Rulemaking Framework for Residential Dehumidifiers 

U.S. Department of Energy 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

August 17, 2012 
i

TABLE OF CONTENTS 

1. INTRODUCTION .................................................................................................................. 1

1.1 The Appliances and Commercial Equipment Standards Program .............................. 1

1.2 Overview of the Rulemaking Process .......................................................................... 2

1.2.1 Test Procedures ......................................................................................................... 2

1.2.2 Rulemaking Process and Stakeholder Participation ................................................. 3

1.3 Preliminary Analysis ................................................................................................... 4

1.4 Notice of Proposed Rulemaking .................................................................................. 4

1.5 Final Rule ..................................................................................................................... 5

2. ANALYSES FOR RULEMAKING ....................................................................................... 6

3. MARKET AND TECHNOLOGY ASSESSMENT ............................................................... 8

3.1 Market Assessment ...................................................................................................... 8

3.2 Product Classes ............................................................................................................ 8

3.3 Technology Assessment .............................................................................................. 9

3.4 Baseline Units ............................................................................................................ 10

4. SCREENING ANALYSIS ................................................................................................... 11

5. ENGINEERING ANALYSIS ............................................................................................... 12

5.1 Engineering Analysis Overview ................................................................................ 12

5.2 Baseline Models ......................................................................................................... 13

5.3 Approach for Determining the Cost-Efficiency Relationship ................................... 14

5.4 Efficiency Levels ....................................................................................................... 16

5.5 Proprietary Designs ................................................................................................... 17

5.6 Outside Regulatory Changes Affecting the Engineering Analysis ............................ 18

6. ENERGY USE ...................................................................................................................... 18

7. MARKUPS FOR PRODUCT PRICE DETERMINATION ................................................ 19

8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS .......................................... 20

8.1 Overview .................................................................................................................... 20

8.2 Approach .................................................................................................................... 21

8.3 Electricity Prices ........................................................................................................ 23

8.4 Maintenance, Repair, and Installation Costs ............................................................. 23

8.5 Product Lifetimes ....................................................................................................... 24

8.6 Discount Rates ........................................................................................................... 24

8.7 Energy Efficiency in the Base Case ........................................................................... 25

9. SHIPMENTS ANALYSIS.................................................................................................... 25

9.1 Base-Case Forecast .................................................................................................... 25

9.2 Impacts of Standards on Product Shipments ............................................................. 26

10. NATIONAL IMPACT ANALYSIS ..................................................................................... 27

10.1 Inputs to Forecasts ..................................................................................................... 27

10.2 National Energy Savings ........................................................................................... 28

10.3 Net Present Value ...................................................................................................... 29
ii

11. CONSUMER SUBGROUP ANALYSIS ............................................................................. 30

12. MANUFACTURER IMPACT ANALYSIS......................................................................... 30

12.1 Sources of Information for the Manufacturer Impact Analysis ................................. 31

12.2 Industry Cash-Flow Analysis .................................................................................... 31

12.3 Manufacturer Subgroup Analysis .............................................................................. 32

12.4 Competitive Impacts Assessment .............................................................................. 33

12.5 Cumulative Regulatory Burden ................................................................................. 33

13. UTILITY IMPACT ANALYSIS .......................................................................................... 34

14. EMPLOYMENT IMPACT ANALYSIS .............................................................................. 35

15. EMISSIONS ANALYSIS ..................................................................................................... 35

15.1 Carbon Dioxide .......................................................................................................... 35

15.2 Sulfur Dioxide ........................................................................................................... 36

15.3 Nitrogen Oxides ......................................................................................................... 36

15.4 Mercury ...................................................................................................................... 36

15.5 Particulate Matter ....................................................................................................... 37

16. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS .......... 37

17. REGULATORY IMPACT ANALYSIS ............................................................................... 38

APPENDIX A – SUMMARY OF ITEMS FOR COMMENT FROM INTERESTED 

PARTIES ................................................................................................................... 40

LIST OF TABLES 

Table 5-1 Dehumidifier Energy Conservation Standards and Proposed Baseline Unit Efficiencies

....................................................................................................................................................... 14

Table 5-2 Efficiency Levels for Dehumidifier (Representative) Analysis ................................... 17

LIST OF FIGURES 

Figure 2-1 Flow Diagram of Analyses for the Residential Dehumidifier Energy Conservation 

Standards Rulemaking Process ....................................................................................................... 7
iii

LIST OF ACRONYMS 

AEO Annual Energy Outlook 

AHAM Association of Home Appliance Manufacturers 

ANOPR advance notice of proposed rulemaking 

ANSI American National Standards Institute 

BT Building Technologies Program 

CAIR Clean Air Interstate Rule 

CEC California Energy Commission 

CFR Code of Federal Regulations 

CO2 carbon dioxide 

CSA Canadian Standards Association 

CSL candidate standard level 

D.C. District of Columbia 

DOE U.S. Department of Energy 

DOJ U.S. Department of Justice 

EERE Office of Energy Efficiency and Renewable Energy 

EF energy factor 

EGU electric generating unit 

EIA Energy Information Administration 

EISA Energy Independence and Security Act of 2007 

EPACT Energy Policy Act of 2005 

EPA U.S. Environmental Protection Agency 

EPCA Energy Policy and Conservation Act 

FR Federal Register

GDP gross domestic product 

GHG greenhouse gas 

GRIM Government Regulatory Impact Model 

Hg Mercury 

HCFC hydrochlorofluorocarbon 

IEC International Electrotechnical Commission 

ImSET Impact of Sector Energy Technologies 

kWh kilowatt-hour 

LCC life-cycle cost 

NAICS North American Industry Classification System 

NECPA National Energy Conservation Policy Act of 1978 

NEMS National Energy Modeling System 

NES national energy savings 

NESHAP national emissions standards for hazardous air pollutants 

NOPR notice of proposed rulemaking 

NOx oxides of nitrogen 

NPV net present value 

OMB U.S. Office of Management and Budget 

PM particulate matter 

PNNL Pacific Northwest National Laboratory 

PBP payback period 
iv

R&D research and development 

RECS Residential Energy Consumption Survey 

SCC social cost of carbon 

SEC Securities and Exchange Commission 

SG&A selling, general, and administrative costs 

SNOPR supplemental notice of proposed rulemaking 

SO2 sulfur dioxide 

SWEF shipment-weighted efficiency 

TSD technical support document 

TSL trial standard level 

U.S. United States 

U.S.C. United States Code
1

Rulemaking Framework for Residential Dehumidifiers 

1. INTRODUCTION 

The purpose of this document is to describe the procedural and analytical approaches the U.S. 

Department of Energy (DOE) anticipates using to evaluate energy conservation standards for 

residential dehumidifiers. 

The DOE Appliances and Commercial Equipment Standards Program, in the Office of Energy 

Efficiency and Renewable Energy’s (EERE’s) Building Technologies Program, develops and 

promulgates test procedures and energy conservation standards for consumer appliances and 

commercial equipment. The process for developing standards involves analyses, public notice, 

and consultation with interested parties. Such parties, collectively referred to as stakeholders, 

include manufacturers, consumers, energy conservation and environmental advocates, State and 

Federal agencies, and any other groups or individuals having an interest in the standards and test 

procedures. 

This document is intended to inform stakeholders of the standards rulemaking process for 

dehumidifiers and to encourage and facilitate stakeholder input during the rulemaking. This 

document is the starting point for developing standards and is not a definitive statement with 

respect to any issue to be determined in the rulemaking. 

Section 1 provides an overview of the rulemaking process. Sections 2 through 17 discuss 

analyses DOE intends to conduct to follow the statutory guidance and requirements for this 

standards rulemaking. In determining whether amended energy conservation standards are 

feasible and justified, DOE will conduct an engineering analysis, a life-cycle cost (LCC) and 

payback period (PBP) analysis, a national impact analysis, and a manufacturer impact analysis, 

among others. 

Information regarding this rulemaking will be maintained on the DOE website at: 

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

1.1 The Appliances and Commercial Equipment Standards Program 

Title III, Part B of the Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163, (42 

U.S.C. 6291–6309), as amended, established an energy conservation program for consumer 

products other than automobiles.1

 

1

 Upon codification in the U.S. Code, Part B was re-designated Part A for editorial reasons. 

This document contains comment boxes that highlight issues on which DOE seeks 

comment and requests feedback from interested parties. The comment boxes also are used 

to ask specific questions on the approaches the Department is proposing to follow to 

conduct the analyses required for the standards rulemaking. Such requests for stakeholder 

feedback are numbered according to the section in which they appear.
2

The Energy Policy Act of 2005 (EPACT 2005), Pub. L. 109-58, amended EPCA to establish 

energy conservation standards for dehumidifiers2

 manufactured as of October 1, 2007. (Section 

135(c)(4)) EPACT 2005 also required that DOE issue a final rule by October 1, 2009, to 

determine whether these standards should be amended. (Id.) Compliance with any amended

standards would be required for dehumidifiers manufactured as of October 1, 2012. (Id.) In the 

event that DOE did not publish a final rule, EPACT 2005 specified a new set of amended 

standards with a compliance date of October 1, 2012. (Id.)

DOE issued an advance notice of proposed rulemaking (ANOPR) to consider energy 

conservation standards for dehumidifiers and other products. 72 FR 64432 (Nov. 15, 2007). The 

Energy Independence and Security Act of 2007 (EISA 2007), Pub. L 110-140 subsequently 

amended EPCA to prescribe new energy conservation standards for dehumidifiers manufactured 

on or after October 1, 2012. DOE codified the EISA 2007 standards at 10 CFR 430.32(v)(2). 74 

FR 12058 (Mar. 23, 2009).

EPCA also requires that, not later than 6 years after the issuance of a final rule establishing or 

amending a standard, DOE publish a notice of proposed rulemaking (NOPR) proposing new 

standards or a notice of determination that the existing standards do not need to be amended. (42 

U.S.C. 6295(m)(1)) 

1.2 Overview of the Rulemaking Process 

The rulemaking process for dehumidifiers is comprised of several steps: establishing test 

procedures to evaluate energy consumption of products; performing various preliminary analyses 

of the technological and economic feasibility of standards; issuing a notice of proposed 

rulemaking; and issuing a final rule. The Department encourages stakeholder participation in the 

rulemaking process. 

1.2.1 Test Procedures 

EPCA specifies that the test procedure for dehumidifiers must be based on the U.S. 

Environmental Protection Agency (EPA)’s test criteria used under the ENERGY STAR Program 

in effect on August 8, 2005, unless DOE revises the test procedures. (42 U.S.C. 6293(b)(13)) 

Those ENERGY STAR test criteria require that American National Standards Institute 

(ANSI)/Association of Home Appliance Manufacturers (AHAM) Standard DH-1 be used to 

measure capacity in pints of moisture removed per day, while Canada’s CAN/Canadian 

Standards Association (CSA)-C749-94 is used to calculate the energy factor (EF) in terms of 

liters of moisture removed per kilowatt-hour (kWh). DOE codified the test procedure 

requirements from EPCA for dehumidifiers at 10 CFR part 430 subpart B, appendix X. 71 FR 

71340 (Dec. 8, 2006).

 

2

 Dehumidifiers are defined as self-contained, electrically operated, and mechanically encased assemblies consisting 

of: (1) a refrigerated surface (evaporator) that condenses moisture from the atmosphere; (2) a refrigerating system, 

including an electric motor; (3) an air-circulating fan; and (4) a means for collecting or disposing of the condensate. 

(42 U.S.C. 6291(34)) 
3

EPCA requires that DOE amend the test procedures for certain residential products, including 

dehumidifiers, to incorporate measures of standby mode and off mode energy use, if technically 

feasible. DOE published a NOPR in which it proposed to incorporate by reference in the test 

procedures for dehumidifiers and other products an international test method for measuring 

standby mode and off mode power consumption, International Electrotechnical Commission 

(IEC) Standard 62301. 75 FR 75290 (Dec. 2, 2010). DOE subsequently published a 

supplemental notice of proposed rulemaking (SNOPR) to propose referencing the updated 

version of IEC Standard 62301. 76 FR 58346 (Sept. 20, 2011). In a second SNOPR, DOE

proposed in relevant part to measure both capacity and EF for dehumidifiers according to the 

current version of AHAM Standard DH-1. 77 FR 31444 (May 25, 2012).

1.2.2 Rulemaking Process and Stakeholder Participation 

Under EPCA, when DOE establishes new or amended standards, it must consider, to the greatest 

extent practicable: (1) the economic impact of the standard on the manufacturers and consumers 

of the affected products; (2) the savings in operating costs throughout the estimated average life 

of the product compared to any increases in the initial cost, or maintenance expense; (3) the total 

projected amount of energy savings likely to result directly from the imposition of the standard; 

(4) any lessening of the utility or the performance of the products likely to result from the 

imposition of the standard; (5) the impact of any lessening of competition, as determined in 

writing by the Attorney General, that is likely to result from the imposition of the standard; (6) 

the need for national energy conservation; and (7) other factors the Secretary considers relevant. 

(42 U.S.C. 6295 (o)(2)(B)(i)) Other statutory requirements include those set forth in 42 U.S.C. 

6295 (o)(1)–(2)(A), (2)(B)(ii)–(iii), and (3)–(4). 

The Department considers stakeholder participation to be a very important part of the process for 

setting energy conservation standards. The Department actively encourages the participation and 

interaction of all stakeholders during the comment period of each rulemaking stage. Beginning 

with public comment on the Framework Document and during subsequent comment periods, 

interactions among stakeholders provide a balanced discussion of critical information required to 

conduct the standards rulemaking. Additionally, the Department encourages the development 

and submission of consensus agreements between stakeholders. 

