1 

# Technical and Editorial Corrections

• Definition of “Dehumidifier”

– DOE proposes to remove the word “refrigerated” from the phrase “mechanically refrigerated encased assembly ” in the dehumidifier
definition in 10 CFR 430.2.

• Clarifies that moisture removal is the main function of this product.

• Is consistent with the EPCA definition ( 42 U.S.C. 6291(34 ))



# – DOE also proposes to clarify that the definition of “dehumidifier” does not apply to portable air conditioners or room air conditioners.



# • Correctly reference sections of Appendix X in 10 CFR 430.23(z) for measuring capacity, EF, and IEF.

• Integrated Energy Factor Calculation

– DOE proposes to include the correct value of 6 for the constant that converts standby power.2 

# Ambient Temperature

• 2009 Residential Energy Consumption Survey (RECS):

– 15 million total homes surveyed with
dehumidifiers

– Majority of homes were in the Northeast (5.1 million) and Midwest (6.5 million)



# • In 2006, AHAM submitted to DOE an
estimate of 1,095 annual active mode operating hours

– 73.5% of operation falls between June and August

– 26.5% of operation occurs in April, May, September, and October AHAM Estimated Usage

Month Operating Hours

Jan 0
Feb 0

Mar 0 Apr 14 May 86

Jun 231
Jul 288 Aug 288 Sep 130

Oct 58

Nov 0

Dec 0
Total 1,095 2009 RECS Data ( homes in millions )

US Total 15 Region: Northeast 5.1

New England 1.5

Mid Atlantic 3.6 Region: Midwest 6.5

East North Central 4.5

West North Central 2 

# Usage by Location3 

# Ambient Temperature

• Collected weather station data from the National Climatic Data Center (NCDC) of the National Oceanic and Atmospheric Administration (NOAA).

– Hourly ambient temperature and relative humidity

– Hourly soil temperature measured at a depth of 40 inches



# • Data were analyzed for states* within the two regions with primary dehumidifier ownership, Northeast and Midwest, and according to RECS.

• All data with relative humidity < 60% was removed from the data set.

Northeast

New England

ME, NH, RI Mid Atlantic

NY, PA Midwest

East North

Central

IL, IN, MI, OH, WI West North Central

IA, KS, MN, MO, ND, NE, SD

*Hourly climate data were not available for all states in each sub

- region (http://www.wcc.nrcs.usda.gov/scan /) 

# Ambient and Soil Temperature Data4 

# Ambient Temperature

Example of Northeast Region Data

Average Ambient Temperature

Northeast April May June July August September October New England 43.20 54.7 59.7 67.4 67.5 58.2 51.5

ME 40.69 52.04 57.93 65.20 65.97 55.58 49.29

NH 43.29 54.41 59.78 67.49 67.09 57.27 50.94

RI 45.66 57.58 61.50 69.49 69.40 61.71 54.21

Mid Atlantic 44.3 62.0 63.5 71.0 68.6 61.6 53.7

NY 42.30 60.46 62.22 69.09 67.26 59.81 53.15

PA 46.39 63.46 64.86 72.99 69.98 63.44 54.34



### Average Soil Temperature at 40” Depth

Northeast April May June July August September October New England 42.8 49.9 57.2 63.7 66.5 62.7 56.2

ME 39.49 47.67 55.38 62.33 64.81 61.20 54.77

RI 46.18 52.06 59.07 65.17 68.24 64.14 57.67

Mid Atlantic 50.4 58.0 66.4 71.8 72.8 69.4 61.9

NY 49.39 57.28 65.92 71.34 72.29 68.51 61.26

PA 51.45 58.70 66.87 72.30 73.27 70.26 62.555 

# Ambient Temperature

• Sub

- region conditions and subsequent regional conditions were then combined using a weighted average based on RECS ownership data.

