APPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTE RVIEW GUIDE

TABLE OF CO NTENTS

12A.1 RESIDENTIAL DEHUMIDI FIERS

................................ ................................ ............. 1

12A

- iAPPENDIX 12A. MANUFACTURER IMPACT ANALYSIS INTERVIEW G UIDE

12A.1 RESIDENTIAL DEHUMIDI FIERS



## Residential Dehumidifier Rulemaking Manufacturer Impact Analysis Interview Guide for

Residential Dehumidifiers

August 8 , 2013

12A

- 1QUESTIONS FOR ENGINE ERING 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 “base line” 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 consid er 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:

12A

- 2Level 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

B aseline 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 (whole

home) 1.93 2.06 2.5 3.50

3 Maximum

Available (whole

home) 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. U nits with 75

– 185 pints/day capacity must have an E F of at least 2.80 liters/kWh, while d ehumidifiers 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 b ase 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 th e whole

- home product class is specified as the DOE standard effe ctive 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 th at 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

- 4 5.00 pints/day dehumidifier ( 1. 5 0 EF ) to efficiency lev el 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 sel ected?

8. Which design changes are associated with converting a baseline portable 45 .01

- 54 .00 pints/day dehumidifier ( 1. 6 0 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

- 7 5.00 pints/day dehumidifier ( 1. 7 0 EF ) to efficiency level 1 (the ENERGY STAR level (1.85

12A

- 3EF))? To efficiency level 2 (2.10 EF)? To the m aximum 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 convertin g 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 Par t 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 ap propriate 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 d o 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 c haracteristics that would impact costs of repair and

maintenance?

12A

- 4PRELIMINARY 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 cha nged 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 manufacturin g 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?

12A

- 53.4 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 Profita bility

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 percent age 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 corresp onding 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?

12A

- 65.3 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 du e 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?

12A

- 7