[Federal Register Volume 80, Number 169 (Tuesday, September 1, 2015)]
[Proposed Rules]
[Pages 52850-52933]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-20218]
[[Page 52849]]
Vol. 80
Tuesday,
No. 169
September 1, 2015
Part II
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for Battery
Chargers; Proposed Rule
Federal Register / Vol. 80, No. 169 / Tuesday, September 1, 2015 /
Proposed Rules
[[Page 52850]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EERE-2008-BT-STD-0005]
RIN 1904-AB57
Energy Conservation Program: Energy Conservation Standards for
Battery Chargers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Supplemental notice of proposed rulemaking.
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SUMMARY: The Energy Policy and Conservation Act of 1975, as amended
(``EPCA'' or in context, ``the Act''), prescribes energy conservation
standards for various consumer products and certain commercial and
industrial equipment, including battery chargers. EPCA also requires
the U.S. Department of Energy (``DOE'' or, in context, ``the
Department'') to determine whether Federal energy conservation
standards for a particular type of product or equipment would be
technologically feasible and economically justified, and save a
significant amount of energy. On March 27, 2012, DOE published a notice
of proposed rulemaking (``NOPR'') to establish energy conservation
standards for battery chargers. DOE received comments suggesting
changes to DOE's proposed approach. To this end, this supplemental
notice of proposed rulemaking (``SNOPR'') updates and revises DOE's
prior analysis by considering, among other things, the impacts
attributable to standards issued by the California Energy Commission
(CEC), along with accompanying data included in the CEC's compliance
database. This notice also announces a public meeting to receive
comment on these proposed standards and associated analyses and
results.
DATES: Comments regarding the likely competitive impact of the proposed
standard should be sent to the Department of Justice contact listed in
the ADDRESSES section before October 1, 2015.
DOE will hold a public meeting on September 15, 2015 from 9 a.m. to
4 p.m., in Washington, DC. The meeting will also be broadcast as a
webinar. See section VII, Public Participation, for webinar
registration information, participant instructions, and information
about the capabilities available to webinar participants.
DOE will accept comments, data, and information regarding this
SNOPR before and after the public meeting, but no later than November
2, 2015. See section VII, Public Participation, for details.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue SW.,
Washington, DC 20585.
Any comments submitted must identify the SNOPR on Energy
Conservation Standards for Battery Chargers, and provide docket number
EE-2008-BT-STD-0005 and/or regulatory information number (RIN) 1904-
AB57. Comments may be submitted using any of the following methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: [email protected]. Include the docket
number and/or RIN in the subject line of the message. Submit electronic
comments in WordPerfect, Microsoft Word, PDF, or ASCII file format, and
avoid the use of special characters or any form of encryption.
3. Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Office, Mailstop EE-5B, 1000 Independence Avenue
SW., Washington, DC 20585-0121. If possible, please submit all items on
a compact disc (CD), in which case it is not necessary to include
printed copies.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Office, 950 L'Enfant Plaza SW., Suite
600, Washington, DC 20024. Telephone: (202) 586-2945. If possible,
please submit all items on a CD, in which case it is not necessary to
include printed copies.
Written comments regarding the burden-hour estimates or other
aspects of the collection-of-information requirements contained in this
proposed rule may be submitted to Office of Energy Efficiency and
Renewable Energy through the methods listed above and by email to
[email protected].
No telefacsimilies (faxes) will be accepted. For detailed
instructions on submitting comments and additional information on the
rulemaking process, see section VII of this document (Public
Participation).
Docket: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at www.regulations.gov.
All documents in the docket are listed in the www.regulations.gov
index. However, some documents listed in the index may not be publicly
available, such as those containing information that is exempt from
public disclosure,
A link to the docket Web page can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx?productid=84. This Web page contains a link to the docket
for this notice on the www.regulations.gov site. The
www.regulations.gov Web page contains simple instructions on how to
access all documents, including public comments, in the docket. See
section VII, ``Public Participation,'' for further information on how
to submit comments through www.regulations.gov.
EPCA requires the Attorney General to provide DOE a written
determination of whether the proposed standard is likely to lessen
competition. The U.S. Department of Justice Antitrust Division invites
input from market participants and other interested persons with views
on the likely competitive impact of the proposed standard. Interested
persons may contact the Division at [email protected]
before October 1, 2015. Please indicate in the ``Subject'' line of your
email the title and Docket Number of this rulemaking notice.
FOR FURTHER INFORMATION CONTACT: Mr. Jeremy Dommu, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, EE-5B, 1000 Independence Avenue SW., Washington,
DC 20585-0121. Telephone: (202) 586-9870. Email:
[email protected].
Mr. Michael Kido, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 586-8145. Email: [email protected].
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact Ms. Brenda Edwards at (202) 586-2945 or by email:
[email protected]
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary
A. Efficiency Distributions
1. 2012 NOPR Efficiency Distributions
2. SNOPR Efficiency Distributions
B. Benefits and Costs to Consumers
C. Impact on Manufacturers
D. National Benefits and Costs
E. Conclusion
II. Introduction
A. Authority
[[Page 52851]]
B. Background
1. Current Standards
2. History of Standards Rulemaking for Battery Chargers
III. General Discussion
A. Test Procedure
B. Product Classes and Scope of Coverage
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
2. Rebuttable Presumption
IV. Methodology and Discussion
A. Market and Technology Assessment
1. Products Included in this Rulemaking
2. Market Assessment
3. Product Classes
4. Technology Assessment
B. Screening Analysis
C. Engineering Analysis
1. Representative Units
2. Battery Charger Efficiency Metrics
3. Calculation of Unit Energy Consumption
4. Battery Charger Candidate Standard Levels
5. Test and Teardowns
6. Manufacturer Interviews
7. Design Options
8. Cost Model
9. Battery Charger Engineering Results
10. Scaling of Battery Charger Candidate Standard Levels
D. Markups Analysis
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analyses
1. Product Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Repair and Maintenance Costs
6. Product Lifetime
7. Discount Rates
8. Sectors Analyzed
9. Base Case Market Efficiency Distribution
10. Compliance Date
11. Payback Period Inputs
G. Shipments Analysis
1. Shipment Growth Rate
2. Product Class Lifetime
3. Forecasted Efficiency in the Base Case and Standards Cases
H. National Impacts Analysis
1. Product Price Trends
2. Unit Energy Consumption and Savings
3. Unit Costs
4. Repair and Maintenance Cost per Unit
5. Energy Prices
6. National Energy Savings
7. Discount Rates
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Manufacturer Production Costs
2. Product and Capital Conversion Costs
3. Comments from Interested Parties Related to Battery Chargers
4. Manufacturer Interviews
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
2. Social Cost of Other Air Pollutants
M. Utility Impact Analysis
N. Employment Impact Analysis
O. Marking Requirements
P. Reporting Requirements
V. Analytical Results
A. Trial Standards Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
2. Economic Impact on Manufacturers
3. National Impact Analysis
4. Impact on Utility and Performance of the Products
5. Impact on Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Other Factors
8. Summary of National Economic Impacts
C. Conclusions
1. Benefits and Burdens of TSLs Considered for Battery Chargers
2. Annualized Benefits and Costs of the Proposed Standards
3. Stakeholder Comments on Standards Proposed in NOPR
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description on Estimated Number of Small Entities Regulated
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap and Conflict with Other Rules and
Regulations
4. Significant Alternatives to the Proposed Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared General Statements For
Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Summary
Title III, Part B \1\ of the Energy Policy and Conservation Act of
1975 (``EPCA'' or in context, ``the Act''), Public Law 94-163 (42
U.S.C. 6291-6309, as codified), established the Energy Conservation
Program for Consumer Products Other Than Automobiles.\2\ These products
include battery chargers, the subject of this document.
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\1\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
\2\ All references to EPCA in this document refer to the statute
as amended through the American Energy Manufacturing Technical
Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).
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Pursuant to EPCA, any new or amended energy conservation standard
must be designed to achieve the maximum improvement in energy
efficiency that is technologically feasible and economically justified.
(42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must
result in significant conservation of energy. (42 U.S.C. 6295(o)(3)(B))
EPCA also provides that not later than 6 years after issuance of any
final rule establishing or amending a standard, DOE must publish either
a notice of determination that standards for the product do not need to
be amended, or a notice of proposed rulemaking including new proposed
energy conservation standards. (42 U.S.C. 6295(m)(1))
DOE had previously proposed to establish new energy conservation
standards for battery chargers in March 2012. See 77 FR 18478 (March
27, 2012). Since the publication of that proposal, the State of
California finalized new energy conservation standards for battery
chargers sold within that State. See 45Z Cal. Reg. 1663, 1664 (Nov. 9,
2012) (summarizing proposed regulations and their final effective
dates). Those new standards were not factored into DOE's analysis
supporting its initial battery charger proposal. To assess whether
DOE's proposal would satisfy the requirements under 42 U.S.C. 6295, DOE
revisited its analysis in light of these new California standards. As a
result, DOE is proposing new energy conservation standards for battery
chargers. The revised proposal would provide a set of maximum annual
energy consumption levels expressed as a function of battery energy.
These proposed standards are shown in Table I-1.
These new standards, if adopted, would apply to all products listed
in Table I-1 and manufactured in, or imported into, the United States
starting on the date corresponding to two years after the publication
of the final rule for this rulemaking.
[[Page 52852]]
Table I-1--Proposed Energy Conservation Standards for Battery Chargers
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Proposed standard as a function of battery
Product class Product class description energy (kWh/yr)
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1.................................... Low-Energy, Inductive 3.04
Connection.
2.................................... Low-Energy, Low-Voltage <4V.. 0.1440 * Ebatt + 2.95
3.................................... Low-Energy, Medium-Voltage 4- For Ebatt <10Wh, 1.42 kWh/y
10 V. Ebatt >=10 Wh,
0.0255 * Ebatt + 1.16
4.................................... Low-Energy, High-Voltage >10V 0.11 * Ebatt + 3.18
5.................................... Medium-Energy, Low-Voltage For Ebatt < 19 Wh,
<20 V. 1.32 kWh/yr
For Ebatt >= 19 Wh,
0.0257 * Ebatt + .815
6.................................... Medium-Energy, High-Voltage For Ebatt < 18 Wh
>=20 V. 3.88 kWh/yr
For Ebatt >= 18 Wh
0.0778 * Ebatt + 2.4
7.................................... High-Energy.................. 0.0502 * Ebatt + 4.53
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A. Efficiency Distributions
To evaluate the potential impacts of standards, DOE develops a base
case efficiency forecast, which represents DOE's estimate of the future
state of the market with respect to efficiency if energy conservation
standards for the units covered under this rulemaking are not adopted.
DOE estimated the efficiency distributions for the base year 2013 in
the original battery charger NOPR (published March 27, 2012), and
updated the distributions based on new market conditions for the base
year 2018 in today's SNOPR.
1. 2012 NOPR Efficiency Distributions
In the battery charger NOPR that was published March 27, 2012, DOE
determined the base case efficiency distribution using test data from
224 models, which enabled application-specific efficiency distributions
to be developed for most product classes. For some product classes,
there were insufficient test data, and the efficiency distributions
were based on manufacturer interviews. DOE further assumed that the
influence of two battery charger programs active at the time (ENERGY
STAR and EU Ecodesign requirements) would shift some of the historical
market share away from baseline efficiency to more efficient CSLs. In
January 2012, the CEC standards on battery chargers were announced with
an effective date of February 1, 2013. To account for this
announcement, DOE assumed that the fraction of battery chargers sold in
California (assumed to equal California's share of US GDP, or 13%)
would shift away from baseline efficiency to CSLs that approximated CEC
standard levels. The market change was assumed to be a ``roll-up'',
such that the market responds to standards by improving those products
that do not meet the standards to the standard level, but no higher,
while the products that were already as or more efficient than the
standard remain unaffected. No further changes in the base-case
efficiency distributions were assumed to occur after the first year of
the analysis.
The following table summarizes the efficiency distribution
assumptions for each product class in the 2012 NOPR analysis. For
reference, the table also includes the Unit Energy Consumption (UEC) of
the representative unit defining each CSL from the NOPR engineering
analysis (see section IV.C.1 and IV.C.2), and estimated shipments in
2018 from the NOPR shipments analysis.
Table I-2--Base Case 2012 NOPR Estimated Efficiency Distributions in 2013 \a\
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Estimated shipments
Product class CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 in 2018
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1..................................... Efficiency Distribution.. 78% 11% 11% 0% N/A 16,150,369
UEC...................... 8.73 6.1 3.04 1.29 N/A
2..................................... Efficiency Distribution.. 18% 22% 57% 3% 0% 266,339,577
UEC...................... 8.66 6.47 2.86 1.03 0.81
3..................................... Efficiency Distribution.. 17% 62% 21% 0% N/A 24,664,587
UEC...................... 11.9 4.68 0.79 0.75 N/A
4..................................... Efficiency Distribution.. 9% 39% 52% 0% N/A 65,163,723
UEC...................... 37.73 9.91 4.57 3.01 N/A
5..................................... Efficiency Distribution.. 28% 52% 7% 13% N/A 5,204,768
UEC...................... 84.6 56.09 29.26 15.35 N/A
6..................................... Efficiency Distribution.. 36% 29% 22% 13% N/A 667,039
UEC...................... 120.6 81.7 38.3 16.79 N/A
7..................................... Efficiency Distribution.. 44% 57% 0% N/A N/A 225,271
UEC...................... 255.05 191.74 131.44 N/A N/A
8..................................... Efficiency Distribution.. 50% 40% 10% 0% N/A 69,745,891
UEC...................... 0.9 0.66 0.24 0.19 N/A
9..................................... Efficiency Distribution.. 25% 50% 25% N/A N/A 10,249,869
UEC...................... 0.79 0.26 0.13 N/A N/A
10.................................... Efficiency Distribution.. 87% 0% 0% 13% N/A 8,556,487
UEC...................... 19.27 6.13 4 1.5 N/A
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\a\ This information was taken from DOE's NOPR that was issued on March 27, 2012.
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2. SNOPR Efficiency Distributions
For the SNOPR analysis considered in today's action, DOE assumed
that the CEC standards, effective since February 1, 2013, had moved the
market not just in California, but nationally as well. To reach this
conclusion, DOE solicited stakeholder comments through a Request for
Information published on March 26, 2013, conducted additional
manufacturer interviews, and performed its own examination of the
efficiency of products sold nationally. In response to the RFI, many
commenters indicated that there was evidence that the market had
accepted the CEC standards and that technology improvements were made
to meet the CEC standards. DOE found products available for sale in
physical locations outside of California and available for sale online
that met CEC standards, and had the accompanying CEC efficiency mark on
them. Finally, additional manufacturer interviews supported the view
that the majority of products sold in California (and thus meeting CEC
standards) were sold nationally as well.
Therefore, DOE re-developed its efficiency distribution analysis,
and based it on the CEC database of certified small battery chargers
(downloaded in November 2014 and containing 12652 unique models). Each
model was assigned an estimated product class and application based off
its battery characteristics. Application-specific efficiency
distributions were then developed using the reported energy performance
for each model in that application. If an application had less than 20
identified models, it was assigned the efficiency distribution of the
overall product class. Due to slight variations between CEC and DOE
metrics, products were conservatively assigned to the higher CSL (in
order to not overstate savings) when their UECs were within 5% of the
next highest CSL compliance line compared to the distance between the
compliance lines of the higher and lower CSLs.
The SNOPR analysis acknowledges, however, that units not complying
with CEC standards can still be sold outside of California, but assumed
the percentage of such units is small. For this analysis, DOE
conservatively assumed 5% of units sold nationally do not meet CEC
standards. To account for this, each application's efficiency
distribution was multiplied by 95%, and then 5% was added to the CSL
below the CEC approximate CSL. These became the base case efficiency
distributions shown in the table below. No further changes in the base-
case efficiency distributions were assumed to occur after the first
year of the analysis. It is important to note that the CSLs were
redefined in the SNOPR analysis, and do not perfectly match those in
the NOPR analysis. This was done based on additional testing conducted
for some product classes and to have a CSL that is a closer
approximation to the CEC standard levels. For reference, the table
below also lists the tested UECs defining each CSL from the SNOPR
engineering analysis and the estimated shipments in 2018 from the SNOPR
shipments analysis.
Table I-3--Base Case SNOPR Estimated Efficiency Distributions in 2018
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Estimated shipments
Product class CSL 0 CSL 1 CSL 2 CSL 3 CSL 4 in 2018
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1..................................... Efficiency Distribution.. 7% 56% 33% 4% N/A 15,772,035
UEC...................... 8.73 6.1 3.04 1.29 N/A
2..................................... Efficiency Distribution.. 9% 42% 9% 15% 25% 400,052,285
UEC...................... 5.33 3.09 1.69 1.58 1.11
3..................................... Efficiency Distribution.. 6% 35% 2% 58% N/A 27,088,679
UEC...................... 3.65 1.42 0.74 0.7 N/A
4..................................... Efficiency Distribution.. 6% 8% 12% 74% N/A 80,146,173
UEC...................... 12.23 5.38 3.63 3.05 N/A
5..................................... Efficiency Distribution.. 0% 5% 95% 0% N/A 4,717,743
UEC...................... 88.1 58.3 21.39 9.45 N/A
6..................................... Efficiency Distribution.. 0% 5% 95% 0% N/A 668,489
UEC...................... 120.71 81.82 33.53 16.8 N/A
7..................................... Efficiency Distribution.. 80% 20% 0% N/A N/A 238,861
UEC...................... 255.05 191.74 131.44 N/A N/A
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8..................................... Efficiency Distribution..
UEC......................
9..................................... Efficiency Distribution.. No longer in scope
UEC......................
10.................................... Efficiency Distribution..
UEC......................
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To support the assumption that 95% of the national market meets CEC
standard levels, DOE examined the top-selling products for various BC
applications at several national online and brick & mortar retailers
(with an online portal). These represent products sold not just in
California, but available nationally. DOE focused its search on the
top-selling 20 products (separately for each retailer) in applications
with the highest shipments. DOE also looked at products in a variety of
product classes. The applications examined cover over 50% of all
battery charger shipments. If the battery charger model number was
found in the CEC's database of certified products, or if the product
was available for sale or pick-up in a physical store in California,
then the product was assumed to meet CEC standard levels. Over 90% of
products in each application examined met CEC standard levels (these
results are lower bounds since battery charger model numbers were not
always available). These results are therefore consistent with DOE's
assumption that 95% of the national market for battery chargers meets
the CEC standards. The table below summarizes the results of DOE's
market examination.