In conducting the energy conservation standards rulemakings, DOE involves stakeholders 

through public notifications (i.e., Federal Register notices). Subsequent to notice of the 

Framework Document, the standards rulemaking process involves three public notices. The 

Preliminary Analysis (see section 1.3) incorporates stakeholder comments to the Framework 

Document and is designed to publicly vet the models and tools used in the rulemaking, and to 

facilitate public participation before the proposed rule stage. The second notice is a notice of 

proposed rulemaking (NOPR, see section 1.4), which presents a discussion of comments 

received in response to the Preliminary Analysis; the analysis of the impacts of standards on 

consumers, manufacturers and the nation; the Department’s weighing of the impacts; and the 

proposed standards. The third notice is the final rule (see section 1.5), which presents a 

discussion of comments received in response to the NOPR; the revised analysis of the impacts of 

standards; the Department’s weighing of the impacts; any final standards adopted by DOE; and 

the compliance dates of such standards. 
4

1.3 Preliminary Analysis 

As part of its initial rulemaking activities, the Department typically identifies the product design 

options or efficiency levels that it will analyze in detail and those it should eliminate from further 

consideration. This process includes a market and technology assessment (see section 3) and a 

screening analysis (see section 4). These activities include identifying the key issues and design 

options or efficiency levels to be considered by the Department in the rulemaking. 

At the start of the Preliminary Analysis, the Department considers potential efficiency levels for 

each product class. The Department uses these efficiency levels to collect manufacturer cost 

data, historical shipment data, shipment-weighted average efficiency data, and preliminary 

manufacturer impact data (e.g., capital conversion expenditures, marketing costs, research and 

development costs). During the Preliminary Analysis stage, DOE presents consumer LCC impact 

and PBP results (see section 8); national energy savings (NES) and consumer net present value 

(NPV) results (see section 10) for a range of efficiency or energy use levels; and will also present 

a preliminary manufacturer impact analysis (see section 12).

The Department bases the selection of efficiency or energy use levels to analyze on the costs and 

benefits of efficiency levels or design options. In addition to the efficiency corresponding to the 

maximum technologically feasible (“max tech”) design and the efficiency corresponding to the 

minimum life-cycle-cost point, DOE generally selects levels or design options for consideration 

that span the full range of technologically achievable efficiencies. 

The range of levels analyzed typically includes: 

• The highest energy efficiency level or lowest energy consumption level that is 

technologically feasible (the “max-tech” level); 

• The level with the lowest LCC; and 

• Levels that incorporate noteworthy technologies or fill in large gaps between other 

efficiency levels considered. 

The efficiency or energy use levels analyzed serve to demonstrate the functions and outputs of 

the models and tools used by DOE . During the Preliminary Analysis, these models and tools are 

tested for the different product classes at each efficiency or energy use level analyzed. 

The Department will make the results of the analyses available on its website for review and will 

consider comments on them after publication of the Preliminary Analysis. When the Department 

publishes the Preliminary Analysis, the Department will also make available a technical support 

document (TSD) containing the details of all the analyses performed to date. 

1.4 Notice of Proposed Rulemaking 

After the publication of the Preliminary Analysis, there is a public comment period and a public 

meeting. DOE also conducts further economic impact analyses. These analyses may include 

refinements of previous analyses, and will include a consumer LCC sub-group analysis (see

section 11), a complete manufacturer impact analysis (see section 12), a utility impact analysis 
5

(see section 13), an employment impact analysis (see section 14), an emissions analysis (see

section 15), and a regulatory impact analysis (see section 17). 

The Department will make the results of all the analyses available on its website for review and 

will consider comments after the publication of the NOPR. This review and comment process 

may result in revisions to the analyses. This analytical process ends with the selection of 

proposed standard levels presented in the NOPR. The Department selects the proposed standard 

levels from the trial standard levels (TSLs) analyzed. The NOPR, published in the Federal 

Register, will document the evaluation and selection of any proposed standards. 

For each product class, the Department will identify the maximum improvement in energy 

efficiency or maximum reduction in energy use that is technologically feasible. If the 

Department proposes a level that is below the maximum technology, it will sequentially explain 

the reasons for eliminating higher levels beginning with the highest level considered. The 

Department will present the analysis results in the NOPR and the analysis details in an 

accompanying TSD. 

The Department considers many factors in selecting proposed standards. These factors or criteria 

are established by statute and capture the many benefits and costs of the standards. When the 

Department publishes the NOPR, it will provide the Department of Justice (DOJ) with a copy of 

the NOPR and TSD and will solicit feedback on the impact of the proposed standard level on 

competition. DOJ will review these standard levels in light of any lessening of competition that 

is likely to result from the imposition of standards. The Department will consider DOJ’s 

determination on the impacts of the proposed standard on competition in preparing the final rule. 

The NOPR is followed by a public comment period that includes a public meeting. 

1.5 Final Rule 

Revisions to the analyses may result from the public comments on the NOPR. On the basis of the 

public comments, DOE will review the engineering and economic impact analyses and proposed 

standards and make modifications as necessary. 

After the publication of the NOPR, the Department will conduct a thorough review of all 

analyses performed, and of the TSLs. Final revisions to the analyses and TSLs will be made as 

appropriate. 

Before the final rule is issued, the Department will consider DOJ comments on the NOPR 

relating to the impacts of the proposed standard levels on competition to determine whether 

changes to these standard levels are needed. 

The standards rulemaking will conclude with the publication of the final rule. The Department 

will select any final standard levels based on the complete record of the standards rulemaking. 

The final rule will promulgate any final standard levels and their compliance date and explain the 

basis for their selection. The final rule will be accompanied by a final TSD. 
6

2. ANALYSES FOR RULEMAKING 

EPCA requires DOE to establish energy conservation standards that achieve the maximum 

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

Economic justification includes consideration of the economic impacts on domestic 

manufacturers and consumers, national benefits including environmental impacts, issues of 

consumer utility, and impacts from any lessening of competition. The purpose of the analyses 

conducted in support of the standards rulemaking will be to ensure that the final standards meet 

these criteria of technological feasibility and economic justification. 

This section offers an overview of DOE’s analytical methodology and discusses the major 

components of the analyses DOE will conduct. A consistent approach to analysis throughout the 

rulemaking will be ensured through the consideration of each analysis as a part of the overall 

standards-setting framework. 

Figure 1 summarizes the analytical components of the standards-setting process. The analyses 

are presented in the center column. Each analysis has a set of key inputs, which are data and 

information required for the analysis. “Approaches” are the methods that will be used to obtain 

key inputs. For example, some key inputs exist in public databases, some will be collected from 

stakeholders, and some will be developed by the project team in support of the rulemaking. The 

results of each analysis are key outputs, which feed directly into the rulemaking. Dotted lines 

connecting one analysis to another indicate the flow of information. 
7

Figure 2-1 Flow Diagram of Analyses for the Residential Dehumidifier Energy 

Conservation Standards Rulemaking Process

Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Revise Preliminary

Analyses

Life-Cycle Cost 

Sub-Group Analysis

Manufacturer Impact 

Analysis

Shipments

Analysis

Employment Impact

Analysis 

Revise Analyses

• Product Classes

• Technology Options

• Industry Cash Flow

• Sub-Group Cash-Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Product Designs

• Life-Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non-Regulatory Programs

Framework Document

• Efficiency-Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products 

• Historical Shipments

•Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Design Options

Product Classes

Retail 

Prices

Design Energy/ Use

Advance Notice of Proposed Rulemaking (ANO)

• Efficiency/Performance

• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy Use 

Data

Environmental

Assessment

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET

• NEMS-BT

• Design Options

• Energy Price Forecasts

• Site-to-Source Factors

• Energy-Efficiency Levels

Direct Employment 

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life-Cycle Costs

• Payback Periods

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC

• Energy Prices

Annual Energy Use (UEC)

Preliminary 

Manufacturer Impact 

Analysis

• Manufacturer Prices

• Average Costs

• Conversion Capital Expenditures

• Direct Employment Impacts

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy-Efficiency 

Levels

• Department of Justice Review

Product Designs

Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Analyses

Life-Cycle Cost 

Sub-Group Analysis

Manufacturer Impact 

Analysis

Shipments

Analysis

Employment Impact

Analysis 

Revise Analyses

• Product Classes

• Technology Options

• Industry Cash Flow

• Sub-Group Cash-Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Product Designs

• Life-Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non-Regulatory Programs

Framework Document

• Efficiency-Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products 

• Historical Shipments

•Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Design Options

Product Classes

Retail 

Prices

Design Energy/ Use

Publication of Preliminary Analyses

• Efficiency/Performance

• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy Use 

Data

Environmental

Assessment

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET

• NEMS-BT

• Design Options

• Energy Price Forecasts

• Site-to-Source Factors

• Energy-Efficiency Levels

Direct Employment 

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life-Cycle Costs

• Payback Periods

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC

• Energy Prices

Annual Energy Use (UEC)

Preliminary 

Manufacturer Impact 

Analysis

• Manufacturer Prices

• Average Costs

• Conversion Capital Expenditures

• Direct Employment Impacts

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy-Efficiency 

Levels

• Department of Justice Review

Product Designs
8

3. MARKET AND TECHNOLOGY ASSESSMENT 

The market and technology assessment will provide information about the residential 

dehumidifier product industries. This assessment is used to determine product classes and 

identify potential design options or efficiency levels for each product class. 

3.1 Market Assessment 

The Department will qualitatively and quantitatively characterize the structure of the residential 

dehumidifier product industries and markets. In the market assessment, the Department will 

identify and characterize the manufacturers of dehumidifiers; estimate market shares and trends 

in the market; address regulatory and non-regulatory initiatives intended to improve the energy 

efficiency or reduce the energy consumption of dehumidifiers; and explore the potential for 

technological improvements in the design and manufacturing of dehumidifiers. 

The Department will use historical equipment shipments and prices as an aid in creating 

shipment scenarios and predicting future prices. Market structure data will be used to assess 

competitive impacts as part of the manufacturer impact analysis. 

Item 3-1 The Department requests information that would contribute to the market 

assessment (e.g., current product features and efficiencies, product-feature and 

efficiency trends, historical product shipments and prices). 

3.2 Product Classes 

The Department intends to separate dehumidifiers into product classes. The Department will 

consider a separate energy conservation standard for each product class. The criteria for 

separation into different classes are: type of energy used and capacity or other performancerelated features that justify a separate energy conservation standard. In determining product 

classes, DOE is required to consider the utility of the feature to the consumer and other factors 

deemed appropriate by the Secretary. (42 U.S.C. 6295(q)) 

For dehumidifiers, EPCA establishes product classes based on the capacity of the unit as 

measured in pints of water extracted per day. (42 U.S.C. 6295(cc)) The Department will analyze 

whether there are unique design constraints associated with a unit’s capacity that warrant the 

creation of separate product classes. In this Framework Document, the Department is considering 

the following product classes as they were established in the EISA 2007 amendments to EPCA 

for dehumidifiers manufactured on or after October 1, 2012 (42 U.S.C. 6295(cc)(2)):3

 

3

 For standards effective October 1, 2007, EPACT 2005, in section 135(c), specified five product classes for 

dehumidifiers: 25.00 pints/day or less, 25.01–35.00 pints/day, 35.01–54.00 pints/day, 54.01–74.99 pints/day, and 

75.00 pints/day or more. EISA 2007, in section 311(a)(1), prescribed a new set of standards for dehumidifiers to 

take effect on October 1, 2012. In providing a new set of standards, EISA 2007 consolidated the two smallest 

product classes (25.00 pints/day or less and 25.01 – 35.00 pints/day) and subdivided the 35.01–54.00 pints/day 

product class into two product classes: 35.01–45.00 pints/day and 45.01–54.00 pints/day. 
9

• Up to 35.00 pints/day; 

• 35.01–45.00 pints/day; 

• 45.01–54.00 pints/day; 

• 54.01–75.00 pints/day; and 

• Greater than 75.00 pints/day. 

DOE notes that whole-home units generally use equivalent dehumidification technologies as 

portable units, but are designed to operate in a ducted installation, typically in conjunction with 

the home’s central air conditioning system. Therefore, whole-home dehumidifier performance is 

affected by the air flow and pressure impacts resulting from the ducting and possibly other 

factors. In addition, whole-home dehumidifiers may be installed with a fresh air intake rather 

than having conditioned air at the intake side. DOE’s research indicates that the capacity of 

whole-home dehumidifiers ranges from approximately 65 to 200 pints/day, with no distinct 

correlation between capacity and EF, as measured by the current DOE test procedure in an 

unducted configuration. Therefore, DOE is considering an additional product class for wholehome dehumidifiers, with the five product classes listed above applying only to portable 

dehumidifiers. 

DOE also recognizes that some portable dehumidifiers can be operated in a ducted installation. 

Because as noted above dehumidifier performance is affected by the backpressure and airflow 

associated with ducting, DOE requests information on how such units should be classified. 

Options may included classifying under the least energy-intensive configuration (i.e., as a 

portable unit with no ducting), a more energy-intensive configuration (i.e., with ducting in place, 

similar to a whole-home or through-the-wall installation), or some alternative or combination 

thereof. 

Item 3-2 The Department requests input from stakeholders on the proposed classes and 

criteria used for creating these product classes. Specifically, should additional or 

fewer criteria beyond those identified above be used as a basis for developing product 

classes? Should DOE consider separate product class(es) for whole-home 

dehumidifiers? How should DOE classify portable dehumidifiers that can be operated 

in a ducted installation? 

