CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

1.1	 PURPOSE OF THE DOCUMENT ................................................................................. 1-1
 

1.2	 OVERVIEW OF STANDARDS FOR RESIDENTIAL CLOTHES DRYERS
 

AND ROOM AIR CONDITIONERS ............................................................................. 1-1
 

1.3	 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS ................... 1-3
 

1.4	 STRUCTURE OF THE DOCUMENT............................................................................ 1-6
 

LIST OF TABLES 

Table 1.3.1 Analyses Under the Process Rule ........................................................................ 1-5
 

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CHAPTER 1. INTRODUCTION
 

1.1 PURPOSE OF THE DOCUMENT
 

This preliminary technical support document (preliminary TSD) is a stand-alone report 

that provides the technical analyses and results supporting the information presented in the 

preliminary notice of public meeting (NOPM) and executive summary for residential clothes 

dryers and room air conditioners. This preliminary TSD reports on the preliminary activities and 

analyses conducted in the period preceding the notice of proposed rulemaking (NOPR) of this 

rulemaking. 

1.2	 OVERVIEW OF STANDARDS FOR RESIDENTIAL CLOTHES DRYERS 

AND ROOM AIR CONDITIONERS 

The Energy Policy and Conservation Act (EPCA) of 1975, Pub. L. 94-163 (42 United 

States Code (U.S.C.) 6291–6309), established an energy conservation program for major 

household appliances. The National Energy Conservation Policy Act of 1978 (NECPA), Pub. L. 

95-619, amended EPCA to add Part Ca of Title III (42 U.S.C. 6311–6317), which established an 

energy conservation program for certain industrial equipment. Additional amendments to EPCA 

give DOE the authority to regulate the energy efficiency of several products, including 

residential clothes dryers and room air conditioners—the products that are the focus of this 

document. The amendments to EPCA in the National Appliance Energy Conservation Act of 

1987 (NAECA), Pub. L. 100-12, established energy conservation standards for room air 

conditioners, as well as requirements for determining whether these standards should be 

amended. (42 U.S.C. 6295(c) and (g)) 

DOE published draft data sheets containing energy-savings potentials for all covered 

products in October 2005 as part of its fiscal year 2006 schedule-setting process. These data 

sheets summarized the following in table format: (1) the potential energy savings from 

regulatory action in cumulative quads from 2010 to 2035, (2) the potential economic benefits or 

burdens, (3) the potential environmental or energy security benefits, (4) the status of required 

changes to test procedures, (5) other regulatory actions, (6) recommendations by interested 

parties, (7) evidence of market-driven or voluntary efficiency improvements, (8) regulatory 

issues, and (9) the 2005 priority. However, DOE had completed the calculations for residential 

clothes dryers and room air conditioners in previous years. Therefore, the following sections cite 

the appropriate fiscal year’s priority-setting activities for which DOE completed the energy 

savings calculations for each product. 

a Part C has been redesignated Part A-1 in the United States Code for editorial reasons. 

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NAECA established prescriptive standards for residential clothes dryers, requiring gas 

clothes dryers not to be equipped with constant burning pilots, and further required that DOE 

conduct two cycles of rulemakings to determine if more stringent standards are justified.b (42 

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

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

the new standards became effective on May 14, 1994. 56 FR 22250. DOE initiated a second 

standards rulemaking for residential clothes dryers by publishing an advance notice of proposed 

rulemaking (ANOPR) in the Federal Register on November 14, 1994. 59 FR 56423. However, 

pursuant to the priority-setting process outlined in the July 15, 1996, “Procedures, Interpretations 

and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer 

Products”c (the “Process Rule”), DOE classified the standards rulemaking for residential clothes 

dryers as a low priority for its fiscal year 1998 priority-setting process. As a result, DOE 

suspended the standards rulemaking activities for them. 