[[Page 52854]]
Table I-4--Summary of DOE Market Examination of CEC Units by Application
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Percentage of
Percentage of models examined
Application Product class total BC Retailers examined * in cec database
shipments in or sold in
application (%) California (%)
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Smartphones...................... 2 21 Amazon, Best Buy, 100
Sears.
Media Tablets.................... 2 8 Amazon, Best Buy, 93
Sears.
MP3 Players...................... 2 8 Amazon, Best Buy, 93
Sears.
Notebook Computers............... 4 8 Amazon, Best Buy, 93
Sears.
Digital Cameras.................. 2 6 Amazon, Best Buy, 97
Sears.
Power Tools (includes DIY and 2, 3, 4 2 Amazon, Home Depot, 90
professional). Sears.
Toy Ride-On Vehicles............. 3, 5 1 Walmart, Toys R Us.. 93
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B. Benefits and Costs to Consumers
Table I-5 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of battery chargers, as measured by the
average life-cycle cost (``LCC'') savings and the simple payback period
(``PBP'').\3\ The average LCC savings are positive for all product
classes, and the PBP is less than the average lifetime of battery
chargers, which is estimated to be between 3.5 and 9.7 years, depending
on product class (see section IV.F.5). For comparative purposes, Table
I-5 also presents the results from the NOPR for battery chargers. See
77 FR 18478 (March 27, 2012).
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\3\ The average LCC savings are measured relative to the base-
case efficiency distribution, which depicts the market in the
compliance year in the absence of standards (see section IV.F.9).
The simple PBP, which is designed to compare specific efficiency
levels, is measured relative to the baseline model (see section
IV.F.11).
Table I-5--Impacts of Proposed Energy Conservation Standards on Consumers of Battery Chargers
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Average LCC savings Simple payback period (years) Average
Product class ---------------------------------------------------------------- lifetime
NOPR (2010$) SNOPR (2013$) NOPR SNOPR (years)
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PC1--Low E, Inductive........... 1.52 0.71 1.7 1.5 5.0
PC2--Low E, Low Voltage......... 0.16 0.07 0.5 0.6 4.0
PC3--Low E, Medium Voltage...... 0.35 0.08 3.9 0.8 4.9
PC4--Low E, High Voltage........ 0.43 0.11 3.0 1.4 3.7
PC5--Medium E, Low Voltage...... 33.79 0.84 0.0 2.7 4.0
PC6--Medium E, High Voltage..... 40.78 1.89 0.0 1.1 9.7
PC7--High E..................... 38.26 51.06 0.0 0.0 3.5
PC 8--DC-DC, <9V Input.......... 3.04 .............. 0.0 .............. ..............
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Note: As described in section IV.A.3 of this notice, the standards proposed in this SNOPR no longer consider
product classes 8 and 10. Products that were found in product class 8 of the NOPR analysis were redistributed
among other product classes for the SNOPR, and product class 10 was removed from consideration. Therefore, for
comparison between the NOPR and SNOPR analyses, the results for product class 8 are included in the table
above, while results for product class 10 are excluded.
DOE's analysis of the impacts of the proposed standards on
consumers is described in section IV.F of this notice.
C. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the base year through the end of the
analysis period (2015 to 2047). Using a real discount rate of 9.1
percent, DOE estimates that the INPV for manufacturers of battery
chargers in the base case is $79,904 million in 2013$. Under the
proposed standards, DOE expects that manufacturers may lose up to 0.7
percent of the INPV, which is approximately -$529 million.
Additionally, based on DOE's interviews with the domestic manufacturers
of battery chargers, DOE does not expect any plant closings or
significant loss of employment.
DOE's analysis of the impacts of the proposed standards on
manufacturers is described in section IV.J of this notice.
D. National Benefits and Costs \4\
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\4\ All monetary values in this section are expressed in 2013
dollars and, where appropriate, are discounted to 2015.
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DOE's analyses indicate that the proposed energy conservation
standards would save a significant amount of energy. Relative to the
base case without amended standards, the lifetime energy savings for
battery chargers purchased in the 30-year period that begins in the
anticipated year of compliance with the new standards (2018-2047)
amount to 0.170 quadrillion Btu (quads).\5\ This represents a savings
of 11.2 percent relative to the energy use of these products in the
base case (i.e. without standards).
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\5\ A quad is equal to 10 \15\ British thermal units (Btu).
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The cumulative net present value (NPV) of total consumer costs and
savings of the proposed standards ranges from $0.6 billion (at a 7-
percent discount rate) to $1.2 billion (at a 3-percent discount rate).
This NPV expresses the estimated total value of future operating-cost
savings minus the estimated increased product costs for battery
chargers purchased in 2018-2047.
In addition, the proposed standards for battery chargers would have
significant environmental benefits. DOE estimates that the proposed
standards would result in cumulative greenhouse gas (GHG) emission
reductions of approximately 10.45 million metric tons
[[Page 52855]]
(Mt) \6\ of carbon dioxide (CO2), 8.92 thousand tons of
sulfur dioxide (SO2), 15.41 thousand tons of nitrogen oxides
(NOX), 44.8 thousand tons of methane, 0.137 thousand tons of
nitrous oxide (N2), and 0.027 tons of mercury (Hg).\3\ The
cumulative reduction in CO2 emissions through 2030 amounts
to 4.3 Mt, which is equivalent to the emissions resulting from the
annual electricity use of approximately half a million homes.
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\6\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO2 are presented in short tons. 3
DOE calculated emissions reductions relative to the base case, which
reflects key assumptions in the Annual Energy Outlook 2014 (AEO2014)
Reference case, which generally represents current legislation and
environmental regulations for which implementing regulations were
available as of October 31, 2013.
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The value of the CO2 reductions is calculated using a
range of values per metric ton of CO2 (otherwise known as
the Social Cost of Carbon, or ``SCC'') developed by a Federal
interagency process.\7\ The derivation of the SCC values is discussed
in section IV.M. Using discount rates appropriate for each set of SCC
values (see Table I-6), DOE estimates that the net present monetary
value of the CO2 emissions reductions (not including
CO2 equivalent emissions of other gases with global warming
potential) is between $0.084 billion and $1.114 billion, with a value
of $0.362 billion using the central SCC case represented by $40.5/t in
2015. DOE also estimates the present monetary value of the
NOX emissions reduction is $13.65 million at a 7-percent
discount rate, and $24.43 million at a 3-percent discount rate.\8\
Table I-6 summarizes the national economic benefits and costs
expected to result from the proposed standards for battery chargers.
---------------------------------------------------------------------------
\7\ Technical Update of the Social Cost of Carbon for Regulatory
Impact Analysis Under Executive Order 12866. Interagency Working
Group on Social Cost of Carbon, United States Government. May 2013;
revised November 2013. (Available at: http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.)
\8\ DOE is currently investigating valuation of avoided
SO2 and Hg emissions.
Table I-6--Summary of National Economic Benefits and Costs of Proposed
Energy Conservation Standards for Battery Chargers (TSL 2) *
------------------------------------------------------------------------
Present value
Category (billion Discount rate
2013$) (%)
------------------------------------------------------------------------
Benefits
------------------------------------------------------------------------
Consumer Operating Cost Savings........ 0.7 7
1.4 3
CO2 Reduction Monetized Value ($12.0/t 0.1 5
case) **..............................
CO2 Reduction Monetized Value ($40.5/t 0.4 3
case) **..............................
CO2 Reduction Monetized Value ($62.4/t 0.6 2.5
case) **..............................
CO2 Reduction Monetized Value ($119/t 1.1 3
case) **..............................
NOX Reduction Monetized Value (at 0.01 7
$2,684/ton) **........................
0.02 3
Total Benefits [dagger]................ 1.1 7
1.8 3
------------------------------------------------------------------------
Costs
------------------------------------------------------------------------
Consumer Incremental Installed Costs... 0.1 7
0.2 3
------------------------------------------------------------------------
Total Net Benefits
------------------------------------------------------------------------
Including Emissions Reduction Monetized *1.0 7
Value[dagger].........................
1.6 3
------------------------------------------------------------------------
* This table presents the costs and benefits associated with battery
chargers shipped in 2018-2047. These results include benefits to
consumers which accrue after 2047 from the products purchased in 2018-
2047. The results account for the incremental variable and fixed costs
incurred by manufacturers due to the standard, some of which may be
incurred in preparation for the rule.
** The CO2 values represent global monetized values of the SCC, in
2013$, in 2015 under several scenarios of the updated SCC values. The
first three cases use the averages of SCC distributions calculated
using 5%, 3%, and 2.5% discount rates, respectively. The fourth case
represents the 95th percentile of the SCC distribution calculated
using a 3% discount rate. The SCC time series incorporate an
escalation factor. The value for NOx is the average of high and low
values found in the literature.
[dagger] Total Benefits for both the 3% and 7% cases are derived using
the series corresponding to average SCC with 3-percent discount rate
($40.5/t case).
Table I-7--Summary of National Economic Benefits and Costs of Energy
Conservation Standards Proposed in the NOPR for Battery Chargers
------------------------------------------------------------------------
Present value
Category (billion Discount rate
2010$) (%)
------------------------------------------------------------------------
Benefits
------------------------------------------------------------------------
Consumer Operating Cost Savings......... 3.815 7
7.007 3
CO2 Reduction Monetized Value ($4.9/t 0.208 5
case) *................................
CO2 Reduction Monetized Value (at $22.3/ 1.025 3
t case) *..............................
CO2 Reduction Monetized Value (at $36.5/ 1.720 2.5
t case) *..............................
CO2 Reduction Monetized Value (at $67.6/ 3.127 3
t case) *..............................
[[Page 52856]]
NOX Reduction Monetized Value (at $2,537/ 0.036 7
ton) *.................................
0.065 3
Total Benefits **....................... 4.876 7
8.097 3
------------------------------------------------------------------------
Costs
------------------------------------------------------------------------
Consumer Incremental Installed Costs -1.435 7
[Dagger]...............................
-2.402 3
------------------------------------------------------------------------
Net Benefits/Costs
------------------------------------------------------------------------
Including Emissions Reduction Monetized 6.311 7
Value **...............................
10.498 3
------------------------------------------------------------------------
Note: As described in section IV.A.3 of this notice, the standards
proposed in this SNOPR no longer consider product classes 8 and 10.
Products that were found in product class 8 of the NOPR analysis were
redistributed among other product classes for the SNOPR, and product
class 10 was removed from consideration. Therefore, for comparison
between the NOPR and SNOPR analyses, the results for product class 8
are included in the table above, while results for product class 10
are excluded.
* These values represent global values (in 2010$) of the social cost of
CO2 emissions in 2010 under several scenarios. The values of $4.9,
$22.3 and $36.5 per ton are the averages of SCC distributions
calculated using 5%, 3%, and 2.5% discount rates, respectively. The
value of $67.6 per ton represents the 95th percentile of the SCC
distribution calculated using a 3% discount rate. The value for NOX
(in 2010$) is the average of the low and high values used in DOE's
NOPR analysis.
** Total Benefits and Net Benefits/Costs for both the 3% and 7% cases
utilize the central estimate of social cost of CO2 emissions
calculated at a 3% discount rate, which is equal to $22.3/ton in 2010
(in 2010$).
[Dagger] Consumer Incremental Installed Costs represent the total
present value (in 2010$) of costs borne by consumers due to increased
manufacturing costs from efficiency improvements. The incremental
product costs for battery chargers are negative because of an assumed
shift in technology from linear power supplies to switch mode power
for the larger battery chargers in product classes 5, 6, and 7. For
more details, see chapter 5 of the NOPR Technical Support Document.
For comparative purposes, Table I-7 summarizes the national
economic benefits and costs for the standards proposed in the March 27,
2012, NOPR for battery chargers shipped in 2013-2042. For the
comparison between the NOPR and SNOPR analyses, products that were
found in product class 8 of the NOPR analysis were redistributed among
other product classes for the SNOPR, and product class 10 was removed
from consideration in the SNOPR. As the CEC standards were effective
since February 1, 2013, DOE did not specifically consider the NPV of
costs and benefits of achieving the CEC efficiency levels in the 2012
NOPR for the California market. For the SNOPR, DOE assumed that the CEC
standards had moved the market not just in California, but for the
remainder of the country. DOE therefore only considered the NPV of
costs and benefits of going beyond the where the market efficiency
levels had moved in response to the CEC standards, across the entire
U.S. See 77 FR 18478 (March 27, 2012).
The benefits and costs of the today's proposed standards, for
products sold in 2018-2047, can also be expressed in terms of
annualized values. The annualized monetary values are the sum of (1)
the annualized national economic value of the benefits from consumer
operation of products that meet the new standards (consisting primarily
of operating cost savings from using less energy, minus increases in
product purchase prices and installation costs, which is another way of
representing consumer NPV), and (2) the annualized monetary value of
the benefits of emission reductions, including CO2 emission
reductions.\9\
---------------------------------------------------------------------------
\9\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2015, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(e.g., 2020 or 2030), and then discounted the present value from
each year to 2015. The calculation uses discount rates of 3 and 7
percent for all costs and benefits except for the value of
CO2 reductions, for which DOE used case-specific discount
rates, as shown in Table I.3. Using the present value, DOE then
calculated the fixed annual payment over a 30-year period, starting
in the compliance year, which yields the same present value.
---------------------------------------------------------------------------
Although combining the values of operating savings and
CO2 emission reductions provides a useful perspective, two
issues should be considered. First, the national operating cost savings
are domestic U.S. consumer monetary savings that occur as a result of
market transactions, whereas the value of CO2 reductions is
based on a global value. Second, the assessments of operating cost
savings and CO2 savings are performed with different methods
that use different time frames for analysis. The national operating
cost savings is measured for the lifetime of battery chargers shipped
in 2018-2047. Because CO2 emissions have a very long
residence time in the atmosphere,\10\ the SCC values after 2050 reflect
future climate-related impacts resulting from the emission of
CO2 that continue beyond 2100.
---------------------------------------------------------------------------
\10\ The atmospheric lifetime of CO2 is estimated of
the order of 30-95 years. Jacobson, MZ (2005). ``Correction to
`Control of fossil-fuel particulate black carbon and organic matter,
possibly the most effective method of slowing global warming,''' J.
Geophys. Res. 110. pp. D14105.
---------------------------------------------------------------------------
Estimates of annualized benefits and costs of the proposed
standards are shown in Table I-8. The results under the primary
estimate are as follows. Using a 7-percent discount rate for benefits
and costs other than CO2 reduction, for which DOE used a 3-
percent discount rate along with the SCC series corresponding to a
value of $40.5/ton in 2015, the cost of the standards in this rule is
$9 million per year in increased equipment costs, while the estimated
annual benefits are $68 million per year in reduced equipment operating
costs, $20 million in CO2 reductions, and $1.26 million in
reduced NOX emissions. In this case, the net benefit amounts
to $80 million per year. Using a 3-percent discount rate for all
benefits and costs and the SCC series corresponding to a value of
$40.5/ton in 2015, the estimated cost of the proposed standards is $10
million per year in increased equipment costs, while the
[[Page 52857]]
estimated annual benefits are $75 million per year in reduced operating
costs, $20 million in CO2 reductions, and $1.32 million in
reduced NOX emissions. In this case, the net benefit amounts
to $86 million per year.
For comparative purposes, Table I-9 presents the annualized results
from the March 27, 2012, NOPR for battery chargers shipped in 2013-
2042. For the comparison between the NOPR and SNOPR analyses, products
that were found in product class 8 of the NOPR analysis were
redistributed among other product classes for the SNOPR, and product
class 10 was removed from consideration in the SNOPR. As the CEC
standards were effective since February 1, 2013, DOE did not
specifically consider the annualized costs and benefits of achieving
the CEC efficiency levels in the 2012 NOPR for the California market.
For the SNOPR, DOE assumed that the CEC standards had moved the market
not just in California, but for the remainder of the country. DOE
therefore only considered the annualized costs and benefits of going
beyond where the market efficiency levels had moved in response to the
CEC standards, across the entire U.S. See 77 FR 18478 (March 27, 2012).
Table I-8--Annualized Benefits and Costs of Proposed Energy Conservation Standards for Battery Chargers (TSL 2)
----------------------------------------------------------------------------------------------------------------
(Million 2013$/year)
-----------------------------------------------------------
Discount rate (%) Low net benefits High net benefits
Primary estimate * estimate * estimate *
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings. 7................. 68................ 68................ 69
3................. 75................ 74................ 76
CO2 Reduction Monetized Value 5................. 6................. 6................. 6
($12.0/t case) *.
CO2 Reduction Monetized Value 3................. 20................ 20................ 20
($40.5/t case) *.
CO2 Reduction Monetized Value 2.5............... 28................ 28................ 28
($62.4/t case) *.
CO2 Reduction Monetized Value 3................. 60................ 60................ 60
($119/t case) *.
NOX Reduction Monetized Value 7................. 1.26.............. 1.26.............. 1.26
(at $2,684/ton) **. 3................. 1.32.............. 1.32.............. 1.32
Total Benefits [dagger]..... 7 plus CO2 range.. 76 to 130......... 75 to 130......... 76 to 131
7................. 89................ 89................ 90
3 plus CO2 range.. 82 to 136......... 82 to 136......... 83 to 138
3................. 96................ 95................ 97
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Consumer Incremental Product 7................. 9................. 9................. 6
Costs. 3................. 10................ 10................ 6
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Total [dagger].................. 7 plus CO2 range.. 66 to 120......... 66 to 120......... 70 to 124
7................. 80................ 79................ 84
3 plus CO2 range.. 73 to 127......... 72 to 126......... 77 to 132
3................. 86................ 86................ 91
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with battery chargers shipped in 2018-2047.
These results include benefits to consumers which accrue after 2047 from the products purchased in 2018-2047.
The results account for the incremental variable and fixed costs incurred by manufacturers due to the
standard, some of which may be incurred in preparation for the rule. The Primary, Low Benefits, and High
Benefits Estimates utilize projections of energy prices from the Annual Energy Outlook for 2014 (``AEO2014'')
Reference case, Low Economic Growth case, and High Economic Growth case, respectively. Additionally, the High
Benefits Estimates include a price trend on the incremental product costs.
** The CO2 values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the
updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and
2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution
calculated using a 3% discount rate. The SCC time series incorporate an escalation factor. The value for NOx
is the average of high and low values found in the literature.
[dagger] Total Benefits for both the 3% and 7% cases are derived using the series corresponding to the average
SCC with a 3-percent discount rate ($40.5/t case). In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2
range,'' the operating cost and NOX benefits are calculated using the labeled discount rate, and those values
are added to the full range of CO2 values.