3.3 Technology Assessment 

The Department uses information about commercially available technology options and 

prototype designs as input in identifying technologies manufacturers could use to attain higher 

energy efficiency levels. In consultation with interested parties, the Department intends to 

develop a list of technologies that can and should be considered in the analysis. Initially, this list 

will include all those technologies that may improve energy efficiency and will serve to establish 

the maximum technologically feasible design. In the screening analysis, DOE will eliminate 

from consideration technologies that are not technologically feasible, or that fail to meet certain 

criteria as to practicability to manufacture, install and service, impacts on product utility or 

availability, or impacts on health or safety. 
10

In the previous standards rulemaking for dehumidifiers, DOE identified the following designs 

which may be used to improve dehumidifier performance. 72 FR 64432, 64451 (Nov. 15, 2007):

• Built-in hygrometer/humidistat 

• Improved compressor efficiency

• Improved condenser performance 

• Improved controls 

• Improved defrost methods 

• Improved demand-defrost controls 

• Improved evaporator performance 

• Improved fan-motor efficiency

• Improved fan efficiency

• Improved flow-control devices

• Low-standby-loss electronic controls 

• Washable air filters 

DOE has also identified through research and review of product literature for this rulemaking 

additional designs which may be used to decrease dehumidifier energy use, including heat pipe 

technology. 

Item 3-3 Of the technologies listed above, are there any that DOE should not consider 

because of their impacts on safety, performance, or consumer utility of the product? 

Item 3-4 Are there other unlisted technologies that DOE should consider as design 

options and what, if any, impacts do the design options have on safety, performance, 

and consumer utility? 

3.4 Baseline Units 

Once the Department establishes product classes, it will select a baseline model as a reference 

point for each product class, against which it can measure changes resulting from energy 

conservation standards. The baseline model in each product class represents the characteristics of 

products in that class. Typically, a baseline model would be a model that just meets currently

required energy conservation standards. 

The Department will use the baseline models in the engineering analysis and the LCC and PBP 

analysis. To determine energy savings and changes in price, the Department will compare each 

higher-energy-efficiency or lower-energy-consumption design option with the baseline model. 

As identified in section 3.2, the Department proposes six product classes for dehumidifiers—the 

five product classes defined for the October 2012 standards and one product class for wholehome dehumidifiers. An initial review of dehumidifier models in DOE’s Compliance 

Certification Database shows a correlation between efficiency and capacity for portable units.

Because efficiency seems to be a function of capacity for these dehumidifiers, the Department 
11

plans to complete the engineering and LCC analyses on the existing product classes that 

represent the majority of portable unit shipments, and then extrapolate to the other two portable 

product classes. Based on these criteria, DOE is considering the 35.01–45.00 pints/day, 45.01–

54.00, and 54.01–75.00 pints/day product classes as the representative product classes. DOE also 

plans to include the whole-home product class for the engineering and LCC analyses. 

EPCA sets minimum energy conservation standards for dehumidifiers based on the unit’s 

capacity (in pints/day). (42 U.S.C. 6295(cc)) The Department will use the EPCA standards of 

1.50 liters/kWh and 1.70 liters/kWh, which become effective October 1, 2012, as the baseline 

efficiencies for these representative units in the 35.01–45.00 pints/day and 54.01–75.00 pints/day 

product classes, respectively. In addition, DOE will conduct the engineering and LCC analysis 

on whole-home dehumidifiers, which are largely classified as greater than 75.00 pints/day 

product class. DOE is considering the 2012 EPCA standard of 2.5 liters/kWh for greater than 

75.00 pints/day as the baseline efficiency for these units. This baseline level may be adjusted if 

DOE determines new test methods are appropriate for whole-home dehumidifiers or if other 

information suggests that a different baseline level is more appropriate. 

Item 3-5 The Department seeks input from stakeholders on the selection of 

representative product classes for the engineering and LCC analyses, and on possible 

methods of extrapolating the engineering and LCC analyses from the representative 

dehumidifier product classes to the other two product classes (e.g., maintaining 

relative incremental energy use specified in EPCA across product classes). 

Item 3-6 The Department seeks input from stakeholders on whether the above energy 

efficiency/conservation levels are appropriate for characterizing the performance of 

baseline units, including the baseline selected for whole home units. 

Item 3-7 The Department seeks information regarding the specific technological 

characteristics of the baseline model for each product class, including the technologies 

described in section 3.4. 

4. SCREENING ANALYSIS 

The purpose of the screening analysis is to screen out design options that DOE will not consider 

in the rulemakings for residential dehumidifiers. 

As an initial matter, DOE will develop a list of design options (through its own research and in 

consultation with interested parties) for consideration in the engineering analysis (see section 5). 

The identified candidate design options will encompass all those technologies that may improve 

energy efficiency. Thereafter, DOE will review each design option in light of the following four 

criteria: 

1. Technological feasibility. DOE will not further consider technologies that are not 

incorporated in commercially-available products or in working prototypes. 
12

2. Practicability to manufacture, install, and service. If DOE determines that mass 

production of a technology in commercial products and reliable installation and servicing 

of the technology could not be achieved on the scale necessary to serve the relevant 

market by the time of the effective date of the standard, then it will not consider that 

technology further. 

3. Adverse impacts on product or equipment utility or availability. If DOE determines a 

technology to have significant adverse impact on the utility of the product to significant 

subgroups of consumers, or result in the unavailability of any covered product type with 

performance characteristics (including reliability), features, size, capacities, and volumes 

that are substantially the same as products generally available in the United States at the 

time, it will not consider that technology further. 

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider that technology 

further. 

DOE will document the reasons for eliminating any design options during the screening analysis 

and will publish this documentation for stakeholder review and comment as part of the 

Preliminary Analysis. 

5. ENGINEERING ANALYSIS 

After conducting the screening analysis described above, DOE will perform an engineering 

analysis based on the remaining design options that would improve product efficiency. The 

engineering analysis consists of estimating the energy consumption and cost of products at 

various levels of increased efficiency. This section provides an overview of the engineering 

analysis (section 5.1), and discusses baseline units (section 5.2), DOE’s proposed approach for 

determining the cost-efficiency relationship (section 5.3), efficiency levels (section 5.4), 

proprietary designs (section 5.5), and cumulative regulatory burdens that might affect the 

engineering analysis (section 5.6).

5.1 Engineering Analysis Overview 

The purpose of the engineering analysis is to determine the relationship between manufacturer 

cost and energy efficiency for residential dehumidifiers. In determining the cost-efficiency 

relationship, DOE will estimate the increase in manufacturer cost associated with technological 

changes that increase the efficiency of these products relative to the baseline models. 

DOE will derive cost estimates for the engineering analysis (which it also will use in the 

manufacturer impact analysis) from a reverse-engineering process, supplemented by 

manufacturer-supplied data. The reverse-engineering process consists of a detailed product 

disassembly process, whereby: (1) representative units are torn down; (2) all components, 

processes, assembly, and manufacturing steps are noted in an activities-based cost model; and (3) 

all manufacturing costs are calculated. Representative units are chosen based on the range of 

efficiencies, design options, and capacities. 
13

The result is a “green-field” model4of the subject unit and the factory in which it would be built. 

These unit-specific factory requirements can then be aggregated by market share, unit shipments, 

or any other method DOE wishes to utilize to derive industry-wide estimates. 

The industry-wide estimates will consist of detailed incremental cost data, disaggregated into the 

incremental costs of material,5labor,6and overhead.7 DOE will associate incremental costs with 

specific design options or design option combinations required to achieve a given efficiency 

level or with the efficiency levels themselves, depending on the analysis approach, as described 

in section 5.3.

DOE seeks design, efficiency, and cost information to determine the cost of improving the 

efficiency of the baseline models. In addition, in tandem with a review of the efficiencies of units 

currently on the market, DOE will use the reverse-engineering to identify design options or 

design option combinations associated with the most efficient products to establish the highest 

efficiency that is technologically feasible (i.e., the max-tech level) within each product class. 

5.2 Baseline Models 

DOE will select a baseline model as a reference point for each product class it reverse-engineers 

against which it can measure changes resulting from energy conservation standards. The baseline 

model in each product class represents the characteristics of common or typical equipment in that 

class. As discussed in section 3.4, a baseline model would be a model that just meets the required 

energy conservation standards as of October 1, 2012, as measured by the EF in liters/kWh. 

At a subsequent stage in its analysis, DOE will use the baseline models to conduct the 

engineering analysis and the LCC and PBP analyses. To determine energy savings and changes 

in manufacturer selling price, DOE will compare each higher-energy-efficiency product design 

against the baseline model. 

Table 5-1 sets forth the minimum energy conservation standards effective October 1, 2012, for 

the six dehumidifier product classes. (10 CFR 430.32(v)(1)) As discussed in section 3.2, DOE is 

considering classifying whole-home dehumidifiers as a separate product class. Therefore, DOE 

 

4

 A “green-field” model estimates the cost of a product as if it were built in a brand-new facility that had just broken 

ground. DOE accounts separately for items such as depreciation and one-time costs that may be incurred. 

5

 Direct material costs are the costs of raw materials such as steel, copper, and insulation, and also include scrap 

metal that can be traced to final or end equipment. Direct material costs do not include indirect material costs which 

are attributed to supplies that may be used in the production process, but are not assigned to final pieces of 

equipment (e.g., lubricating oil for production machinery). 

6

 Labor costs are the earnings of workers who assemble parts into a finished good or operate machines in the 

production process. Direct labor includes the fringe benefits of direct laborers such as group health care, as well as 

overtime pay. Direct labor does not include indirect labor, which is defined as the earnings of employees who do not 

work directly in assembling a piece of equipment—such as supervisors, janitors, stockroom personnel, inspectors, 

and forklift operators. 

7

 Factory overhead excludes depreciation, but includes indirect labor, downtime, set-up costs, indirect material, 

expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory overhead does not 

include selling, general, and administrative costs (SG&A), research and development (R&D), interest, or profit 

(which DOE accounts for separately). 
14

seeks comment on an appropriate baseline EF for whole-home dehumidifiers, and whether such 

energy efficiency may be measured by the DOE dehumidifier test procedure. 

Table 5-1 Dehumidifier Energy Conservation Standards and Proposed Baseline Unit 

Efficiencies 

Product Class EF (liters/kWh)

Portable, up to 35.00 pints/day 1.35

Portable, 35.01–45.00 pints/day 1.50

Portable, 45.01–54.00 pints/day 1.60

Portable, 54.01–75.00 pints/day 1.70

Portable, greater than 75.00 

pints/day

2.5

Whole-home 2.5

Item 5-1 DOE seeks input from stakeholders on whether the above energy efficiency 

levels are appropriate for characterizing the performance of baseline units. 

Item 5-2 DOE seeks input on an appropriate baseline unit efficiency for whole-home 

dehumidifiers and whether the DOE test procedure is capable of measuring the 

performance of these units. 

Item 5-3 DOE seeks information regarding the specific technological characteristics of 

the baseline model for each product class, including the technologies described in section 

3.3. 

5.3 Approach for Determining the Cost-Efficiency Relationship 

DOE intends to utilize a design-option approach, using reverse engineering (physical teardowns 

and testing of existing equipment in the market) to identify the incremental cost and efficiency 

improvement associated with each design option or design option combination. DOE has 

reviewed existing dehumidifier product databases, including those compiled by DOE,8the 

California Energy Commission (CEC),9and AHAM,10 and determined that there is little 

variation in EF within most product classes for dehumidifiers that are currently on the market. 

Therefore, it is appropriate to analyze design options individually to understand what 

technologies manufacturers utilize to affect efficiency. DOE notes that should the dehumidifier 

 

8

 A database of residential dehumidifiers for which manufacturers have submitted compliance certification to DOE 

is available at: www.regulations.doe.gov/certification-data/Category.html

9

 A database of available dehumidifiers for sale in California is available on CEC’s website at: 

www.appliances.energy.ca.gov. 

10 A database of dehumidifiers which have been certified by AHAM’s voluntary program is available on AHAM’s 

website at: www.ahamdir.com/aham_cm/site/pages/index.html?code=r.deh.aboutThisProgram. 
15

test procedure be revised to capture the benefits of high-efficiency dehumidifiers (such as those 

that incorporate heat-pipe technology), a wider range in EF would result. 

DOE will analyze technologies and associated costs representative of baseline units as part of the 

reverse-engineering process. DOE intends, at a minimum, to perform reverse engineering on the 

four representative product classes being analyzed. Whenever possible, DOE will attempt to 

reverse engineer test units that share similar platforms to better identify the efficiency benefits 

and costs of design options. As units are torn down, all design options used in them are noted and 

reviewed. 

Prior to tear down, DOE also plans to conduct limited testing to establish what control strategies 

are being used by manufacturers in conjunction with design options and platform design. Unit 

testing will likely include the measurement of disaggregated energy consumption to identify the 

relationship between particular components and control strategies taken by manufacturers to 

achieve rated EFs. As part of the reverse-engineering process, DOE will attempt to generate a 

cost-efficiency relationship for each design option identified. 

In support of this design-option approach, DOE requests incremental cost data for each 

dehumidifier design option. DOE intends the data to represent the average industry-wide 

incremental production cost for each technology. 