As reported, DOE’s draft data sheets for the fiscal year 2006 schedule-setting process 

included an updated analysis suggesting that amended standards for residential clothes dryers 

would have an energy savings potential ranging from 1.6 to 4.8 quadrillion British thermal units 

(Btu), or “quads,” for electric clothes dryers and an energy savings potential of 0.06 quads for 

gas clothes dryers.d DOE based the low- and high-potential energy savings estimates for electric 

clothes dryers on the use of microwave and heat pump technologies, respectively. DOE is 

unaware of any commercially available microwave dryers that are currently for sale in any 

country. There are at least four manufacturers of heat pump dryers in Europe and Japane, but 

DOE is unaware of any such models on the market in the United States. 

NAECA established performance standards for room air conditioners that became 

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

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

1994, DOE published in the Federal Register a notice of proposed rulemaking (NOPR) for 

b DOE defines “electric clothes dryer” under EPCA as “a cabinet-like appliance designed to dry fabrics in a tumbletype drum with forced air circulation. The heat source is electricity and the drum and blower(s) are driven by an 

electric motor(s).” 10 CFR 430.2. Gas clothes dryers would have a similar definition, but the heat source would be 

gas. 

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

d DOE based these estimates on the 2003 prioritization analysis, with a small adjustment for the 2010–2035 

timeframe. 

e Paul Roggema, “Sustainability in Home Appliances,” Appliance Magazine European Edition, May 2007, p. 5. 

Available online at: http://www.appliancemagazine.com/editorial.php?article=1747&zone=208&first=1. 

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

conditioner,’ which is powered by a single phase electric current and which is an encased assembly designed as a 

unit for mounting in a window or through the wall for the purpose of providing delivery of conditioned air to an 

enclosed space. It includes a prime source of refrigeration and may include a means for ventilating and heating.” 10 

CFR 430.2. 

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several products, including room air conditioners. 59 FR 10464. As a result of the Process Rule, 

DOE suspended activities to finalize standards for room air conditioners. DOE subsequently 

resumed rulemaking activities related to room air conditioners, and, on September 24, 1997, 

DOE published a final rule establishing an updated set of performance standards, with an 

effective date of October 1, 2000. 62 FR 50122. 

As reported in DOE’s draft data sheets for the fiscal year 2006 schedule-setting process, 

amended standards for room air conditioners would be expected to have an energy savings 

potential ranging from 0.8 to 1.5 quads.g The low- and high-potential energy savings estimates 

corresponded to efficiency increases of 10 and 20 percent, respectively. 

1.3 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS 

Under EPCA, when DOE is studying new or amended standards, it must consider, to the 

greatest extent practicable, the following seven factors (42 U.S.C. 6295 (o)(2)(B)(i)): 

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. 

Other statutory requirements are set forth in 42 U.S.C. 6295 (o)(1)–(2)(A), (2)(B)(ii)– 

(iii), and (3)–(4) and 42 U.S.C. 6316(e). 

g DOE based these energy savings estimates on an updated analysis of room air conditioners it conducted for its 

2005 priority setting. The spreadsheet is available from the DOE Building Technologies Program, Appliances and 

Commercial Equipment Standards website at: 

www.eere.energy.gov/buildings/appliance_standards/docs/2006_schedule_setting_spreadsheets.zip 

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

setting energy conservation standards. Through formal public notifications (i.e., Federal Register 

notices), DOE actively encourages the participation and interaction of all stakeholders during the 

comment period in each stage of the rulemaking. Beginning with the framework document and 

during subsequent comment periods, interactions among stakeholders provide a balanced 

discussion of the information that is required for the standards rulemaking. 

Before DOE determines whether or not to adopt a proposed energy conservation 

standard, it must first solicit comments on the proposed standard. (42 U.S.C. 6313(a)(6)(B)(i)) 

Any new or amended standard must be designed to achieve significant additional conservation of 

energy and be technologically feasible and economically justified. (42 U.S.C. 6313(a)(6)(A)) To 

determine whether economic justification exists, DOE must review comments on the proposal 

and determine that the benefits of the proposed standard exceed its burdens to the greatest extent 

practicable, weighing the seven factors listed above. (42 U.S.C. 6295 (o)(2)(B)(i)) 

After the publication of the framework document, the energy conservation standards 

rulemaking process involves three additional, formal public notices, which DOE publishes in the 