• Example

–



# • Using AHAM monthly usage estimates, national weighted average
annual conditions were calculated. Month of Operation Average Monthly Temperature in 2012 when Hourly %RH>60, in ° F (NOAA, NCDC ) Weighted Average Overall Temperature Northeast ( Weighted ) New England Mid
Atlantic Midwest ( Weighted ) East North
Central West North
Central Apr 44.01 43.21 44.35 46.22 46.05 46.61 45.25
May 59.82 54.68 61.96 58.43 59.55 55.93 59.04

Jun 62.42 59.74 63.54 64.03 63.96 64.17 63.32

Jul 69.97 67.39 71.04 71.32 71.72 70.44 70.73
Aug 68.28 67.49 68.62 64.37 64.87 63.24 66.09 Sep 60.61 58.19 61.63 56.31 57.66 53.27 58.20

Oct 53.08 51.48 53.74 45.73 47.20 42.41 48.96 2009 RECS Data ( millions )

US Total 15 Region: Northeast 5.1

New England 1.5

Mid Atlantic 3.6 Region: Midwest 6.5

East North Central 4.5

West North Central 2

Month of Operation Operating

Hours Weighted Average Ambient Temperature ( ° F ) Weighted Average Soil Temperature ( ° F )

Apr 14 45.25 48.59 May 86 59.04 55.20

Jun 231 63.32 62.31
Jul 288 70.73 68.39 Aug 288 66.09 69.18 Sep 130 58.20 66.06

Oct 58 48.96 58.46 

### National Weighted Average Annual Ambient Temperature is 

### 64.06 ° F

National Weighted Average Annual Soil Temperature is 

### 65.22 ° F6 

# Ambient Temperature

• Based on DOE’s analysis, national average annual ambient temperature and soil temperature at 40” depth in regions of dehumidifier use are both close to 65 ° F

• This is consistent with ANSI/AHAM DH

- 1

- 2008 Low T emperature Test with conditions
of 65 ° F dry

- bulb temperature and 60% RH.

• 433 national annual operating hours are at 65 ° F test conditions (65 ° F ± 2 ° F)

• 112 national annual operating hours are at 80 ° F test conditions (80 ° F ± 2 ° F)

0 20 40 60 80 100 120 140 160

30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 90Hours

Temperature ( ° F ) Overall Hours per Ambient Temperature (relative humidity >60%) 

# Representative Ambient Temperature7 

# Ambient Temperature

Whole

- Home Dehumidifier Ambient Temperature

• Commenters suggested that the dry

- bulb temperature of the inlet air
for whole

- home dehumidifiers is different than portable dehumidifiers
and would be close to the thermostat setting in the home.

• RECS provides average indoor temperature for three scenarios based on 1,735 homes in the Northeast and Midwest:

– Daytime when the residence is occupied,

– Daytime when the residence is unoccupied, and

– Nighttime when the residence is occupied.



# • According to RECS, the average indoor temperature is 72.7 ° F.

Time of Day Occupied Season Temperature ( ° F )

Day Yes Summer 72.3

Day No Summer 73.7

Night Yes Summer 72.2

Average 72.7

Number of Homes 1,7358 

# Ambient Temperature

• Capacity and EF are calculated based on measured condensate collected and energy consumed during the 6 hour rating test period

. Product Capacity and EF Calculation Review

CCCCCCCCCCCCCCCC pp pp
dd = CCCC CC CCCCCC llll × 24 hrr

DDDD oo TT hrr × 1

. 04 llll HH 2 OO



## pp pp HH 2 OO



## EEEE LL

kkkk = CCCC CC CCCCCC llll × 0

. 454 kkkk llll

EE CCCC CCCC kkkk × 1

. 0 kkkk HH 2 OO 

## ll HH 2 OO

*Additional details and full equations are found in Sections 7.1.7 and 7.2.2 of ANSI/AHAM DH

- 1

- 2008.9 

# Ambient Temperature

Performance Impacts at Reduced Temperature

– Portable

• When a dehumidifier operates at a lower temperature, heat transfer capabilities in the system are decreased, thereby reducing capacity and performance.

• DOE investigated dehumidification mode performance of 13 portable and 10 whole

- home dehumidifiers (ducted with 0.5” H 2 

### O except as noted) when tested according to the proposed 65 ° F test conditions.

• EF was examined because it is directly impacted by temperature. IEF would factor in combined low

- power mode energy use.

• Test results demonstrated an average reduction in capacity per product class of 35

– 53% and EF of 21

- 36%.