To be useful in the manufacturer impact analysis, manufacturer cost information should reflect 

the variability in baseline models, design strategies, and cost structures that can exist among 

manufacturers. This information allows DOE to better understand the industry and its associated 

cost structure, and, thus, it helps predict the most likely impact that new energy efficiency 

regulations would have. For example, the reverse-engineering methodology allows DOE to 

estimate the “green-field” costs of building new facilities, yet the majority of plants in any given 

industry are comprised of a mix of assets in different stages of depreciation. Interviews with 

manufacturers not only help DOE refine its capital expenditure estimates, but they also allow 

DOE to refine depreciation and other financial parameters. 

DOE will refine the cost-efficiency data it generates through the reverse-engineering activities 

with information obtained through follow-up manufacturer interviews and, as necessary, 

information contained in the market and technology assessment and further review of publicly 

available cost and performance information. 

DOE will estimate the contribution of the depreciation of conversion capital expenditures to the 

incremental overhead. During the interviews, DOE will gather information about the capital 

expenditures necessary to increase the efficiency of the baseline models to various efficiency 

levels (i.e., conversion capital expenditures by efficiency or energy-use level). DOE will also 

request information about the depreciation method that manufacturers use to expense the 

conversion capital. 

Item 5-4 DOE requests feedback on the use of a design-option approach to determine 

the relationship between manufacturer cost and energy efficiency for residential 

dehumidifiers. 
16

5.4 Efficiency Levels 

The following tables present the efficiency levels DOE intends to analyze for residential 

dehumidifiers. It should be noted that the “maximum available” efficiency levels in the tables 

correspond to models with the maximum efficiency currently available in the market, but may 

not necessarily correspond to the “max-tech” levels. “Maximum available” models may not 

incorporate all possible design options for increasing efficiency and, therefore, may not achieve 

an efficiency level as high as the “max-tech” level. Also, it is possible that some of the design 

options that have met the screening criteria (i.e., passed the screening analysis) may not yet be 

commercially available (e.g., working prototypes) and, therefore, would not be found in today’s 

“maximum available” products. DOE seeks stakeholder input to determine appropriate max-tech 

efficiency levels. (42 U.S.C. 6295 (p)(2)) 

DOE believes that the technologies relevant to portable residential dehumidifiers are comparable 

among the various product classes, and for some classes there are too few models available to 

reverse engineer without divulging proprietary information. Therefore, DOE proposes to test 

three portable dehumidifier capacity ranges in its reverse-engineering analysis that represent the 

majority of shipments and to then extrapolate to the other identified product classes. DOE will 

also reverse-engineer whole-home dehumidifiers, which may be defined as a separate product 

class, to determine whether there are different technologies available for these units. 

DOE expects to examine four product classes: 35.01–45.00 pints/day portable, 45.01–54.00 

pints/day portable, 54.01–75.00 pints/day portable, and whole-home dehumidifiers, which may 

be similar to the 75.00 pints/day or more product class for portable units. Once the incremental 

product costs and design options have been identified for these four product classes, DOE 

intends to extrapolate its results to determine similar results for the remaining product classes, a 

process which may include teardowns. 

Table 5-2 provides both the efficiency level and the reference source of each level for the four 

dehumidifier product classes that DOE will analyze. The first efficiency level corresponds to the 

ENERGY STAR program’s qualification criteria as of October 1, 2012. The second efficiency 

level is a gap fill between the ENERGY STAR levels and the maximum available efficiencies, 

while the third efficiency level is the maximum available efficiencies according to the ENERGY 

STAR qualification database as of May 2012. The efficiency levels for whole-home 

dehumidifiers are based on testing according to the current test procedure; thus, these levels may 

be adjusted according to any test procedure amendments for this type of dehumidifier. 
17

Table 5-2 Efficiency Levels for Dehumidifier (Representative) Analysis 

Level

Efficiency 

Level Source

Efficiency Levels (liters/kWh)

Portable, 35.01–

45.00 pints/day

Portable, 45.01–

54.00 pints/day

Portable, 54.01–

75.00 pints/day Whole-Home

Baseline DOE 

Standard 1.50 1.60 1.70 2.50†

1

ENERGY 

STAR* (Max 

Available for 

35.01–45.00 

pints/day, 

Gap Fill for 

45.01–54.00 

pints/day)

1.62 1.70 1.85 2.80

2

Gap Fill

(Max 

Available for 

45.01–54.00 

pints/day

-- 1.8 2.10 3.50

3

Maximum 

Available -- -- 2.47 4.17

* ENERGY STAR qualification criteria effective October 1, 2012, require all portable and whole-home 

dehumidifiers less than 75 pints per day to have an EF of at least 1.85 liters/kWh, which is greater than the 

maximum available efficiency of 35.01–45.00 pints/day units. Units with 75–185 pints/day capacity must have an 

EF of at least 2.80 liters/kWh, while dehumidifiers with a capacity greater than 185 pints/day are excluded. 

† The baseline efficiency for the whole home product class is specified as the DOE standard effective October 1, 

2012, for dehumidifiers with a capacity greater than 75.00 pints/day. 

Item 5-5 DOE seeks input from stakeholders concerning the efficiency levels it 

proposes to use for collecting incremental cost data from manufacturers of residential 

dehumidifiers. DOE also seeks input from stakeholders on appropriate maximum 

technologically feasible efficiency levels. 

5.5 Proprietary Designs 

DOE will consider in its engineering and economic analyses all design options that are 

commercially available or present in a working prototype, including proprietary designs and 

technologies. However, DOE will consider a proprietary design in the subsequent analyses only 

if the achieved efficiency level can also be reached using other non-proprietary design options. If 

the proprietary design is the only approach available to achieve a given efficiency level, then 

DOE will reject that efficiency level, as the analytical results would appear to favor one 

manufacturer over others. 

DOE is sensitive to manufacturer concerns regarding proprietary designs and will make 

provisions to maintain the confidentiality of proprietary data submitted by manufacturers or 

discussed during manufacturer interviews. Materials provided to Navigant Consulting, Inc., a 

DOE contractor for this rulemaking, are generally subject to the terms of the applicable 
18

agreement under which those materials are submitted. In the case of materials provided to NCI in 

the context of a DOE rulemaking and subject to a non-disclosure agreement, those materials are 

generally not shared with DOE, apart from aggregated data that do not identify particular 

submitters. These materials may also be subject to a variety of laws and regulations governing 

the disclosure of Federal agency information. Information submitted to DOE will be protected in 

accordance with all applicable federal laws, rules, or regulations, including but not limited to the 

Trade Secrets Act, 18 U.S.C. §1905, and the Freedom of Information Act (FOIA), 5 U.S.C. 

§552, and DOE's implementing regulations at 10 CFR 1004. 

Item 5-6 Are there proprietary designs or technologies of which DOE should be aware 

for any of the dehumidifiers under consideration in this rulemaking? If so, how should 

DOE acquire the cost data necessary for evaluating these designs? 

5.6 Outside Regulatory Changes Affecting the Engineering Analysis 

In conducting an engineering analysis, DOE takes into consideration the effects of regulatory 

changes outside DOE’s statutory energy conservation standards rulemaking process that can 

impact the manufacturers of the covered equipment. Some of these changes can also affect the 

energy efficiency or energy consumption of the products covered under this rulemaking. DOE 

will attempt to identify all cumulative engineering issues that could impact the engineering 

analysis. The consideration of these issues is closely related to the cumulative regulatory burden 

assessment that DOE will carry out as part of the manufacturer impact analysis. Based on 

consideration of the comments received on the engineering analysis documented in the 

Preliminary Analysis, DOE will make the necessary changes to the analysis. It will reflect those 

changes in the documentation of the NOPR. 

Item 5-7 Are there outside regulatory issues that DOE should consider in its analysis of 

residential dehumidifiers? 

6. ENERGY USE 

DOE establishes the annual energy consumption of a product and assesses the energy-savings 

potential of various product efficiencies. As part of the energy use analysis, certain engineering 

assumptions may be required regarding product application, including how often the product is 

operated and under what conditions. DOE uses the annual energy consumption and energysavings potential in the LCC and PBP analyses to establish the savings in consumer operating 

costs at various product efficiency levels.

In DOE’s 2007 ANOPR, DOE utilized studies documenting annual dehumidifier usage and data 

provided by AHAM. Based on the data AHAM provided, which utilized monthly dehumidifier 

usage to determine annual energy use, DOE derived an average value of 1,095 hours per year for 

characterizing dehumidifier usage. The data provided by AHAM was also used to determine the 

variability of energy consumption. 
19

Because energy use by residential dehumidifiers varies greatly based on consumer usage 

patterns, the Department will conduct further research to establish a range of energy use for 

dehumidifiers. The Energy Information Administration (EIA)’s Residential Energy Consumption 

Survey is one source for defining the range of energy use for dehumidifiers. 

. 

Item 6-1 DOE seeks stakeholder input on its proposed approaches for specifying 

typical annual energy consumption. Most importantly, the Department is interested in 

sources of data that can assist in characterizing the annual energy consumption of 

dehumidifiers. 

Item 6-2 The Department seeks stakeholder input on data sources that it can use to 

characterize the variability in annual energy consumption for dehumidifiers. The 

Department is particularly interested in field monitoring studies and data. 

7. MARKUPS FOR PRODUCT PRICE DETERMINATION 

Because DOE uses retail (consumer) price data in its LCC, PBP, and national impact analyses, 

DOE typically uses manufacturer-to-consumer markups to convert estimates of the manufacturer 

selling price derived from the engineering analysis (section 5) to consumer prices. The 

manufacturer-to-consumer markups are in addition to the markups on production costs that DOE 

uses in estimating manufacturer selling price in the engineering analysis. To validate those 

markups, DOE will collect data on current market prices. 

Before it can develop markup information, however, DOE first needs to identify distribution 

channels (i.e., how the product is distributed from the manufacturer to the consumer). AHAM’s 

2005 Fact Book (the latest available version) shows that more than 93 percent of all appliances 

are distributed from the manufacturer directly to some type of retailer. Retailers identified in 

AHAM’s 2005 Fact Book include home improvement stores (such as Lowe’s or Home Depot), 

membership warehouse clubs/stores (such as Sam’s Club or Costco), department stores (such as 

Sears or Kohl’s), discount stores (such as Wal-Mart or Kmart), and appliance or consumer 

electronics stores. Because an overwhelming majority of appliances are sold through retail 

stores, DOE plans to analyze dehumidifier sales based on the assumption that the appliances are 

sold in a manufacturer-to-consumer distribution channel consisting of three parties: (1) the 

manufacturers producing the products; (2) the retailers purchasing the products from 

manufacturers and selling them to consumers; and (3) the consumers who purchase the products. 

DOE will determine an average manufacturer markup by examining the annual Securities and 

Exchange Commission (SEC) 10-K reports filed by publicly traded manufacturers of appliances 

whose product range includes dehumidifiers. DOE will determine an average retailer markup by 

analyzing both economic Census data from the U.S. Census Bureau and the annual SEC 10-K 

reports filed by publicly traded retailers. 
20

In addition to developing manufacturer and retailer markups, DOE will develop and include sales 

taxes to calculate appliance retail prices. DOE will use an Internet source, the Sales Tax 

Clearinghouse, to calculate applicable sales taxes. 

DOE will also use collected retail price data to validate the overall manufacturer-to-consumer 

markup. DOE has purchased dehumidifier sales data for 2007–2011 from NPD Group, Inc. 

(NPD), which provides sales-weighted retail price data. In addition to purchasing retail price 

data, DOE may also consult retailers’ Internet sites, although the representativeness of any given 

price data point is unknown. 

This analysis will generate retail prices for each potential efficiency level, assuming that each 

level represents a new minimum efficiency standard. DOE will make this assumption to capture 

the effect on retail prices that may be produced by manufacturers’ higher production volumes of 

more efficient products as required by the standard. Because DOE expects to develop a range of 

price estimates, it may describe new retail prices within a range of uncertainty. If the results of 

DOE’s analysis show a large range of retail prices for each product, DOE will develop 

probability distributions of retail price to use as inputs to the LCC and PBP analysis in order to 

determine the impact of uncertainty on the economic feasibility of amended energy conservation 

standards. 

Item 7-1 The Department welcomes suggestions and comments concerning its proposed 

approach to developing estimates of future retail prices. 

8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

This section describes the life-cycle cost (LCC) and payback period (PBP) analysis that DOE 

will perform for dehumidifiers, including how DOE develops the inputs to the calculation. The 

LCC analysis establishes the total cost of an appliance over its lifetime (including purchase price 

and operating costs). The PBP analysis calculates the amount of time required for energy cost 

savings to pay back any increased cost of a higher-efficiency product. 

8.1 Overview 

The effects of amended energy conservation standards on the consumer of a product include a 

change in operating cost (usually decreased) and a change in purchase price (usually increased). 

DOE usually analyzes the net effect on consumers by calculating the LCC and PBP, 

incorporating the engineering performance data (described in section 5), the energy consumption 

data (described in section 6), and the product retail price (described in section 7). Inputs to the 

calculation of LCC and PBP include the total installed cost to the consumer (purchase price plus 

any installation cost) and operating cost (energy expenditures and, if applicable, repair and 

maintenance costs). Additional inputs to the LCC calculation include energy price forecasts, the 

lifetime of the appliance or other defined period of analysis, and discount rates. 
21

8.2 Approach 

In the Preliminary Analysis stage of the dehumidifier rulemaking, DOE will conduct the LCC 

and PBP analysis by using Monte Carlo simulation and probability distributions to model both 

the uncertainty and variability in the inputs. The Monte Carlo approach provides a significant 

advantage over alternative approaches (e.g., an approach using typical or average values to 

characterize inputs) because it identifies the percentages of consumers benefiting from or being 

impacted by a prospective standard. 