Federal Register. The first of the rulemaking notices is a NOPM, which is designed to publicly 

vet the models and tools used in the preliminary rulemaking and to facilitate public participation 

before the NOPR stage. The second notice is the NOPR, which presents a discussion of 

comments received in response to the NOPM and the preliminary analyses and analytical tools; 

analyses of the impacts of potential amended energy conservation standards on consumers, 

manufacturers, and the Nation; DOE’s weighting of these impacts of amended energy 

conservation standards; and the proposed energy conservation standards for each product. The 

third notice is the final rule, which presents a discussion of the comments received in response to 

the NOPR; the revised analyses; DOE’s weighting of these impacts; the amended energy 

conservation standards DOE is adopting for each product; and the effective dates of the amended 

energy conservation standards. 

In October 2007, DOE published a notice of public meeting and availability of the 

framework document. 10 CFR 430 (October 9, 2007) The framework document, Rulemaking 

Framework Document for Residential Clothes Dryers and Room Air Conditioners, describes the 

procedural and analytical approaches DOE anticipated using to evaluate the establishment of 

amended energy conservation standards for these products. This document is available at: 

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

mework.pdf. 

Subsequently, DOE held a public meeting on October 24, 2007, (“October 2007 public 

meeting”) to discuss procedural and analytical approaches to the rulemaking. In addition, DOE 

used the public meeting to inform and facilitate involvement of interested parties in the 

rulemaking process. The analytical framework presented at the public meeting described the 

different analyses, such as the engineering analysis and the consumer economic analyses (i.e., 

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the life-cycle cost (LCC) and payback period (PBB) analyses), the methods proposed for 

conducting them, and the relationships among the various analyses. 

Table 1.3.1 Analyses Under the Process Rule 

Preliminary Analyses NOPR Final Rule 

Market and technology assessment Revised preliminary analyses Revised NOPR analyses 

Screening analysis Life-cycle cost sub-group 

analysis 

Engineering analysis Manufacturer impact analysis 

Energy use determination Utility impact analysis 

Markups for equipment price 

determination 

Environmental assessment 

Life-cycle cost and payback period 

analysis 

Employment impact analysis 

Shipments analysis Regulatory impact analysis 

National impact analysis 

Preliminary manufacturer impact analysis 

During the October 2007 public meeting, interested parties commented about numerous 

issues relating to each one of the analyses listed in Table 1.3.1. Comments from interested parties 

submitted during the framework document comment period elaborated on the issues raised 

during the public meeting. DOE attempted to address these issues during its preliminary analyses 

and summarized the comments and DOE’s responses in chapter 2 of the preliminary TSD. 

As part of the information gathering and sharing process, DOE organized and held 

interviews with manufacturers of the residential clothes dryers and room air conditioners 

considered in this rulemaking as part of the engineering analysis. DOE selected companies that 

represented production of all types of products, ranging from small to large manufacturers, and 

included the Association of Home Appliance Manufacturers (AHAM) member companies. DOE 

had four objectives for these interviews: (1) solicit manufacturer feedback on the draft inputs to 

the engineering analysis; (2) solicit feedback on topics related to the preliminary manufacturer 

impact analysis; (3) provide an opportunity, early in the rulemaking process, to express 

manufacturers’ concerns to DOE; and (4) foster cooperation between manufacturers and DOE. 

DOE incorporated the information gathered during the engineering interviews with 

manufacturers into its engineering analysis (chapter 5) and the preliminary manufacturer impact 

analysis (chapter 12). Following the publication of the preliminary analyses and the NOPM 

public meeting, DOE intends to hold additional meetings with manufacturers as part of the 

consultative process for the manufacturer impact analysis conducted during the NOPR phase of 

the rulemaking. 

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DOE developed spreadsheets for the engineering, LCC, PBP, and national impact 

analyses for each product. For each product, DOE developed an LCC spreadsheet that calculates 

the LCC and PBP at various energy efficiency levels. DOE also developed a national impact 

analysis spreadsheet that calculates the national energy savings (NES) and national net present 

values (NPVs) at various energy efficiency levels. This spreadsheet includes a model that 

forecasts the impacts of amended energy conservation standards at various levels on product 

shipments. All of these spreadsheets are available on the DOE website for residential clothes 

dryers and the DOE website for room air conditioners: 

(http://www1.eere.energy.gov/buildings/appliance_standards/residential/clothes_dryers.html, 

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

1.4 STRUCTURE OF THE DOCUMENT 

This preliminary TSD outlines the analytical approaches used in this rulemaking. The 

TSD consists of fourteen chapters, an environmental assessment, a regulatory impact analysis, 

and appendices. 