Table I-9--Annualized Benefits and Costs of Energy Conservation Standards Proposed in the NOPR for Battery
Chargers
----------------------------------------------------------------------------------------------------------------
Monetized (Million 2010$/year)
-----------------------------------------------------------
Discount rate Low net benefits High net benefits
Primary estimate * estimate * estimate *
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings. 7%................ 352.0............. 335.4............. 368.6
3%................ 379.2............. 359.8............. 399.2
[[Page 52858]]
CO2 Reduction Monetized Value 5%................ 14.9.............. 14.9.............. 14.9
($4.9/t case) **.
CO2 Reduction Monetized Value 3%................ 55.5.............. 55.5.............. 55.5
($22.3/t case) **.
CO2 Reduction Monetized Value 2.5%.............. 86.3.............. 86.3.............. 86.3
($36.5/t case) **.
CO2 Reduction Monetized Value 3%................ 169.3............. 169.3............. 169.3
($67.6/t case) **.
NOX Reduction Monetized Value 7%................ 3.3............... 3.3............... 3.3
($2,537/ton) **.
3%................ 3.5............... 3.5............... 3.5
Total Benefits 7% plus CO2 range. 370.2 to 524.6.... 353.6 to 508.0.... 386.9 to 541.2
[dagger][dagger].
7%................ 410.8............. 394.2............. 427.4
3%................ 438.2............. 418.8............. 458.2
3% plus CO2 range. 397.7 to 552.1.... 378.2 to 532.6.... 417.7 to 572.0
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Consumer Incremental Product 7%................ (132.4)........... (132.4)........... (132.4)
Costs [dagger].
3%................ (130.0)........... (130.0)........... (130.0)
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Total [dagger][dagger]...... 7% plus CO2 range. 502.7 to 657.0.... 486.1 to 640.4.... 519.3 to 673.6
7%................ 543.2............. 526.6............. 559.8
3%................ 568.2............. 548.8............. 588.2
3% plus CO2 range. 527.7 to 682.0.... 508.2 to 662.6.... 547.7 to 702.0
----------------------------------------------------------------------------------------------------------------
Note: As described in section IV.A.3 of this notice, the standards proposed in this SNOPR no longer consider
product classes 8 and 10. Products that were found in product class 8 of the NOPR analysis were redistributed
among other product classes for the SNOPR, and product class 10 was removed from consideration. Therefore, for
comparison between the NOPR and SNOPR analyses, the results for product class 8 are included in the table
above, while results for product class 10 are excluded.
* The results include benefits to consumers which accrue after 2042 from the products purchased from 2013
through 2042. Costs incurred by manufacturers, some of which may be incurred prior to 2013 in preparation for
the rule, are indirectly included as part of incremental equipment costs. The Primary, Low Benefits, and High
Benefits Estimates utilize forecasts of energy prices from the AEO2010 Reference case, Low Estimate, and High
Estimate, respectively.
** The CO2 values represent global monetized values (in 2010$) of the social cost of CO2 emissions in 2010 under
several scenarios. The values of $4.9, $22.3, and $36.5 per ton are the averages of SCC distributions
calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The value of $67.6 per
ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The
value for NOX (in 2010$) is the average of the low and high values used in DOE's NOPR analysis.
[dagger] The incremental product costs for battery chargers are negative because of an assumed shift in
technology from linear power supplies to switch mode power for the larger battery chargers in product classes
5, 6, and 7. For more details, see chapter 5 of the NOPR Technical Support Document.
[dagger][dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the SCC value
calculated at a 3-percent discount rate, which is $22.3/ton in 2010 (in 2010$). In the rows labeled as ``7%
plus CO2 range'' and ``3% plus CO2 range,'' the operating cost and NOX benefits are calculated using the
labeled discount rate, and those values are added to the full range of CO2 values.
DOE's analysis of the national impacts of the proposed standards is
described in sections IV.H, IV.K and IV.L of this SNOPR.
E. Conclusion
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. DOE further notes that products
achieving these standard levels are already commercially available for
all product classes covered by this proposal. Based on the analyses
described above, DOE has tentatively concluded that the benefits of the
proposed standards to the Nation (energy savings, positive NPV of
consumer benefits, consumer LCC savings, and emission reductions) would
outweigh the burdens (loss of INPV for manufacturers and LCC increases
for some consumers).
DOE also considered more-stringent energy efficiency levels as
trial standard levels, and is still considering them in this
rulemaking. However, DOE has tentatively concluded that the potential
burdens of the more-stringent energy efficiency levels would outweigh
the projected benefits. Based on consideration of the public comments
DOE receives in response to this notice and related information
collected and analyzed during the course of this rulemaking effort, DOE
may adopt energy efficiency levels presented in this notice that are
either higher or lower than the proposed standards, or some combination
of level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority
underlying this proposed rule, as well as some of the relevant
historical background related to the establishment of standards for
battery chargers. Generally, battery chargers are power conversion
devices that transform input voltage to a suitable voltage for the
battery they are powering. A portion of
[[Page 52859]]
the energy that flows into a battery charger flows out to a battery
and, thus, cannot be considered to be consumed by the battery charger.
A. Authority
Title III, Part B of the Energy Policy and Conservation Act of
1975, as amended (``EPCA'' or in context ``the Act''), Public Law 94-
163 (42 U.S.C. 6291-6309, as codified), established the Energy
Conservation Program for Consumer Products Other Than Automobiles,\11\
a program covering most major household appliances (collectively
referred to as ``covered products'').
---------------------------------------------------------------------------
\11\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
---------------------------------------------------------------------------
Section 309 of the Energy Independence and Security Act (``EISA
2007'') amended EPCA by directing DOE to prescribe, by rule,
definitions and test procedures for the power use of battery chargers
(42 U.S.C. 6295(u)(1)), and to issue a final rule that prescribes
energy conservation standards for battery chargers or classes of
battery chargers or to determine that no energy conservation standard
is technologically feasible and economically justified. (42 U.S.C.
6295(u)(1)(E))
Pursuant to EPCA, DOE's energy conservation program for covered
products consists essentially of four parts: (1) Testing; (2) labeling;
(3) the establishment of Federal energy conservation standards; and (4)
certification and enforcement procedures. The Federal Trade Commission
(FTC) is primarily responsible for labeling, and DOE implements the
remainder of the program. Subject to certain criteria and conditions,
DOE is required to develop test procedures to measure the energy
efficiency, energy use, or estimated annual operating cost of each
covered product. (42 U.S.C. 6295(o)(3)(A) and (r)) Manufacturers of
covered products must use the prescribed DOE test procedure as the
basis for certifying to DOE that their products comply with the
applicable energy conservation standards adopted under EPCA and when
making representations to the public regarding the energy use or
efficiency of those products. (42 U.S.C. 6293(c) and 6295(s))
Similarly, DOE must use these test procedures to determine whether the
products comply with standards adopted pursuant to EPCA. (42 U.S.C.
6295(s)) The DOE test procedures for battery chargers appear at title
10 of the Code of Federal Regulations (CFR) part 430, subpart B,
appendix X.
DOE must follow specific statutory criteria for prescribing new and
amended standards for covered products. Any new or amended standard for
a covered product must be designed to achieve the maximum improvement
in energy efficiency that is technologically feasible and economically
justified. (42 U.S.C. 6295(o)(2)(A) and (3)(B)) Furthermore, DOE may
not adopt any standard that would not result in the significant
conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not
prescribe a standard: (1) for certain products, including battery
chargers, if no test procedure has been established for the product, or
(2) if DOE determines by rule that the new or amended standard is not
technologically feasible or economically justified. (42 U.S.C.
6295(o)(3)(A)-(B)) In deciding whether a proposed standard is
economically justified, DOE must determine whether the benefits of the
standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make
this determination after receiving comments on the proposed standard,
and by considering, to the greatest extent practicable, the following
seven statutory factors:
1. The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
2. The savings in operating costs throughout the estimated average
life of the covered products in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered products that are likely to result from the standard;
3. The total projected amount of energy, or as applicable, water,
savings likely to result directly from the standard;
4. Any lessening of the utility or the performance of the covered
products likely to result from 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
standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
EPCA, as codified, also contains what is known as an ``anti-
backsliding'' provision, which prevents the Secretary from prescribing
any amended standard that either increases the maximum allowable energy
use or decreases the minimum required energy efficiency of a covered
product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe a
new or amended standard if interested persons have established by a
preponderance of the evidence that the standard is likely to result in
the unavailability in the United States of any covered product type (or
class) of performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as those generally available in the United States. (42 U.S.C.
6295(o)(4))
Further, EPCA, as codified, establishes a rebuttable presumption
that a standard is economically justified if the Secretary finds that
the additional cost to the consumer of purchasing a product complying
with an energy conservation standard level will be less than three
times the value of the energy savings during the first year that the
consumer will receive as a result of the standard, as calculated under
the applicable test procedure. See 42 U.S.C. 6295(o)(2)(B)(iii).
Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when
promulgating an energy conservation standard for a covered product that
has two or more subcategories. DOE must specify a different standard
level for a type or class of products that has the same function or
intended use, if DOE determines that products within such group: (A)
Consume a different kind of energy from that consumed by other covered
products within such type (or class); or (B) have a capacity or other
performance-related feature which other products within such type (or
class) do not have and such feature justifies a higher or lower
standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-
related feature justifies a different standard for a group of products,
DOE must consider such factors as the utility to the consumer of such a
feature and other factors DOE deems appropriate. Id. Any rule
prescribing such a standard must include an explanation of the basis on
which such higher or lower level was established. (42 U.S.C.
6295(q)(2))
Federal energy conservation requirements generally supersede State
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers
of Federal preemption for particular State laws or regulations, in
accordance with the procedures and other provisions set forth under 42
U.S.C. 6297(d).
Finally, pursuant to the amendments contained in EISA 2007, any
final rule for new or amended energy conservation standards promulgated
after July 1, 2010 is required to address standby mode and off mode
energy use. (42 U.S.C. 6295(gg) (3)) Specifically, when DOE adopts a
standard for a covered product after that date, it must,
[[Page 52860]]
if justified by the criteria for adoption of standards under EPCA (42
U.S.C. 6295(o)), incorporate standby mode and off mode energy use into
a single standard, or, if that is not feasible, adopt a separate
standard for such energy use for that product. (42 U.S.C.
6295(gg)(3)(A)-(B)) DOE's current test procedures and proposed
standards for battery chargers address standby mode and off mode energy
use.
B. Background
1. Current Standards
Currently, there are no Federal energy conservation standards that
apply to battery chargers.
2. History of Standards Rulemaking for Battery Chargers
Section 135 of the Energy Policy Act of 2005, Public Law 109-58
(Aug. 8, 2005), amended sections 321 and 325 of EPCA by defining the
term ``battery charger.'' That provision also directed DOE to prescribe
definitions and test procedures related to the energy consumption of
battery chargers and to issue a final rule that determines whether to
set energy conservation standards for battery chargers or classes of
battery chargers. (42 U.S.C. 6295(u)(1)(A) and (E))
On December 8, 2006, DOE complied with the first of these
requirements by publishing a final rule that prescribed test procedures
for a variety of products. 71 FR 71340, 71365-71375. That rule, which
was codified in multiple sections of the Code of Federal Regulations
(CFR), included a definition and test procedure for battery chargers.
The test procedure for these products is found in 10 CFR part 430,
subpart B, Appendix Y (``Uniform Test Method for Measuring the Energy
Consumption of Battery Chargers'').
On December 19, 2007, Congress enacted the Energy Independence and
Security Act of 2007 (``EISA 2007''). Public Law 110-140 (Dec. 19,
2007). Section 309 of EISA 2007 amended section 325(u)(1)(E) of EPCA by
directing DOE to issue a final rule that prescribes energy conservation
standards for battery chargers or classes of battery chargers or to
determine that no energy conservation standard is technologically
feasible and economically justified. (42 U.S.C. 6295(u)(1)(E))
Finally, section 310 of EISA 2007 established definitions for
active, standby, and off modes, and directed DOE to amend its test
procedures for battery chargers to include a means to measure the
energy consumed in standby mode and off mode. (42 U.S.C.
6295(gg)(2)(B)(i)) Consequently, DOE published a final rule
incorporating standby- and off-mode measurements into the DOE test
procedure. 74 FR 13318, 13334-13336 (March 27, 2009) Additionally, DOE
amended the test procedure for battery chargers to include an active
mode measurement. 76 FR 31750 (June 1, 2011).
DOE initiated its current rulemaking effort for these products by
issuing the Energy Conservation Standards Rulemaking Framework Document
for Battery Chargers and External Power Supplies (the Framework
Document). See http://www.regulations.gov/#!documentDetail;D=EERE-2008-
BT-STD-0005-0005. The Framework Document explained the issues,
analyses, and process DOE anticipated using to develop energy
conservation standards for those products. DOE also published a notice
announcing the availability of the Framework Document, announcing a
public meeting to discuss the proposed analytical framework, and
inviting written comments concerning the development of standards for
battery chargers and external power supplies (EPSs). 74 FR 26816 (June
4, 2009). DOE held the Framework Document public meeting on July 16,
2009. Manufacturers, trade associations, environmental advocates,
regulators, and other interested parties attended the meeting and
submitted comments.
On September 15, 2010, having considered comments from interested
parties, gathered additional information, and performed preliminary
analyses for the purpose of developing potential amended energy
conservation standards for Class A EPSs and new energy conservation
standards for battery chargers and non-Class A EPSs, DOE announced a
public meeting and the availability on its Web site of a preliminary
technical support document (preliminary TSD). 75 FR 56021. The
preliminary TSD is available at: http://www.regulations.gov/#!documentDetail;D=EERE-2008-BT-STD-0005-0031. The preliminary TSD
discussed the comments DOE received at the framework stage of this
rulemaking and described the actions DOE took in response to those
comments. That document also described in detail the analytical
framework DOE used, and the content and results of DOE's preliminary
analyses. Id. at 56023-56024. DOE convened the public meeting to
discuss and receive comments on: (1) The product classes DOE analyzed,
(2) the analytical framework, models, and tools that DOE was using to
evaluate potential standards, (3) the results of the preliminary
analyses performed by DOE, (4) potential standard levels that DOE might
consider, and (5) other issues participants believed were relevant to
the rulemaking. Id. at 56021, 56024. DOE also invited written comments
on these matters. The public meeting took place on October 13, 2010.
Many interested parties participated, twelve of whom submitted written
comments during the comment period; two additional parties filed
comments following the close of the formal comment period.
After considering all of these comments, DOE published its notice
of proposed rulemaking (``NOPR''). 77 FR 18478 (March 27, 2012). DOE
also released the NOPR TSD, which incorporated the analyses DOE
conducted and accompanying technical documentation. The TSD included
the LCC spreadsheet, the national impact analysis (NIA) spreadsheet,
and the manufacturer impact analysis (MIA) spreadsheet--all of which
are available at: http://www.regulations.gov/#!documentDetail;D=EERE-
2008-BT-STD-0005-0070. In the March 2012 NOPR, DOE proposed new energy
conservation standards for battery chargers as follows:
Table II-1--NOPR Proposed Energy Conservation Standards for Battery
Chargers
------------------------------------------------------------------------
Proposed standard as
Product class Product class a function of battery
description energy (kWh/yr)
------------------------------------------------------------------------
1............................. Low-Energy, 3.04
Inductive.
2............................. Low-Energy, Low- 0.2095 * (Ebatt) +
Voltage. 5.87
3............................. Low-Energy, For Ebatt < 9.74 Wh,
Medium-Voltage. 4.68; For Ebatt >=
9.74 Wh, = 0.0933 *
(Ebatt) + 3.77
4............................. Low-Energy, High- For Ebatt < 9.71 Wh,
Voltage. 9.03; For Ebatt >=
9.71 Wh, = 0.2411 *
(Ebatt) + 6.69
5............................. Medium-Energy, For Ebatt < 355.18
Low-Voltage. Wh, 20.06; For Ebatt
>= 355.18 Wh, =
0.0219 * (Ebatt) +
12.28
6............................. Medium-Energy, For Ebatt < 239.48
High-Voltage. Wh, 30.37; For Ebatt
>= 239.48 Wh, =
0.0495 * (Ebatt) +
18.51
7............................. High-Energy...... 0.0502 * (Ebatt) +
4.53
8............................. Low-Voltage DC 0.1140 * (Ebatt) +
Input. 0.42; For Ebatt <
1.17 Wh, 0.55 kWh/yr
[[Page 52861]]
9............................. High-Voltage DC No Standard.
Input.
10a........................... AC Output, VFD For Ebatt < 37.2 Wh,
(Voltage and 2.54; For Ebatt >=
Frequency 37.2 Wh, 0.0733 *
Dependent). (Ebatt)--0.18
10b........................... AC Output, VI For Ebatt < 37.2 Wh,
(Voltage 6.18; For Ebatt >=
Independent). 37.2 Wh, 0.0733 *
(Ebatt) + 3.45
------------------------------------------------------------------------
In the March 2012 NOPR, DOE identified 24 specific issues on which
it sought the comments and views of interested parties. Id. at 18642-
18644. In addition, DOE also specifically requested comments and data
that would allow DOE to clarify certain issues and potential solutions
to address them. DOE also held a public meeting in Washington, DC, on
May 2, 2012, to receive public comments on its proposal. DOE also
received many written comments responding to the March 2012 NOPR, which
are further presented and addressed throughout this notice. All
commenters, along with their corresponding abbreviations and
organization type, are listed in Table II-2 below.
Table II-2--List of NOPR Commenters
----------------------------------------------------------------------------------------------------------------
Organization Abbreviation Organization type Comment
----------------------------------------------------------------------------------------------------------------
Actuant Electric....................... Actuant Electric......... Manufacturer............. 146
ARRIS Group, Inc....................... ARRIS Broadband.......... Manufacturer............. 90
Appliance Standards Awareness Project.. ASAP..................... Energy Efficiency 162
Advocates.
ASAP, ASE, ACEEE, CFA, NEEP, and NEEA.. ASAP, et al.............. Energy Efficiency 136
Advocates.
Association of Home Appliance AHAM..................... Industry Trade 124
Manufacturers. Association.
Brother International Corporation...... Brother International.... Manufacturer............. 111
California Building Industry CBIA..................... Industry Trade 126
Association. Association.
California Energy Commission........... California Energy State Entity............. 117
Commission.
California Investor-Owned Utilities.... CA IOUs.................. Utilities................ 138
City of Cambridge, MA.................. City of Cambridge, MA.... Local Government......... 155
Cobra Electronics Corporation.......... Cobra Electronics........ Manufacturer............. 130
Consumer Electronics Association....... CEA...................... Industry Trade 106
Association.
