APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE

TABLE OF CONTENTS

12A.1 RESIDENTIAL DEHUMIDIFIERS .............................................................................1

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APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE

12A.1 RESIDENTIAL DEHUMIDIFIERS

Residential Dehumidifier Rulemaking 

Manufacturer Impact Analysis Interview Guide for 

Residential Dehumidifiers

August 8, 2013

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QUESTIONS FOR ENGINEERING ANALYSIS 

AND PRELIMINARY 

MANUFACTURER IMPACT ANALYSIS

DOE would like to confirm information on the incremental costs of increasing product efficiency 

by understanding the design options involved in the efficiency improvement. 

1. Which design features impacting energy use are generally incorporated into a “baseline” 

dehumidifier in the following product classes:

a. Portable, 35.00 pints/day or less?

b. Portable, 35.01 to 45.00 pints/day?

c. Portable, 45.01 to 54.00 pints/day?

d. Portable, 54.01 to 75.00 pints/day?

e. Portable, greater than 75.00 pints/day?

f. Whole-home?

2. What are the typical costs associated with the major components of the baseline 

dehumidifiers in each of these product classes (e.g., compressors, blowers, heat 

exchangers, controls)?

3. Are there other product classes that DOE should consider? Should DOE consider 

combining or splitting any of these product classes?

4. DOE is proposing to analyze the following efficiency levels for a subset of the proposed 

product classes that represent the greatest number of available models. Please note that 

some of these levels are different than those proposed in the Framework Document, due 

to the recent introductions of new models to the market and the elimination of older 

models:

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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 1.80** 2.50†

1 ENERGY 

STAR* 1.85 1.85 1.85 2.80

2

Maximum 

Available/ 

Gap Fill 

(wholehome)

1.93 2.06 2.5 3.50

3

Maximum 

Available

(wholehome)

1.93 2.06 2.5 4.2

* 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. 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 DOE standard for units with 54.01–75.00 pints/day is EF = 1.70. However, there are an insufficient number 

of models at this level on which to base an analysis. DOE is considering analyzing EF = 1.80 as the baseline for this 

class because 58% of available units in this product class are at that level.

† 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.

5. Do you agree with the proposed efficiency levels? If not, can you suggest appropriate 

values?

6. If you believe that other portable dehumidifier product classes should be analyzed, can 

you suggest baseline, max-tech, and if necessary, gap fill efficiency levels for those 

product classes?

7. Which design changes are associated with converting a baseline portable 35.01-45.00 

pints/day dehumidifier (1.50 EF) to efficiency level 1 (1.62 EF)? To efficiency level 2 

(1.85 EF)? To the maximum available level (1.93 EF)? Are these design changes 

comparable for portable dehumidifiers with capacities of 35.00 pints/day or less? What 

are the costs of the individual design options selected?

8. Which design changes are associated with converting a baseline portable 45.01-54.00 

pints/day dehumidifier (1.60 EF) to efficiency level 1 (1.70 EF)? To efficiency level 2 

(1.85 EF)? To the maximum available level (2.06 EF)? What are the costs of the 

individual design options selected?

9. Which design changes are associated with converting a baseline portable 54.01-75.00 

pints/day dehumidifier (1.70 EF) to efficiency level 1 (the ENERGY STAR level (1.85 

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EF))? To efficiency level 2 (2.10 EF)? To the maximum available level (2.47 EF)? Are 

these design changes comparable for portable dehumidifiers with capacities greater than 

75.00 pints/day? What are the costs of the individual design options selected?

10. Which design changes are associated with converting a baseline whole-home 

dehumidifier (2.50 EF) to efficiency level 1 (the ENERGY STAR level for 75 to 185 

pints/day (2.80 EF))? To efficiency level 2 (3.50 EF)? To the maximum available level 

(4.17 EF)? Are these design changes comparable to those used for portable units with 

capacity greater than 75 pints/day? What are the costs of the individual design options 

selected?

11. Do you believe that the DOE dehumidifier test procedure that will be in effect at the time 

of any new dehumidifier standards (10 CFR Part 430, Subpart B, Appendix X1) is 

appropriate for measuring the energy use of whole-home dehumidifiers? If not, can you 

suggest an alternative test method?

12. Do you believe that the test conditions of Appendix X1 (80 °F dry-bulb temperature, 60% 

RH) are appropriate for measuring dehumidifier performance? Should other test 

conditions be included? If so, which ones for portable dehumidifiers? For whole-home 

dehumidifiers? Can you comment on the test burden associated with multiple test 

conditions? 

