a design­option

approach for clothes dryers. AHAM supported this approach for clothes dryers, with the caveat

that the design­option approach is less preferable, but, in light of the limited data available for

clothes dryers, appears to be the most reasonable way for DOE to proceed. AHAM stated that it

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EERE-2007-BT-STD-0010 COMMENT 20.3
                         

                       

                             

                           

                                 

                             

                       

                         

             

                         

                         

                       

                         

                           

                           

   

   

                     

             

                         

                             

                                 

                             

                           

                                   

                             

                     

                             

                           

                           

                         

                   

                         

                             

                            

   

                       

                             

                         

would assist DOE in collecting aggregate cost data using the design­option approach. (AHAM,

Public Meeting Transcript, No. 4.6 at pp 88–89) Whirlpool commented that the design­option

approach is more viable than efficiency­level approach for clothes dryers because there is not a

wide dispersion in efficiency among various models and configurations, and because there are no

key inputs to adjust (such as water temperature in clothes washers). (Whirlpool, No. 7 at p. 5)

ALS also supports the design­option approach because it is not aware of any database listing

clothes dryer efficiencies based on multiple design options that could support an efficiency­level

analysis. ALS stated, therefore, that it opposes using the efficiency­level approach for clothes

dryers. (ALS, No. 6 at p. 3)

As noted above in section 2.2.4.1, DOE has limited aggregated cost­efficiency data that

does not indicate design options for meeting efficiency levels. Based on discussions with

manufacturers, DOE determined that multiple design changes were used to meet various

efficiency levels and that different approaches were used among the various manufacturers to

reach specific efficiency levels. Because various design options can be selected to meet the

proposed efficiency levels, DOE intends to use an efficiency­level approach for the clothes dryer

engineering analysis.

2.4.3.2 Room Air Conditioners

AHAM commented that the efficiency­level approach is appropriate for room air

conditioners. (AHAM, No. 8 at p. 5)

The analysis approach for room air conditioners was complicated by the conversion to R410A, which is discussed at greater length in section 2.9.4.1. The conversion to this new

refrigerant is expected to take place for products sold in 2010 because the use of HCFC­22 in

room air conditioners sold or distributed beginning January 1, 2010, is prohibited (74 FR 66450

(Dec. 15, 2009)), but there has been very limited data available regarding performance of

products using it. DOE was not able to purchase a range of products using the new refrigerant as

part of the reverse engineering effort. DOE also submitted data requests sheets to AHAM for

collection of data, including information regarding incremental costs associated with higher

efficiency levels of room air conditioners. AHAM was not able to collect sufficient numbers of

responses regarding these incremental costs to allow aggregation of the data and submission to

DOE. As a result, design option analysis was the only appropriate analytical approach. The

analyses made use of information obtained from reverse engineering of HCFC­22 products, from

component vendors, and from discussions with manufacturers. Energy modeling and

manufacturing cost modeling were used to determine efficiency and costs of products converted

to R­410A refrigerant, with groups of design options applied to the models for improvement of

efficiency. The analysis is described in detail in chapter 5 of the preliminary TSD.

2.4.4 Efficiency Metrics

In the framework document, DOE proposed to base its analysis of energy conservation

standards on the existing efficiency metrics; i.e., energy factor (EF) for clothes dryers and energy

efficiency ratio (EER) for room air conditioners. However, EISA 2007 amended EPCA to

2­29

EERE-2007-BT-STD-0010 COMMENT 20.3
                           

                     

                               

                             

                           

                               

                       

                           

                           

     

     

                             

                               

                           

                       

                        

     

                             

                           

                               

                         

                             

                           

                           

                             

                           

                               

                       

            

                             

                             

                           

                               

                         

                           

                           

                       

                           

                       

                           

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)) DOE

conducted the preliminary analyses based on the IEF and IEER discussed in section 2.2.3.3.

These metrics integrate standby and off mode energy into an overall efficiency metric, as

directed by EPCA.

2.4.5 Baseline Efficiency Levels

DOE used baseline products in the engineering analysis to establish a reference point for

improving the energy efficiency of each product class. Chapter 5 of this TSD includes details on

the baseline products for each product class. The definition of baseline products in the

preliminary analyses takes into consideration the new efficiency metrics integrating the energy

use associated with standby and off modes, as described in section 2.4.4.

2.4.5.1 Residential Clothes Dryers

AHAM agreed with the baseline EFs for vented clothes dryers proposed by DOE in the

framework document, noting changes to the test procedure will have a substantial impact on

these baseline energy factors. (AHAM, No. 8 at p. 4) ALS supports the definition of baseline

efficiency levels using existing Federal standard for clothes dryers, unless AHAM data reveals

some unexpected baseline. ALS stated that baseline models are likely to be those sold through

Sears, and low­ to mid­priced units represent high volume sales. ALS also commented that

AHAM should report shipment­weighted EF for 2006. (ALS, No. 6 at p. 2) Whirlpool

commented that primary efficiency gains in clothes dryer efficiency are a result of reduced RMC

in the clothes washer. Whirlpool has been designing products to meet those levels. Whirlpool

stated that revisions to test procedure are expected to lead to significantly lower EFs, and, thus,

baseline efficiency levels should be adjusted subsequent to revising the test procedure.

(Whirlpool, No. 7 at p. 5)

As noted above, DOE has initiated a test procedure rulemaking to amend the active mode

test procedure. As part of this rulemaking, DOE will consider whether the clothes dryer test

initial RMC should be updated to reflect current usage patterns and capabilities. In this

rulemaking, DOE intends to address the effects of changing the initial RMC on the ability of

baseline clothes dryers to meet the existing energy conservation standards. Under 42 U.S.C.

6923, EPCA sets forth procedures for DOE’s adoption and amendment of test procedures. EPCA

provides that, “[i]f the Secretary determines that the amended test procedure will alter the

measured efficiency or measured use, the Secretary shall amend the applicable energy

conservation standard during the rulemaking carried out with respect to such test procedure. In

determining the amended energy conservation standard, the Secretary shall measure, pursuant to

the amended test procedure, the energy efficiency, energy use, or water use of a representative

2­30

EERE-2007-BT-STD-0010 COMMENT 20.3
                           

                           

                       

       

                       

                             

                               

                                   

                                 

                             

                           

                                 

                           

                         

                         

                         

                             

                     

                             

                               

                           

                           

                             

                         

                       

   

                         

                           

                             

                             

                               

                     

                                 

      

                   

                             

                         

                             

                               

                             

sample of covered products that minimally comply with the existing standard. The average of

such energy efficiency, energy use, or water use levels determined under the amended test

procedure shall constitute the amended energy conservation standard for the applicable covered

products.” (42 U.S.C. 6293(e)(2))

Whirlpool and AHAM commented that, without a valid test procedure for vent­less

clothes dryers, there can be no baseline efficiency for these product classes. Whirlpool stated it

will collaborate on development of such a test procedure through AHAM. (Whirlpool, No. 7 at p.

5; AHAM, No. 8 at p. 5) AHAM does not have any data for vent­less clothes dryer baseline

levels, but stated it would commit to collect this perhaps even prior to the rulemaking process to

assist DOE with the rulemaking analysis. (AHAM, Public Meeting Transcript, No. 4.6 at p. 78)

EEI questioned whether DOE would be using the same efficiency metric (EF) for vent­less

clothes dryers as for other product classes. (EEI, Public Meeting Transcript, No. 4.6 at p. 77)

As noted above, as part of the concurrent test procedure rulemaking to address active

mode clothes dryer testing procedures, DOE plans to consider provisions for testing vent­less

clothes dryers. For the preliminary analyses, to conduct the engineering analysis and provide

information on which interested parties can comment, DOE reviewed literature and test reports

on vent­less clothes dryers to determine an appropriate baseline level. In addition, DOE tested a

vent­less electric compact (240 V) clothes dryer and a vent­less combination washer/dryer

according to the testing procedure proposed for vent­less clothes dryers published in the notice of

LG’s Petition for Waiver and denial of the Application of Interim Waiver. 71 FR 49437 (Aug.

23, 2006). The proposed alternate test procedure consists of adding separate definitions for a

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

vent­less design), and further qualified the requirement for an exhaust simulator in the test setup

so that it would only apply to conventional clothes dryers. DOE subsequently established

baseline efficiency levels for both vent­less product classes based on this testing.

2.4.5.2 Room Air Conditioners

In the framework document, DOE proposed that the room air conditioner baselines would

be represented by the existing energy conservation standards, which are expressed in terms of

EER. As discussed in section 2.4.4, EPCA now requires use of efficiency metrics that integrate

the energy use associated with standby and off modes, and DOE based the preliminary analyses

for room air conditioners on the IEER. As a result, DOE developed descriptions of baseline room

air conditioners combining the existing minimum energy conservation standards (which are

based on EER) with a representative standby energy use. This is described in detail in chapter 5

of this TSD.