DOE plans to develop an LCC and PBP model that incorporates both Monte Carlo simulation 

and probability distributions by using Microsoft Excel spreadsheets combined with Crystal Ball 

(a commercially available add-in program). Each Monte Carlo simulation will consist of 10,000 

LCC and PBP calculations. The model will perform each calculation using input values sampled 

from probability distributions where possible, or characterized using single-point values in other 

cases. The analysis results are a distribution of 10,000 data points showing the range of LCC 

savings and PBPs for a given efficiency level relative to the baseline level. 

DOE will use probability distributions to characterize most of the operating cost inputs to the 

LCC and PBP analysis, including product lifetimes and consumer discount rates. As described in 

section 7, DOE will use a combination of sales data from the NPD Group and data from the CEC 

model (as described in section 5.3) to establish the annual energy consumption of each product 

class. Dehumidifier energy use will be characterized using sales-weighted probability 

distributions. As described in section 8.3, the LCC and PBP analysis will capture the regional 

variability in electricity prices. The methodology for developing maintenance and repair costs is 

described in section 8.4. 

DOE expects to use point values to characterize most of the inputs to total installed cost, 

including the manufacturer markup and retailer markup. DOE expects installation costs to be 

negligible for portable dehumidifiers. For whole-home dehumidifiers, installation costs can 

include electrical and duct work. If the manufacturer cost estimates developed in the engineering 

analysis are characterized using uncertainty or variability, DOE will use probability distributions 

to capture this uncertainty and variability; otherwise, DOE will use single-point values for this 

input. DOE will characterize sales taxes using probability distributions that capture their regional 

variability. 

Another factor in identifying how consumers would be impacted by a particular standard is the 

distribution of product efficiencies currently sold in the marketplace. In the case of 

dehumidifiers, product efficiency is expressed as annual energy use. Assuming those data are 

available, DOE will use probability distributions to characterize the current product mix. DOE 

will determine the LCC and PBP for a particular standard level based on the distribution of 

appliance efficiencies. For example, in performing an iteration of the Monte Carlo simulation for 

a given consumer, product efficiency will be chosen based on its probability. If the chosen 

product efficiency is greater than or equal to the efficiency of the standard level under 

consideration, the LCC and PBP calculation will reveal that a consumer is not impacted by the 

standard level. By accounting for consumers who already purchase more efficient products, DOE 

avoids overstating the potential benefits from increasing product efficiency. To enable DOE to 

use this methodology, DOE will ask stakeholders to provide data on the current mix of product 
22

efficiencies. DOE could also use the CEC model data described in section 5.3 to develop 

efficiency distributions based on availability of various models. 

DOE will determine as part of the LCC and PBP analyses whether there may be a rebound (or 

“take back”) effect associated with more efficient dehumidifiers. The “take-back” in energy 

consumption associated with the rebound effect typically involves greater use that can result 

from increases in energy efficiency and the associated reduction in operating costs. The rebound 

effect assumes that consumers will increase their overall annual usage of a more efficient 

product, thereby decreasing their overall annual savings 

DOE will conduct the LCC and PBP analysis for the representative product classes on which it 

plans to perform an engineering analysis (section 5.2). To identify the consumers who benefit 

from or are burdened by a prospective standard, DOE requests base case efficiency distribution 

or market-share efficiency data from the industry. 

Based on the results of the LCC analysis, DOE would select candidate standard levels (CSLs) for 

the Preliminary Analysis. The range of CSLs typically includes the efficiency level with the 

minimum LCC, the highest efficiency level that is technologically feasible, and other 

intermediate levels. 

The following sections discuss the methodologies DOE plans to use to develop several of the 

inputs to the LCC and PBP analysis, including (1) electricity prices; (2) maintenance, repair, and 

installation costs; (3) product lifetimes; and (4) discount rates. The other inputs to the LCC and 

PBP analysis—manufacturer costs (section 5), annual energy consumption (section 6), and 

markups for the determination of consumer retail prices (section 7)—were discussed previously. 

DOE is also required to perform a PBP analysis to determine whether the rebuttable presumption 

of economic justification applies (whether the higher installed cost of more energy efficient 

equipment is less than three times the value of the lowered operating costs in the first year of the 

energy conservation standard). (42 U.S.C. 6295(o)(2)(B)(iii)) To determine the rebuttablepresumption PBP, DOE would determine the value of the first year’s energy savings by 

calculating the quantity of those savings in accordance with DOE’s test procedure. Although 

DOE will examine the rebuttable-presumption criteria, DOE determines whether selected CSLs 

are economically justified through an analysis of the economic impacts of increased efficiency 

pursuant to section 325(o)(2)(B)(i) of EPCA. (42 U.S.C. 6295(o)(2)(B)(i)) 

In preparing the NOPR, DOE carefully reviews all the comments it receives on the Preliminary 

Analysis LCC analysis, makes any necessary revisions to the analysis, and if necessary evaluates 

additional parameters not included in the Preliminary Analysis. 

Item 8-1 DOE seeks stakeholder input on its proposed approach of using probability 

distributions and Monte Carlo simulation to conduct the LCC and PBP analysis 

Item 8-2 DOE requests data from stakeholders to characterize the current mix of 

dehumidifier efficiencies in the market. 
23

8.3 Electricity Prices 

DOE plans to estimate average electricity prices using EIA data covering 13 geographic areas—

the nine U.S. Census divisions, with four large states (New York, Florida, Texas, and California) 

treated separately. For Census divisions that contain one of the large states, DOE calculates the 

regional average values leaving out data for the large state—for example, the Pacific region 

average does not include California, and the West South Central region average does not include 

Texas. DOE will develop a discrete probability distribution consisting of 13 regional electricity 

prices based on the household population in each region to assess the variability of energy prices 

at the regional level. 

To calculate electricity prices for residential consumers in each of the above geographic areas, 

DOE will use information provided by electric utilities as summarized in the most recent EIA 

Form 861 data.11 These data, which cover the residential, commercial, and industrial sectors for 

every utility serving final customers, are published annually and include annual electricity sales 

in kWh, revenues from electricity sales, and number of customers. DOE’s calculation of an 

average residential electricity price proceeds in two steps: (1) for each utility, estimate an 

average residential price by dividing residential revenues by residential sales; and (2) calculate a 

regional average price, weighting each utility that has customers in a region by the number of 

residential customers served in that region. 

In its LCC analysis DOE uses projections of national average electricity prices to residential 

consumers to estimate future energy prices. DOE uses the most recently available edition of 

EIA’s Annual Energy Outlook (AEO) as the default source of projections for future energy 

prices. 

Item 8-3 DOE seeks stakeholder input on the planned approach for estimating current 

and forecasted energy prices. 

8.4 Maintenance, Repair, and Installation Costs 

DOE will consider any expected changes to maintenance, repair, and installation costs for the 

dehumidifiers subject to new standards. Typically, small incremental changes in product 

efficiency incur little or no change in repair and maintenance costs over baseline products. 

Products having efficiencies that are significantly higher than the baseline are more likely to 

incur increased repair and maintenance costs, because such products are more likely to 

incorporate technologies that are not widely available. DOE will use input from manufacturers 

and other stakeholders to develop appropriate repair and maintenance cost estimates, as 

necessary. 

With regard to installation costs, unless the increased efficiency levels considered for this 

rulemaking result in significantly larger or heavier products, DOE expects that more efficient 

portable dehumidifiers will incur no increased installation costs. For whole-home dehumidifiers, 

installation costs may include electrical and duct work. 

 

11 Available at www.eia.doe.gov/cneaf/electricity/page/eia861.html. 
24

Item 8-4 DOE seeks stakeholder input on the merits of its proposed analytical 

assumption that changes in maintenance, repair, and installation costs will be 

negligible for more-efficient residential dehumidifiers. If that assumption is incorrect, 

DOE is interested in the reasons why this is so and in specific ways to correct that 

assumption. 

8.5 Product Lifetimes 

The product lifetime is the age at which a product is retired from service. From one source12, 

DOE identified dehumidifier lifetime ranging from a low of 5 years, a high of 10 years, and an 

average of 7 years. DOE has characterized dehumidifier survival functions using Weibull 

distributions. DOE tentatively plans to use those averages for the analyses. In addition, DOE 

plans to use additional literature sources, industry experts, and input from manufacturers and 

other interested parties to determine a range for the lifetime of residential dehumidifiers. 

Item 8-5 DOE seeks stakeholder input on appropriate product lifetimes for 

dehumidifiers. Specifically, DOE seeks data sources for establishing product lifetimes. 

8.6 Discount Rates 

The calculation of consumer LCC requires the use of an appropriate discount rate. DOE uses a 

discount rate to determine the present value of lifetime operating expenses. The discount rate 

used in the LCC analysis represents the rate from an individual consumer’s perspective.13 For 

residential consumers of dehumidifiers, DOE plans to use estimates of the interest or “finance 

cost” to purchase residential products. The finance cost of raising funds to purchase 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). Household equity is represented by holdings 

in assets such as stocks and bonds, as well as the return on homeowner equity. Much of the data 

required for determining the cost of debt and equity comes from the Federal Reserve Board’s 

triennial Survey of Consumer Finances.

14

Item 8-6 DOE seeks stakeholder input on its planned approach for estimating discount 

rates for residential consumers. 

Based on consideration of the comments received on the LCC and PBP analysis documented for 

the Preliminary Analysis, DOE would make the necessary changes to the analysis, and reflect 

those changes in the NOPR and TSD.

 

12 Appliance Magazine, “U.S. Appliance Industry: Market Value, Life Expectancy & Replacement Picture for 2005–

2012”, January 2011. 

13 The consumer discount rate differs from the discount rates used in the national impact analysis, which are 

intended to represent the rate of return on capital in the U.S. economy, as well as the societal rate of return on 

private consumption. Refer to section 10.3 for additional information. 

14 Available at www.federalreserve.gov/econresdata/scf/scfindex.htm. 
25

8.7 Energy Efficiency in the Base Case 

To estimate the share of consumers affected by a standard at a particular efficiency level, DOE’s 

LCC and PBP analysis considers the projected distribution (i.e., market shares) of product 

efficiencies that consumers will purchase in the first compliance year under the base case (the 

case without amended energy conservation standards). DOE requests market-share efficiency 

data (i.e., data on the distribution of shipments by efficiency) for the product classes of 

residential dehumidifiers. 

In its prior 2007 rulemaking on dehumidifiers, DOE based its analysis of base-case market 

shares on AHAM data showing the distribution of dehumidifier efficiencies in 2005 for two of 

the six product classes examined for that rulemaking: 35.01–45.00 and 54.01–74.99 pints per 

day. In cases where market-share efficiency data are not available, DOE will use efficiency 

distributions based on available models as a proxy. In the prior rulemaking, for example, because 

DOE conducted the engineering and LCC and PBP analyses on the combined product class of 0–

35.00 pints per day, DOE estimated that the market share data for the 0–35.00 pints per day 

combined product class were equivalent to the market shares for the closest product class—that 

for 35.01–45.00 pints per day. 

Forecasted market shares will use available data on recent market trends in residential 

dehumidifier efficiency and will take into account the potential impacts of the ENERGY STAR 

program and other programs or policies (such as consumer rebate programs or State tax credits to 

consumers for the purchase more efficient products, and manufacturer tax credits that encourage 

the production of more efficient products) that may affect the demand for more efficient 

residential dehumidifiers. 

Item 8-7 DOE seeks stakeholder input on dehumidifier efficiency in the base case, 

historical efficiency data on dehumidifiers, and projected trends in dehumidifier 

efficiency. DOE is especially interested in any data pertaining to whole-home 

dehumidifiers. 

9. SHIPMENTS ANALYSIS 

DOE uses shipments forecasts to calculate the national impacts of standards and to calculate the 

future cash flows of manufacturers. DOE develops shipments forecasts based on an analysis of 

key market drivers for a particular product. 

9.1 Base-Case Forecast 

To evaluate the impacts of standards, DOE first develops a base-case forecast against which to 

compare forecasts for higher efficiency levels. (Forecasts for higher efficiency levels are also 

referred to as standards-case forecasts.) DOE designs the base case to depict what would be 

anticipated to happen to energy consumption and costs over time if DOE does not adopt energy 

conservation standards. In determining the base case for products, DOE calibrates its forecasts 

against historical shipments. DOE also considers the mix of efficiencies that would be sold in the 
26

absence of new standards and how that mix might change over time. As a result, DOE must 

acquire data on historical product shipments and the market shares of the various efficiency 

levels offered in each product class. Based on detectable trends in the collected efficiency data, 

DOE forecasts base case shipment-weighted efficiencies (SWEF). Forecasts of SWEFs are 

discussed in greater detail in section 10.1.

DOE has reviewed historical shipments data from three sources: (1) from Appliance Magazine,

15

(2) as provided by AHAM as part of the 2007 residential dehumidifier standards rulemaking, and 

(3) from the ENERGY STAR program. 16 The shipments data from Appliance Magazine are for 

2006–2012; the data from AHAM are for 1989–2005; and the data from ENERGY STAR are for 

2004–2010. When it develops base case shipments forecasts, DOE plans to use public sources of 

data, such as data from the NPD Group. 

Because little is known about the adoption of dehumidifiers in established and new households, 

and the historical data may not provide observable trends that can be relied on to forecast 

shipments trends into the future, DOE likely will use various scenarios to forecast base case 

shipments. The scenarios may range from constant shipments (based either on a historical 

average observed in the AHAM and/or Appliance Magazine or NPD data sets to increases in 

shipments tied to overall economic growth as indicated by the gross domestic product. 