• The alternate approach to combine two test conditions would still result in a significant impact, as
the 65 ° F condition would be assigned a 79% weighting. Product Class (pints / day) Test Unit Percent Change
from 80 ° F to 65 ° F (%)

Capacity EF

< 35.00 P1

- 35

- 26 Class Average

- 35

- 26

35.01

- 45.00 P2

- 77

- 61

P3

- 48

- 32

P4

- 33

- 15 Class Average

- 53

- 36

45.01

- 54.00 P5

- 39

- 25

P6

- 33

- 21

P7

- 36

- 21 Class Average

- 36

- 22

54.01

- 75.00 P8

- 61

- 39

P9

- 39

- 32

P10

- 65

- 36

P11

- 59

- 35

P12

- 36

- 14 Class Average

- 52

- 31

> 75.00 P13

- 27

- 15

W3

- 35

- 21

W4

- 42

- 29

W5

- 49

- 26

W7

- 27

- 15

W8

- 24 5

W9

- 49

- 33

W10

- 20

- 4

W12

- 42

- 35

W13

- 45

- 35

W14*

- 39

- 25 Class Average

- 36

- 21

* Unducted10 

# Ambient Temperature

• DOE numerically estimated whole

home dehumidifier performance at the
alternate test condition of 73 ° F dry

bulb temperature and 60 % RH, ducted
with 0.5” H 2 

# O .

• Numerical estimations were determined for capacity and EF using biquadratic equations as a function of temperature and relative humidity.*

*In this case, relative humidity is held constant at 60%, and the equation therefore simplified to a quadratic equation with terms that scale with the temperature and square of the temperature. Test
Unit Dehumidification Technology Percent Change
from 80 ° F to 73 ° F ( % )

Capacity EF

W3 Refrigerant

- 15

- 6

W4 Refrigerant

- 18

- 9

W5 Refrigerant

- 21

- 8

W7 Refrigerant

- Desiccant

- 12

- 5

W8 Refrigerant

- 10 2

W9 Refrigerant

- 21

- 10

W10 Refrigerant

- 9

- 1

W12 Refrigerant

- Desiccant

- 18

- 11

W13 Refrigerant

- 19

- 11
Average

- 16

- 7 

# Performance Impacts at Reduced Temperature

– Whole

- Home

CCCCCCCCCCCCCCCC oooo EEEE = AA × TTTTTT 22 

### + BB × TTTTTT + CC × RRRR 22 

### + DD × RRRR + EE × TTTTTT × RRRR +

CCCCCCCCCCCCCCCC oooo EEEE = GG × TTTTTT 22 

### + × TTTTTT + II11 

# Relative Humidity

• American Society of Heating, Refrigerating and Air

- Conditioning Engineers (ASHRAE) 55

- Thermal Environmental Conditions for Human Occupancy

– Identifies 0.012 humidity ratio (lb H 2 O 

# / lb air 

# ) as upper comfort limit

– Corresponds to 55% RH at 80 ° F or ≥60%RH at lower temperatures



# • U.S . Department of Labor, Occupational Safety and Health Administration (OSHA ) Technical Manual

– Recommends relative humidity be maintained between 20% and 60%



# • CADMUS Group Field Study

– Average consumer

- selected setpoint was 50% RH and ranged from 35%

to 65%

– Values are not representative of ambient %RH while dehumidifying, only the consumer setpoint at which dehumidification ceases 

# DOE reviewed studies and conducted additional research12 

# Relative Humidity

• DOE Metering Study

– On average, 5% of hours were spent at >60 % RH

.

– 3 of the 10 sites exceeded 60 % RH for 15 to 25% of the time.



# • Wisconsin Energy Center Field Study

– 11 of 40 sites exceeded 60 % RH for at least 25% of the summer.

– 16 of 40 sites ranged from 50 to 60 % RH for at least 25% of the summer.



# • Manufacturer Literature

– Based on DOE research of various manufacturers and brands, most common default RH setpoint is 60%. 