DOE received comments regarding room air conditioner baseline efficiency levels,

primarily on the issue of how the conversion from HCFC­22 refrigerant to R­410A would affect

the baseline definitions. AHAM commented that there would be costs associated with converting

to the new refrigerant in addition to the costs associated with improvement of efficiency. AHAM

also agreed with a proposed efficiency reduction of 5 to 7 percent associated with the refrigerant

conversion, suggesting that it is closer to 7 percent. (AHAM, Public Meeting Transcript, No. 4.6

2­31

EERE-2007-BT-STD-0010 COMMENT 20.3
                             

                                       

                                     

                           

                         

                         

                             

                       

                             

                           

                       

                           

             

   

                         

                           

                       

                         

                         

                         

                           

          

      

                               

                             

                              

                             

                             

       

                         

                         

                           

                           

                             

                         

                       

                               

                               

at p. 80) EEI commented that manufacturers will have already converted to the new refrigerant

by the time of the final rule in 2011 and the time new standards would take effect in 2014, and

that a key question will be what impact that will have on the cost of the baseline product. (EEI,

Public Meeting Transcript, No. 4.6 at 83) ACEEE commented that the baseline product will

already include the conversion to the new refrigerant. The comment also addressed the

possibility of product redesign that would overcome the efficiency gap. (ACEEE, Public Meeting

Transcript, No. 4.6 at pp. 111–112) DOE is conducting the analysis based on definition of

baseline room air conditioners meeting existing energy conservation standards, but with R­410A

refrigerant, which is expected to be the applicable refrigerant in 2014, when the new standards

would take effect. DOE acknowledges that there may be costs associated with production of

room air conditioners meeting existing energy conservation standards with the new refrigerant.

These costs, however, are considered as part of the cumulative regulatory burden rather than

additional costs associated with the engineering analysis.

2.4.6 Efficiency Levels

In the engineering analysis, DOE established energy efficiency levels for each product

class to reflect the current room air conditioner and residential clothes dryer markets. These

efficiency levels are based on the integrated efficiency metrics, IEF and IEER. Additionally,

DOE associated each efficiency level selected with a particular technology or combination of

technologies, thus making its engineering analysis more transparent. See chapter 5 of the

preliminary TSD for details on the efficiency levels and the associated technologies. DOE

received several comments on the efficiency levels proposed in the framework document and the

technologies associated with those levels.

2.4.6.1 Residential Clothes Dryers

ALS commented that there is a need to update data from the June CEC appliance product

database, because, on October 5, 2008, CEC required manufacturers to report their data based on

the results of unspecified litigation. (ALS, Public Meeting Transcript, No. 4.6 at p. 99) As

discussed below in section 2.4.6.1, DOE analyzed data in the most recent CEC appliance product

database at the time of the preliminary analyses, and updated the proposed efficiency levels for

residential clothes dryers accordingly.

AHAM stated that the gap­fill levels proposed in the framework document for some

clothes dryer product classes (electric standard and gas) are minimally different and perhaps

even non­measurably different, in terms of cost and products, so suggested merging into a single

gap­fill level. (AHAM, Public Meeting Transcript, No. 4.6 at pp. 92–93) AHAM believes that

the clothes dryer published data shows that there are not many opportunities to increase the

efficiency of clothes dryers. (AHAM, Public Meeting Transcript, No. 4.6 at p. 12)

ASAP recommended another gap­fill level between efficiency levels 2 and 3 for clothes

dryers (electric and gas) because there is a relatively large gap in EF currently between them.

Even though these levels may not represent options on the market today, ASAP believes that the

2­32

EERE-2007-BT-STD-0010 COMMENT 20.3
                       

            

                         

                                 

                           

                               

                         

               

                         

                             

                               

                           

                         

                       

                     

                             

                                 

                             

                           

                               

                               

                       

                               

                           

           

   

                       

                           

                           

                             

                             

                             

                               

                         

                             

                               

                               

                       

                                 

design­option approach may guide the analysis to these levels. (ASAP, Public Meeting

Transcript, No. 4.6 at pp. 94–95)

The Joint Comment stated that the marketplace offers a surprisingly large range of

clothes dryer efficiencies. According to the Joint Comment, the ranges in EF for all of the vented

product classes are significantly larger than the ranges in the energy conservation metric for

other products, such as gas and electric storage water heaters. The Joint Comment also stated that

there is substantial "headroom" for raising standards, and for achieving such standards with

current technologies. (Joint Comment, No. 9 at p. 13)

For the preliminary analysis, DOE has conducted a recent market survey of vented

clothes dryers available on the market, using data in the most current CEC appliance product

database. Based on this review, DOE has updated the efficiency levels that were proposed in the

framework document. For details on these updated efficiency levels, see chapter 5 of this

preliminary TSD. DOE believes the updated efficiency levels are representative of the current

market and provide measurable differences in terms of incremental efficiency and cost.

Whirlpool commented that efficiency levels for vent­less dryers cannot be established

until an appropriate test procedure for these products is developed. This further supports that the

test procedure should be the primary focus of this standards activity. (Whirlpool, No. 7 at p. 6)

As noted above in section 2.4.5.1, DOE plans to consider procedures for testing vent­less clothes

dryers in the concurrent test procedure rulemaking. In the interim, DOE has developed efficiency

levels based on review of literature and test reports for vent­less clothes dryers, because the test

procedure used for these reports is similar to that which DOE may propose. DOE welcomes data

from manufacturers on vent­less clothes dryers tested according to the test procedure proposed

by DOE in the LG’s Petition for Waiver and denial of the Application of Interim Waiver,

described above in section 2.4.5.1. DOE also invites inputs on potential clothes dryer test

procedure amendments to test vent­less clothes dryers.

2.4.6.2 Room Air Conditioners

ACEEE observed that the range of room air conditioner efficiencies for each

representative product class, excluding CEE Tier 2 which is not necessarily available on the

market, is relatively large compared to the ranges of published energy conservation metrics for

certain other products, such as water heaters. The room air conditioner EER ranges are, on

average, 2 or 3 times the range of product availability differences for water heaters [because

room air conditioners and water heaters don’t use the same efficiency metric, this comment is

presumed to be based on contrast between the two products of the ratio of maximum difference

in efficiency observed in available products to the minimum efficiency level]. (ACEEE, Public

Meeting Transcript, No. 4.6 at p. 106) Similarly, the Joint Comment noted that current market

data for the representative room air conditioner product classes show that there is a larger range

of efficiencies for room air conditioners than for other products, such as gas or electric storage

water heaters. Thus, the data indicate significant room for improved, cost­effective standards.

(Joint Comment, No. 9 at p. 10) DOE acknowledges that there is a wide range of efficiency

2­33

EERE-2007-BT-STD-0010 COMMENT 20.3
                       

         

                       

                             

                             

                                 

                           

                       

                               

                         

                               

                         

                                     

                                   

                           

                         

                             

                           

       

                       

                       

                           

                             

            

                         

                         

                     

      

                         

                             

                     

                               

                       

                                 

                               

                           

                               

                           

levels among available room air conditioner products. The preliminary analysis examines this

full range of available efficiencies.

AHAM commented that DOE standard and ENERGY STAR levels are appropriate for

room air conditioner efficiency levels. (AHAM, No. 8 at p. 5) ACEEE estimated that ENERGY

STAR­qualified room air conditioners are one third to one half of total sales. Therefore, ACEEE

questioned why it would be necessary to have the Level 1 gap fill. ACEEE commented that the

ENERGY STAR level would change no matter what happened with the standard level, as

ENERGY STAR tracks with models, which presumably track with sales. (ACEEE, Public

Meeting Transcript, No. 4.6 at pp. 104–105) AHAM countered that it is not known that the

ENERGY STAR efficiency level will change, pointing out that there has been no announcement

to this effect. (AHAM, Public Meeting Transcript, No. 4.6 at 105) DOE attempts to conduct its

engineering and subsequent analyses using a reasonable range and number of efficiency levels.

The labeling of particular efficiency levels as ENERGY STAR or CEE Tier 1 or 2, as well as the

establishment of gap fill levels, is for convenience only and should in no way be interpreted as a

prejudgment of whether these are appropriate new minimum efficiency levels. The goal is to

conduct an analysis based on enough efficiency levels so that the appropriate maximum costeffective level can be identified without selecting so many levels to make the analysis overly

burdensome. DOE has retained many of the gap­fill levels initially proposed in the framework

document.

2.4.7 Maximum Technology Efficiency Levels

DOE has determined the maximum improvement in energy efficiency that is

technologically feasible (“max­tech”) for clothes dryers and room air conditioners, as required

by section 325(o) of EPCA. (42 U.S.C. 6295(o)) DOE identified the max­tech efficiency levels

as part of the engineering analysis. Chapter 5 includes additional details on the max­tech levels

DOE determined for this preliminary stage.

DOE received comments from interested parties on the max­tech efficiency levels that

were proposed in the framework document, which were based primarily on highest efficiencies

that are achieved by products currently on the market (“max available”).

2.4.7.1 Residential Clothes Dryers

ACEEE and NPCC suggested that the max available efficiencies for clothes dryers come

from models available in the United States, but that technologies such as heat pump clothes

dryers available elsewhere may result in higher efficiencies. (ACEEE, Public Meeting

Transcript, No. 4.6 at p. 100; NPCC, Public Meeting Transcript, No. 4.6 at p. 96) ACEEE

believes that basing the max­tech level on max­available efficiencies excludes technologies such

as heat pump dryers, and that it is important to include in the analysis products which are

available in Europe and Asia. ACEEE commented that, since heat pump dryers are now on the

market, such units represent an appropriate max­tech level to include in the engineering analysis.