Item 9-1 DOE seeks historical shipments data from stakeholders. If such data are 

provided, DOE requests market share data showing the percentage of dehumidifier 

shipments for portable and whole-home products and including within each category 

dehumidifier type (i.e. compressor/condenser-based, dessicant, etc.). 

Item 9-2 If stakeholders are unable to provide historical shipments data, DOE seeks 

comment on whether the AHAM and Appliance Magazine shipments data or the NPD 

sales data is more representative of historical shipments and why. 

Item 9-3 DOE seeks input on the types of scenarios it should use to forecast base case 

shipments and the reason(s) for the suggested scenario(s). 

9.2 Impacts of Standards on Product Shipments 

DOE will develop a set of shipment forecasts for each set of efficiency levels analyzed for each 

product class. DOE uses the standards-case forecasts to evaluate the impacts of standards on 

product shipments. DOE derives standards-case forecasts using the same data sets as used for the 

base-case forecasts. Because the standards-case forecasts take into account the increase in 

purchase price and the decrease in operating costs caused by standards, forecasted shipments for 

a standards case typically deviate from those for the base case. Household income also factors 

into consumer purchase decisions. Therefore, the magnitude of the difference between the 

shipment forecasts for the standards and base cases depends on the estimated purchase price 

 

15 Available for purchase at www.appliancemagazine.com. 

16 Available in the ENERGY STAR archives at 

www.energystar.gov/index.cfm?c=partners.unit_shipment_data_archives. 
27

increase and operating cost savings relative to household income. Because purchase price tends 

to have a larger impact than operating cost on appliance purchase decisions, standards-case 

forecasts typically show a decrease in product shipments relative to the base case. 

DOE’s past standards analyses have attempted to quantify the sensitivity of shipments to 

increased purchase price and operating cost savings, as well as to changes in household income. 

DOE has conducted literature reviews and analyses of historical appliance price and efficiency 

data to develop sensitivities. DOE will attempt to develop purchase price and operating cost 

sensitivities for dehumidifiers. If the data required to develop those sensitivities are unavailable, 

DOE will consider modeling standards-case shipments forecasts using scenarios (i.e., specified 

impacts to product shipments).

Market-pull programs, such as consumer rebate programs that encourage the purchase of more 

efficient products and manufacturer tax credits that encourage the production of more efficient 

products, also affect forecasts of standards-case shipments. To the extent that such programs 

exist, DOE will consider their impact on the forecast of both base-case and standards-case 

shipments. 

Item 9-4 As part of the preliminary manufacturer impact analysis, DOE seeks input 

from manufacturers on the potential impact of new energy conservation standards on 

dehumidifier shipments. DOE also seeks input from other stakeholders on the potential 

impact of standards on product shipments. 

Item 9-5 DOE also requests input on any current market-pull programs that promote 

the adoption of more efficient dehumidifiers. 

10. NATIONAL IMPACT ANALYSIS 

This section discusses DOE’s assessment of the aggregate impacts of potential efficiency 

standards at the national level. Measures of impact that DOE will report include the future 

national energy savings (NES) from each efficiency level and the net present value (NPV) of 

total consumer LCCs. 

10.1 Inputs to Forecasts 

In analyzing impacts of Federal energy conservation standards for dehumidifiers, DOE compares 

projected U.S. energy consumption with, and without, new or amended standards. The forecasts 

contain projections of annual appliance shipments (section 9), the annual energy consumption of 

new appliances (section 6), and the purchase price of new appliances (section 7).

A key component of DOE’s estimates of NES and NPV are the product energy efficiencies 

forecasted over time for the base case (without new standards) and each standards case. 

Forecasted efficiencies represent the annual shipment-weighted annual energy consumption of 

covered dehumidifiers during the forecast period (i.e., from the assumed compliance date of a 

new standard to 30 years after that date). Because key inputs to the calculation of NES and NPV 
28

(annual energy consumption for the NES, and retail prices and annual operating costs for the 

NPV) depend on estimated efficiencies, those efficiencies are vital to the analysis. 

To develop SWEFs for the various standards cases, DOE seeks market-share efficiency data (i.e., 

data on the distribution of product shipments by efficiency) for the four representative 

dehumidifier product classes DOE currently is considering. These market-share efficiency data 

(otherwise known as base-case efficiency distributions) are the same as those DOE is requesting 

for the LCC and PBP analysis (see section 8.2). DOE uses input from stakeholders to develop 

estimates of base-case historical SWEFs. For the 2007 ANOPR, AHAM and manufacturers 

provided market share efficiency distributions for two of the six product classes: 35.01–45.00 

pints/day and 54.10–74.99 pints/day. DOE applied the market share efficiency distributions of 

the 35.01–45.00 pints/day class to product classes up through 54.00 pints/day, and applied the 

market share efficiency distribution of the 54.10–74.99 pints/day class to the ≥75.00 pints/day 

class. DOE asks AHAM, manufacturers, and other interested parties to provide historical SWEF 

data for dehumidifiers for this rulemaking. If such data are not be available, DOE may use the 

CEC model data described in section 5.3 to develop efficiency distributions for each year for 

which CEC data are available. 

The market-share efficiency data will enable DOE to estimate the effect on efficiency that 

standards may have in the year manufacturers must begin to comply with them. For the 

dehumidifier rulemaking, DOE plans to use a “roll-up” scenario. Under this scenario, DOE 

assumes (1) product efficiencies in the base case that do not meet the standard level under 

consideration will “roll up” to meet the new standard level; and (2) product efficiencies that 

exceed the standard level under consideration will not be affected.17 After DOE establishes the 

SWEF for the assumed effective date of a standard, it can estimate future SWEFs by using the 

same rate of forecasted efficiency growth as for the base-case efficiency trend. 

Item 10-1 DOE seeks historical SWEF data for dehumidifiers. DOE also seeks historical 

market share data showing the percentages of product shipments by efficiency level. 

10.2 National Energy Savings 

DOE intends to calculate national energy consumption for each year beginning with the expected 

compliance date of the standard. It will calculate national energy consumption for the base case 

and each standard level analyzed to estimate the NES associated with each standard level. DOE 

plans to perform this calculation using a spreadsheet model that accounts for the stock of 

equipment affected by standards.18 The energy savings are measured over the entire lifetime of 

products purchased in the 30-year projection period.19

 

17 DOE believes that a “shift” scenario, in which there is change in the market above the standard level, is not likely 

for dehumidifiers due to the limited consumer interest in the efficiency of this product. 

18 For example, the NIA spreadsheet model from the rulemaking for residential clothes washers can be found, along 

with the TSD chapters, on DOE’s website at 

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

19 In the past DOE presented energy savings results for only the 30-year period that begins in the year of 

compliance. In the calculation of economic impacts, however, DOE considered operating cost savings measured 
29

DOE intends to determine whether there may be a rebound effect associated with more efficient 

dehumidifiers. If data indicate that there may be a rebound affect and allow for the quantification 

of this effect for dehumidifiers, DOE will account for the rebound effect into its calculation of 

NES. 

DOE has historically presented NES in terms of primary energy savings. On August 18, 2011, 

DOE announced its intention to use full-fuel-cycle (FFC) measures of energy use and 

greenhouse gas and other emissions in the national impact analyses and emissions analyses 

included in future energy conservation standards rulemakings. (76 FR 51282) While DOE stated 

in that notice that it intended to use the Greenhouse Gases, Regulated Emissions, and Energy 

Use in Transportation (GREET) model to conduct the analysis, it also said it would review 

alternative methods, including the use of NEMS. After evaluating both models and the 

approaches discussed in the August 18, 2011 notice, DOE has determined NEMS is a more 

appropriate tool for this specific use. Therefore, DOE intends to use the NEMS model, rather 

than the GREET model, to conduct future FFC analyses. The method used to derive the FFC 

multipliers will be described in the preliminary TSD. 

Based on consideration of the comments DOE may receive on the Preliminary Analysis, DOE 

will make any necessary changes to the analysis. It will reflect those changes in the 

documentation for the NOPR. 

Item 10-2 DOE seeks input on its plan to develop spreadsheet models for estimating 

national energy savings attributable to amended energy conservation standards for 

dehumidifiers. For example, are spreadsheet models still the preferred approach for 

estimating national impacts? 

10.3 Net Present Value 

In conjunction with the NES, DOE calculates the national net present value (NPV) of energy 

conservation standards. It calculates annual energy expenditures based on annual energy 

consumption by incorporating forecasted energy prices, using the forecasts of shipments and 

average energy efficiency described in section 9. DOE calculates annual product expenditures by 

multiplying the price per unit by the number of forecasted shipments. The difference between a 

base case and a standards-case scenario gives the national energy cost savings and increased 

product expenditures in dollars. The difference each year between energy cost savings and 

increased product expenditures is the net savings (if positive) or net costs (if negative). DOE 

discounts those annual values to the present time and sums them to obtain a NPV. Consistent 

with guidelines set by the U.S. Office of Management and Budget (OMB), DOE will conduct 

two NPV calculations, one using a real discount rate of 3 percent and the other using a real 

discount rate of 7 percent (OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). The 

discount rates for the determination of NPV differ from the discount rates used in the LCC 

 

over the entire lifetime of products purchased in the 30-year period. DOE has chosen to modify its presentation of 

national energy savings to be consistent with the approach used for its national economic analysis. 
30

analysis (which are developed from a consumer’s perspective). The 7-percent real value is an 

estimate of the average before-tax rate of return on private capital in the U.S. economy. The 3-

percent real value represents the “societal rate of time preference,” which is the rate at which 

society discounts future consumption flows to their present value. Based on consideration of any 

comments received on the Preliminary Analysis, DOE will make any necessary changes to the 

analysis and the CSLs.

As noted in section 10.2, DOE intends to consider whether there may be a rebound effect 

associated with more efficient dehumidifiers in its determination of NES. As discussed in section 

8.2, increased product utilization may result from an increase in energy efficiency. If data 

indicate that there may be a rebound affect and allow quantification of this effect for 

dehumidifiers, DOE will account for the rebound effect in its calculation of NPV. 

11. CONSUMER SUBGROUP ANALYSIS 

DOE analyzes the consumer impact of any new standards by dividing consumers into subgroups 

that comprise subsets of the population that are likely, for one reason or another, to be affected 

disproportionately by new or revised energy conservation standards. The purpose of a subgroup 

analysis is to determine the extent of this disproportional impact. DOE will work with 

stakeholders early in the rulemaking process to identify any subgroups for consideration. DOE 

will analyze the consumer subgroups during the NOPR stage of the analysis. 

In comparing potential effects on different consumer subgroups, DOE will evaluate variations in 

regional electricity prices, energy use profiles, and purchase prices that might affect the LCC of 

an energy conservation standard for identified consumer subgroups. To the extent possible, DOE 

may obtain estimates of the variability in each input variable and consider this variability in its 

calculation of consumer impacts. DOE will discuss with stakeholders the variability in each input 

variable and likely sources of information on that variability. 

Item 11-1 The Department requests input as to what consumer subgroups are 

appropriate to evaluate for residential dehumidifiers. 

12. MANUFACTURER IMPACT ANALYSIS 

DOE will collect, evaluate, and report preliminary information and data on manufacturer impacts 

in the preliminary TSD. Such preliminary information includes the anticipated conversion capital 

expenditures by efficiency level and the corresponding anticipated impacts on employment in the 

dehumidifier industry. DOE will solicit further information during the preliminary engineering 

analysis manufacturer interviews. 

DOE intends the manufacturer impact analysis to provide an assessment of the potential impacts 

of energy conservation standards on manufacturers of residential dehumidifiers. In addition to 

financial impacts, a wide range of quantitative and qualitative effects may occur following 

adoption of a standard that may require changes to the manufacturing practices for these 
31

products. DOE will identify these effects through interviews with manufacturers, as well as other 

interested parties and experts. 

For the NOPR, DOE will supplement the results of the preliminary manufacturer impact analysis 

conducted as part of the Preliminary Analysis with more detailed analyses, described in sections 

12.1 through 12.5. Specifically, DOE will carry out an industry-wide cash-flow analysis using 

the Government Regulatory Impact Model (GRIM), identify and analyze subgroups of 

manufacturers whose business varies significantly from the industry as a whole, perform a 

competitive impacts assessment, and review the cumulative regulatory burden for the industry. 

12.1 Sources of Information for the Manufacturer Impact Analysis 

Many of the analyses described earlier provide important information that DOE uses as inputs 

for the manufacturer impact analysis. Such information includes financial parameters developed 

in the market assessment (section 3.1), manufacturing costs from the engineering analysis 

(section 5.3), retail price forecasts (section 7), and shipments forecasts (section 9). DOE 

supplements this information with information gathered during manufacturer interviews. 

DOE will conduct detailed interviews with manufacturers to gain insight into the range of 

potential impacts of standards. The interview process plays a key role in the manufacturer impact 

analysis, since it provides an opportunity for directly affected parties to express their views on 

important issues. During the interviews, DOE will solicit information on the possible impacts of 

standards on manufacturing costs, equipment prices, sales, direct employment, capital assets, and 

industry competitiveness. Both qualitative and quantitative information are valuable in terms of 

this analysis. DOE prefers an interactive interview process, because it helps clarify responses and 

provides the opportunity to identify additional issues. 