13. How do your portable dehumidifier units sense the need for a defrost cycle? What is the 

range of energy use during the defrost cycle?

14. Does your company collect consumer usage information that can be provided in detail or 

summary?

15. What is the typical lifetime for your different dehumidifier products?

16. For whole-home dehumidifiers:

a. How do repair and maintenance costs change as a function of the expected 

lifetime?

b. How do repair and maintenance costs change with changing energy efficiency?

c. Are there any other characteristics that would impact costs of repair and 

maintenance?

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PRELIMINARY MANUFACTURER IMPACT ANALYSIS TOPICS

1 Issues

1.1 What are the key issues for your company regarding this dehumidifier rulemaking?

2 Shipments – Historical Trends and Future Projections

2.1 When did your company begin manufacturing portable and/or whole home dehumidifiers?

2.2 What is your company’s approximate market share in each of the product classes? 

2.3 How has the distribution of efficiencies for your dehumidifier shipments changed over 

time?

2.4 How was your market share affected by the standards which became effective on October 

1, 2012? How might this be different for future amended standards?

2.5 How would you expect shipments to change for the industry as a whole as a function of

future amended standards and why?

2.6 How do you see the dehumidifier market changing absent amended energy conservation 

standards? Do projected changes in climate, (e.g. higher summer temperatures, increasing 

severity of storms, etc.) play a role in shaping this market?

2.7 Looking at price/cost effects only, how would you expect shipments to change for a 25%, 

50%, 100%, or 200% manufacturer price/cost increase?

3 Conversion Costs

3.1 What level and type of capital expenditures and investments in product development and 

testing would you anticipate to make at higher standard levels? Please describe what they 

are and provide your best estimate of their respective magnitudes.

3.2 Do you manufacture products domestically? If so, what fraction of your production is 

performed domestically? If not, do you manufacture products overseas in your own 

factories, or do you OEM from other product manufacturers?

3.3 How would the imposition of amended energy conservation standards affect capacity 

utilization and manufacturing assets at your domestic production facilities? Would a new 

standard result in stranded capital assets? Would any facilities be closed or downsized? 

Added or upgraded?

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3.4 How might a future amended standard impact product innovation?

3.5 At what efficiency levels do you expect to (address those that are applicable):

• Retire lower-efficiency platforms (and how many)?

• Close current manufacturing plants rather than upgrading them to make higher-efficiency 

dehumidifiers (e.g. moving production to new facilities, out-sourcing, ceasing operations 

altogether)? 

• Require the development of a “clean sheet” product platform to meet higher efficiency 

levels?

• Transition from domestic production to importing or rebranding foreign-made products?

4 Product Mix and Profitability

4.1 How would your company’s product mix and marketing strategy change with future 

amended standards?

4.2 Would the current percentage of shipments at the ENERGY STAR level for residential 

dehumidifiers be the same under amended standards? Did the percentage of shipments at 

the ENERGY STAR level change when the current standard and ENERGY STAR criteria 

took effect? How might amended standards impact the ENERGY STAR program, and 

consequently your firm?

4.3 What distribution channels are used from the manufacturer to the retail outlet for portable 

units and whole-home dehumidifiers? What is the share of product going through each 

distribution channel?

4.4 Generally how would new product standards impact your customer mix, distribution 

channels, and corresponding profit margins?

4.5 What is the current and historical approximate percentage of shipments (i.e., market share) 

for each product, or more specifically, for each product class, for each efficiency level?

5 Market Shares and Industry Consolidation

5.1 In the absence of new standards (excluding those that took effect in October 2012), do you 

expect any industry consolidation?

5.2 How would amended standards affect your ability to compete?

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5.3 Could amended standards disproportionately advance or harm the competitive positions of 

some firms? In particular, are there any small businesses that would be disproportionately 

harmed?

5.4 Do any firms hold intellectual property that would effectively prevent other firms’ 

products from meeting higher energy conservation standards?

5.5 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups?

5.6 Beyond price and energy efficiency, could amended standards result in products that will 

be more or less desirable to consumers due to changes in product functionality, utility, or 

other features?

6 Cumulative Regulatory Burden

6.1 Are there recent or impending regulations on your specific product or other products that 

you manufacture that impose a cumulative burden on the industry?

6.2 If so, what is the total expected impact of those other regulations?

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