(ACEEE, Public Meeting Transcript, No. 4.6 at pp. 36 and 100) The Joint Comment stated that

DOE should evaluate efficiency levels beyond those available on the market today and should

2­34

EERE-2007-BT-STD-0010 COMMENT 20.3
                             

                       

                         

                                 

                             

                          

                         

                     

                               

                           

                               

                             

                     

             

                               

                           

                         

                           

                       

                             

                     

                             

                         

                             

             

                       

                                 

                           

                       

                           

   

                       

                               

                             

                             

                           

                       

use advanced technologies as the basis for the efficiency levels subject to analysis. Examples that

it provided include optimal components and control—i.e., using modulating fan and drum

speeds, modulating heat capacity, and controls that vary the parameters to minimize energy

use— and heat pump clothes dryers, which are on the market in Europe and thus can be

analyzed. The Joint Comment stated that the max­tech efficiency level should not be limited to

those products currently on the market. (Joint Comment, No. 9 at p. 14)

AHAM commented that in terms of max available versus max­tech, there are many

prototypes in existence, implying that these prototypes have higher efficiencies. However,

AHAM also noted that, for clothes washers, the max­tech level was defined as a hybrid of

metrics from two different products on the market. AHAM objected to this hybrid approach,

stating that it is more appropriate to use max available units to define max­tech efficiency levels.

(AHAM, Public Meeting Transcript, No. 4.6 at pp. 100–101) ALS supports DOE using CEC and

Natural Resources Canada’s (NRCan's) database to define max­tech clothes dryer efficiency

levels. (ALS, No. 6 at p. 3)

As discussed in further detail in chapter 3 and chapter 5 of this preliminary TSD, DOE

has evaluated heat pump technology for electric clothes dryers because of its wide commercial

availability outside the United States. DOE has tentatively determined that this technology could

achieve an EF higher than the maximum available level presented in the framework document.

Therefore, DOE has included an additional efficiency levels beyond the maximum available

levels for electric clothes dryers to account for this max­tech level corresponding to heat pump

technology. Although DOE initially considered in its recent commercial clothes washer

rulemaking a max­tech level consisting of max available values of the two closely, but not

uniquely, related efficiency metrics defined for clothes washers, a single efficiency metric is

defined for clothes dryers. Therefore, DOE will not use a hybrid approach to determine max­tech

levels for clothes dryers in this rulemaking.

Whirlpool commented that the definition of max­tech and gap­fill levels is inconsistent

with a design­option approach for clothes dryers. (Whirlpool, No. 7 at p. 6) DOE did not have

sufficient data on specific design options and their associated improvements to EF to suggest

appropriate design changes and efficiency levels using a design­option approach. Therefore, as

noted above, DOE has used an efficiency­level approach for clothes dryers in the preliminary

analyses.

2.4.7.2 Room Air Conditioners

NRDC commented that, for room air conditioners, the max available efficiency would

not reach the max­tech level because the economics for this product are so disconnected that no

manufacturer has the incentive to reach max­tech in a $100 room air conditioner. (NRDC, Public

Meeting Transcript, No. 4.6 at p. 97) EEI suggested using max available room air conditioner

efficiencies published by AHAM or ENERGY STAR, rather than using values for max­tech that

cannot be met or verified currently. (EEI, No. 5 at p. 3)

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DOE has conducted the engineering and subsequent analyses based on maximum

efficiency levels consistent with the maximum levels identified for current products. Prototype

performance data showing higher efficiency levels are not readily available. Also, DOE

conducted energy analyses, described in chapter 5 of the preliminary TSD, to calculate efficiency

levels of modified design configurations. The energy analysis did not indicate that higher

efficiency levels are possible without increasing product size significantly beyond the size of

baseline efficiency products. DOE concludes that efficiency levels significantly higher than max

available are not feasible with current technology.

2.4.8 Cost­Efficiency Relationships

ACEEE stated that some literature and prior rulemakings indicated that, historically, an

increase in standards has not necessarily been associated with an increase in prices, leaving aside

commodity effects experienced in the recent central air conditioner rulemaking. ACEEE stated

that DOE should apply skepticism to the lower end of the cost­efficiency curve where standards

are likely to be implemented. ACEEE questioned whether such standards would actually result in

a consumer price increase. (ACEEE, Public Meeting Transcript, No. 4.6 at p. 78)

Thorough review of the accuracy of cost modeling of past rulemakings is beyond the

scope of this rulemaking. DOE recognizes the need for accuracy in determination of the cost of

achieving higher efficiency levels. To that end, DOE refrains from making or using projections

of costs that cannot be verified based on current information, and also refrains from making

estimates that cannot be substantiated. DOE recognizes that inevitably this leads to cost estimates

which may be high after a standard takes effect. DOE notes that EISA 2007 modified EPCA to

require that not later than 6 years after issuance of any final rule establishing or amending a

standard, DOE shall publish either a notice of the determination that standards for the product do

not need to be amended, or a notice of proposed rulemaking including new proposed standards.

(42 U.S.C. 6295, section 325 (m)) Hence, if the cost­effectiveness of higher efficiency standards

improves significantly, the energy conservation standards can be adjusted in a subsequent

rulemaking.

2.5 MARKUPS TO DETERMINE PRODUCT PRICES

DOE used markups to convert the manufacturer costs estimated in the engineering

analysis to consumer prices, which then were used in the life­cycle cost (LCC) and payback

period (PBP) and manufacturer impact analyses. DOE calculates markups for baseline products

(baseline markups) and for more efficient products (incremental markups). The incremental

markup relates the change in the manufacturer sales price of higher­efficiency models (the

incremental cost increase) to the change in the retailer or distributor sales price.

To develop markups, DOE identifies how the products are distributed from the

manufacturer to the customer. After establishing appropriate distribution channels, DOE relied

on economic data from the U.S. Census Bureau and other sources to define how prices are

marked up as the products pass from the manufacturer to the customer. See chapter 6 for details

on the development of markups.

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Whirlpool questioned DOE’s calculation of the manufacturer markup. Whirlpool stated

that many appliance manufacturers operate in multiple regions of the world, are part of larger

corporations, or both. Because of this structure of appliance manufacturing, Whirlpool believes

that using corporate financial statements to calculate the manufacturer markup can be

misleading. Whirlpool stated that DOE should use financial statements where possible to obtain

relevant North American data. Additionally, Whirlpool recommended that DOE should seek

other data sources in support of this analysis. (Whirlpool, No. 7 at p. 7)

DOE uses publicly available financial information, such as filings from the U.S.

Securities Exchange Commission, to estimate the manufacturer markup. Additionally, DOE

seeks feedback from manufacturers regarding markups, revenues, and other financial parameters

during interviews for the manufacturer impact analysis.

2.6 ENERGY USE CHARACTERIZATION

The energy use characterization, which assesses the energy savings potential from higher

efficiency levels, provides the basis for the energy savings values used in the LCC and

subsequent analyses. Studies show that measurements of field energy use often vary

considerably from the rated usage as determined by the DOE test procedure. To determine the

field energy use by products that would meet possible energy efficiency standards, DOE used

data from the 2005 RECS.

2 RECS is a national sample survey of housing units that collects

statistical information on the consumption of and expenditures for energy in housing units along

with data on energy­related characteristics of the housing units and occupants. DOE developed

separate samples for homes that used residential clothes dryers and room air conditioners, and

then developed sub­samples for each considered product class. For room air conditioners, DOE

used climate data specific to each sample household to apportion annual electricity use for room

air conditioner operation among the months in the year.

2.6.1 Residential Clothes Dryers

For clothes dryers with a specific efficiency, the annual energy consumption depends on

the annual number of cycles. AHAM stated that decreasing average clothes dryer use cycles

from 416 to 329 per year is appropriate, based on information on clothes washer use. (AHAM,

No. 8 at p. 1) The Joint Comment stated that DOE should establish the number of annual clothes

dryer cycles independent of the number of clothes washer cycles. (Joint Comment, No. 9 at p.

11) CEE said that it supports decreasing the number of clothes dryer cycles from 416 to be more

consistent with the number of clothes washer cycles in the clothes washer test procedure, and

recommended that DOE re­examine the clothes dryer utilization factor. (CEE, No. 10 at p. 1)

Whirlpool stated its belief that the annual number of dryer cycles should be 298. (Whirlpool, No.

7 at p. 2)

DOE estimated the number of clothes dryer cycles per year for each sample home using

data given by RECS on the number of laundry loads (clothes washer cycles) washed per week

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and the frequency of clothes dryer use. The calculated average is 285 cycles per year for electric

standard clothes dryers and 271 cycles per year for gas standard clothes dryers.

EEI stated that DOE should account for the effect that new clothes washer standards and

ENERGY STAR programs will have on reducing moisture content and thereby lowering clothes

dryer energy use. (EEI, No. 5 at p. 5) DOE agrees that as new clothes washers enter the stock,

RMC will decline. To estimate the RMC of clothes washers in the future housing stock, DOE

used a distribution of values for models listed in the Dec. 22, 2008 CEC directory. The RMC

values range from 30 percent to 61 percent, with an average of 46 percent.