Delta-Q Technologies Corp.............. Delta-Q Technologies..... Manufacturer............. 113
Duracell............................... Duracell................. Manufacturer............. 109
Earthjustice........................... Earthjustice............. Energy Efficiency 118
Advocates.
ECOVA.................................. ECOVA.................... Private Entity........... 97
Energizer.............................. Energizer................ Manufacturer............. 123
Flextronics Power...................... Flextronics.............. Manufacturer............. 145
GE Healthcare.......................... GE Healthcare............ Manufacturer............. 142
Information Technology Industry Council ITI...................... Industry Trade 131
Association.
Korean Agency for Technology and Republic of Korea........ Foreign Government....... 148
Standards.
Lester Electrical...................... Lester................... Manufacturer............. 87, 139
Microsoft Corporation.................. Microsoft................ Manufacturer............. 110
Motorola Mobility, Inc................. Motorola Mobility........ Manufacturer............. 121
National Electrical Manufacturers NEMA..................... Industry Trade 134
Association. Association.
Natural Resources Defense Council...... NRDC..................... Energy Efficiency 114
Advocate.
Nebraska Energy Office................. Nebraska Energy Office... State Government......... 98
Nintendo of America Inc................ Nintendo of America...... Manufacturer............. 135
Nokia Inc.............................. Nokia.................... Manufacturer............. 132
Northeast Energy Efficiency NEEP..................... Energy Efficiency 144, 160
Partnerships. Advocate.
Panasonic Corporation of North America. Panasonic................ Manufacturer............. 120
PG&E................................... PG&E..................... Utility.................. 16
PG&E and SDG&E......................... PG&E and SDG&E........... Utilities................ 163
Philips Electronics.................... Philips.................. Manufacturer............. 128
Power Sources Manufacturers Association PSMA..................... Industry Trade 147
Association.
Power Tool Institute, Inc.............. PTI...................... Industry Trade 133
Association.
Power Tool Institute, Inc., Association PTI, AHAM, CEA........... Industry Trade 161
of Home Appliance Manufacturers, Association.
Consumer Electronics Association.
NOPR Public Meeting Transcript, various Pub. Mtg. Tr............. Public Meeting........... 104
parties.
Representatives of Various State States................... State Government......... 159
Legislatures.
Salcomp Plc............................ Salcomp Plc.............. Manufacturer............. 73
Schneider Electric..................... Schneider Electric....... Manufacturer............. 119
Schumacher Electric.................... Schumacher Electric...... Manufacturer............. 143
[[Page 52862]]
Southern California Edison............. SCE...................... Utility.................. 164
Telecommunications Industry Association TIA...................... Industry Trade 127
Association.
Wahl Clipper Corporation............... Wahl Clipper............. Manufacturer............. 153
----------------------------------------------------------------------------------------------------------------
Of particular interest to commenters was the potential interplay
between DOE's proposal and a competing proposal to establish battery
charger energy conservation standards published by the California
Energy Commission (``the CEC'') on January 12, 2012. (The CEC is
California's primary energy policy and planning agency.) The CEC
standards, which eventually took effect on February 1, 2013,\12\
created an overlap between the classes of battery chargers covered by
the CEC rule and those classes of battery chargers DOE proposed to
regulate in the March 2012 NOPR. Additionally, the standards proposed
by DOE differed when compared to the ones issued by the CEC, with some
being more stringent and others being less stringent than the CEC
standards. To better understand the impact of these standards on the
battery charger market in the U.S., DOE published a request for
information (RFI) on March 26, 2013 that sought stakeholder comment on
a variety of issues related to the CEC standards. 78 FR 18253.
---------------------------------------------------------------------------
\12\ http://www.energy.ca.gov/appliances/battery_chargers.
Table II-3--List of RFI Commenters
----------------------------------------------------------------------------------------------------------------
Organization Abbreviation Organization type Comment
----------------------------------------------------------------------------------------------------------------
AHAM, CEA, PTI, TIA Joint Comments..... AHAM, et al.............. Industry Trade 203
Association.
Alliance for Wireless Power............ ASAP..................... Energy Efficiency 196
Advocates.
ASAP, NRDC, ACEEE, CFA, NCLC, NEEA, ASAP, NRDC, ACEEE, CFA, Energy Efficiency 206
NPCC Joint Comments. NCLC, NEEA, NPCC. Advocates.
Association of Home Appliance AHAM..................... Industry Trade 202
Manufacturers. Association.
Brother International Corporation...... Brother International.... Manufacturer............. 204
California Energy Commission........... California Energy State Entity............. 199
Commission.
California IOUs........................ CA IOUs.................. Utilities................ 197
Consumer Electronics Association....... CEA...................... Industry Trade 208
Association.
Dual-Lite, a division of Hubbell Dual-Lite................ Manufacturer............. 189
Lighting.
Energizer Holdings..................... Energizer................ Manufacturer............. 213
Garmin International................... Garmin................... Manufacturer............. 194
Information Technology Industry Council ITI...................... Industry Trade 201
Association.
Ingersoll Rand (Club Car).............. Ingersoll Rand........... Manufacturer............. 195
Jerome Industries, a subsidiary of Jerome................... Manufacturer............. 191
Astrodyne.
Mercury Marine......................... Mercury.................. Manufacturer............. 212
National Marine Manufacturers NMMA..................... Industry Trade 190
Association. Association.
NEEA and NPCC.......................... NEEA and NPCC............ Industry Trade 200
Association.
P&G (Duracell)......................... Duracell................. Manufacturer............. 193
Panasonic.............................. Panasonic................ Manufacturer............. 210
Philips................................ Philips.................. Manufacturer............. 198
Power Tool Institute................... PTI...................... Industry Trade 207
Association.
Schneider Electric..................... Schneider Electric....... Manufacturer............. 211
Schumacher Electric.................... Schumacher Electric...... Manufacturer............. 192
Telecommunications Industry Association TIA...................... Industry Trade 205
Association.
----------------------------------------------------------------------------------------------------------------
Many of these RFI comments reiterated the points that commenters
made in response to the NOPR. Additionally, many commenters listed in
the table above indicated that there was evidence that the market had
accepted the CEC standards and that technology improvements were made
to meet the CEC standards at costs aligned with DOE's estimates in the
March 2012 NOPR. (See AHAM et al., No. 203 at p. 5) Some manufacturers
argued that while some of their units are CEC-compliant, they continue
to sell non-compliant units in other parts of the U.S. for various
reasons associated with cost. (See Schumacher Electric, No. 192 at p.
2) DOE has addressed these comments by updating and revising its
analysis in today's SNOPR by considering, among other things, the
impacts attributable to the standards issued by CEC. Specifically,
based on the responses to the RFI, DOE collected additional data on new
battery chargers identified in the CEC database as being compliant with
the CEC standards. These data supplemented DOE's earlier analysis from
the March 2012 NOPR. DOE's analysis and testing of units within the CEC
database showed that many battery chargers are CEC-compliant. The
teardown and economic analysis incorporating these units has also shown
that technically equivalent levels to the CEC standards are now
[[Page 52863]]
technologically feasible and economically justified for the U.S. as a
whole. Therefore, this proposal outlines standards that are technically
equivalent, or where justified, more stringent than the CEC standards.
The revisions to the analysis, which address the comments received from
stakeholders in response to DOE's RFI, are explained in the analysis
sections below and summarized in Table II-4.
In addition to updating the proposed standards to account for the
impact of the CEC standards, several other significant changes were
made while updating the proposed standards presented in the SNOPR.
While much of the analysis has been updated, the significant changes
since the NOPR are presented in Table II-4.
Table II-4--Summary of Significant Changes
------------------------------------------------------------------------
Item NOPR Changes for SNOPR
------------------------------------------------------------------------
Proposed Standard Levels
------------------------------------------------------------------------
Proposed Standard for PC1....... = 3.04............ No Change.
Proposed Standard for PC2....... = 0.2095(Ebatt) + 0.1440(Ebatt) +
5.87. 2.95.
Proposed Standard for PC3....... For Ebatt < 9.74 For Ebatt < 10Wh,
Wh, = 4.68 For = 1.42; Ebatt >=
Ebatt >= 9.74 Wh, 10 Wh,
= 0.0933(Ebatt) + 0.0255(Ebatt) +
3.77. 1.16.
Proposed Standard for PC4....... For Ebatt < 9.71 0.11(Ebatt) +
Wh, = 9.03 For 3.18.
Ebatt >= 9.71 Wh,
= 0.2411(Ebatt) +
6.69.
Proposed Standard for PC5....... For Ebatt < 355.18 For Ebatt < 19 Wh,
Wh, = 20.06 For 1.32 kWh/yr; For
Ebatt >= 355.18 Ebatt >= 19 Wh,
Wh, = 0.0257(Ebatt) +
0.0219(Ebatt) + .815.
12.28.
Proposed Standard for PC6....... For Ebatt < 239.48 For Ebatt < 18 Wh,
Wh, = 30.37 For 3.88 kWh/yr; For
Ebatt >= 239.48 Ebatt >= 18 Wh,
Wh, = 0.0778(Ebatt) +
0.0495(Ebatt) + 2.4.
18.51.
Proposed Standard for PC7....... = 0.0502(Ebatt) + No Change.
4.53.
Proposed Standard for PC8....... = 0.1140(Ebatt)+ Removed, covered
0.42 For Ebatt < under PC2
1.17 Wh, = 0.55 proposed
kWh/yr. standards.
Proposed Standard for PC9....... No Standard....... No Change.
Proposed Standard for PC10a..... For Ebatt < 37.2 Deferred to Future
Wh, = 2.54 For Rulemaking.
Ebatt >= 37.2 Wh,
= 0.0733(Ebatt)--
0.18.
Proposed Standard for PC10b..... For Ebatt < 37.2 Deferred to Future
Wh, = 6.18 For Rulemaking.
Ebatt >= 37.2 Wh,
= 0.0733(Ebatt) +
3.45.
------------------------------------------------------------------------
Changes in Analysis
------------------------------------------------------------------------
Engineering Analysis-- Combination of Used new or
Representative Units. test data and updated units in
manufacturer PC 2, PC 3, PC 4,
inputs. and PC 5, while
keeping the same
representative
units for PC 1,
PC 6, and PC 7
and same Max Tech
units for all
PCs.
Usage Profiles.................. Weighted average PC 2, PC 3, PC 4,
of application PC 5, and PC 6
specific usage. usage profiles
updated based on
new shipment data
(See Section
IV.F.3).
Efficiency Distributions........ From Market Obtained from the
Assessment. CEC's database of
Small Battery
Chargers.
------------------------------------------------------------------------
Lastly, DOE announced that it will investigate the potential
benefits and burdens of Federal efficiency standards for Computers and
Battery Backup Systems in a Framework Document \13\ published on July
11, 2014. DOE will be including uninterruptible power supplies (UPSs)
that meet the definition of a consumer product within the scope of
coverage of that rulemaking effort. Therefore, DOE will no longer
consider these products within the scope of the battery chargers
rulemaking.
---------------------------------------------------------------------------
\13\ http://www.regulations.gov/#!documentDetail;D=EERE-2014-BT-
STD-0025-0001
---------------------------------------------------------------------------
III. General Discussion
A. Test Procedure
In analyzing the products covered under this rulemaking, DOE
applied the battery charger test procedure in Appendix Y to 10 CFR part
430 subpart B. Concurrently with the publication of this SNOPR, DOE is
also publishing a Notice of Proposed Rulemaking to propose several
revisions to the battery charger test procedure. A link to the test
procedure NOPR is available at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx?productid=84. DOE advises stakeholders
to review the proposed changes to the test procedure and provide
comments to DOE as part of that separate rulemaking.
B. Product Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE
divides covered products into product classes by the type of energy
used or by capacity or other performance-related features that
justifies a different standard. In making a determination whether a
performance-related feature justifies a different standard, DOE must
consider such factors as the utility of the feature to the consumer and
other factors DOE determines are appropriate. (42 U.S.C.
6295(q))Further discussion of products covered under this proposed rule
and product classes can be found in Section IV.
C. Technological Feasibility
The following sections address the manner in which DOE assessed the
technological feasibility of the new and amended standards. Energy
conservation standards promulgated by DOE must be technologically
feasible.
1. General
In each standards rulemaking, DOE conducts a screening analysis
based on information gathered on all current technology options and
prototype designs that could improve the efficiency of the products or
equipment that are the subject of the rulemaking. As the first step in
such an analysis, DOE develops a list of technology options for
consideration in consultation with manufacturers, design engineers, and
other interested parties. DOE then determines which of those
[[Page 52864]]
means for improving efficiency are technologically feasible. DOE
generally considers technologies incorporated in commercially available
products or in working prototypes to be technologically feasible. See,
e.g. 10 CFR 430, subpart C, appendix A, section 4(a)(4)(i) (providing
that ``technologies incorporated in commercially available products or
in working prototypes will be considered technologically feasible.'').
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
Practicability to manufacture, install, or service; (2) adverse impacts
on product utility or availability; and (3) adverse impacts on health
or safety. See10 CFR part 430, subpart C, appendix A, section 4(a)(4).
Additionally, it is DOE policy not to include in its analysis any
proprietary technology that is a unique pathway to achieving a certain
efficiency level. Section IV.B of this notice discusses the results of
the screening analysis for battery chargers, particularly the designs
DOE considered, those it screened out, and those that are the basis for
the trial standard levels (TSLs) analyzed in this rulemaking. For
further details on the screening analysis for this rulemaking, see
chapter 4 of the SNOPR technical support document (TSD).
Additionally, DOE notes that it has received no comments from
interested parties regarding patented technologies and proprietary
designs that would inhibit manufacturers from achieving the energy
conservation standards contained in this proposal. At this time, DOE
believes that the proposed standard for the products covered as part of
this rulemaking will not mandate the use of any such technologies.
2. Maximum Technologically Feasible Levels
When proposing an amended standard for a type or class of covered
product, DOE must ``determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible'' for such product. (42 U.S.C. 6295(p)(1)). DOE determined the
maximum technologically feasible (``max-tech'') efficiency levels by
interviewing manufacturers, vetting their data with subject matter
experts, and presenting the results for public comment.
In preparing this proposed rule, which includes max-tech levels for
the seven product classes initially addressed in DOE's preliminary
analysis, DOE developed a means to create max-tech levels for those
classes that were previously not assigned max-tech levels. For the
product classes that DOE was previously unable to generate max-tech
efficiency levels, DOE used multiple approaches to develop levels for
these classes. During the NOPR phase, DOE solicited manufacturers for
information and extrapolated performance parameters from its best-in-
market efficiency levels. Extrapolating from the best-in-market
performance efficiency levels required an examination of the devices.
From this examination, DOE determined which design options could be
applied and what effects they would likely have on the various battery
charger performance parameters. (See Chapter 5, Section 5.4 of the
accompanying SNOPR TSD) Table III-1 below shows the reduction in energy
consumption when increasing efficiency from the baseline to the max-
tech efficiency level.
Table III-1--Reduction in Energy Consumption at Max-Tech for Battery
Chargers
------------------------------------------------------------------------
Reduction of
Max-tech unit energy
energy consumption
Product class consumption (kWh/ relative to the
yr) baseline
(percentage)
------------------------------------------------------------------------
1 (Low-Energy, Inductive)......... 1.29 85
2 (Low-Energy, Low-Voltage)....... 1.11 79
3 (Low-Energy, Medium-Voltage).... 0.70 80
4 (Low-Energy, High-Voltage)...... 3.05 75
5 (Medium-Energy, Low-Voltage).... 9.45 89
6 (Medium-Energy, High-Voltage)... 16.79 86
7 (High-Energy)................... 131.44 48
------------------------------------------------------------------------
Additional discussion of DOE's max-tech efficiency levels and
comments received in response to the NOPR analysis can be found in the
discussion of candidate standard levels (CSLs) in section IV.C.4.
Specific details regarding which design options were considered for the
max-tech efficiency levels (and all other CSLs) can be found in Chapter
5, Section 5.4 of the accompanying SNOPR TSD, which has been developed
as a stand-alone document for this SNOPR and supports all of the
standard levels proposed in this SNOPR.
D. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the products that
are the subject of this rulemaking purchased in the 30-year period that
begins in the year of compliance with any new standards (2018-2047).
The savings are measured over the entire lifetime of products purchased
in the 30-year period.\14\ DOE quantified the energy savings
attributable to each TSL as the difference in energy consumption
between each standards case and the base case. The base case represents
a projection of energy consumption in the absence of new energy
conservation standards, and considers market forces and policies that
may affect future demand for more efficient products.
---------------------------------------------------------------------------
\14\ 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 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.
---------------------------------------------------------------------------
DOE used its NIA spreadsheet model to estimate energy savings from
potential new standards for battery chargers. The NIA spreadsheet model
(described in section IV.H of this notice) calculates energy savings in
site energy, which is the energy directly consumed by products at the
locations where they are used. For electricity, DOE calculates national
energy savings on an annual basis in terms of primary energy savings,
which is the savings in the energy that is used to generate and
transmit electricity to the site. To
[[Page 52865]]
calculate primary energy savings from site electricity savings, DOE
derives annual conversion factors from data provided in the Energy
Information Administration's (EIA) most recent Annual Energy Outlook
(AEO).
In addition to primary energy savings, DOE also calculates full-
fuel-cycle (FFC) energy savings. As discussed in DOE's statement of
policy, the FFC metric includes the energy consumed in extracting,
processing, and transporting primary fuels (i.e., coal, natural gas,
petroleum fuels), and presents a more complete picture of the impacts
of energy conservation standards. 76 FR 51282 (August 18, 2011), as
amended by 77 FR 49701 (August 17, 2012). DOE's approach is based on
the calculation of an FFC multiplier for each of the energy types used
by covered products or equipment. For more information, see section
IV.H.6.
2. Significance of Savings
To adopt any new or amended standards for a covered product, DOE
must determine that such action would result in ``significant'' energy
savings. Although the term ``significant'' is not defined in the Act,
the U.S. Court of Appeals for the DC Circuit, in Natural Resources
Defense Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985),
indicated that Congress intended ``significant'' energy savings in this
context to be savings that were not ``genuinely trivial.'' The energy
savings for all of the TSLs considered in this rulemaking (presented in
section V.B.3) are nontrivial, and, therefore, DOE considers them
``significant'' within the meaning of section 325 of EPCA.