DOE will ask interview participants to identify all confidential information provided in writing 

or orally, and DOE will determine whether the information submitted is entitled to confidential 

treatment. It will consider information gathered, as appropriate, in the energy conservation 

standards decision-making process. However, DOE will not make confidential information 

available in the public record. DOE also will ask participants to identify all information that they 

wish to have included in the public record but that they do not want to have associated with their 

interview that would identify that particular manufacturer; DOE will incorporate this information 

into the public record, but will report it without attribution. 

DOE will prepare a summary of the major issues and outcomes resulting from the manufacturer 

interviews. This summary will become part of the TSD produced for this rulemaking. 

12.2 Industry Cash-Flow Analysis 

The industry cash-flow analysis relies primarily on the GRIM. DOE uses the GRIM to analyze 

the financial impacts of new or amended energy conservation standards on the industries that 

produce the products covered by the standard. 

The GRIM analysis uses a number of inputs—annual expected revenues; manufacturer costs 

such as costs of goods sold; selling, general, and administrative costs; taxes; and capital 
32

expenditures (both ordinary capital expenditures and those related to standards)—to determine a 

series of annual cash flows beginning from the announcement of the new standard and 

continuing for several years after its implementation. DOE compares the results against basecase projections that involve no new standards. The financial impact of new standards is the 

difference between the two sets of discounted annual cash flows. Other performance metrics, 

such as return on invested capital, also are available from the GRIM. 

DOE will gather the inputs needed for the GRIM from two primary sources: the analyses 

conducted to this point and interviews with manufacturers and other interested parties. 

Information gathered from previous analyses will include financial parameters, manufacturing 

costs, price forecasts, and shipments forecasts. Interviews with manufacturers and other 

interested parties will be essential in supplementing this information. 

12.3 Manufacturer Subgroup Analysis 

Average industry cost values may not adequately assess differential impacts among subgroups of 

manufacturers. DOE recognizes that smaller manufacturers, niche players, and manufacturers 

exhibiting a cost structure that differs significantly from the industry average may be affected 

differently by the imposition of standards. Ideally, DOE would consider the impact on every firm 

individually. In highly concentrated industries, this may be possible. In industries having 

numerous participants, however, DOE uses the results of the market and technology assessment 

to group manufacturers into subgroups, as appropriate. 

Small businesses, as defined by the U.S. Small Business Administration (SBA) for electric 

housewares and household fan manufacturers, which includes residential portable electric 

dehumidifiers, are enterprises with 750 employees or fewer. Small businesses are also defined by 

the SBA for air-conditioning and warm air heating equipment and commercial and industrial 

refrigeration equipment manufacturers as having 750 employees or fewer. Small business size 

standards are listed by North American Industry Classification System (NAICS) code and 

industry description. Electric housewares and household fan manufacturing is classified under 

NAICS 335211, while air-conditioning and warm air heating equipment and commercial and 

industrial refrigeration equipment manufacturing is classified under NAICS 333415. A search of 

small businesses of this NAICS code listed in the SBA website and the Dun & Bradstreet reports 

indicates that there are at least five small businesses that manufacture residential dehumidifiers 

that would be covered by this rulemaking. As part of its subgroup analysis, DOE will identify 

small businesses that manufacture these products and interview small businesses affected by the 

rulemaking to determine if there are differential impacts on these companies that may result from 

new energy conservation standards. DOE will examine publicly available data and contact 

manufacturers, when needed, to determine if they meet the SBA’s definition of a small 

manufacturing facility and if their manufacturing facilities are located within the United States. 

DOE will also consider this information in satisfying the requirements of the Regulatory 

Flexibility Act for this rulemaking. 

The detailed manufacturer subgroup impact analysis will entail calculating cash flows separately 

for each defined class of manufacturer. 
33

Item 12-1 DOE seeks comment on appropriate manufacturer subgroups, if any, that 

DOE should consider in a manufacturer subgroup analysis for residential dehumidifiers. 

Item 12-2 DOE seeks comment on small businesses that could be impacted by energy 

conservation standards for dehumidifiers, and what the impacts on small businesses of 

potential standards might be. 

12.4 Competitive Impacts Assessment 

EPCA directs DOE to consider any lessening of competition likely to result from an imposition 

of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney General to determine 

in writing the impacts, if any, of any lessening of competition. (42 U.S.C. 6295(o)(2)(B)(ii)) 

DOE will gather and report available firm-specific financial information and impacts, and it will 

then report the aggregated impact of the standard on manufacturers. The competitive impacts 

analysis will focus on assessing the impacts to smaller, yet significant, manufacturers. DOE will 

base the assessment on manufacturing cost data and on information collected from interviews 

with manufacturers. The manufacturer interviews will focus on gathering information that will 

help in assessing 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). DOE will provide the Attorney General with a copy of the NOPR for 

consideration in his/her evaluation of the impact of standards on the lessening of competition. 

12.5 Cumulative Regulatory Burden 

DOE is aware that other regulations may apply to equipment covered under this rulemaking, as 

well as to other equipment produced by the same manufacturers of equipment covered under this 

rulemaking. Multiple regulations may result in a cumulative regulatory burden on these 

manufacturers. Accordingly, DOE will analyze and seek to mitigate the overlapping effects of 

amended DOE standards and other regulatory actions on manufacturers of residential 

dehumidifiers. DOE will consider these issues during the manufacturer impact analysis. 

Regulations that could affect the industries impacted by this rulemaking include:

• DOE standards for residential dehumidifiers. Manufacturers have gone through redesign 

cycles mandated by standards since 2007. Most recently, EISA 2007 prescribed standards 

for residential dehumidifiers that will take effect October 1, 2012. 

• EPA-mandated phase-out of HCFCs. The EPA-mandated phase-out of 

hydrochlorofluorocarbon (HCFC) refrigerants affected multiple residential products (i.e., 

refrigerators, room air-conditioners, and dehumidifiers), requiring manufacturers to 

switch to non-ozone-depleting refrigerants as of January 1, 2010. 

• Reduction of Hazardous Substances (RoHS) directive. The Directive on the Restriction of 

the Use of Certain Hazardous Substances in Electrical and Electronic Equipment was 

adopted in February 2003 by the European Union (EU) and became effective July 1, 
34

2006.20 RoHS identifies specific categories of products that can contain no more than 

threshold amounts of mercury, lead, cadmium, hexavalent chromium, and two fire 

retardants. While this legislation does not extend to products in the United States, 

domestic manufacturers selling to the EU market must produce RoHS-compliant 

appliances. These manufacturers may choose to promulgate the associated design 

changes across their entire product line. 

Item 12-3 What other regulations or pending regulations should DOE consider in its 

examination of cumulative regulatory burden? 

13. UTILITY IMPACT ANALYSIS 

To estimate the impacts that energy conservation standards for residential dehumidifiers would 

have on electric utility industries, DOE plans to use a variant of the EIA’s National Energy 

Modeling System (NEMS), called NEMS-BT. NEMS is a large, multi-sectoral, partialequilibrium model of the U.S. energy sector that EIA has developed over several years, primarily 

for preparing the AEO. NEMS, which is available in the public domain, produces what is termed 

a reference-case forecast for the United States through 2035.21

In the utility impact analysis, the NEMS-BT model results for the base case and standards cases 

are compared. Outputs of the analysis usually parallel results that appear in the latest AEO, with 

some additions. Typical outputs of the utility impact analysis include forecasts of electricity 

sales, generation, and avoided capacity. DOE plans to conduct the utility impact analysis as a 

scenario departing from the latest AEO reference case. In other words, DOE will model the 

energy savings impacts from amended energy conservation standards using NEMS-BT to 

generate forecasts that deviate from the AEO reference case.22

Item 13-1 DOE seeks input from stakeholders on its plans to use NEMS-BT to conduct 

the utility impact analysis. Examples of the type of input sought by DOE include, but 

are not limited to, whether the NEMS-BT model is appropriate for assessing the utility 

impacts of efficiency standards — and if not, what a more appropriate model would be. 

 

20 Available at http://ec.europa.eu/environment/waste/weee/index_en.htm. 

21 For more information on NEMS, refer to the DOE Energy Information Administration documentation. A useful 

summary is National Energy Modeling System: An Overview 2000, DOE/EIA-0581(March 2000), available at 

http://tonto.eia.doe.gov/ftproot/forecasting/05812000.pdf. EIA approves use of the name NEMS to describe only 

an official version of the model without any modification to code or data. Because this analysis entails some 

minor code modifications and runs the model under policy scenarios that are variations on EIA assumptions, DOE 

refers to the model as NEMS-BT (“BT” refers to DOE’s Building Technologies Program, under whose aegis this 

work has been performed). 

22 A description of the NEMS-BT model from a rulemaking for residential furnaces and boilers can be found on 

DOE’s website at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/fb_fr_tsd/chapter_13.pdf. 
35

14. EMPLOYMENT IMPACT ANALYSIS 

In addition to estimating the effects of standards on employment for product manufacturers 

(direct employment impacts, see section 12), DOE estimates the effects of standards on 

employment in the economy in general. Indirect impacts may result from expenditures shifting 

among goods (the substitution effect) and changes in income that lead to a change in overall 

expenditure levels (the income effect). DOE defines indirect employment impacts as net jobs 

eliminated or created in the general economy as a result of increased spending driven by the 

increased product prices and reduced spending on energy related to standards. 

DOE investigates combined direct and indirect employment impacts using the Pacific Northwest 

National Laboratory (PNNL)’s “Impact of Sector Energy Technologies” (ImSET) model. PNNL 

developed ImSET for DOE’s Office of Planning, Budget, and Analysis. The model estimates the 

employment and income effects of energy-saving technologies in buildings, industry, and 

transportation. In comparison with simple economic multiplier approaches, ImSET allows for 

more complete and automated analysis of the economic impacts of energy efficiency 

investments. 

Item 14-1 DOE welcomes feedback on its planned approach for assessing national 

employment impacts, and it is interested in whether tools other than ImSet or 

additional factors should be considered for its analysis. If other tools or factors should 

be considered, please identify them and explain why, and how, they should be 

integrated into DOE's analysis. 

15. EMISSIONS ANALYSIS 

In the emissions analysis, DOE uses the NEMS-BT model to estimate the standards-related 

reduction in power sector emissions of carbon dioxide (CO2), nitrogen oxides (NOX), and 

mercury (Hg). In the emissions analysis, NEMS-BT is run similarly to the AEO NEMS, except 

that dehumidifier product energy use is reduced by the amount of energy saved (by fuel type) 

due to each considered standard level. The input, national energy savings, comes from the 

spreadsheet model used for the national impact analysis; the output is the forecasted physical 

emissions. The net benefit of each considered standard level is the difference between the 

emissions estimated by NEMS-BT at that level and the AEO reference case. 

In addition to estimating impacts of standards on power sector emissions, DOE will estimate 

emissions impacts in production activities that provide the energy inputs to power plants. (These 

are referred to as “upstream” emissions.) This FFC analysis includes impacts on emissions of 

methane and nitrous oxide, both of which are recognized as greenhouse gases. 

15.1 Carbon Dioxide 

In the absence of any Federal regulation of power plant emissions of CO2, a DOE standard is 

likely to result in reductions of those emissions. NEMS-BT tracks CO2 emissions using a 
36

detailed module that provides results with broad coverage of all sectors and inclusion of 

interactive effects. The net reduction is the difference between CO2 emissions estimated by 

NEMS-BT at each standard level considered and the AEO reference case. 

15.2 Sulfur Dioxide 

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide and 

regional emissions cap-and-trade programs, which DOE preliminarily has determined create 

uncertainty about the potential standards’ impact on SO2 emissions. Title IV of the Clean Air Act 

sets an annual emissions cap on SO2 for affected EGUs in the 48 contiguous states and the 

District of Columbia (D.C.). SO2 emissions from 28 eastern states and D.C. are also limited 

under the Clean Air Interstate Rule (CAIR, 70 Fed. Reg. 25162 (May 12, 2005)), which created 

an allowance-based trading program. CAIR was remanded to the EPA by the U.S. Court of 

Appeals for the District of Columbia Circuit (D.C. Circuit), see North Carolina v. EPA, 550 F.3d 

1176 (D.C. Cir. 2008), though it remained in effect temporarily, consistent with the D.C. 

Circuit’s earlier opinion in North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008). On July 6, 

2011 EPA issued a replacement for CAIR, the Cross-State Air Pollution Rule. 76 FR 48208 

(Aug. 8, 2011). (See www.epa.gov/crossstaterule/). On December 30, 2011, however, the D.C. 

Circuit stayed the new rules while a panel of judges reviews them, and told EPA to continue 

enforcing CAIR (see EME Homer City Generation v. EPA, No. 11-1302, Order at *2 (D.C. Cir. 

Dec. 30, 2011)). 

The attainment of emissions caps typically is flexible among EGUs through the use of emissions 

allowances and tradable permits. Under existing EPA regulations, any excess SO2 emissions 

allowances resulting from the lower electricity demand caused by the imposition of an efficiency 

standard could be used to offset increases in SO2 emissions by any regulated EGU. If the 

standard resulted in a permanent increase in the quantity of unused emissions allowances, 

however, there would be an overall reduction in SO2 emissions due to the standards. Although 

there remains some uncertainty about the ultimate effects of efficiency standards on SO2

emissions covered by the cap-and-trade system, the NEMS-BT modeling system currently 

indicates that no physical reductions in power sector emissions would occur for SO2.