2.6.2 Room Air Conditioners

For room air conditioners with a specific size and EER, the annual energy use depends on

the annual hours of operation. CEE requested that DOE perform additional research on the

number of annual operating hours of a room air conditioner, and noted that CEE member

efficiency programs believe the annual operating hours to be higher than 500. (CEE, No. 10 at p.

2)

For each considered room air conditioner capacity, DOE calculated the number of

operating hours for each room air conditioner in the residential sample using the reported energy

use for room air conditioning in the 2005 RECS, along with estimates of the EER of the room air

conditioner(s) in each sample home. DOE based the latter on the reported age of the unit and

historical data on shipment­weighted average EER. The estimated mean number of operating

hours for the residential room air conditioner sample is 1,310 hr for the >6000 Btu/h product

class, 678 hr for the 8,000 to 13,999 Btu /h product classes, and 394 hr for the ≥ 20,000 Btu /h

product class.

EEI and NRDC stated that DOE should account for use of room air conditioners in

commercial buildings, where operating hours are higher. (EEI, No. 5 at p. 4; NRDC, No. 4.6 at p.

126) DOE developed a separate building sample for commercial­sector use of room air

conditioners and accounted for the distinct features of room air conditioner utilization in

commercial buildings. DOE estimated the number of operating hours for each room air

conditioner in the commercial sample using a relationship between indoor comfort requirements

and climate conditions in different parts of the country. The estimated mean number of operating

hours is 1,219 hr for the >6000 Btu/h product class, 1,144 hr for the 8,000 to 13,999 Btu /h

product classes, and 1,180 hr for the ≥ 20,000 Btu /h product class.

EEI stated that energy use determination for homes with multiple room air conditioners

needs to account for differences in how the units are used, as well as the operation of room air

conditioners in homes that primarily use central air conditioning systems. (EEI, No. 5 at p. 4)

DOE acknowledges that the utilization of each of the room air conditioners in a home may vary,

but DOE had no way to estimate such variation, so it used the average consumption per unit for

homes with multiple room air conditioners. Also, DOE did not have sufficient information to

estimate the energy use of room air conditioners in the households that primarily use central air

conditioning systems and therefore did not account for the operation in such cases.

2­38

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The Joint Comment stated that actual outdoor operating temperatures should be taken

into account in the analysis for room air conditioners. (Joint Comment, No. 9 at p. 9) DOE’s

calculation of room air conditioner energy use is based on the reported energy use for room air

conditioning in the 2005 RECS. This energy consumption estimate was based on actual

electricity bills for the sample homes and therefore reflects the operating conditions for each

home in the sample. In addition, DOE used climate data specific to each sample household to

apportion annual electricity use for room air conditioner operation among the months in the year.

Chapter 7 of the preliminary TSD provides more detail about DOE’s approach for

characterizing energy use of clothes dryers and room air conditioners.

2.7 LIFE­CYCLE COST AND PAYBACK PERIOD ANALYSES

New energy conservation standards affect products’ operating expenses—usually

decreasing them—and consumer prices for the products—usually increasing them. DOE

analyzes the effect of amended standards on consumers by evaluating changes in the LCC of

owning and operating the product. To evaluate the change in LCC, DOE used the cost­efficiency

relationship derived in the engineering analysis, along with the energy costs derived from the

energy use characterization. Inputs to the LCC calculation include the installed cost of a product

to the consumer (consumer purchase price plus installation cost), operating expenses (energy

expenses and maintenance costs), the lifetime of the unit, and a discount rate.

Because the installed cost of a product typically increases while operating cost typically

decreases in response to new standards, there is a time in the life of products having higher­thanbaseline efficiency when the net operating­cost benefit (in dollars) since the time of purchase is

equal to the incremental first cost of purchasing the higher­efficiency product. The length of time

required for products to reach this cost­equivalence point is known as the payback period (PBP).

Recognizing that several inputs to the determination of consumer LCC and PBP are

either variable or uncertain, DOE conducted the LCC and PBP analysis by modeling both the

uncertainty and variability in the inputs using Monte Carlo simulation and probability

distributions. DOE developed LCC and PBP spreadsheet models incorporating both Monte Carlo

simulation and probability distributions by using Microsoft Excel spreadsheets combined with

Crystal Ball (a commercially available add­in program).

As described above in section 2.6, DOE developed samples of individual households or

commercial enterprises that use residential clothes dryers and room air conditioners. By

developing such samples, DOE was able to perform the LCC and PBP calculations for each

household to account for the variability in energy consumption and electricity price associated

with actual users of the considered products. DOE identified several other input values for

estimating the LCC, including retail prices; discount rates; and product lifetimes and

characterized them with probability distributions.

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DOE developed discount rates separately for residential consumers and commercial

customers. Because some room air conditioners are used in commercial applications, DOE

developed commercial discount rates for those commercial subsectors that purchase room air

conditioners. DOE developed discount rates from estimates of the interest rate, or finance cost,

applied to purchases of residential and commercial products. Following accepted principles of

financial theory, the finance cost of raising funds to purchase such products can be interpreted as:

(1) the financial cost of any debt incurred to purchase products, principally interest charges on

debt; or (2) the opportunity cost of any equity used to purchase products, principally interest

earnings on household equity.

2.7.1 Energy Prices

DOE developed prices of electricity and natural gas specific for each product user in the

LCC samples.

For clothes dryers, DOE used EIA’s 2007 energy price data to determine average annual

residential prices of electricity and natural gas in 13 geographic areas.

For room air conditioners, the Joint Comment stated that DOE should base the LCC

analysis on rates that reflect the actual price faced by users of room air conditioners, such as

summer rates or time­of­use (TOU) rates applied to estimated peak and non­peak hours of use.

(Joint Comment, No. 9 at p. 9) EEI said that DOE should use summer prices because room air

conditioners are mainly operating during the summer season. (EEI, No. 5 at p. 4) NWPCC stated

that DOE should use the same type of methodology for establishing electricity prices for room

air conditioners as it did for the commercial unitary air conditioner standards rulemaking (i.e.,

consider room air conditioner load shape and tariff structures). (NWPCC, No. 4.6 at p. 141­143)

DOE used utility tariff data to develop monthly marginal electricity prices for each RECS

household used in the LCC analysis. The marginal prices are calculated by taking account of the

difference between the household’s electricity expenditures for the base case electricity use and

for a candidate standard level, in combination with the associated change in energy use. The

price used is based on the default (non­TOU) tariffs, because TOU are optional and very few

customers opt for such rates. DOE then applied the monthly prices to the estimated electricity

use by the room air conditioner in each corresponding month. This approach applies summer

rates to the estimated consumption in summer months. DOE also used tariff data to develop

marginal electricity prices for each commercial building in the LCC sample.

To estimate the future trends in energy prices, DOE used projections from EIA’s Annual

Energy Outlook 2009 (AEO 2009).3

2.7.2 Installation, Maintenance and Repair Costs

DOE considered installation, maintenance and repair costs for the efficiency levels

considered in this rulemaking. Typically, small incremental changes in energy efficiency

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produce no, or only minor, changes in repair and maintenance costs over baseline efficiency

products. Products having efficiencies that are significantly greater than baseline models can

incur increased repair and maintenance costs, as they are more likely to incorporate technologies

that are new to the industry.

For clothes dryers, AHAM, ALS, GE and Whirlpool agreed with the above

characterization. (AHAM, No. 8 at p. 6; ALS, No. 6 at p. 4; GE, No. 4.6 at p. 148; Whirlpool,

No. 7 at p. 7) AHAM and Whirlpool noted that heat pump dryers would be considerably heavier

than conventional dryers, leading to increased installation costs. GE and Whirlpool stated that

condensing dryers require plumbing to drain the condensate, which will increase the installation

cost of the system. Whirlpool added that such dryers would also cost two to three times as much

to repair due to their complex nature and the cost of disconnecting/reconnecting water sources.

The comments, however, provided no specific evidence of change in installation, maintenance

and repair costs for the efficiency levels considered in this rulemaking for clothes dryers or room

air conditioners.

For room air conditioners, AHAM stated that installation, repair and maintenance costs

will increase where part­load performance is added. (AHAM, No. 8 at p. 6) DOE’s analysis did

not consider units operating at part load.

2.7.3 Product Lifetime

Because the lifetime of appliances varies depending on utilization and other factors, DOE

develops a distribution of lifetimes from which specific values are assigned to the appliances in

the samples. For clothes dryers, AHAM, ALS and Whirlpool stated that DOE should use the

value of 12 years given in Appliance Magazine. (AHAM, No. 8 at p. 6; ALS, No. 6 at p. 4;

Whirlpool, No. 7 at p. 8) For room air conditioners, AHAM cited an average life expectancy of 9

years, adding that the life expectancy of room air conditioners varies with unit size, with smaller

units having substantially lower life expectancy.