E. Economic Justification
1. Specific Criteria
EPCA provides seven factors to be evaluated in determining whether
a potential energy conservation standard is economically justified. (42
U.S.C. 6295(o)(2)(B)(i)) The following sections discuss how DOE has
addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential new standard on
manufacturers, DOE conducts a manufacturer impact analysis (MIA), as
discussed in section IV.J. DOE first uses an annual cash-flow approach
to determine the quantitative impacts. This step includes both a short-
term assessment--based on the cost and capital requirements during the
period between when a regulation is issued and when entities must
comply with the regulation--and a long-term assessment over a 30-year
period. The industry-wide impacts analyzed include: (1) Industry net
present value (INPV), which values the industry on the basis of
expected future cash flows; (2) cash flows by year; (3) changes in
revenue and income; and (4) other measures of impact, as appropriate.
Second, DOE analyzes and reports the impacts on different types of
manufacturers, including impacts on small manufacturers. Third, DOE
considers the impact of standards on domestic manufacturer employment
and manufacturing capacity, as well as the potential for standards to
result in plant closures and loss of capital investment. Finally, DOE
takes into account cumulative impacts of various DOE regulations and
other regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the
changes in life-cycle cost (LCC) and payback period (PBP) associated
with new standards. These measures are discussed further in the
following section. For consumers in the aggregate, DOE also calculates
the national net present value of the economic impacts applicable to a
particular rulemaking. DOE also evaluates the impacts of potential
standards on identifiable subgroups of consumers that may be affected
disproportionately by a standard.
b. Savings in Operating Costs Compared to Increase in Price (LCC and
PBP)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product in the
type (or class) compared to any increase in the price of, or in the
initial charges for, or maintenance expenses of, the covered product
that are likely to result from a standard. (42 U.S.C.
6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP
analysis.
The LCC is the sum of the purchase price of a product (including
its installation) and the operating expense (including energy,
maintenance, and repair expenditures) discounted over the lifetime of
the product. The LCC analysis requires a variety of inputs, such as
product prices, product energy consumption, energy prices, maintenance
and repair costs, product lifetime, and consumer discount rates. To
account for uncertainty and variability in specific inputs, such as
product lifetime and discount rate, DOE uses a distribution of values,
with probabilities attached to each value. For its LCC and PBP
analysis, DOE assumes that consumers will purchase the covered products
in the first year of compliance with amended standards. The LCC savings
for the considered efficiency levels are calculated relative to a base
case that reflects projected market trends in the absence of amended
standards. DOE's LCC and PBP analysis is discussed in further detail in
section IV.F.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for imposing an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As
discussed in section IV.H, DOE uses the NIA spreadsheet to project
national energy savings.
d. Lessening of Utility or Performance of Products
In establishing product classes, and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
standards that would not lessen the utility or performance of the
considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data
available to DOE, the standards proposed in this notice would not
reduce the utility or performance of the products under consideration
in this rulemaking. DOE received no comments that the proposed
standards for battery chargers would increase their size and reduce
their convenience, increase the length of time to charge a product,
shorten the intervals between chargers, or cause any other significant
adverse impacts on consumer utility.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider any lessening of competition, as
determined in writing by the Attorney General, that is likely to result
from proposed standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also
directs the Attorney General to determine the impact, if any, of any
lessening of competition likely to result from a standard and to
transmit such determination to the Secretary within 60 days of the
publication of a proposed rule, together with an analysis of the nature
and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE followed
this requirement after publication of the March 2012 NOPR. Although the
Department of Justice had no comments regarding the proposal, DOE will
transmit a courtesy copy of the supplemental notice and accompanying
TSD to the Attorney General. DOE will
[[Page 52866]]
make public any comments or determination provided by DOJ.
f. Need for National Energy Conservation
The energy savings from new standards are likely to provide
improvements to the security and reliability of the nation's energy
system. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy savings from the
proposed standards are likely to provide improvements to the security
and reliability of the nation's energy system. Reductions in the demand
for electricity also may result in reduced costs for maintaining the
reliability of the nation's electricity system. DOE conducts a utility
impact analysis to estimate how standards may affect the nation's
needed power generation capacity, as discussed in section IV.M.
The proposed new standards also are likely to result in
environmental benefits in the form of reduced emissions of air
pollutants and greenhouse gases associated with energy production and
use. DOE conducts an emissions analysis to estimate how potential
standards may affect these emissions, as discussed in section IV.K; the
emissions impacts are reported in section V.B.6of this notice. DOE also
estimates the economic value of emissions reductions resulting from the
considered TSLs, as discussed in section IV.L.
g. Other Factors
EPCA allows the Secretary of Energy, in determining whether a
standard is economically justified, to consider any other factors that
the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a
rebuttable presumption that an energy conservation standard is
economically justified if the additional cost to the consumer of a
product that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. DOE's LCC and PBP
analyses generate values used to calculate the effect potential new
energy conservation standards would have on the payback period for
consumers. These analyses include, but are not limited to, the 3-year
payback period contemplated under the rebuttable-presumption test. In
addition, DOE routinely conducts an economic analysis that considers
the full range of impacts to consumers, manufacturers, the nation, and
the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The
results of this analysis serve as the basis for DOE's evaluation of the
economic justification for a potential standard level (thereby
supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable presumption payback calculation
is discussed in section V.B.1.c of this proposed rule.
IV. Methodology and Discussion
This section addresses the analyses DOE performed for this
rulemaking with regard to battery chargers. Separate subsections
address each component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the
standards proposed in this document. First, DOE used a spreadsheet that
calculates the LCC and PBP of potential amended or new energy
conservation standards. Second, the national impacts analysis uses a
spreadsheet that provides shipments forecasts and calculates national
energy savings and net present value resulting from potential energy
conservation standards. Third, DOE uses the Government Regulatory
Impact Model (GRIM) to assess manufacturer impacts of potential
standards. These three spreadsheet tools are available on the docket:
http://www.regulations.gov/#!docketDetail;D=EERE-2008-BT-STD-0005.
Additionally, DOE used output from the latest version of EIA's Annual
Energy Outlook (AEO), a widely known energy forecast for the United
States, for the emissions and utility impact analyses.
A. Market and Technology Assessment
When beginning an energy conservation standards rulemaking, DOE
develops information that provides an overall picture of the market for
the products concerned, including the purpose of the products, the
industry structure, and market characteristics. This activity includes
both quantitative and qualitative assessments, based primarily on
publicly available information. The subjects addressed in the market
and technology assessment for this rulemaking include a determination
of the scope of this rulemaking; product classes and manufacturers;
quantities and types of products sold and offered for sale; retail
market trends; regulatory and non-regulatory programs; and technologies
or design options that could improve the energy efficiency of the
product(s) under examination. See Chapter 3 of the SNOPR TSD for
further detail.
1. Products Included in this Rulemaking
This section addresses the scope of coverage for this proposed rule
and details which products would be subject to the standards proposed
in this notice. The numerous comments DOE received on the scope of
these standards are also summarized and addressed in this section.
A battery charger is a device that charges batteries for consumer
products, including battery chargers embedded in other consumer
products. (42 U.S.C. 6291(32)) Functionally, a battery charger is a
power conversion device used to transform input voltage to a suitable
voltage for the battery the charger is powering. Battery chargers are
used in conjunction with other end-use consumer products, such as cell
phones and digital cameras. However, the battery charger definition
prescribed by Congress is not limited solely to products powered from
AC mains--i.e. products that plug into a wall outlet. Further, the
statutory definition encompasses battery chargers that may be wholly
embedded in another consumer product, wholly separate from another
consumer product, or partially inside and partially outside another
consumer product. While devices that meet the statutory definition are
within the scope of this rulemaking, DOE is not proposing to set
standards for all battery chargers.
With respect to the different kinds of battery chargers that are
available, DOE received a number of comments. DOE received three
comments related to battery chargers for backup batteries. ARRIS
Broadband described a broadband modem/VoIP device that contains a
backup battery that provides power to the telephone system, a primary
function, in the event of power loss and sought guidance on whether
this product would be required to comply with DOE's proposed standards.
(ARRIS Broadband, No. 90 at p.1) Brother urged DOE to exclude from its
scope those battery chargers that are used to charge batteries that
power only secondary functions of the end-use product in the event of a
power loss. Brother noted by way of example that some multifunction
devices (MFD) contain a rechargeable battery that enables the MFD to
maintain its memory and power an internal clock in the event of power
loss. Brother added that regulating battery chargers of this type would
``create significant regulatory burdens and produce insignificant
energy savings.'' (Brother International, No. 111 at p.2) Motorola
Mobility urged DOE to exclude continuous use products such as
[[Page 52867]]
answering machines, home security systems, modems, and LAN/WAN adapters
from battery standards because battery charging represents a small
fraction of the total energy use of the products. ARRIS Broadband and
Motorola Mobility also claimed that the test procedure does not provide
an adequate way to distinguish energy from battery charging from other
functions. (ARRIS Broadband, No. 90 at p.1; Motorola Mobility, No. 121
at pp. 5-6)
After evaluating these comments and examining these devices
further, particularly with respect to their test results, DOE has
tentatively decided to refrain from proposing standards for battery
chargers that are intended to charge batteries that provide backup
power, or battery chargers considered to be continuous use devices at
this time. DOE outlined several issues with testing these devices.
Since battery chargers that are typically embedded within continuous
use devices do not charge batteries as their primary function, it is
often difficult, if not impossible, to use current techniques and
technologies to consistently and reliably isolate the tested battery
charger`s energy use during testing. As a result, the test procedure
cannot be applied to these products to accurately measure the energy
use of a battery charger embedded within the product. Because of these
technical limitations, DOE has proposed that battery chargers that
provide power from the battery to a continuous use device solely during
a loss of main power would not be required to be tested under DOE's
test procedure. Because the DOE procedure cannot adequately account for
the energy usage of these kinds of devices, and DOE has been unable at
this time to develop appropriate modifications that would remedy this
limitation, battery chargers that fall into these categories cannot be
evaluated using the procedure detailed in Appendix Y. See the Test
Procedure NOPR at http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx?productid=84.
Ultimately, DOE recognizes that such battery chargers may be used
in a different manner from other battery chargers, spending nearly all
of their time in maintenance mode. Additionally, DOE believes that
testing and regulating these devices as a system, which is being
addressed in DOE's Computer and Battery Backup Systems rulemaking, is a
more appropriate venue to aaddress these devices. See 79 FR 41656 (July
17, 2014).
Motorola Mobility also commented that in-vehicle battery chargers
should not be included in the scope of this rulemaking because they do
not consume energy from the utility grid. (Motorola Mobility, No. 121
at p. 7) In examining the products identified by Motorola Mobility, DOE
observed that these devices were designed to work not only as in-
vehicle devices, but could also be plugged into AC mains. Accordingly,
in DOE's view, these devices are designed to use mains power. DOE
further notes that 42 U.S.C 6292(a) provides in part, that covered
consumer products exclude consumer products designed solely for use in
recreational vehicles and other mobile equipment. Thus, a product
designed to be exclusively used in recreational vehicles or other
mobile equipment would be excluded from being considered a covered
product while a device that is designed to be used in vehicles and on
AC mains, may be considered a covered consumer product. As discussed in
section V.B.2.f in the March 2012 NOPR, a battery charger is in Product
Class 9 if it operates using a DC input source greater than 9V, it is
unable to operate from a universal serial bus (USB) connector, and a
manufacturer does not package, recommend, or sell a wall adapter for
the device. If an in-vehicle battery charger is also capable of
operating on AC mains (via a USB or a wall adapter), then it would be
subject to the AC-DC standards based on its characteristics when
charging a battery using AC mains. DOE found that new standards for
battery charger Product Class 9 (those with DC input of greater than
9V, including all in-vehicle battery chargers) were not cost effective
for any of the evaluated standard levels. Because standards are not
economically justified, DOE is not proposing standards for such
products at this time.
a. Definition of Consumer Product
DOE received comments from a number of stakeholders seeking
clarification on the definition of a consumer product. Schneider
Electric commented that the definition of consumer product is
``virtually unbounded'' and ``provides no definitive methods to
distinguish commercial or industrial products from consumer products.''
(Schneider Electric, No. 119 at p. 2) ITI commented that a narrower
definition of a consumer product is needed to determine which state
regulations are preempted by Federal standards. (ITI, No. 131 at p. 2)
NEMA commented that the FAQ on the DOE Web site is insufficient to
resolve its members' questions. See https://www1.eere.energy.gov/buildings/appliance_standards/pdfs/cce_faq.pdf.
(NEMA, No. 134 at p. 2) These stakeholders suggested ways that DOE
could clarify the definition of a consumer product:
Adopt the ENERGY STAR battery charger definition.
Limit the scope to products marketed as compliant with the
FCC's Class B emissions limits.
Define consumer products as ``pluggable Type A Equipment
(as defined by IEC 60950-1), with an input rating of less than or equal
to 16A.''
EPCA defines a consumer product as any article of a type that
consumes or is designed to consume energy and which, to any significant
extent, is distributed in commerce for personal use or consumption by
individuals without regard to whether such article of such type is in
fact distributed in commerce for personal use or consumption by an
individual. See 42 U.S.C. 6291(1). Manufacturers are advised to use
this definition (in conjunction with the battery charger definition) to
determine whether a given device shall be subject to battery charger
standards. Consistent with these definitions, any battery charger that
is of a type that is capable of charging batteries for a consumer
product would be considered a covered product and possibly subject to
DOE's energy conservation standards, without regard to whether that
battery charger was in fact distributed in U.S. commerce to operate a
consumer product. Only battery chargers that have identifiable design
characteristics that would make them incapable of charging batteries of
a consumer product would be considered to not meet EPCA's definition of
a battery charger. DOE would consider the ability of a battery charger
to operate using residential mains power--Standard 110-120 VAC, 60 Hz
input--as an identifiable design characteristic when considering
whether a battery charger is capable of charging the batteries of a
consumer product.
b. Medical Products
In the NOPR, DOE stated that standards for battery chargers used to
power medical devices had the potential to yield energy savings. GE
Healthcare, a manufacturer of battery chargers used in medical devices,
responded to the NOPR. It gave several reasons why DOE should not apply
standards to these products. It noted that the design, manufacture,
maintenance, and post-market monitoring of medical devices are already
highly regulated by the Food and Drug Administration, and requiring
these devices to comply with energy efficiency standards would only add
to
[[Page 52868]]
these existing requirements. GE added that there are a large number of
individual medical device models, each of which must be tested along
with its component battery charger to ensure compliance with applicable
standards; redesign of the battery charger to meet DOE standards would
require that all of these models be retested and reapproved, at a
significant per-unit cost, especially for those devices that are
produced in limited quantities. (GE Healthcare, No. 142 at p. 2)
Given these concerns, DOE has reevaluated its proposal to set
energy conservation standards for medical device battery chargers.
While setting standards for these devices may yield energy savings, DOE
also wishes to avoid any action that could potentially impact their
reliability and safety. In the absence of sufficient data on this
issue, and consistent with DOE's obligation to consider such adverse
impacts when identifying and screening design options for improving the
efficiency of a product, DOE has decided to refrain from setting
standards for medical device battery chargers at this time. Similar to
the limitation already statutorily-prescribed for Class A EPSs, DOE is
proposing at this time to refrain from setting standards for those
device that require Federal Food and Drug Administration (FDA) listing
and approval as a life-sustaining or life-supporting device in
accordance with section 513 of the Federal Food, Drug, and Cosmetic Act
(21 U.S.C. 360(c)). See 42 U.S.C. 6295(o)(2)(b)(i)(VII). See also 10
CFR part 430, subpart C, appendix A, (4)(a)(4) and (5)(b)(4)
(collectively setting out DOE's policy in evaluating potential energy
conservation standards for a product).
2. Market Assessment
To characterize the market for battery chargers, DOE gathered
information on the products that use them. DOE refers to these products
as end-use consumer products or battery charger ``applications.'' This
method was chosen for two reasons. First, battery chargers are nearly
always bundled with or otherwise intended to be used with a given
application; therefore, the demand for applications drives the demand
for battery chargers. Second, because most battery chargers are not
stand-alone products, their shipments, lifetimes, usage profiles, and
power requirements are all determined by the associated application.
DOE analyzed the products offered by online and brick-and-mortar
retail outlets to determine which applications use battery chargers and
which battery charger technologies are most prevalent. The list of
applications analyzed and a full explanation of the market assessment
methodology can be found in chapter 3 of the accompanying SNOPR TSD.
While DOE identified the majority of battery charger applications,
some may not have been included in the NOPR analysis. This is due in
part because the battery chargers market is dynamic and constantly
evolving. As a result, some applications that use a battery charger
were not initially found because they either made up an insignificant
market share or were introduced to the market after the NOPR analysis
was conducted. The battery chargers for any other applications not
explicitly analyzed in the market assessment would still be subject to
the proposed standards as long as they fall into one of the battery
charger classes outlined in Section IV.A.1. That is, DOE's omission of
any particular battery charger application from its analysis is not, by
itself, an indication that the battery charger that powers that
application would not be subject to the battery chargers standards.
DOE relied on published market research to estimate base-year
shipments for all applications. In the NOPR, DOE estimated that in
2009, a total of 437 million battery chargers were shipped for final
sale in the United States. For this SNOPR, DOE conducted additional
research and updated its shipments estimates to provide shipments data
for 2011. Where more recent data were available, DOE updated the
shipments data based on the more recent shipments data collected. Where
more recent information could not be found, DOE derived the 2011
shipments value based on the 2009 estimates, and used its shipments
model as described in section IV.G.1 to project the 2009 shipments to
2011. In 2011, DOE estimated that a total of 506 million battery
chargers units were shipped.
DOE received comments from several stakeholders on the accuracy of
its shipment estimates for certain applications in the NOPR. NRDC
commented that DOE's estimate of 8 million units for toy ride-on
vehicles seemed too high, citing the fact that it was four times higher
than the estimate for remote control toy shipments. (NRDC, No. 114 at
p. 7) DOE estimated toy ride-on vehicle shipments by dividing annual
sales dollars ($1.8 billion) by the average retail price of surveyed
toy ride-on vehicles ($222.50). DOE could not find data on remote
control toys, but assumed in the NOPR that annual shipments would be
roughly equivalent to its estimate for ride-on toys (see chapter 3 of
the NOPR TSD). However, when conducting product surveys, DOE found that
a large share of remote control toys used disposable batteries.
Therefore, DOE altered its analysis and assumed that only 30% of remote
control toys utilized a battery charger compared to 100% of ride-on
toys. For the SNOPR, DOE retained the same approach and updated its
shipment estimates for remote control toys and ride-on toys to
approximately 2.2 million and 3.7 million units, respectively.