15.3 Nitrogen Oxides 

Under CAIR, there is a cap on NOX emissions in 28 eastern states and D.C. All those states and 

D.C. have elected to reduce their NOX emissions by participating in cap-and-trade programs for 

EGUs. Therefore, energy conservation standards for residential dehumidifiers may have little or 

no physical effect on those emissions in the 28 eastern states and D.C. for the same reasons that 

they may have little or no physical effect on SO2 emissions. DOE will use the NEMS-BT to 

estimate NOX emissions reductions from potential standards in the states where emissions are not 

capped. 

15.4 Mercury 

On February 16, 2012, EPA issued national emissions standards for hazardous air pollutants 

(NESHAPs) for mercury and certain other pollutants emitted from coal and oil-fired EGUs. 77 

FR 9304. The NESHAPs do not include emissions caps and, as such, DOE’s energy conservation 
37

standards would likely reduce Hg emissions. For this rulemaking, DOE plans to estimate Hg 

emissions reductions using NEMS-BT based on AEO2012, which does not incorporate the 

NESHAPs. DOE expects that future versions of the NEMS-BT model will reflect 

implementation of the NESHAPs. 

15.5 Particulate Matter 

DOE acknowledges that particulate matter (PM) exposure can affect human health. Power plant 

emissions can have either direct or indirect impacts on PM. Some pollutants emitted by a power 

plant are in the form of particulates leaving the smoke stack. Those are direct, or primary, PM 

emissions. The great majority of PM emissions associated with power plants, however, are in the 

form of secondary sulfates, which are produced at a significant distance from power plants by 

complex atmospheric chemical reactions that often involve the gaseous (non-particulate) 

emissions of power plants, SO2 and NOX. The quantity of the secondary sulfates produced is 

determined by a complex set of factors that include the atmospheric quantities of SO2 and NOX

and other atmospheric constituents and conditions. Because those highly complex chemical 

reactions produce PM comprised of various constituents from various sources, EPA, does not 

distinguish direct PM emissions from power plants from the secondary sulfate particulates in its 

ambient air quality requirements, monitoring of ambient air quality, or PM emissions 

inventories. For these reasons, it currently is impossible to determine how amended standards 

would affect either direct or indirect PM emissions. Therefore, DOE is not planning to assess the 

impact of standards on PM emissions. Further, as described previously, it is uncertain whether 

efficiency standards will result in a net decrease in power plant emissions of SO2, which are now 

largely regulated by cap-and-trade systems. 

Item 15-1 DOE seeks input on its plans to use NEMS-BT to analyze emissions associated 

with the dehumidifiers covered by this potential rulemaking. 

16. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS 

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the standard levels 

considered for dehumidifiers.

In order to estimate the monetary value of benefits resulting from reduced emissions of CO2, 

DOE plans to use the most current social cost of carbon (SCC) values developed and/or agreed to 

by an interagency process. The SCC represents a monetary measure of the incremental damage 

resulting from greenhouse gas (GHG) emissions, including, but not limited to, net loss of 

agricultural productivity, human health effects, property damage from sea level rise, and changes 

in ecosystem services. Any effort to quantify and monetize the harms associated with climate 

change raises 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. 
38

At the time of this notice, the most recent interagency estimates of the potential global benefits 

resulting from reduced CO2 emissions in 2010, expressed in 2011$, were $5.1, $23.0, $37.7, and 

$69.6 per metric ton avoided. For emissions reductions that occur in later years, those values 

grow in real terms over time. Additionally, the interagency group determined that a range of 

values from 7 percent to 23 percent should be used to adjust the global SCC when calculating 

domestic effects, although DOE will give preference to consideration of the global benefits of 

reducing CO2 emissions. 

DOE recognizes that scientific and economic knowledge continues to evolve rapidly regarding 

the contribution of CO2 and other GHG to changes in the global climate and the potential 

resulting damages to the world economy. Thus, the values are subject to change. 

DOE also intends to estimate the potential monetary benefit of reduced NOX 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 $460 to $4,722 per ton in 2011$.23 In

accordance with OMB guidance, DOE will conduct two calculations of the monetary benefits 

derived for NOX, one using a real discount rate of 3 percent and the other a real discount rate of 7 

percent.24

DOE does not plan to monetize estimates of Hg in this rulemaking. DOE has decided to await 

further guidance regarding consistent valuation and reporting of Hg emissions before it 

monetizes Hg in its rulemakings. 

Item 16-1 Are there any other environmental factors the Department should consider in 

this rulemaking? 

Item 16-2 Are there other approaches to the emissions analysis that the Department 

should consider? 

17. REGULATORY IMPACT ANALYSIS 

In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis to address 

the potential for non-regulatory approaches to supplant or augment energy conservation 

standards to improve the efficiency of residential dehumidifiers. DOE recognizes that voluntary 

or other non-regulatory efforts by manufacturers, utilities, and other interested parties can result 

in substantial improvements in efficiency. DOE intends to analyze the likely effects of nonregulatory initiatives on product energy use, consumer utility, and LCC. DOE will attempt to 

base its assessment on the impacts of any such initiatives to date, but will also consider 

information presented regarding the impacts that an initiative might have in the future. 

 

23 For additional information, refer to U.S. 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, Washington, D.C. 

24 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 
39

If DOE proposes energy conservation standards for residential dehumidifiers, and the NOPR 

constitutes a significant regulatory action as defined under section 3(f) of Executive Order 

12866, “Regulatory Planning and Review,” 58 FR 51735 (October 4, 1993), DOE will prepare 

and submit to OMB for review the assessment of costs and benefits required under section 

6(a)(3) of the order. 
40

APPENDIX A – SUMMARY OF ITEMS FOR COMMENT FROM INTERESTED 

PARTIES 

DOE requests comments from interested parties on the following issues: 

Item 3-1 The Department requests information that would contribute to the market 

assessment (e.g., current product features and efficiencies, product-feature 

and efficiency trends, historical product shipments and prices). ................................. 8

Item 3-2 The Department requests input from stakeholders on the proposed classes and 

criteria used for creating these product classes. Specifically, should additional 

or fewer criteria beyond those identified above be used as a basis for 

developing product classes? Should DOE consider separate product class(es) 

for whole-home dehumidifiers? How should DOE classify portable 

dehumidifiers that can be operated in a ducted installation? ....................................... 9

Item 3-3 Of the technologies listed above, are there any that DOE should not consider 

because of their impacts on safety, performance, or consumer utility of the 

product? ..................................................................................................................... 10

Item 3-4 Are there other unlisted technologies that DOE should consider as design 

options and what, if any, impacts do the design options have on safety, 

performance, and consumer utility? .......................................................................... 10

Item 3-5 The Department seeks input from stakeholders on the selection of 

representative product classes for the engineering and LCC analyses, and on 

possible methods of extrapolating the engineering and LCC analyses from the 

representative dehumidifier product classes to the other two product classes 

(e.g., maintaining relative incremental energy use specified in EPCA across 

product classes). ......................................................................................................... 11

Item 3-6 The Department seeks input from stakeholders on whether the above energy 

efficiency/conservation levels are appropriate for characterizing the 

performance of baseline units, including the baseline selected for whole home 

units. ........................................................................................................................... 11

Item 3-7 The Department seeks information regarding the specific technological 

characteristics of the baseline model for each product class, including the 

technologies described in section 3.4. ....................................................................... 11

Item 5-1 DOE seeks input from stakeholders on whether the above energy efficiency 

levels are appropriate for characterizing the performance of baseline units. ............ 14

Item 5-2 DOE seeks input on an appropriate baseline unit efficiency for whole-home 

dehumidifiers and whether the DOE test procedure is capable of measuring 

the performance of these units. .................................................................................. 14

Item 5-3 DOE seeks information regarding the specific technological characteristics of 

the baseline model for each product class, including the technologies 

described in section 3.3. ............................................................................................. 14
41

Item 5-4 DOE requests feedback on the use of a design-option approach to determine 

the relationship between manufacturer cost and energy efficiency for 

residential dehumidifiers. .......................................................................................... 15

Item 5-5 DOE seeks input from stakeholders concerning the efficiency levels it 

proposes to use for collecting incremental cost data from manufacturers of 

residential dehumidifiers. DOE also seeks input from stakeholders on 

appropriate maximum technologically feasible efficiency levels. ............................ 17

Item 5-6 Are there proprietary designs or technologies of which DOE should be aware 

for any of the dehumidifiers under consideration in this rulemaking? If so, 

how should DOE acquire the cost data necessary for evaluating these 

designs? ...................................................................................................................... 18

Item 5-7 Are there outside regulatory issues that DOE should consider in its analysis of 

residential dehumidifiers? .......................................................................................... 18

Item 6-1 DOE seeks stakeholder input on its proposed approaches for specifying 

typical annual energy consumption. Most importantly, the Department is 

interested in sources of data that can assist in characterizing the annual 

energy consumption of dehumidifiers. ...................................................................... 19

Item 6-2 The Department seeks stakeholder input on data sources that it can use to 

characterize the variability in annual energy consumption for dehumidifiers. 

The Department is particularly interested in field monitoring studies and data. ....... 19

Item 7-1 The Department welcomes suggestions and comments concerning its 

proposed approach to developing estimates of future retail prices. ........................... 20

Item 8-1 DOE seeks stakeholder input on its proposed approach of using probability 

distributions and Monte Carlo simulation to conduct the LCC and PBP 

analysis ...................................................................................................................... 22

Item 8-2 DOE requests data from stakeholders to characterize the current mix of 

dehumidifier efficiencies in the market. .................................................................... 22

Item 8-3 DOE seeks stakeholder input on the planned approach for estimating current 

and forecasted energy prices. ..................................................................................... 23

Item 8-4 DOE seeks stakeholder input on the merits of its proposed analytical 

assumption that changes in maintenance, repair, and installation costs will be 

negligible for more-efficient residential dehumidifiers. If that assumption is 

incorrect, DOE is interested in the reasons why this is so and in specific ways 

to correct that assumption. ......................................................................................... 24

Item 8-5 DOE seeks stakeholder input on appropriate product lifetimes for 

dehumidifiers. Specifically, DOE seeks data sources for establishing product 

lifetimes. .................................................................................................................... 24

Item 8-6 DOE seeks stakeholder input on its planned approach for estimating discount 

rates for residential consumers. ................................................................................. 24

Item 8-7 DOE seeks stakeholder input on dehumidifier efficiency in the base case, 

historical efficiency data on dehumidifiers, and projected trends in 
42

dehumidifier efficiency. DOE is especially interested in any data pertaining 

to whole-home dehumidifiers. ................................................................................... 25

Item 9-1 DOE seeks historical shipments data from stakeholders. If such data are 

provided, DOE requests market share data showing the percentage of 

dehumidifier shipments for portable and whole-home products and including 

within each category dehumidifier type (i.e. compressor/condenser-based, 

dessicant, etc.). ........................................................................................................... 26

Item 9-2 If stakeholders are unable to provide historical shipments data, DOE seeks 

comment on whether the AHAM and Appliance Magazine shipments data or 

the NPD sales data is more representative of historical shipments and why. ............ 26

Item 9-3 DOE seeks input on the types of scenarios it should use to forecast base case 

shipments and the reason(s) for the suggested scenario(s). ....................................... 26

Item 9-4 As part of the preliminary manufacturer impact analysis, DOE seeks input 

from manufacturers on the potential impact of new energy conservation 

standards on dehumidifier shipments. DOE also seeks input from other 

stakeholders on the potential impact of standards on product shipments. ................. 27

Item 9-5 DOE also requests input on any current market-pull programs that promote 

the adoption of more efficient dehumidifiers. ........................................................... 27

Item 10-1 DOE seeks historical SWEF data for dehumidifiers. DOE also seeks historical 

market share data showing the percentages of product shipments by 

efficiency level. .......................................................................................................... 28

Item 10-2 DOE seeks input on its plan to develop spreadsheet models for estimating 

national energy savings attributable to amended energy conservation 

standards for dehumidifiers. For example, are spreadsheet models still the 

preferred approach for estimating national impacts? ................................................. 29

Item 11-1 The Department requests input as to what consumer subgroups are 

appropriate to evaluate for residential dehumidifiers. ............................................... 30

Item 12-1 DOE seeks comment on appropriate manufacturer subgroups, if any, that 

DOE should consider in a manufacturer subgroup analysis for residential 

dehumidifiers. ............................................................................................................ 33

Item 12-2 DOE seeks comment on small businesses that could be impacted by energy 

conservation standards for dehumidifiers, and what the impacts on small 

businesses of potential standards might be. ............................................................... 33

Item 12-3 What other regulations or pending regulations should DOE consider in its 

examination of cumulative regulatory burden? ......................................................... 34

Item 13-1 DOE seeks input from stakeholders on its plans to use NEMS-BT to conduct 

the utility impact analysis. Examples of the type of input sought by DOE 

include, but are not limited to, whether the NEMS-BT model is appropriate 

for assessing the utility impacts of efficiency standards — and if not, what a 

more appropriate model would be. ............................................................................ 34
43

Item 14-1 DOE welcomes feedback on its planned approach for assessing national 

employment impacts, and it is interested in whether tools other than ImSet or 

additional factors should be considered for its analysis. If other tools or 

factors should be considered, please identify them and explain why, and how, 

they should be integrated into DOE's analysis. ......................................................... 35

Item 15-1 DOE seeks input on its plans to use NEMS-BT to analyze emissions 

associated with the dehumidifiers covered by this potential rulemaking. ................. 37

Item 16-1 Are there any other environmental factors the Department should consider in 

this rulemaking? ......................................................................................................... 38

Item 16-2 Are there other approaches to the emissions analysis that the Department 

should consider? ........................................................................................................ 38