DOE found that the basis for the lifetime estimates in the literature for room air

conditioners and clothes dryers is uncertain. Therefore, DOE conducted an analysis of actual

lifetime in the field using a combination of shipments data, the stock of the considered

appliances, and responses in RECS on the age of the appliances in the homes. The data allowed

DOE to estimate a survival function, which provides an average and a median appliance lifetime.

This analysis yielded an average lifetime for room air conditioners of approximately 10.5 years

and for clothes dryers of approximately 16 years. DOE incorporated the survival functions as a

probability distribution in its LCC analysis.

2.7.4 Energy Efficiency in the Base Case

To estimate the share of consumers that would be affected by a standard at a particular

efficiency level, DOE’s LCC and PBP analysis considered the projected distribution (i.e., market

shares) of product efficiencies that consumers purchase under the base case (i.e., the case without

2­41

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new energy efficiency standards). DOE primarily relied on data submitted by AHAM to estimate

the efficiency distributions in recent years for each of the product classes that were analyzed in

the LCC and PBP analysis.

EEI stated that DOE should account for the effect that ENERGY STAR programs will

have on increasing product efficiency for room air conditioners, as well as the likelihood that

utilities will offer incentives for high efficiency laundry equipment and room air conditioners in

the near future. (EEI, No. 5 at p. 5) Whirlpool stated that market transformation programs for

clothes dryers are unlikely to be successful, in part because of the modest differential in

efficiency among existing products. (Whirlpool, No. 7 at p. 9)

DOE found that the data on recent trends in shipment­weighted average efficiency of

room air conditioners and shares of ENERGY STAR products are inconclusive. Therefore, DOE

assumed that the market shares of the efficiency levels in 2014 will be roughly the same as the

shares in 2007. DOE also found little evidence suggesting much change in the distribution of

energy efficiencies of clothes dryers in coming years. Chapter 8 provides more detail about the

approach for base case efficiency distributions.

2.8 NATIONAL IMPACT ANALYSIS

The national impact analysis assesses the aggregate impacts at the national level of

potential energy conservation standards for each of the considered products, as measured by the

NPV of total consumer economic impacts and the NES. DOE determined the NPV and NES for

the efficiency levels considered for each of the product classes analyzed. To make the analysis

more accessible and transparent to all interested parties, DOE prepared a Microsoft Excel

spreadsheet model to forecast NES and the national consumer economic costs and savings

resulting from new standards. The spreadsheet model uses typical values as inputs (as opposed to

probability distributions). To assess the effect of input uncertainty on NES and NPV results,

DOE may conduct sensitivity analyses by running scenarios on specific input variables.

2.8.1 Shipments Analysis

Forecasts of product shipments are needed to calculate the national impacts of standards

on energy use, NPV, and future manufacturer cash flows. DOE developed shipment forecasts

based on an analysis of key market drivers for each considered product. In DOE’s shipments

model, shipments of products are driven by new construction, stock replacements, and other

types of purchases.

The shipments models take an accounting approach, tracking market shares of each

product class and the vintage of units in the existing stock. Stock accounting uses product

shipments as inputs to estimate the age distribution of in­service product stocks for all years. The

age distribution of in­service product stocks is a key input to calculations of both the NES and

NPV, because operating costs for any year depend on the age distribution of the stock.

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DOE also considers the impacts on shipments from changes in product purchase price

and operating cost associated with higher energy efficiency levels. Chapter 9 of the preliminary

TSD provides additional details on the shipments analysis.

2.8.2 Efficiency Trends

Several of the inputs for determining NES and NPV depend on the forecast trends in

product energy efficiency. For the base case (which presumes no revised standards), DOE uses

the efficiency distributions developed for the LCC analysis, and assumes some rate of change

over the forecast period. In this analysis, DOE has used a roll­up scenario in developing its

forecasts of efficiency trends after standards take effect. Under a roll­up scenario, all products

that perform at levels below a prospective standard are moved, or rolled­up, to the minimum

performance level allowed under the standard. Product efficiencies above the standard level

under consideration would remain the same as before the revised standard takes effect.

2.8.3 National Energy Savings

The inputs for determining the NES for each product analyzed are: (1) annual energy

consumption per unit; (2) shipments; (3) product stock; (4) national energy consumption; and (5)

site­to­source conversion factors. DOE calculated the national energy consumption by

multiplying the number of units, or stock, of each product (by vintage, or age) by the unit energy

consumption (also by vintage). DOE calculated annual NES based on the difference in national

energy consumption for the base case (without new efficiency standards) and for each higher

efficiency standard. DOE estimated energy consumption and savings based on site energy, and

converted the electricity consumption and savings to source primary) energy. Cumulative energy

savings are the sum of the NES for each year.

2.8.4 Net Present Value of Consumer Benefit

The inputs for determining NPV of the total costs and benefits experienced by consumers

of the considered appliances are: (1) total annual installed cost; (2) total annual savings in

operating costs; (3) a discount factor; (4) present value of costs; and (5) present value of savings.

DOE calculated net savings each year as the difference between the base case and each standards

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

savings over the life of each product. NPV is the difference between the present value of

operating cost savings and the present value of total installed costs.

DOE calculated increases in total installed costs as the product of the difference in total

installed cost between the base case and standards case (i.e., once the standards take effect).

DOE expressed savings in operating costs as decreases associated with the lower energy

consumption of products bought in the standards case compared to the base efficiency case.

Total savings in operating costs are the product of savings per unit and the number of units of

each vintage that survive in a given year.

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To calculate the NPV, DOE used a discount factor based on real discount rates of 3

percent and 7 percent to discount future costs and savings to present values. The Joint Comment

urged DOE to use a societal discount rates of 2–3 percent in its national impact analysis. (Joint

Comment, No. 9 at p. 6)

DOE notes that OMB Circular A­4, referencing Circular A­94, indicates that a real

discount rate of 7 percent should be used as a base case for regulatory analysis. The 7­percent

rate is an estimate of the average before­tax rate of return to private capital in the U.S. economy.

It approximates the opportunity cost of capital and, according to Circular A­94, is the appropriate

discount rate whenever the main effect of a regulation is to displace or alter the use of capital in

the private sector. OMB revised Circular A­94 in 1992 after extensive internal review and public

comment. OMB found that the average rate of return to capital remains near the 7­percent rate

estimated in 1992. Circular A­4 also states that when regulation primarily and directly affects

private consumption, a lower discount rate is appropriate. “The alternative most often used is

sometimes called the social rate of time preference...the rate at which ‘society’ discounts future

consumption flows to their present value.”4 It suggests that the real rate of return on long­term

government debt may provide a fair approximation of the social rate of time preference, and

states that over the last 30 years, this rate has averaged around 3 percent in real terms on a pretax basis. It concludes that “for regulatory analysis, [agencies] should provide estimates of net

benefits using both 3 percent and 7 percent.”5 DOE finds that the guidance from OMB is

reasonable, and incorporated it in its national impact analysis.

2.8.5 Other Impacts

The national impacts analysis examines the potential economic impacts of alternative

standard levels on consumers who purchase the considered products. The Joint Comment stated

that DOE should consider the effect of standards on gas and electricity prices. (Joint Comment,

No. 9 at p. 6) DOE evaluated the impact on future natural gas prices from amended standards on

clothes dryers and room air conditioners using the NEMS­BT model, which provides an estimate

of the price change for each year of the forecast period. The reduction in natural gas

consumption includes impacts on power sector natural gas demand associated with decreased

electricity demand from the standards. DOE then calculated the nominal savings in total natural

gas expenditures in each year by multiplying the annual changes in the average­user price for

natural gas by the total annual U.S. natural gas consumption forecast by AEO 2009. Lastly, it

discounted the annual savings in expenditures to calculate a net present value.

Regarding impacts on electricity prices, DOE investigated the possibility of estimating

the impact of specific standard levels on electricity prices in its rulemaking for general service

fluorescent lamps and incandescent reflector lamps.6 Whereas natural gas markets exhibit a fairly

simple chain of agents from producers to consumers, the power industry is a complex mix of fuel

suppliers, producers and distributors. While the distribution of electricity is regulated

everywhere, its institutional structure varies, and upstream components are more complicated,

with generation priced using different methods across the country. For these and other reasons,

accurate modeling of the response of electricity prices to a decrease in residential­sector demand

due to standards is problematic. Thus, DOE does not plan to estimate the value of potentially

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reduced electricity costs for all consumers associated with revised standards for residential

clothes dryers and room air conditioners. DOE acknowledges, however, that there may be some

positive economic benefit from reduced electricity demand.

Chapter 10 of the preliminary TSD provides additional details regarding the national

impacts analysis.

2.9 PRELIMINARY MANUFACTURER IMPACT ANALYSIS

DOE performed a preliminary manufacturer impact analysis (MIA) to estimate the

financial impact of higher energy conservation standards on manufacturers of residential clothes

dryers and room air conditioners, and to calculate the impact of such standards on employment

and manufacturing capacity. The MIA has both quantitative and qualitative aspects. The

quantitative part of the MIA relies on the government regulatory impact model (GRIM), an

industry­cash­flow model customized for these two industries. The following is an overview of

the information DOE collected and the analysis that was conducted during the preliminary MIA.