Schumacher Electric commented that DOE's estimate of 500,000 annual
auto/marine/RV battery charger shipments in 2009 was too low, stating
that they alone shipped 2.6 million units in 2011. (Schumacher
Electric, No. 143 at p. 6) DOE's estimate of 500,000 units was based on
a PG&E study (PG&E, No. 16 at p.3). Schumacher's comment did not
specify whether its 2.6 million shipments were global or domestic, or
what their market share is for auto/marine/RV battery chargers. For the
SNOPR, DOE retained the 2009 estimate based on PG&E study and used its
shipments model to estimate shipments in 2011. DOE determined that a
total of 507,427 units shipped in 2011.
Delta-Q Technologies commented that the lifetime of a golf cart (or
``golf car'') is typically 10-12 years and explained that the majority
of new golf carts are sold to commercial customers for a 3- to 4-year
lease and then sold to consumers. (Delta-Q Technologies, No. 113 at p.
1) DOE believes the lifetime estimates for these products are similar
to the 3.5 years and 6.5 years that DOE assumes for commercial and
residential users, respectively. Therefore, DOE retained the same
lifetime estimates as in NOPR.
3. Product Classes
When necessary, DOE divides covered products into classes by the
type of energy used, the capacity of the product, and any other
performance-related feature that could justify different standard
levels, such as features affecting consumer utility. (42 U.S.C.
6295(q)) DOE then conducts its analysis and considers establishing or
amending standards to provide separate standard levels for each product
class.
DOE created 11 product classes for battery chargers based on
various electrical characteristics shared by particular groups of
products. As these electrical characteristics change, so does the
utility and efficiency of the devices.
a. Battery Charger Product Classes
As described in the NOPR analysis, DOE used five electrical
characteristics to disaggregate battery charger product classes--
battery voltage, battery energy, input and output characteristics
(e.g.,
[[Page 52869]]
inductive charging capabilities),\15\ input voltage type (line AC or
low-voltage DC), and AC output. Further details on DOE's reasoning are
outlined in Chapter 3 of the SNOPR TSD.
---------------------------------------------------------------------------
\15\ Inductive charging is a utility-related characteristic
designed to promote cleanliness and guarantee uninterrupted
operation of the battery charger in a wet environment. In wet
environments, such as a bathroom where an electric toothbrush is
used, these chargers ensure that the user is isolated from mains
current by transferring power to the battery through magnetic
induction rather than using a galvanic (i.e., current carrying)
connection.
Table IV-1--Battery Charger Product Classes
----------------------------------------------------------------------------------------------------------------
Battery energy Special characteristic or
Product class No. Input/output type (Wh) battery voltage
----------------------------------------------------------------------------------------------------------------
1....................................... AC In, DC Out............. <100 Inductive Connection.
2....................................... .......................... .............. <4 V.
3....................................... .......................... .............. 4-10 V.
4....................................... .......................... .............. >10 V.
5....................................... .......................... 100-3000 <20 V.
6....................................... .......................... .............. >=20 V.
7....................................... .......................... >3000 --
8....................................... DC In, DC Out............. .............. <9 V Input.
9....................................... .......................... .............. >=9 V Input.
10a..................................... AC In, AC Out............. .............. Voltage and Frequency
Dependent.
10b..................................... .......................... .............. Voltage Independent.
----------------------------------------------------------------------------------------------------------------
In response to the NOPR analysis, Energizer and Philips argued that
the wide variety of battery charger usage patterns in Product Class 2
warranted the creation of subcategories of battery chargers based on
usage. (Energizer, No. 123 at p. 2; Philips, No. 128 at p. 5) Philips
claimed that infrequently used products would not be able to save a
significant amount of energy from improved efficiency measures. It
argued that infrequent use is a performance-related feature that
required DOE to set different standards. Neither party provided
additional data in support of its respective views. Despite these
claims, DOE has not received evidence that infrequently-used battery
chargers have any technical differences from battery chargers that are
used more often. Because there are no technical differences between
these battery chargers and the units used to represent this product
class, there is no rationale for establishing separate product classes
based on frequency of use.
DOE also received comments from Delta-Q Technologies, who observed
that there has been a shift towards high-frequency switch-mode battery
chargers in the golf cart segment, due to rising raw materials cost of
older technology and some cost reductions available due to new high
frequency switch-mode technologies. In the absence of standards, it
asserted that this trend would continue and in the next few years all
golf cart chargers would meet the proposed standards. (Delta-Q
Technologies, No. 113 at p. 1) DOE's research suggests, and public
comments submitted by Club Car responding to the March 2013 RFI express
similar concerns, that while there is a clear trend in the direction of
more efficient high-frequency switch-mode technologies, some
manufacturers are holding back on adopting this technology due to
reliability concerns. (Ingersoll Rand, No. 195 at p. 2) However, DOE
has also found that U.S. manufacturers are now offering both linear and
high-frequency switch-mode battery chargers. As a result, DOE believes
its efficiency distribution estimate and representative units for
Product Class 7 are accurate, reflecting that a portion of the market
would be based on less efficient and legacy linear technology and the
remainder would rely on switch-mode technology in 2015.
DOE also received several comments regarding Product Class 9 in
response to the NOPR analysis. NRDC and CEC argued that DOE should
regulate Product Class 9 products using the proposed Product Class 8
standards. (NRDC, No. 114 at p. 8; California Energy Commission, No.
117 at p. 28) Cobra and the Power Tool Institute (PTI) supported DOE's
proposal not to regulate products intended only for in-vehicle use
(i.e., Product Class 9). (Cobra Electronics, No. 130 at p. 9: PTI, No.
133 at p. 6) See the March 2012 NOPR TSD, Chapter 5, Sec. 5.7.15,
(explaining that Product Class 9 devices are overwhelmingly charged by
12V DC output of an automotive cigarette lighter receptacle). These
products are decidedly different than those in Product Class 2 and
Product Class 8 because they can only be used in vehicles, which is a
unique utility, and input voltage can impact battery charger
performance. However, as described in the March 2012 NOPR LCC analysis,
DOE determined that the legal requirements necessary for setting
standards for product class 9 were not met, and thus, DOE is not
proposing to regulating this product class under this proposed rule.
Finally, DOE also received comments regarding Product Classes 10a
and 10b, which are no longer within scope of this proposed rulemaking.
See section IV.A.1 above. However, NEMA, Schneider, and ITI responded
to the NOPR by suggesting that the definitions of 10a and 10b be
harmonized with the IEC 62040-3 standard definitions for universal
power supplies (``UPSs''). In this case, Product Class 10a would be
reclassified from ``non-automatic voltage regulator'' (``non-AVR'') to
``Voltage and Frequency Dependent'' (VFD) and Product Class 10a would
be reclassified as ``Voltage Independent'' (VI). Stakeholders stated
that these definitions are accepted industry wide. By making such
changes, manufacturers asserted that the scope of those battery
chargers defined as basic and AVR in the NOPR would be clarified and
concerns over scope, particularly what determines consumer grade UPSs,
would be eliminated. (NEMA, No. 134 at p. 7, 8: Schneider. Pub. Mtg.
Tr, No. 104 at p. 253: Schneider, No. 119 at p. 2: ITI, No. 131 at p.
3, 7) Schneider suggested that DOE define additional product classes
10c and 10d, where Product Class 10c should be defined as Voltage
Independent with Sinusoidal output (VI-SS) and Product Class 10d should
be defined as Voltage and Frequency Independent (VFI). (Schneider, No.
119 at p. 3)
DOE has recently proposed to remove battery chargers that provide
power
[[Page 52870]]
from a battery to a continuous use device solely during a loss of main
power from the testing requirements for battery chargers. This would
include battery chargers within Product Class 10 for which DOE had
previously proposed standards in the NOPR. As discussed below in
Section IV.A.3.b.ii., DOE is no longer proposing standards or
definitions for these battery chargers.
b. Elimination of Product Classes 8, 9,10a, and 10b
Since publishing the NOPR, DOE has conducted further market
analysis, technical analysis, and testing. As a result, DOE has chosen
to move forward with proposed standards for a smaller number of
products classes. Specifically, DOE is no longer proposing standards
for battery chargers falling into Product Classes 8, 9, 10a, and 10b in
this SNOPR. As stated above and in the NOPR, DOE determined that no
standards were warranted for Product Class 9 products and DOE received
no additional information that would alter this determination.
i. Product Class 8
DOE has determined that there are no products falling into Product
Class 8 that do not also fall into Product Class 2. DOE has also
determined that the battery chargers previously analyzed in Product
Class 8 do not technically differ from those found in Product Class 2.
Specifically, DOE analyzed battery chargers used with end use
applications such as MP3 players and mobile phones. DOE found that
these products can be used with AC to DC power supplies and are
functionally identical products found in Product Class 2. For these
reasons, DOE has combined all previously analyzed products, and related
shipments in Product Class 8 into Product Class 2. Therefore, these
products will be subject to Product Class 2 proposed standards.
ii. Product Classes 10a and 10b
DOE is considering energy conservation standards for battery backup
systems (including UPSs) and other continuous use products as part of
the Computer and Backup Battery Systems rulemaking. 79 FR 41656 By
including UPSs in the new rulemaking and analysis, DOE will no longer
be considering standards for battery chargers embedded in UPSs as part
of this rule and is not proposing standards for Product Classes 10a and
10b in this SNOPR.
DOE requests stakeholder comment on the elimination of Product
Classes 8, 9, 10a, and 10b from this SNOPR.
4. Technology Assessment
In the technology assessment, DOE identifies technology options
that appear to be feasible to improve product efficiency. This
assessment provides the technical background and structure on which DOE
bases its screening and engineering analyses. The following discussion
provides an overview of the technology assessment for battery chargers.
Chapter 3 of the SNOPR TSD provides additional detail and descriptions
of the basic construction and operation of battery chargers, followed
by a discussion of technology options to improve their efficiency and
power consumption in various modes.
a. Battery Charger Modes of Operation and Performance Parameters
DOE found that there are five modes of operation in which a battery
charger can operate at any given time--active (or charge) mode,
maintenance mode, no-battery (or standby) mode, off mode, and unplugged
mode. During active mode, a battery charger is charging a depleted
battery, equalizing its cells, or performing functions necessary for
bringing the battery to the fully charged state. In maintenance mode,
the battery is plugged into the charger, has reached full charge, and
the charger is performing functions intended to keep the battery fully
charged while protecting it from overcharge. No-battery mode involves a
battery charger plugged into AC mains but without a battery connected
to the charger. Off mode is similar to no-battery mode but with all
manual on-off switches turned off. Finally, during unplugged mode, the
battery charger is disconnected from mains and not consuming any
electrical power.\16\
---------------------------------------------------------------------------
\16\ Active mode, maintenance mode, standby mode, and off mode
are all explicitly defined by DOE in Appendix Y to Subpart B of Part
430--Uniform Test Method for Measuring the Energy Consumption of
Battery chargers.
---------------------------------------------------------------------------
For each battery charger mode of operation, DOE's battery charger
test procedure has a corresponding test that is performed that outputs
a metric for energy consumption in that mode. The tests to obtain these
metrics are described in greater detail in DOE's battery charger test
procedure. When performing a test in accordance with this procedure,
certain items play a key role in evaluating the efficiency performance
of a given battery charger--24-hour energy, maintenance mode power, no-
battery mode power, off-mode power, and unplugged mode power . (10 CFR
part 430 Appendix Y to Subpart B)
First, there is the measured 24-hour energy of a given charger.
This quantity is defined as the power consumption integrated with
respect to time of a fully metered charge test that starts with a fully
depleted battery. In other words, this is the energy consumed to fully
charge and maintain at full charge a depleted battery over a period
that lasts 24 hours or the length of time needed to charge the tested
battery plus 5 hours, whichever is longer. Next, is maintenance mode
power, which is a measurement of the average power consumed while a
battery charger is known to be in maintenance mode. No-battery (or
standby) mode power is the average power consumed while a battery
charger is in no-battery or standby mode (only if applicable). \17\
Off-mode power is the average power consumed while an on-off switch-
equipped battery charger is in off mode (i.e., with the on-off switch
set to the ``off'' position). Finally, unplugged mode power consists of
the average power consumed while the battery charger is not physically
connected to a power source. (This quantity is always 0.)
---------------------------------------------------------------------------
\17\ If the product contains integrated power conversion and
charging circuitry, but is powered through a non-detachable AC power
cord or plug blades, then no part of the system will remain
connected to mains, and standby mode measurement is not applicable.
(Section 5.11.d ``Standby Mode Energy Consumption Measurement, CFR
part 430 Appendix Y to Subpart B).
---------------------------------------------------------------------------
Additional discussion on how these parameters are derived and
subsequently combined with assumptions about usage in each mode of
operation to obtain a value for the UEC is discussed below in section
IV.C.2.
b. Battery Charger Technology Options
Since most consumer battery chargers contain an AC to DC power
conversion stage, similar to that found in an EPS, DOE examined many of
the same technology options for battery chargers as it did for EPSs in
the EPS final rule. See 79 FR 7845 (Feb. 10, 2014). The technology
options used to decrease EPS no-load power affect battery charger
energy consumption in no-battery and maintenance modes (and off mode,
if applicable), while those options used to increase EPS conversion
efficiency will affect energy consumption in active and maintenance
modes.
DOE considered many technology options for improving the active-
mode charging efficiency as well as the no-battery and maintenance
modes of battery chargers. The following list, organized by charger
type, provides technology options that DOE evaluated
[[Page 52871]]
during the NOPR and again in today's SNOPR. Although many of these
technology options could be used in both fast and slow chargers, doing
so may be impractical due to the cost and benefits of each option for
the two types of chargers. Therefore, in the list below, the options
are grouped with the charger type where they would be most practical.
Slow charger technology options include:
Improved Cores: The efficiency of line-frequency
transformers, which are a component of the power conversion circuitry
of many slow chargers, can be improved by replacing their cores with
ones made of lower-loss steel.
Termination: Substantially decreasing the charge current
to the battery after it has reached full charge, either by using a
timer or sensor, can significantly decrease maintenance-mode power
consumption.
Elimination/Limitation of Maintenance Current: Constant
maintenance current is not required to keep a battery fully charged.
Instead, the battery charger can provide current pulses to ``top off''
the battery as needed.
Elimination of No-Battery Current: A mechanical AC line
switch inside the battery charger ``cup'' automatically disconnects the
battery charger from the mains supply when the battery is removed from
the charger.
Switched-Mode Power Supply: To increase efficiency, line-
frequency (or linear) power supplies can be replaced with switched-mode
EPSs, which greatly reduce the biggest sources of loss in a line-
frequency EPS: the transformer.
Fast charger technology options include:
Low-Power Integrated Circuits: The efficiency of the
battery charger's switched-mode power supply can be further improved by
substituting low-power integrated circuit (``IC'') controllers.
Elimination/Limitation of Maintenance Current: See above.
Schottky Diodes and Synchronous Rectification: Both line-
frequency and switched-mode EPSs use diodes to rectify output voltage.
Schottky diodes and synchronous rectification can replace standard
diodes to reduce rectification losses, which are increasingly
significant at low voltage.
Elimination of No-Battery Current: See above.
Phase Control To Limit Input Power: Even when a typical
battery charger is not delivering its maximum output current to the
battery, its power conversion circuitry continues to draw significant
power. A phase control circuit, like the one present in most common
light dimmers, can be added to the primary side of the battery charger
power supply circuitry to limit input current in lower-power modes.
An in-depth discussion of these technology options can be found in
Chapter 3 of the accompanying SNOPR TSD.
B. Screening Analysis
DOE uses the following four screening criteria to determine which
design options are suitable for further consideration in a standards
rulemaking:
1. Technological feasibility. DOE considers technologies
incorporated in commercial products or in working prototypes to be
technologically feasible.
2. Practicability to manufacture, install, and service. If mass
production and reliable installation and servicing of a technology in
commercial products could be achieved on the scale necessary to serve
the relevant market at the time the standard comes into effect, then
DOE considers that technology practicable to manufacture, install, and
service.
3. Adverse impacts on product utility or product availability. If
DOE determines a technology would have a significantly adverse impact
on the utility of the product to significant subgroups of consumers, or
would result in the unavailability of any covered product type with
performance characteristics (including reliability), features, sizes,
capacities, and volumes that are substantially the same as products
generally available in the United States at the time, it will not
consider this 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 this technology further.
See generally 10 CFR part 430, subpart C, appendix A, (4)(a)(4) and
(5)(b).
For battery chargers, after considering the four criteria, DOE
screened out:
1. Non-inductive chargers for use in wet environments because of
potential adverse impacts on safety;
2. Capacitive reactance because of potential adverse impacts on
safety; and
3. Lowering charging current or increasing battery voltage because
of potential adverse impacts on product utility to consumers.
For additional details, please see Chapter 4 of the SNOPR TSD.
C. Engineering Analysis
In the engineering analysis (detailed in Chapter 5 of the SNOPR
TSD), DOE presents a relationship between the manufacturer selling
price (MSP) and increases in battery charger efficiency. The efficiency
values range from that of an inefficient battery charger sold today
(i.e., the baseline) to the maximum technologically feasible efficiency
level. For each efficiency level examined, DOE determines the MSP; this
relationship is referred to as a cost-efficiency curve.
DOE structured its engineering analysis around two methodologies:
(1) A ``test and teardown'' approach, which involves testing products
for efficiency and determining cost from a detailed bill of materials
(``BOM'') derived from tear-downs and (2) the efficiency-level
approach, where the cost of achieving increases in energy efficiency at
discrete levels of efficiency are estimated using information gathered
in manufacturer interviews that was supplemented and verified through
technology reviews and subject matter experts (``SMEs''). When
analyzing the cost of each CSL--whether based on existing or
theoretical designs--DOE differentiates the cost of the battery charger
from the cost of the associated end-use product.
When developing the engineering analysis for battery chargers, DOE
selected representative units for each product class. For each
representative unit, DOE tested a number of different products. After
examining the test results, DOE selected CSLs that set discrete levels
of improved battery charger performance in terms of energy consumption.
Subsequently, for each CSL, DOE used either teardown data or
information gained from manufacturer interviews to generate costs
corresponding to each CSL for each representative unit. Finally, for
each product class, DOE developed scaling relationships using
additional test results and generated UEC equations based on battery
energy.
1. Representative Units
For each product class, DOE selected a representative unit upon
which it conducted its engineering analysis and developed a cost-
efficiency curve. The representative unit is meant to be an idealized
battery charger typical of those used with high-volume applications in
its product class. Because results from the analysis of these
representative units would later be extended, or applied to other units
in each respective product class, DOE selected high-volume and/or high-
energy-consumption applications that use batteries that are typically
found across battery chargers in the given product class. The analysis
of these battery chargers is pertinent to all the applications in the
product class under the assumption that all battery
[[Page 52872]]
chargers with the same battery voltage and energy provide similar
utility to the user, regardless of the actual end-use product with
which they work. Table IV-2 shows the representative units for each
product class that DOE analyzed.