Chapter 1	 Introduction: provides an overview of the appliance standards program 

and how it applies to this rulemaking, and outlines the structure of the 

document. 

Chapter 2	 Analytical Framework: describes the rulemaking process. 

Chapter 3	 Market and Technology Assessment: characterizes the market for the 

considered products and the technologies available for increasing 

product efficiency. 

Chapter 4	 Screening Analysis: identifies all the design options that improve 

efficiency of the considered products, and determines which technology 

options are viable for consideration in the engineering analysis. 

Chapter 5	 Engineering Analysis: discusses the methods used for developing the 

relationship between increased manufacturer price and increased 

efficiency. 

Chapter 6	 Markups to Determine Product Cost: discusses the methods used for 

establishing markups for converting manufacturer prices to customer 

product costs. 

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Chapter 7	 Energy Use Determination: discusses the process used for generating 

energy-use estimates for the considered products as a function of 

standard levels. 

Chapter 8	 Life-Cycle Cost and Payback Period Analysis: discusses the effects of 

standards on individual customers and users of the products and 

compares the LCC and PBP of products with and without higher 

efficiency standards. 

Chapter 9	 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher efficiency standards, including how 

product purchase decisions are economically influenced and how DOE 

models this relationship with econometric equations. 

Chapter 10	 National Impact Analysis: Discusses the methods used for forecasting 

national energy consumption and national economic impacts based on 

annual product shipments and estimates of future product energy 

efficiency distributions in the absence and presence of amended energy 

conservation standards. 

Chapter 11	 Life-Cycle Cost Subgroup Analysis: discusses the effects of standards 

on different subgroups of consumers and compares the LCC and PBP of 

products with and without higher efficiency standards for these 

consumers. 

Chapter 12	 Manufacturer Impact Analysis: discusses the effects of standards on the 

finances and profitability of product manufacturers. 

Chapter 13	 Utility Impact Analysis: discusses the effects of standards on electric 

and gas utilities. 

Chapter 14	 Employment Impact Analysis: discusses the effects of standards on 

national employment. 

Environmental Assessment for Residential Clothes Dryers and Room Air Conditioners: 

discusses the effects of standards on three pollutants—sulfur dioxide 

(SO2), nitrogen oxides (NOx), and mercury—as well as carbon 

emissions. 

Regulatory Impact Analysis for Residential Clothes Dryers and Room Air Conditioners: 

discusses the impact of non-regulatory alternatives to efficiency 

standards. 

Appendix 5A	 AHAM Data Request Sheets 

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Appendix 5B Data Submissions 

Appendix 5C Engineering Questionnaires 

Appendix 5D Room Air Conditioner Engineering Data 

Appendix 6A Equipment Price Markup Data 

Appendix 7A RECS 2005 Variables and Values 

Appendix 7B CBECS 2003 Variables and Values 

Appendix 7C LCC Energy Use Calculations 

Appendix 7D Weather and Temperature Parameters 

Appendix 8A User Instructions for LCC and PBP Spreadsheets 

Appendix 8B Uncertainty and Variability 

Appendix 8C Lifetime Distributions 

Appendix 8D Distributions Used for Discount Rates 

Appendix 8E Technical Aspects of the Tariff-Based Approach for Room Air 

Conditioner Energy Prices 

Appendix 8F Development of Monthly Allocation Factors for Residential Baseline 

Energy Use 

Appendix 8G Rebuttable Payback Analysis Results 

Appendix 8H Determination of Base-case Efficiency Distributions 

Appendix 9A User Instructions for Shipments and National Energy Savings 

Spreadsheet Model 

Appendix 9B National Energy Savings and Net Present Value Using Alternative 

Energy Price Scenarios 

Appendix 12A Preliminary MIA Questionnaire 

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