For more detail on the MIA, see chapter 12 of the preliminary TSD.

2.9.1 Industry Cash­Flow Analysis

The industry cash­flow analysis relies primarily on the GRIM. DOE uses the GRIM to

analyze the financial impacts of more stringent energy conservation standards on the industry

that produces the products covered by the standard. For more information on the industry cashflow analysis, refer to chapter 12 of the preliminary TSD.

2.9.2 Manufacturer Subgroup Analysis

Industry cost estimates are not adequate to assess differential impacts among subgroups

of manufacturers. For example, small and niche manufacturers, or manufacturers whose cost

structure differs significantly from the industry average, could experience a more negative

impact from the imposition of standards. Ideally, DOE would consider the impact on every firm

individually; however, since this usually is not possible, DOE typically uses the results of the

industry characterization to group manufacturers exhibiting similar characteristics.

DOE outlined the process it uses to establish manufacturer subgroups in the framework

document and sought comment from interested parties on any potential subgroups within the two

industries.

In response to the manufacturer subgroup discussion in the framework document, AHAM

agreed with DOE’s approach in considering subgroups of manufacturers in other rulemakings.

However, AHAM did not have any information on subgroups of residential clothes dryer or

room air conditioner manufacturers that could be differentially impacted (AHAM, Public

Meeting Transcript, No. 4.6 at p. 183). ALS stated that “low­volume” manufacturers of

residential clothes dryers should be considered as a manufacturer subgroup. ALS defined lowvolume manufacturers as having less than five percent market share. (ALS, No. 6 at p. 5)

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DOE research suggests that there are no residential clothes dryer manufacturers in the

United States that are designated as small businesses by the U.S. Small Business Administration,

but that there is at least one room air conditioner manufacturer designated as a small business.

DOE seeks comment on its estimates of the number of small businesses who may be impacted by

the rule and what those impacts might be.

2.9.3 Competitive Impacts Assessment

DOE must also consider whether a new standard is likely to reduce industry competition,

and the Attorney General must determine the impacts, if any, of any reduced competition. DOE

will make a determined effort to gather and report firm­specific financial information and

impacts. The competitive impacts assessment will focus on assessing the impacts on smaller

manufacturers. DOE will base this assessment on manufacturing cost data and information

collected from interviews with manufacturers. The manufacturer interviews will focus on

gathering information to help assess asymmetrical cost increases to some manufacturers,

increased proportion of fixed costs potentially increasing business risks, and potential barriers to

market entry (e.g., proprietary technologies). The notice of proposed rulemaking will be

submitted to the Attorney General for a review of the impacts of standards on competition. The

Attorney General’s comments on the proposed rule will be considered in preparing the final rule.

2.9.4 Cumulative Regulatory Burden

DOE recognizes and seeks to mitigate the overlapping effects on manufacturers of new or

revised DOE standards and other regulatory actions affecting the same equipment. DOE will

analyze and consider the impact on manufacturers of multiple, product­specific regulatory

actions. Based on its own research and discussions with manufacturers, DOE identified several

regulations relevant to clothes dryers and room air conditioners, including the prohibition of

hydrochlorofluorocarbon (HCFC) refrigerants, amended energy conservation standards for other

products made by clothes dryer and room air conditioner manufacturers, State energy

conservation standards, and international energy conservation standards.

DOE outlined the cumulative regulatory burden process in the framework document and

sought comment from interested parties on any additional regulations facing the clothes dryer

and room air conditioner industries. ALS agreed with the list of regulatory burdens shown in the

framework document. (ALS, No. 6 at p. 5) The following sections discuss specific regulatory

actions for which DOE received comments.

2.9.4.1 HCFC Phaseout

The HCFC phaseout is discussed in section 2.4.5.2, which explains that costs associated

with meeting existing room air conditioner efficiency levels with the new R­410A refrigerant are

considered part of the cumulative regulatory burden. Many of the comments made regarding the

refrigerant conversion debate how significant the costs will be (1) to achieve the existing

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standards; and (2) to then achieve higher efficiency levels. DOE will rigorously investigate the

costs associated with both of these steps. As mentioned, the first set of costs is an input to the

cumulative regulatory burden, while the second set of costs is an input to the engineering

analysis. Additional comments made during the framework meeting and framework comment

period that specifically relate to cumulative regulatory burden are discussed in this section.

AHAM stated that the 2010 ban on the import of HCFC in room air conditioners and

other products is a critical issue for DOE to consider. The 2010 ban will have an impact on room

air conditioners, which are primarily produced abroad and currently use HCFC­22 refrigerant.

(AHAM, Public Meeting Transcript, No. 4.6 at pp. 62–63) AHAM commented that it is

concerned that data gathering for room air conditioners will be commencing before

manufacturers have determined how they'll make the refrigerant switch. AHAM also stated it is

almost certain that new compressors will be required because existing compressors do not work

with [R­410A]. (AHAM, Public Meeting Transcript, No. 4.6 at p. 83)

AHAM commented that refrigerant legislation is only proposed at the time of its

comment. The proposal is to add a 30­cent per pound fee, paid by the manufacturer, at the time

of purchase of a virgin refrigerant ­­ HFC, CFC, or HCFC. AHAM commented that collected

money would be used to encourage reclaimers to reclaim refrigerant at the end of life. This

would increase purchase cost of refrigerant by the manufacturer. (AHAM, Public Meeting

Transcript, No. 4.6 at p. 109)

DOE conducted initial interviews with manufacturers during the preliminary analysis

phase at a time when development work associated with the refrigerant work was ongoing. Much

information regarding costs associated with the conversion was available at the time, but DOE

acknowledges that a better understanding of the cost impacts may have emerged since these

initial interviews were conducted. DOE is prepared to update analyses as needed in the NOPR

analyses, to the extent that revised information is made available. DOE notes further that a full

manufacturing impact analysis was not part of the preliminary analysis phase. Hence, the

cumulative regulatory burden of the refrigerant conversion has not yet been quantified. The costs

of the conversion should now be fully understood by manufacturers, because products using the

new refrigerant likely started production in late 2009.

2.9.4.2 Underwriters Laboratory Fire Safety Regulation

ALS commented that Underwriters Laboratory (UL) is changing the electric clothes dryer

standard to include a fire containment requirement, which will probably have a 4­year

implementation period. This is the same timing as this rule, so DOE would have to consider how

that would impact the baseline product. (ALS, Public Meeting Transcript, No. 4.6 at p. 110)

ALS, AHAM, and EEI commented that DOE should consider the proposed revision to UL 2158

to add a "fire containment test requirement", which could impact clothes dryer efficiency. (ALS,

No. 6 at p. 3; AHAM, No. 8 at p. 5; EEI, No. 5 at p. 3) Whirlpool and ALS commented that it is

not clear at this time what impact the UL clothes dryer fire containment regulation may have on

dryer performance, efficiency, and cost. (Whirlpool, No. 7 at p. 6; ALS, Public Meeting

Transcript, No. 4.6 at p. 111) ACEEE commented that they hoped ALS comments would address

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efficiency impact as well as regulatory input of the fire suppression standard for electric clothes

dryers. (ACEEE, Public Meeting Transcript, No. 4.6 at p. 110­111)

DOE confirmed in interviews with manufacturers that the impacts of compliance with the

upcoming UL fire containment regulation are unclear, particularly in conjunction with potential

amended clothes dryer energy conservation standards. DOE seeks information from interested

parties to further evaluate this issue in the NOPR analyses.

2.9.4.3 Clothes Washer Energy Conservation Standards

Whirlpool stated that the residential clothes washer standard that took effect January 1,

2007 is an additional burden. Whirlpool manufactures residential clothes washers, dishwashers,

and refrigerators that are subjected to energy conservation standards as well as the Energy Star

program. Whirlpool stated that these regulations would impact multiproduct manufacturers.

(Whirlpool, Public Meeting Transcript, No. 4.6 at p. 182) Whirlpool also stated that "burden" has

typically been represented as the costs of complying with regulations for doing things that are

not currently demanded in the marketplace. Whirlpool stated that for public companies, the

biggest burden is regulations limiting their ability to do other things that might be more desired

by consumers and/or stockholders. (Whirlpool, Public Meeting Transcript, No. 4.6 at p. 184)

DOE will consider these cumulative burdens in its development of the NOPR.

2.9.4.4 Other Regulatory Burden Comments

ACEEE asked if AHAM could identify manufacturer subgroups that could be

differentially impacted by regulatory burdens. (ACEEE, Public Meeting Transcript, No. 4.6 at p.

183) DOE will analyze manufacturer subgroups as part of the MIA it conducts at the NOPR

stage of the rulemaking.