Table IV-2--Battery Charger Representative Units for Each Product Class
----------------------------------------------------------------------------------------------------------------
Special
Input/Output Battery energy characteristic Rep. unit Rep. unit
Product class No. type (Wh) or battery battery battery energy
voltage voltage (V) (Wh)
----------------------------------------------------------------------------------------------------------------
1............................ AC In, DC Out... <100 Inductive 3.6 1.5
Connection.
2............................ ................ .............. <4 V........... 2.4 1
3............................ ................ .............. 4-10 V......... 7.2 10
4............................ ................ .............. >10 V.......... 12 20
5............................ ................ 100-3000 <20 V.......... 12 800
6............................ ................ .............. >=20 V......... 24 400
7............................ ................ >3000 ............... 48 3,750
----------------------------------------------------------------------------------------------------------------
Additional details on the battery charger representative units can
be found in Chapter 5 of the accompanying SNOPR TSD.
2. Battery Charger Efficiency Metrics
In the NOPR and this SNOPR, DOE used a single metric (i.e., UEC) to
illustrate the improved performance of battery chargers. DOE designed
the calculation of UEC to represent an annualized amount of the non-
useful energy consumed by a battery charger in all modes of operation.
Non-useful energy is the total amount of energy consumed by a battery
charger that is not transferred and stored in a battery as a result of
charging (i.e., losses). In order to calculate UEC, DOE must have the
performance data, which comes directly from its battery charger test
procedure (see section III.A). DOE must also make assumptions about the
amount of time spent in each mode of operation. The collective
assumption about the amount of time spent in each mode of operation is
referred to as a usage profile and is addressed in section IV.E and
further detail in Chapter 7 of the accompanying SNOPR TSD. DOE
recognizes that a wide range of consumers may use the same product in
different ways, which may cause some uncertainty about usage profiles.
Notwithstanding that possibility, DOE used the weighted average of
usage profiles based on a distribution of user types and believes that
its assumptions are appropriate gauges of product use to represent each
product class. These assumptions also rely on a variety of sources
including information from manufacturers and utilities. Details on
DOE's usage profile assumptions can be found in section IV.E of this
notice and Chapter 7 of the accompanying SNOPR TSD.
Finally, DOE believes that by aggregating the performance
parameters of battery chargers into one metric and applying a usage
profile, it will allow manufacturers more flexibility to improve
performance in the modes of operation that will be the most beneficial
to their consumers rather than being required to improve the
performance in each mode of operation, some of which may not provide
any appreciable benefit. For example, a battery charger used with a
mobile phone is likely to spend more time per day in no-battery mode
than a battery charger used for a house phone, which is likely to spend
a significant portion of every day in maintenance mode. Consequently,
it would be more beneficial to consumers if mobile phone battery
charger manufacturers improved no-battery mode and home phone battery
charger manufacturers improved maintenance mode. Therefore, DOE is
using the UEC as the single metric for battery chargers.
DOE's proposed use of a single metric generated several comments.
CEC, Arris, and the Republic of Korea stated that they believe DOE
should alter the single metric compliance approach in favor of the
approaches followed by the CEC or ENERGY STAR. (California Energy
Commission, No. 117 at p. 17, 24; ARRIS Broadband 1, No. 90 at p. 2;
Republic of Korea, No. 148 at p. 2) Conversely, PTI supported the use
of a single metric based upon the usage factors associated with each
product class. (PTI, No. 133 at p. 4) DOE's compliance equation and
metrics give manufacturers the flexibility to re-design their products
in any way that they choose. In this way, manufacturers can pursue
improvements in any modes of operation, which would benefit their users
in the manner that matters most to them. Furthermore, DOE cannot issue
a standard with the two separate metrics found in the CEC rule. That
rule uses two separate metrics, both of which incorporate maintenance
mode as defined in the battery charger test procedure \18\ and used in
this SNOPR. EPCA requires that DOE regulate standby and off mode into a
single metric unless it is technically infeasible to do so. See 42
U.S.C. 6295(gg)(3). Standby mode, as defined by 42 U.S.C. 6295(gg)(3),
occurs when the energy-consuming product is connected to the mains and
offers a user-oriented or protective function such as facilitating the
activation or deactivation of other functions (including active mode)
by remote switch (including remote control), internal sensor, or timer.
See 42 U.S.C. 6295(gg)(1)(A)(iii). Because maintenance mode, as used in
this SNOPR, meets the statutory definition of standby mode, DOE must
incorporate maintenance mode into a single metric.
---------------------------------------------------------------------------
\18\ CFR part 430 Appendix Y to Subpart B, Section 2.8 ``Battery
maintenance mode or maintenance mode is the mode of operation when
the battery charger is connected to the main electricity supply and
the battery is fully charged, but is still connected to the
charger.''
---------------------------------------------------------------------------
3. Calculation of Unit Energy Consumption
UEC is based on a calculation designed to give the total annual
amount of energy lost by a battery charger from the time spent in each
mode of operation. For the preliminary analysis, the various
performance parameters were combined with the usage profile parameters
and used to calculate UEC with the following equation:
UEC = 365(n(E24-Pm(24-tc)-
Ebatt) + (Pm(ta&m-(tcn))) +
(Psbtsb) + (Pofftoff))
Where
E24 = 24-hour energy
Ebatt = Measured battery energy
Pm = Maintenance mode power
Psb = Standby mode power
Poff = Off mode power
tc = Time to completely charge a fully discharged battery
n = Number of charges per day
ta&m = Time per day spent in active and maintenance mode
tsb = Time per day spent in standby mode
toff = Time per day spent in off mode \19\
---------------------------------------------------------------------------
\19\ Those values shown in italics are parameters assumed in the
usage profile and change for each product class. Further discussion
of them and their derivation is found in section IV.E. The other
values should be determined according to section 5 of Appendix Y to
Subpart B of Part 430.
[[Page 52873]]
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When separated and examined in segments, it becomes evident how
this equation gives a value for energy consumed in each mode of
operation per day and ultimately, energy consumption per year. These
segments are discussed individually below.
Active (or Charge) Mode Energy per Day
n(E24-Pm(24-tc)-Ebatt) =
EActive Mode/day
In the first portion of the above equation, DOE combines the
assumed number of charges per day, 24-hour energy, maintenance mode
power, charge time, and measured battery energy to calculate the active
mode energy losses per day. To calculate this value, 24-hour energy
(E24) is reduced by the measured battery energy (i.e., the
useful energy inherently included in a 24-hour energy measurement) and
the product of the value of the maintenance mode power multiplied by
the quantity of 24 minus charge time. This latter value (24 minus
charge time) corresponds to the amount of time spent in maintenance
mode, which, when multiplied by maintenance mode power, yields the
amount of maintenance mode energy consumed by the tested product. Thus,
maintenance mode energy and the value of the energy transferred to the
battery during charging are both subtracted from 24-hour energy,
leaving a quantity theoretically equivalent to the amount of energy
required to fully charge a depleted battery. This number is then
multiplied by the assumed number of charges per day (n) resulting in a
value for the active mode energy per day. Details on DOE's usage
profile assumptions can be found in section IV.E of this notice and
SNOPR TSD Chapter 7.
Maintenance Mode Energy per Day
(Pm(ta&m-(tcn))) =
EMaintenance Mode/day
In the second segment of DOE's equation, shown above, maintenance
mode power, time spent in active and maintenance mode per day
(ta&m), charge time, and the assumed number of charges per
day are combined to obtain maintenance mode energy per day. Time spent
in active and maintenance mode is subtracted from the product of the
charge time multiplied by the number of charges per day. The resulting
quantity is an estimate of time spent in maintenance mode per day,
which, when multiplied by the measured value of maintenance mode power,
yields the energy consumed per day in maintenance mode.
The use of ta&m generated several comments from the CEC,
who stated that the general use of assumptions for this metric would
introduce errors into the calculation. (California Energy Commission,
No. 117 at p. 17, 18, 20, 26) Though the energy usage tables
disaggregate active and maintenance mode time assumptions
(ta and tm) for each application, these values
should not be used alone for determining compliance. DOE believes that
it is inappropriate to use the individual assumptions for ta
and tm for all the products within a single product class
because of the variability in charge time. Variation in charge time has
a direct effect on any product and how much time it spends in both
active and maintenance mode. These variations are accounted for in the
test procedure, by virtue of the charge and maintenance mode test and
the output, E24. Therefore, DOE did not disaggregate active
and maintenance mode in its compliance calculation of UEC; instead, the
outputs of the test procedure would dictate that balance for each
product. Therefore, DOE has determined that the usage profile
assumptions outlined in Section E below are critical in determined real
world energy use of battery chargers.
Standby (or No-Battery) Mode Energy per Day
(Psbtsb) = EStandby Mode/day
In the third part of DOE's UEC equation, the measured value of
standby mode power is multiplied by the estimated time in standby mode
per day, which results in a value of energy consumed per day in standby
mode.
Off-Mode Energy per Day
(Pofftoff) = ENo_Battery Mode/day
In the final part of DOE's UEC equation, the measured value of off-
mode power is multiplied by the estimated time in off-mode per day,
which results in a value of energy consumed per day in off-mode.
To obtain UEC, the values found through the above calculations are
added together. The resulting sum is equivalent to an estimate of the
average amount of energy consumed by a battery charger per day. That
value is then multiplied by 365, the number of days in a year, and the
end result is a value of energy consumed per year.
Modifications to Equation for Unit Energy Consumption
On April 2, 2010, DOE published a proposal to revise its test
procedures for battery chargers and EPSs. (75 FR 16958) In that notice,
DOE proposed to use a shorter version of the active mode test procedure
in scenarios where a technician could determine that a battery charger
had entered maintenance mode, 75 FR 16970. However, during its testing
of battery chargers, DOE observed complications arising when attempting
to determine the charge time for some devices, which, in turn, could
affect the accuracy of the UEC calculation. DOE ultimately decided that
the duration of the charge test must not be shortened and be a minimum
of 24 hours. See 10 CFR part 430, subpart B, Appendix Y (``Uniform Test
Method for Measuring the Energy Consumption of Battery Chargers''). The
test that DOE adopted has a longer duration if it is known (e.g.,
because of an indicator light on the battery charger) or it can be
determined from manufacturer information that fully charging the
associated battery will take longer than 19 hours.\20\
---------------------------------------------------------------------------
\20\ The charge mode test must include at least a five-hour
period where the unit being tested is known to be in maintenance
mode. Thus, if a device takes longer than 19 hours to charge, or is
expected to take longer than 19 hours to charge, the entire duration
of the charge mode test will exceed 24 hours in total time after the
five-hour period of maintenance mode time is added. 76 FR 31750,
31766-67, and 31780.
---------------------------------------------------------------------------
This revision to the test procedure is important because it
underscores the potential issues with trying to determine exactly when
a battery charger has entered maintenance mode, which creates
difficulty in determining charge time. To address this situation, DOE
modified its initial UEC equation. The new equation, which was
presented to manufacturers during interviews, is mathematically
equivalent to the equation presented in the preliminary analysis. When
the terms in the preliminary analysis UEC equation are multiplied,
those terms containing a factor of charge time cancel each other out
and drop out of the equation. What is left can be factored and
rewritten as done below. This means that even though the new equation
looks different from the equation presented for the preliminary
analysis, the value that is obtained is the same and represents the
same value of unit energy consumption.
New Base UEC Equation
UEC = 365(n(E24-Ebatt) +
(Pm(ta&m-(24n))) + (Psbtsb)
+ (Pofftoff))
In addition to initially considering a shortened battery charger
active mode test procedure, DOE considered capping the measurement of
24-hour energy at the 24-hour mark of the test. However, following this
approach could result in inaccuracies because that measurement would
exclude the full amount of
[[Page 52874]]
energy used to charge a battery if the charge time is longer than 24
hours in duration. To account for this possibility, DOE altered this
initial approach in its test procedure final rule by requiring the
measurement of energy for the entire duration of the charge and
maintenance mode test, which includes a minimum of 5 hours in
maintenance mode. See 10 CFR part 430, subpart B, appendix Y, Sec. 5.2.
The modifications to the UEC calculation do not alter the value
obtained when the charge and maintenance mode test is completed within
24 hours. However, if the test exceeds 24 hours, the energy lost during
charging is scaled back to a 24-hour, or per day, cycle by multiplying
that energy by the ratio of 24 to the duration of the charge and
maintenance mode test. In the equation below, tcd,
represents the duration of the charge and maintenance mode test and is
a value that the test procedure requires technicians to determine. DOE
also modified the equation from the NOPR by inserting a provision to
subtract 5 hours of maintenance mode energy from the 24-hour energy
measurement. This change was made because the charge and maintenance
mode test includes a minimum of 5 hours of maintenance mode time.
Consequently, in the second portion of the equation below, DOE would
reduce the amount of time subtracted from the assumed time in active
and maintenance mode time per day.
In other words, the second portion of the equation, which is an
approximation of maintenance mode energy, is reduced by 5 hours. This
alteration was needed to address instances when the charge and
maintenance mode test exceeds 24 hours, because the duration of the
test minus 5 hours is an approximation of charge time. This
information, tcd, can then be used to approximate the
portion of time that a device is assumed to spend in active and
maintenance mode per day (ta&m) and is solely dedicated to
maintenance mode.\21\ The primary equation (i) that manufacturers will
use to determine their product's unit energy consumption and whether
their device complies with DOE's standards is below.
---------------------------------------------------------------------------
\21\ For a test exceeding 24 hours, the duration of the test
less 5 hours is equal to the time it took the battery being tested
to become fully charged (tcd - 5). That value, multiplied
by the assumed number of charges per day, gives an estimate of
charge (or active) time per day, which can then be subtracted from
DOE's other assumption for ta&m. That difference is an
approximation for maintenance mode time per day.
---------------------------------------------------------------------------
Primary Equation (i)
[GRAPHIC] [TIFF OMITTED] TP01SE15.000
Secondary Calculation of UEC
For some battery chargers, the equation described above is not
appropriate and an alternative calculation is necessary. Specifically,
in those cases where the charge test duration (as determined according
to section 5.2 of Appendix Y to Subpart B of Part 430) minus 5 hours is
multiplied by the number of charges per day (n) is greater than the
time assumed in active and maintenance mode (ta&m), an
alternative equation must be used. A different equation must be used
because if the number of charges per day multiplied by the time it
takes to charge (charge test duration minus 5 hours--or the charge time
per day) is longer than the assumption for the amount of time spent in
charge mode and maintenance mode per day, that difference creates an
inconsistency between the measurements for the test product and DOE's
assumptions. This problem can be corrected by using an alternative
equation, which is shown below.
Secondary Equation (ii)
[GRAPHIC] [TIFF OMITTED] TP01SE15.001
This alternative equation (ii) resolves this inconsistency by
prorating the energy used for charging the battery.
The final UEC equations generated several comments from the CEC. It
asserted that the UEC equation fails to incentivize manufacturers to
improve maintenance mode power in their products (California Energy
Commission, No. 117 at p. 17). Specifically, in its view, UEC equation
(i) would reward manufacturers of battery chargers with higher
maintenance mode power, since maintenance mode power is subtracted from
the estimated annual energy consumption (California Energy Commission,
No. 117 at p. 22). Additionally, it stated that UEC equation (ii) is
also flawed, as it does not account for the energy consumed by the
maintenance mode of a product (California Energy Commission, No. 117 at
p. 21). The CEC also concluded that the usage assumptions contain
flaws, thereby introducing errors into the UEC calculation (California
Energy Commission, No. 117 at p. 18). The CEC requested that DOE
combine the alternative UEC equation with the main UEC equation,
resulting in a single equation for calculating UEC. (California Energy
Commission, No. 117 at p. 27).
While the CEC accurately noted there is a negative term related to
maintenance mode power in the UEC equation when combined with the
Product Class 2 usage profile, the primary and secondary UEC equations
are not flawed and are both necessary. The usage profile for this
product class simply reflects that the consumer benefits more greatly
from improved charge efficiency rather than improved maintenance mode.
The CEC concluded that manufacturers are incentivized to increase their
maintenance mode power to reduce their UEC, but the CEC's conclusion
neglects the fact that if maintenance mode power is increased, so would
the 24-hour energy consumption. The value of 24-hour energy will
increase by an amount equivalent to the maintenance mode power
increase, multiplied by the difference between 24 and the time to
charge the battery. Furthermore, if two units have all of the same
performance parameters except for maintenance mode power consumption
(i.e., 24-hour
[[Page 52875]]
energy, standby mode power, and off mode power), it follows that the
device with the higher maintenance mode power consumption is more
efficient during charging. As mentioned, the usage profile for Product
Class 2 suggests that, on average, users of these products will benefit
more from an efficient charge rather than an efficient maintenance mode
and, therefore, the unit with the higher maintenance mode power will
have a lower UEC. More details on DOE's analysis for this conclusion
can be found in Chapter 5 of the accompanying SNOPR TSD.
4. Battery Charger Candidate Standard Levels
After selecting its representative units for battery chargers, DOE
examined the impacts on the cost of improving the efficiency of each of
the representative units to evaluate the impact and assess the
viability of potential energy efficiency standards. As described in the
technology assessment and screening analysis, there are numerous design
options available for improving efficiency and each incremental
technology improvement increases the battery charger efficiency along a
continuum. The engineering analysis develops cost estimates for several
CSLs along that continuum.
CSLs are often based on (1) efficiencies available in the market;
(2) voluntary specifications or mandatory standards that cause
manufacturers to develop products at particular efficiency levels; and
(3) the maximum technologically feasible level.\22\
---------------------------------------------------------------------------
\22\ The ``max-tech'' level represents the most efficient design
that is commercialized or has been demonstrated in a prototype with
materials or technologies available today. ``Max-tech'' is not
constrained by economic justification, and is typically the most
expensive design option considered in the engineering analysis.
---------------------------------------------------------------------------
Currently, there are no energy conservation standards for battery
chargers. Therefore, DOE based the CSLs for its battery charger
engineering analysis on the efficiencies obtainable through the design
options presented previously (see section IV.A). These options are
readily seen in various commercially available units. DOE selected
commercially available battery chargers at the representative-unit
battery voltage and energy levels from the high-volume applications
identified in the market survey. DOE then tested these units in
accordance with the DOE battery charger test procedure. For each
representative unit, DOE then selected CSLs to correspond to the
efficiency of battery charger models that were comparable to each other
in most respects, but differed significantly in UEC (i.e. efficiency).
In general, for each representative unit, DOE chose the baseline
(CSL 0) unit to be the one with the highest calculated unit energy
consumption, and the best-in-market (CSL 2) to be the one with the
lowest. Where possible, the energy consumption of an intermediate model
was selected as the basis for CSL 1 to provide additional resolution to
the analysis.