# Studies and Research, continued13 

# Whole

- Home Dehumidifiers

Duct Configuration: Horizontal Inlet Duct14 

# Whole

- Home Dehumidifiers

Duct Configuration: Horizontal Outlet Duct15 

# Whole

- Home Dehumidifiers

Duct Configuration: Vertical Inlet Duct16 

# Whole

- Home Dehumidifiers

Duct Configuration: Vertical Outlet Duct17 

# Whole

- Home Dehumidifiers

• DOE reviewed several standards for static pressure accuracy requirements.

– AMCA 210

- 07 specifies a pressure measurements have a maximum uncertainty of 0.005” H2O at the proposed 0.5” H2O

– ANSI/ASHRAE Standard 37

- 2009, “Methods of Testing for Rating Electrically Driven Unitary Air

- Conditioning and Heat Pump Equipment”, specifies a static pressure accuracy of ± 0.01” H2O

– Appendix M to 10 CFR Part 430 subpart B, section 2.5.3 for testing central air conditioners and heat pumps specifies that the differential pressure instrument shall have a resolution of no more than 0.01” H2O



# • DOE proposed that pressure instruments have an accuracy within ± 0.01” H2O

– Consistent with ASHRAE 37

- 2009 and Appendix M

– Less burdensome than the 0.005” H2O in AMCA 210

- 07. 

# Static Pressure Accuracy18 

# Certification

• The capacity for each basic model must be reported, but the current test procedure does not specify how to determine the rated capacity.

• The consequence of an incorrectly reported capacity may be the application of an incorrect standard.

• DOE proposed to specify in 10 CFR 429.36 that the average of the capacities measured for a given sample of a basic model be used for certification purposes.19 

# Verification

• DOE proposed to require in 10 CFR 429.134(f) that measured capacity be within 5 percent of the certified capacity, or 1 pint/day, whichever is greater.

– If this condition was met , the certified capacity would be used to
determine the minimum allowable EF for the basic model

– If this condition was not met, the mean of the measured capacities
would be used to determine the minimum allowable EF



# • This tolerance is the same as for AHAM’s dehumidifier verification program.

• DOE also proposed to clarify in 10 CFR 430.23(z ) the specific sections in Appendix X and Appendix X1 which would be used to measure capacity, and provide rounding instructions for capacity and IEF.20 

# Compliance Dates

• Amended Appendix X1:

– Clarifications and corrections would not affect a manufacturer’s ability to comply with current standards

– Would be required for representations 180 days after the publication of
the final rule



# • New Appendix X1:

– May be used for early compliance with any amended standards

– Would be required for use upon the compliance date of amended
standards21 

# Small Business Impacts

• DOE identified five small business manufacturers

.

• Impacts of reduced ambient test temperature:

– AHAM DH

- 1

- 2008 includes a test at 65 ° F, which suggests that some manufacturers already test at the proposed lower temperature.



# • DOE estimated the costs associated with the proposal.

– Whole

- home test ducts:

• Refrigeration

- only whole

- home dehumidifier: $1,500 to $3,000

• Refrigerant

- desiccant dehumidifier : $8,100



# – Fan

- only mode test can use the same measurement devices as the current test procedure.

• Cost of additional meter: $2,000 (if needed)



# – Proposed limit of one psychrometer per dehumidifier test could require the purchase of additional psychrometers.

• Cost to purchase and calibrate one psychrometer: $1000

• Cost of sampling tree: $30022 

# Small Business Impacts

• Testing at both 80 ° F and 65 ° F would double the
dehumidification mode test burden

• DOE considered chilled mirror hygrometers to measure wet

bulb temperature in test ducts, but proposed the use of aspirating psychrometers to avoid the high cost and burden of using hygrometers.

• DOE could require that test ducts be used for both the inlet and outlet ports rather than only the outlet port.

– Cost of extra test duct: $3000. 

# Proposal Alternatives23 

# Backup Slides for Standards24 

# Markups Analysis

• Manufacturer Markups

– DOE used 10

- K reports of dehumidifier manufacturing companies from
2008 to 2012.

– DOE assumed baseline dehumidifier units have the same markup as more efficient units.

– DOE assumed whole

- home manufacturers has the same markup as portable manufacturing companies

.