ACEEE stated that cumulative regulatory burden also includes burden on stakeholders

beyond the equipment manufacturers. It includes the burdens on utilities who are attempting to

deliver efficiency to their customers. (ACEEE, Public Meeting Transcript, No. 4.6 at p. 182)

NRDC was concerned that cumulative regulatory burden could be a reason for DOE to propose a

lower energy conservation standard. However, NRDC stated that this decision making process

could also lead to more regulatory costs. For example, a standard in the European Union (EU)

could be a burden on manufacturers. However, according to NRDC, if DOE decided not to

regulate this product because of regulatory burden an argument could be made that if the EU

does not regulate a product, DOE should not regulate the product either. (NRDC, Public Meeting

Transcript, No. 4.6 at p. 184)

The cumulative burden focuses on the impacts of other product­specific Federal

requirements on manufacturers of the covered products with a compliance date 3 years prior to

and 3 years after the anticipated compliance dates of the amended energy conservation standards

of this rulemaking. Section 2.9.4 identifies several regulations that affect manufacturers of

products covered by this rulemaking in addition to the amended energy conservation standards

for residential clothes dryers and room air conditioners. While DOE discusses these and other

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regulations in chapter 12 of the preliminary TSD, only the cumulative impacts of other Federal

regulatory actions are considered as part of the cumulative regulatory burden on manufacturers.

2.9.5 Preliminary Results for the Manufacturer Impact Analysis

As part of the preliminary MIA, DOE discussed potential impacts of amended energy

conservation standards with manufacturers responsible for a majority of room air conditioner and

residential clothes dryer sales. These discussions took place during the interviews DOE

conducted for the engineering analysis. The interviews provided valuable information that DOE

used to evaluate the impacts of amended energy conservation standards on manufacturers’ cash

flows, manufacturing capacities, and employment levels. DOE discusses its findings from the

preliminary MIA interviews in the executive summary and in chapter 12 of the preliminary TSD.

2.10 LIFE­CYCLE COST SUBGROUP ANALYSIS

The LCC subgroup analysis evaluates economic impacts on selected groups of consumers

who might be adversely affected by a change in the national energy conservation standards for

the considered products. DOE evaluates impacts on particular subgroups of consumers primarily

by analyzing the LCC impacts and PBP for those particular consumers. DOE intends to evaluate

impacts of standards on low­income and fixed­income (i.e., senior) consumers.

DOE will use the LCC spreadsheet model to evaluate impacts on consumer subgroups.

DOE can analyze the LCC for any subgroup by applying the LCC spreadsheet model to only that

subgroup. DOE is particularly sensitive to increases in the consumer price of the considered

products, wishing to avoid a negative economic impact on any identified consumer subgroup.

2.11 UTILITY IMPACT ANALYSIS

The utility impact analysis includes an analysis of the effect of new energy conservation

standards on the electric and the gas utility industries. For this analysis, DOE adapted NEMS,

which is a large multi­sectoral, partial­equilibrium model of the U.S. energy sector that the EIA

has developed throughout the past decade, primarily for preparing EIA’s AEO. In previous

rulemakings, a variant of NEMS (currently termed NEMS­BT, BT referring to DOE’s Building

Technologies Program), was developed to better address the specific impacts of an energy

conservation standard. NEMS, which is available in the public domain, produces a widely

recognized baseline energy forecast for the United States through the year 2030. The typical

NEMS outputs include forecasts of electricity and natural gas sales, prices, and electric

generating capacity.

DOE conducts the utility impact analysis as a scenario that departs from the latest AEO

reference case. In other words, the energy savings impacts from amended energy conservation

standards are modeled using NEMS­BT to generate forecasts that deviate from the AEO

reference case.

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EEI stated that DOE should analyze avoided gas production and pipeline capacity due to

gas clothes dryer standards. (EEI, No. 5 at p. 5) NEMS allows DOE to report gas production

under alternative standards, but not pipeline capacity. However, the expected magnitude of

change in gas demand due to revised gas clothes dryer standards would likely have a negligible

effect on pipeline capacity.

2.12 ENVIRONMENTAL IMPACT ANALYSIS

The intent of the environmental assessment is to fulfill requirements to properly quantify

and consider the environmental effects of amended energy conservation standards for room air

conditioners and clothes dryers. The primary environmental effects of energy conservation

standards for the products considered in this rulemaking would be reduced power plant

emissions resulting from reduced consumption of electricity. DOE will assess these

environmental effects by using NEMS­BT to provide key inputs to its analysis. The portion of

the environmental assessment that will be produced by NEMS­BT considers carbon dioxide

(CO2), nitrogen oxides (NOX), and mercury (Hg). The environmental assessment also considers

impacts on SO2 emissions. After a brief discussion of general methodology, this section will

address each of the relevant emissions. This section then explains how DOE plans to monetize

the benefits associated with emissions reductions.

2.12.1 Carbon Dioxide

In the absence of any regulation of power plant emissions of CO2, a DOE standard is

likely to result in reductions of these emissions. The CO2 emission reductions likely to result

from a standard will be estimated using NEMS­BT and national energy savings estimates drawn

from the NIA spreadsheet model. The net benefit of the standard is the difference between

emissions estimated by NEMS­BT at each standard level considered and the AEO Reference

Case. NEMS­BT tracks CO2 emissions using a detailed module that provides results with broad

coverage of all sectors and inclusion of interactive effects.

EEI stated that DOE should account for the rise in renewable portfolio standards and the

possibility of an upcoming CO2 cap and trade program, which would reduce the amount of CO2

produced per kWh generated. (EEI, No. 5 at p. 6) As stated above, DOE utilizes the most recent

forecasts from EIA’s NEMS to estimate the future mix of power generation sources. EIA

accounts for policies that have been enacted at the time of its analysis, including renewable

portfolio standards and regional cap and trade programs. DOE believes that its approach provides

the most reliable basis for estimating future power sector emissions.

2.12.2 Sulfur Dioxide

DOE has preliminarily determined that SO2 emissions from affected Electric Generating

Units (EGUs) are subject to nationwide and regional emissions cap and trading programs that are

likely to eliminate the standards’ impact on SO2 emissions. The costs of meeting such emission

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cap requirements are integrated in the electricity prices used in DOE’s analysis of the standards.

Title IV of the Clean Air Act sets an annual emissions cap on SO2 for all affected EGUs. SO2

emissions from 28 eastern States and the District of Columbia (DC) are also limited under the

Clean Air Interstate Rule (CAIR, published in the Federal Register on May 12, 2005. 70 FR

25162 (May 12, 2005)), which creates an allowance­based trading program that will gradually

replace the Title IV program in those States and DC. (The recent legal history surrounding CAIR

is discussed below.) The attainment of the emissions caps is flexible among EGUs and is

enforced through the use of emissions allowances and tradable permits. Under existing EPA

regulations, any excess SO2 emission allowances resulting from the lower electricity demand

caused by the imposition of an efficiency standard could be used to permit offsetting increases in

SO2 emissions by any regulated EGU. However, if the standard resulted in a permanent increase

in the quantity of unused emission allowances, there would be an overall reduction in SO2

emissions from the standards. While there remains some uncertainty about the ultimate effects

of efficiency standards on SO2 emissions covered by the existing cap and trade system, the

NEMS­BT modeling system that DOE plans to use to forecast emissions reductions currently

indicates that no physical reductions in power sector emissions would occur for SO2.

Even if there is no significant reduction in the overall emissions of SO2 that results from

the standard, there may still be some economic benefit from reduced demand for SO2 emission

allowances that is not fully reflected in the cost savings experienced by individual consumers.

Electricity savings that decrease the overall demand for SO2 emissions allowances could lower

allowance prices and thereby result in some economic benefits for all electricity consumers, not

just those that reduced their electricity use as a result of an efficiency standard. DOE does not

plan to monetize this particular benefit because the effect on the SO2 allowance price from any

single energy conservation standard is likely to be small and highly uncertain.

2.12.3 Nitrogen Oxides

NEMS­BT has an algorithm for estimating NOx emissions from power generation. The

impact of these emissions, however, will be affected by the CAIR, which the Environmental

Protection Agency (EPA) issued on May 12, 2005. CAIR will permanently cap emissions of NOx

in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12, 2005).

Much like SO2 emissions, a cap on NOX emissions means that the amended standards

may have little or no physical effect on these emissions in the 28 eastern States and the DC

covered by CAIR. Although CAIR has been remanded to the EPA by the DC Circuit, it will

remain in effect until it is replaced by a rule consistent with the Court’s July 11, 2008, opinion in

North Carolina v. EPA. 531 F.3d 896 (DC Cir. 2008); see also North Carolina v. EPA, 550 F.3d

1176 (DC Cir. 2008). Because all States covered by CAIR opted to reduce NOX emissions

through participation in cap­and­trade programs for electric generating units, emissions from

these sources are capped across the CAIR region.

Standards may produce an environmental­related economic benefit in the form of lower

prices for emissions allowance credits. As with SO2 allowance prices, however, DOE does not

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plan to monetize this particular benefit because the effect on the NOX allowance price from any

single energy conservation standard is likely small and highly uncertain.

DOE plans to use NEMS­BT to estimate the emissions reductions from possible

standards in the 22 States where emissions are not capped.

2.12.4 Mercury

Similar to emissions of SO2 and NOX, future emissions of Hg would have been subject to

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 28606

(May 18, 2005). CAMR would have permanently capped emissions of mercury for new and

existing coal­fired power plants in all States by 2010. However, on February 8, 2008, the DC

Circuit issued its decision in New Jersey v. Environmental Protection Agency, in which the DC

Circuit, among other actions, vacated the CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has

decided to develop emissions standards for power plants under the Clean Air Act (Section 112),

consistent with the DC Circuit’s opinion on the CAMR. See

http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending EPA's

forthcoming revisions to the rule, DOE is excluding the CAMR from its Environmental

Analysis. In the absence of CAMR, a DOE standard would likely reduce Hg emissions, and

DOE plans to use NEMS­BT to estimate these emission reductions.

2.12.5 Particulate Matter

DOE acknowledges that particulate matter (PM) impacts are of concern due to human

exposures that can impact health. But impacts of PM emissions reduction are much more

difficult to estimate than other emissions reductions due to the complex interactions between

PM, other power plant emissions, meteorology, and atmospheric chemistry that impact human

exposure to particulates. Human exposure to PM usually occurs at a significant distance from the

power plants that are emitting particulates and particulate precursors. When power plant

emissions travel this distance, they undergo highly complex atmospheric chemical reactions.

Although the EPA does keep inventories of direct PM emissions of power plants, in its source

attribution reviews, the EPA does not separate direct PM emissions from power plants from the

sulfate particulates indirectly produced through complex atmospheric chemical reactions. The

great majority of PM emissions from power plants are of these secondary particles (secondary

sulfates). Thus, it is not useful to examine how the amended standard impacts direct PM

emissions independent of indirect PM production and atmospheric dynamics. Therefore, DOE is

not planning to assess the impact of these standards on particulate emissions. Further, even the

cumulative impact of PM emissions from power plants and indirect emissions of pollutants from

other sources is unlikely to be significant.

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2.12.6 Monetization of Emissions Reduction Benefits

For those emissions for which real national emission reductions are anticipated (CO2, Hg,

and NOX for 22 states), only ranges of estimated economic values based on environmental

damage studies of varying quality and applicability are available. Therefore, DOE plans on

reporting estimates of monetary benefits derived using these values and plans to consider these

benefits in weighing the costs and benefits of each of the standard levels considered. In

accordance with U.S. Office of Management and Budget (OMB) guidance, DOE will conduct

two calculations of the monetary benefits derived using each of the economic values used, one

using a real discount rate of 3 percent and another using a real discount rate of 7 percent.f

In order to estimate the monetary value of benefits resulting from reduced emissions of

CO2 emissions, it is DOE’s intent to use in its analysis the most current Social Cost of Carbon

(SCC) values developed and/or agreed to by interagency reviews. The SCC is intended to be a

monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions,

including, but not limited to, net agricultural productivity loss, human health effects, property

damage from sea level rise, and changes in ecosystem services. Any effort to quantify and to

monetize the harms associated with climate change will raise serious questions of science,

economics, and ethics. But with full regard for the limits of both quantification and monetization,

the SCC can be used to provide estimates of the social benefits of reductions in GHG emissions.

At the time of this notice, the most recent interagency estimates of the potential global

benefits resulting from reduced CO2 emissions were $5, $10, $20, $34 and $56 per metric ton,

and the estimate of the potential domestic benefits was approximately $1 per metric ton. All of

these unit values represent emissions that are valued in 2008$ for emissions that occur in 2007.

For emissions (or emission reductions) that occur in later years, these values are escalated in real

terms by 3 percent per year, then discounted to the present using real discount rates of 7 percent

and 3 percent.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to

the contribution of CO2 and other GHG to changes in the future global climate and the potential

resulting damages to the world economy. Thus, these values are subject to change.

DOE also intends to estimate the potential monetary benefit of reduced NOx and Hg

emissions resulting from the standard levels it considers. For NOx emissions, available estimates

suggest a very wide range of monetary values for NOx emissions, ranging from $370 per ton to

$3,800 per ton of NOx from stationary sources, measured in 2001$ (equivalent to a range of $442

to $4,540 per ton in 2008$). Refer to the OMB, Office of Information and Regulatory Affairs,

“2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded

Mandates on State, Local, and Tribal Entities,” for additional information.

For Hg emissions reductions, DOE has previously determined that the impact of mercury

emissions from power plants on humans is considered highly uncertain. However, DOE

f OMB, Circular A­4: Regulatory Analysis (Sept. 17, 2003).

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identified two estimates of the environmental damage of mercury based on two estimates of the

adverse impact of childhood exposure to methyl mercury on intelligence quotient (IQ) for

American children, and subsequent loss of lifetime economic productivity resulting from these

IQ losses. The high­end estimate is based on an estimate of the current aggregate cost of the loss

of IQ in American children that results from exposure to mercury of U.S. power plant origin

($1.3 billion per year in year 2000$), which works out to $33.3 million per ton emitted per year

(2008$). Refer to L. Trasande et al., “Applying Cost Analyses to Drive Policy that Protects

Children,” 1076 Ann. N.Y. Acad. Sci. 911 (2006) for additional information. The low­end

estimate is $0.66 million per ton emitted (in 2004$) or $0.745 million per ton in 2008$. DOE

derived this estimate from a published evaluation of mercury control using different methods and

assumptions from the first study but also based on the present value of the lifetime earnings of

children exposed. See Ted Gayer and Robert Hahn, “Designing Environmental Policy: Lessons

from the Regulation of Mercury Emissions,” Regulatory Analysis 05–01, American Enterprise

Institute­Brookings Joint Center for Regulatory Studies, Washington, DC (2004). A version of

this paper was published in the Journal of Regulatory Economics in 2006. The estimate was

derived by back­calculating the annual benefits per ton from the net present value of benefits

reported in the study.

The Joint Comment stated DOE should monetize the value of emissions savings

produced by different trial standard levels. (Joint Comment, No. 9 at p. 5) Whirlpool argued

against using values for avoided CO2 in DOE’s analysis, stating that projected market values are

too uncertain. (Whirlpool, No. 15 at p. 13) As stated above, DOE plans on reporting estimates of

monetary benefits derived using ranges of values and plans to consider these benefits in

weighing the costs and benefits of each of the standard levels considered. The ranges used and

the basis for them are summarized in the environmental assessment in the preliminary TSD.

For more detail on the environmental assessment, refer to the environmental assessment

report in the preliminary TSD.

2.13 EMPLOYMENT IMPACT ANALYSIS

The imposition of standards can affect employment both directly and indirectly. Direct

employment impacts are changes, produced by new standards, in the number of employees at

plants that produce the covered products and at the affiliated distribution and service companies.

DOE evaluates direct employment impacts in the manufacturer impact analysis. Indirect

employment impacts that occur because of the imposition of standards may result from

consumers shifting expenditures between goods (the substitution effect) and from changes in

income and overall expenditure levels (the income effect).

DOE will utilize Pacific Northwest National Laboratory’s impact of sector energy

technologies (ImSET) model to investigate the indirect employment impacts from standards. The

ImSET model, which was developed for DOE’s Office of Planning, Budget, and Analysis,

estimates the employment and income effects energy­saving technologies produce in buildings,

industry, and transportation. In comparison with simple economic multiplier approaches, ImSET

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allows for more complete and automated analysis of the economic impacts of energy

conservation investments.

2.14 REGULATORY IMPACT ANALYSIS

In the NOPR stage, DOE will prepare a regulatory impact analysis (RIA) pursuant to

Executive Order 12866, Regulatory Planning and Review, 58 FR 51735, October 4, 1993, which

is subject to review under the Executive Order by the Office of Information and Regulatory

Affairs at the Office of Management and Budget. The RIA addresses the potential for nonregulatory approaches to supplant or augment energy conservation standards in order to improve

the energy efficiency or reduce the energy consumption of the products covered under this

rulemaking.

DOE recognizes that voluntary or other non­regulatory efforts by manufacturers, utilities,

and other interested parties can substantially affect energy efficiency or reduce energy

consumption. DOE will base its assessment on the actual impacts of any such initiatives to date,

but also will consider information presented by interested parties regarding the impacts existing

initiatives might have in the future.

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REFERENCES
 

1	 T. Richter. Energy Efficient Laundry Process. 2005. GE Global Research, Final Project

Report for the Department of Energy, DOE Award DE­FC26­01NT41261.

2 U.S. Department of Energy­Energy Information Administration, Residential Energy

Consumption Survey, 2005 Public Use Microdata Files, 2009. Washington, DC. Available

online at: http://www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html

3	 U.S. Department of Energy­Energy Information Administration, An Updated Annual Energy

Outlook 2009 Reference Case Reflecting Provisions of the American Recovery and

Reinvestment Act and Recent Changes in the Economic Outlook, April 2009. Washington,

DC. Report #: SR­OIAF/2009­03.

http://www.eia.doe.gov/oiaf/servicerpt/stimulus/index.html?featureclicked=1&

4	 Office of Management and Budget, OMB Circular A­4, “Regulatory Analysis,” Sept. 17,

2003. Washington, DC. p. 33. Available online at:

www.whitehouse.gov/omb/circulars/index.html

5	 Ibid., p. 34.

6	 U.S. Department of Energy­Office of Energy Efficiency and Renewable Energy, Energy

Conservation Program: Energy Conservation Standards for General Service Fluorescent

Lamps and Incandescent Reflector Lamps; Proposed Rule. Federal Register, 2009. 74(69):

pp. 16920–16968.

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