# • Retail Markups for Portable Dehumidifiers

– D OE used U.S . Census Bureau Business Expenses Survey for “Household Appliance Stores ”



# • Distributor Markups for Whole

- home Dehumidifiers

– D OE used 2007 Economic Census industrial cost data.

– DOE derived the baseline and incremental markups for both replacement and first time owner markets.25 

# Markups Analysis

• DOE applies markups to product MSP to determine the customer purchase price of analyzed equipment.

• DOE used baseline and incremental markups, applied to the MSP in the base case, and the incremental difference in MSP in each standards case for portable and whole

- home
dehumidifiers.

Markup Baseline Incremental

Manufacturer 1.43

Retailer 1.36 1.11

Sales Tax 1.071

Overall 2.08 1.70 Markup Replacement First Time Owner

Baseline Incremental Baseline Incremental

Manufacturer 1.43 1.43

Wholesaler 1.36 1.10 1.36 1.10

Mechanical

Contractor 1.53 1.22 1.45 1.15

General

Contractor -- 1.47 1.34

Sales Tax 1.071

--

Overall 3.19 2.06 4.15 2.42 

# Portable Dehumidifiers Whole

- Home Dehumidifiers26 

# Markups Analysis

• Consumer Price = Manufacturing Cost × Markups × Sales Tax

– Manufacturing cost vs. efficiency relationships developed in the Engineering Analysis

– Markups and Sales Taxes developed in the Markups Analysis to determine product price

Std

- Level
Manufacturer

Cost Baseline
Manufacturer

Cost

Manufacturer Markup

Retailer or
Distributor

Markup

Sales Tax Consumer Price 

# Consumer Price27 

# Energy Use Analysis

• Portray the variability of annual energy use for portable dehumidifiers using household samples from RECS 2009.

CCDD: Climate Controlled, Direct Drain CCB: Climate Controlled, with bucket

NCCDD: Non

- Climate Controlled, Direct Drain NCCB: Non

- Climate Controlled, with bucket

Fan Run Time 

# Variability: Portable Dehumidifier28 

# Energy Use Analysis

• DOE also used the probability distribution of operating hours by mode
found in Willem’s (2013b) report.

• DOE also used the probability distribution of power demand for Fan

only mode (131

- 158 W) and Standby mode (2.6

- 4.2 W) in Willem’s (2013b)
report.

0.0% 5.0% 10.0% 15.0% 20.0% 25.0%Probability Distribution (%)

Hours Hours/day in Compressor Mode 0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0%Probability Distribution (%)

Hours Hours/day in Fan

- only Mode

0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0%Probability Distribution (%)

Hours Hours/day in Standby Mode 

# Variability: Whole

- Home Dehumidifiers29 

# Operating Costs: Electricity Prices Geographic Area Average Price (2012$/kWh) Geographic Area Average Price (2012$/kWh)
Connecticut, Maine, New Hampshire,
Rhode Island, Vermont 0.174 Delaware, DC, Maryland, West
Virginia 0.132

Massachusetts 0.151 Georgia 0.114

New York 0.197 North Carolina, South Carolina 0.108

New Jersey 0.166 Florida 0.118

Pennsylvania 0.137 Alabama, Kentucky, Mississippi 0.104

Illinois 0.122 Tennessee 0.102

Indiana, Ohio 0.112 Arkansas, Louisiana, Oklahoma 0.094

Michigan 0.136 Texas 0.114

Wisconsin 0.133 Colorado 0.115

Iowa, Minnesota, North Dakota, South

Dakota 0.108 Idaho, Montana, Utah, Wyoming 0.091

Kansas, Nebraska 0.103 Arizona 0.113

Missouri 0.100 Nevada, New Mexico 0.117

Virginia 0.109 California 0.151
Alaska, Hawaii, Oregon,
Washington 0.118

Source: EIA Form 861 

# Life

- Cycle Cost and Payback Period Analysis30 

# Operating Cost Inputs: Average Residential Electricity Prices

0.90 0.95 1.00 1.05 1.10 1.15 1.20 1.25Electricity Price Trend (2012=100) 

## AEO 2013 Electricity Projection (National)

Reference Case High Low 

# Life

- Cycle Cost and Payback Period Analysis