Unlike the previous three CSLs, CSL 3 was not based on an
evaluation of the efficiency of individual battery charger units in the
market, since battery chargers with maximum technologically feasible
efficiency levels are not commercially available due to their high
cost. Where possible, DOE analyzed manufacturer estimates of max-tech
costs and efficiencies. In some cases, manufacturers were unable to
offer any insight into efficiency level beyond the best ones currently
available in the market. Therefore, DOE projected the efficiency of a
max-tech unit by estimating the impacts of adding any remaining energy
efficiency design options to the CSL unit analyzed.
On January 12, 2012, California proposed standards for small
battery chargers, which the State eventually adopted.\23\ The
California standards are based on two metrics, one for 24-hour energy
use, and one for the combined maintenance mode and standby mode power
usage. DOE, using the usage profiles it developed to translate these
standards into a value of UEC, compared its CSLs with the levels
adopted by California. DOE found that, in most cases, the California
proposed standards generally corresponded closely with one of DOE's
CSLs for each product class when the standards were converted into a
value of UEC (using DOE's usage profile assumptions). However, since
the adoption of the CEC standards, DOE has attempted to adjust its CSLs
to align with the CEC standards to the extent possible. For example if
DOE's test and teardown approach resulted in a representative unit used
to create CSL1 and the resulting CSL1 was slightly more stringent than
DOE's translation of the CEC level, then DOE would shift CSL1 to be
more stringent and to more closely align with the CEC's standard. This
methodology is outlined in more detail in Chapter 5 of the accompanying
SNOPR TSD. DOE seeks comment from stakeholders on this approach.
---------------------------------------------------------------------------
\23\ The term ``small battery charger system'' is defined by the
CEC as a battery charger system ``with a rated input power of 2 kW
or less, and includes golf cart battery charger systems regardless
of the output power.'' 20 Cal. Code 1602(w) (2014).
---------------------------------------------------------------------------
Table IV-3 below shows which CSL aligns most closely with the
California standards for each product class.
Table IV-3--CSLs Approximate to California Standards
------------------------------------------------------------------------
CSL approximate to CEC
Product class standard
------------------------------------------------------------------------
1 (Low-Energy, Inductive)................. CSL 0
2 (Low-Energy, Low-Voltage)............... CSL 1
3 (Low-Energy, Medium-Voltage)............ CSL 1
4 (Low-Energy, High-Voltage).............. CSL 1
5 (Medium-Energy, Low-Voltage)............ CSL 2
6 (Medium-Energy, High-Voltage)........... CSL 2
7 (High-Energy)........................... CSL 1
------------------------------------------------------------------------
In addition, DOE received comments on specific CSLs for specific
product classes. For Product Class 2 (low-energy, low-voltage) and
Product Class 3 (low-energy, medium voltage) since stakeholders
believed that intermediate CSLs that more closely align with the CEC's
levels could be shown to be cost effective based on specific units in
the marketplace that meet intermediate levels. Specifically, these
stakeholders suggested modifying Product Class 2 to include a ``CSL
2.5'' and Product Class 3 to include a CSL ``1.8.'' (CA IOUs, No. 138
at p. 5-8; ASAP, No. 162 at p. 4, 6; NRDC, No. 114 at p. 5) NRDC and
the CEC also both urged DOE to reconsider the analysis for Product
Class 3 and develop an intermediate CSL between CSL 1 and CSL 2. (NRDC,
No. 114 at p. 6; California Energy Commission, No. 117 at p. 12)
Concerning Product Class 4, ARRIS asserted that setting the standard at
TSL 1 (CSL 1) will have no major effect on energy savings since the
majority of products already meet this level. (ARRIS Broadband 1, No.
90 at p. 3)
DOE also received comments regarding the specific limits chosen for
Product Class 10. Schneider requested that DOE reconsider the proposed
level set for CSL 2 and CSL 3, noting in particular that the product
relied on by DOE to develop CSL2 was no longer on the market
(Schneider, No. 119 at p. 4) Furthermore, Schneider requested that CSL
0 or CSL 1 be selected, stating that CSL 3 is speculative, if not
impossible, in terms of feasibility. (Schneider, No. 119 at p. 4)
Schneider requested that if CSL 2 is chosen, a 3-year compliance window
from the date of the published final rule be set. (Schneider, No. 119
at p. 4) Regarding Product Class 10B,
[[Page 52876]]
Schneider requested that DOE recalculate higher levels for CSL 0 and
CSL 1 and that one of these levels be chosen with a 5-year compliance
window from the date of the published final rule. (Schneider, No. 119
at p. 5, 6) NEMA argued that if the standards proposed in the NOPR were
adopted, manufacturers would likely petition DOE for hardship
exemptions. (NEMA, No. 134 at p. 5)
With the exception of the max tech level, the CSLs presented in the
March 2012 NOPR for all product classes (including CSLs 2, 3, and 4),
were based on commercially available products and the costs to reach
these levels were independently verified by manufacturers and subject
matter experts. For the SNOPR, DOE attempted to align at least one CSL
in each product class subject to this proposed rule as closely as
possible to the CEC standards to address comments to the NOPR
suggesting that DOE create a new CSL that more closely aligns with the
CEC levels. Additionally, as previously stated, DOE is no longer
proposing standards for product class 10 because these products are now
being considered as part of the Computer and Backup Battery Systems
rulemaking. See 79 FR 41656. As such, comments related to product class
10 are no longer relevant to this rulemaking and DOE will not be
addressing comments submitted in response to the NOPR for Product Class
10 in this SNOPR.
5. Test and Teardowns
The CSLs used in the battery charger engineering analysis were
based on the efficiencies of battery chargers available in the market.
Following testing, the units corresponding to each commercially
available CSL were disassembled to (1) evaluate the presence of energy
efficiency design options and (2) estimate the materials cost. The
teardowns included an examination of the general design of the battery
charger and helped confirm the presence of any of the technology
options discussed in section IV.A
After the battery charger units corresponding to the CSLs were
evaluated, they were torn down by IHS Technology (formerly iSuppli), a
DOE contractor and industry expert. An in-depth teardown and cost
analysis was performed for each of these units. For some products, like
camcorders and notebook computers, the battery charger constitutes a
small portion of the circuitry. In evaluating the related costs, IHS
Technology identified the subset of components in each product
enclosure responsible for battery charging. The results of these
teardowns were then used as the primary source for the MSPs.
For this SNOPR engineering analysis, DOE continued to rely on its
test and teardown data. Consequently, the test and teardown results
reflected the current technologies on the market and did not attempt to
predict which technological designs may become available in the future.
Multiple interested parties criticized the test and teardown approach
to the battery charger engineering because the market does not
naturally push products to become just more efficient. Instead,
improved efficiency is often a byproduct of other added utilities, such
as making products smaller and lighter. These parties believed that DOE
over-estimated its costs to achieve certain CSLs. (NRDC, No. 114 at p.
1: ASAP, No. 162 at p. 1: CA IOUs, No. 138 at p. 4)
Additionally, responding to the NOPR analyses, NRDC, the CA IOUs,
NEEP, and ASAP suggested that DOE's engineering analysis for battery
chargers should reflect a baseline in which the EPS that accompanies
the battery charger is compliant with DOE's (then) future regulations
for EPSs. (NRDC, No. 114 at p. 4; CA IOUs, No. 138 at pp. 7, 8; ASAP,
et al., No. 136 at p. 7; ASAP, No. 162 at p. 1, 5) One interested party
also stated that DOE should ensure that the units it uses to represent
higher battery charger CSLs should incorporate EPSs that meet future
standards because those EPSs are cost-effective. (NEEP, No. 144 at p.
2) Finally, one interested party suggested that DOE overstated the
costs of complying with higher efficiency standards because it tore
down units rather than explicitly making modifications to the EPSs of
less efficient battery chargers, thereby failing to capture potentially
cost-effective savings of EPS improvements. (ASAP, et al., No. 136 at
p. 4)
The first two points made by interested parties are similar and
both points suggest that DOE modify CSLs to account for future EPS
regulations. However, DOE notes that not all battery chargers will
incorporate an EPS that is, or will be, subject to efficiency
regulations. For that reason, the baseline efficiency and all higher
efficiency levels that DOE analyzes are not required to reflect a
combination of technologies that includes an EPS that meets the higher
efficiency levels that will apply to certain classes of EPSs in 2016.
Regarding the assertions that DOE has overstated its costs by using a
test and teardown approach, as mentioned above, not all battery
chargers will necessarily have to incorporate a more efficient EPS as a
result of any new standards for those products. In fact, such an
assumption would have the effect of steepening a cost-efficiency curve.
If DOE were to assume that the EPS must be improved in all battery
charger systems, then DOE would be removing a design path that battery
charger manufacturers could potentially take. This would have the
effect of making incremental improvements to performance more costly
because it removes a degree of freedom from battery charger
manufacturers. The test and teardown approach has the benefit of not
eliminating any practicable design options from the analysis. This
approach is technology neutral, and although DOE does provide an
analysis of the technologies that were used in the products that it
tore down, that does not mean that is the only design path to achieve
that performance level. Instead, it is a reflection of the choices that
various battery charger manufacturers are currently making to improve
the performance of their products.
Finally, DOE verified the accuracy of the IHS Technology results by
reviewing aggregated results with individual manufacturers during
interviews and subject matter experts. As discussed later, DOE
performed additional manufacturer interviews for the NOPR and during
these interviews, the initial IHS Technology results were again
aggregated and reviewed with manufacturers. DOE believes that it has
sufficiently verified the accuracy of its teardown results and believes
that all of the engineering costs gleaned from IHS Technology are
appropriate.
6. Manufacturer Interviews
The engineering analysis also relies in part on information
obtained through interviews with several battery charger manufacturers.
These manufacturers consisted of companies that manufacture battery
chargers and original equipment manufacturers (OEMs) of battery-
operated products who package (and sometimes design, manufacture, and
package) battery chargers with their end-use products. DOE followed
this interview approach to obtain data on the possible efficiencies and
resultant costs of consumer battery chargers. Aggregated information
from these interviews is provided in Chapter 5 of the SNOPR TSD. The
interviews also provided manufacturer inputs and comments in preparing
the manufacturer impact analysis, which is discussed in detail in
section IV.J.
DOE attempted to obtain teardown results for all of its product
classes, but encountered difficulties in obtaining useful and accurate
teardown results for
[[Page 52877]]
one of its products classes--namely, Product Class 1 (e.g., electric
toothbrushes). For this product class, DOE relied heavily on
information obtained from manufacturer interviews. DOE found that when
it attempted to teardown Product Class 1 devices, most contained
potting (i.e., material used to waterproof internal electronics).
Removal of the potting also removed the identifying markings that IHS
Technology needed to estimate a cost for the components. As a result,
manufacturer interview data helped furnish the necessary information to
assist DOE in estimating these costs.
7. Design Options
Design options are technology options that remain viable for use in
the engineering analysis after applying the screening criteria as
discussed above in section IV.B. DOE notes that all technology options
that are not eliminated in the screening analysis, section IV.B, become
design options that are considered in the engineering analysis. Most
CSLs, except for those related to max-tech units and chargers falling
in Product Class 1 and Product Class 6, where DOE did not tear down
units, are based on actual teardowns of units manufactured and sold in
today's battery charger market. Consequently, DOE did not control which
design options were used at each CSL. No technology options were
preemptively eliminated from use with a particular product class.
Similarly, if products are being manufactured and sold, DOE believes
that fact indicates the absence of any significant loss in utility,
such as an extremely limited operating temperature range or shortened
cycle-life. Therefore, DOE believes that all CSLs can be met with
technologies that are feasible and that fit the intended application.
Details on the technology associated with each CSL can be found in
Chapter 5 of the accompanying SNOPR TSD.
For the max-tech designs, which are not commercially available, DOE
developed these levels in part with a focus on maintaining product
utility as projected energy efficiency improved. Although some
features, such as decreased charge time, were considered as added
utilities, DOE did not assign any monetary value to such features.
Additionally, DOE did not assume that such features were undesirable,
particularly if the incremental improvement in performance causes a
significant savings in energy costs. Finally, to the extent possible
DOE considered durability, reliability, and other performance and
utility-related features that affect consumer behavior. See SNOPR TSD,
Chapter 5 for additional details.
In response to the NOPR engineering analysis, DOE received multiple
comments on design options that were not mentioned in DOE's analysis.
ECOVAECOVA argued that more efficient nickel-based charger designs
exist and should be considered for determining costs of standards. Its
comments also noted, however, that no commercially available products
use these more efficient designs. (ECOVAECOVA, No. 97 at p. 1) The CEC
and ASAP suggested that DOE consider designs presented by ECOVAECOVA
that demonstrated the higher efficiency levels that are possible when
compared to what is currently available in the marketplace for nickel-
based designs. (California Energy Commission, No. 117 at p. 2;
Transcript, No. 104 at p. 256; ASAP, et al., No. 136 at p. 8) The
California Investor-Owned Utilities (``CA IOUs'') made a similar
comment, stating that a teardown and redesign of Product Class 4 shows
the previously proposed CSL 2 to be cost effective. (CA IOUs, No. 138
at p. 9) NRDC and NEEP also argued that DOE overestimated the costs to
improve efficiency in Product Classes 2-6, stating that DOE's
representative units do not use the most cost-effective designs to
achieve proposed and that the previously proposed CSL 2 in Product
Class 3 could be achieved with a battery chemistry other than lithium.
(NRDC, No. 114 at p. 3; NEEP, No. 144 at pp. 1-2) Southern California
Edison (SCE) similarly stated that the reason no nickel-based chargers
that meet the previously proposed CSL 2 for Product Classes 2-4 have
been found is that strong market forces discourage the development of
efficient nickel chargers and, therefore, the current market is an
ineffective place to identify high efficiency designs. (SCE, No. 164 at
p. 1) Finally, SCE stated that current charge rates seen in the
previously proposed CSL 1 for Product Classes 2-4 can be 3-12 times
lower while still maintaining a full charge. (SCE, No. 164 at p. 2)
In response to public comments made by ECOVAECOVA at the NOPR
public meeting, PTI, AHAM and CEA, challenged the idea that lower
maintenance mode power levels could be achieved. PTI noted that the CEC
standards are not achievable for battery chargers that charge nickel-
cadmium (Ni-Cd) or nickel-metal-hydride (Ni-MH) cells and that
ECOVAECOVA's claims fail to meet any possible criteria for technical
feasibility. (PTI, No. 133 at p. 2) AHAM similarly noted that
ECOVAECOVA's claims neglect the requirement of nickel-based chemistries
that they be maintained at a high charge due to the secondary
recombination reaction that occurs in sealed cells, which affects state
of charge and the life of the battery cells. (AHAM, No. 124 at p. 3)
However, SCE separately noted that the recombination reaction is
important to account for during the charge cycle (or active mode
charging) but accounting for this reaction does not need to persist in
maintenance mode. It added that the current calculated for the CEC
standard level is sufficient. (SCE, No. 164 at p. 2) Finally, PTI,
AHAM, and CEA jointly stated that ECOVA's suggested design
modifications are technically infeasible, resulting in reduced battery
lifetimes, and that adopting efficiency levels at the stringency
suggested by ECOVA would effectively eliminate Ni-Cd products with
battery energies above 20Wh. (PTI, AHAM, CEA, No. 161 at p. 3)
DOE based its analysis on commercially available products when
establishing candidate standard levels for Product Classes 2-6. Through
extensive testing, discussion with SMEs, and market research, DOE found
that manufacturers have already moved away from nickel-based systems,
to lithium-based systems, partly as a means of improving efficiency
(lithium also offers other benefits to consumers, such as higher energy
density and cycle life). This shift away from nickel-based systems is
due, in part, to the fact that these systems have to counteract
secondary reactions within the battery cells, which result in self-
discharge--which, in turn, shortens battery life. To counteract this,
nickel-based chargers must have a certain level of maintenance mode
power to preserve a full (100%) charge and maintain consumer utility.
(Lithium-based systems experience similar reactions, but with much
lower levels of self-discharge and can reach much lower power levels in
maintenance mode.) DOE has updated this analysis to focus on improved
nickel-based battery chargers and through further testing and teardowns
conducted as part of this SNOPR, found that designs similar to ECOVA's
proposed design are being implemented and sold into the market. These
already-available designs suggest that improvements to nickel-based
designs may be a feasible option in certain cases for manufacturers to
employ to meet their utility requirements and improve the energy
efficiency of their battery chargers. Accordingly, DOE has updated the
proposed CSLs and found that deploying solely lithium-based systems
[[Page 52878]]
would not necessarily be required to meet the proposed levels.
DOE received further comments from stakeholders concerning the
costs associated with moving from nickel to lithium designs rather than
to more efficient nickel designs. NRDC and CEC commented that by using
lithium designs, the actual costs of moving from the previously
proposed CSL 1 to CSL 2 in Product Class 3 are over stated. (NRDC, Pub.
Mtg. Tr., No. 104 at p. 57: NRDC, No. 114 at p. 5) NRDC and CEC claimed
that this same argument applies to Product Classes 2-6 and that the
costs for all of these product classes are overstated and inaccurate.
(California Energy Commission, No. 117 at p. 7, 12, 13: NRDC, No. 114
at p. 5) When considering design solutions and paths, DOE relied
heavily on information provided by manufacturers during interviews.
However, DOE has conducted additional testing and market research in
response to these comments. DOE found that while many lithium-based
systems have been introduced into the market, there are also many
products deploying nickel-based battery charging systems with minor
updates that reduce maintenance mode and overall energy use at a lower
cost than some lithium designs. The costs used in this SNOPR reasonably
reflect real world design changes and the feasibility and cost of such
changes have been corroborated by manufacturers and subject matter
experts.
Finally, DOE received comments from GE Healthcare and Schumacher
noting that outside elements may prevent them from pursuing certain
design pathways for their respective products. GE Healthcare commented
that there are medical devices which are deployed in adverse
conditions, extreme temperatures, or gaseous environments which may
prevent certain types of battery chemistries from being used. (GE
Healthcare, No. 142 at p. 2) Schumacher commented that certain design
patents held by their competition prevent them from deploying switch
mode designs in their engine-start automotive battery chargers.
(Schumacher, No. 143 at p. 4) As noted earlier, DOE is not proposing to
set standards that would affect medical battery chargers. More
generally in response to both comments, DOE notes that if a
manufacturer finds that meeting the standard for battery chargers would
cause special hardship, inequity, or unfair distribution of burdens,
the manufacturer may petition the Office of Hearings and Appeals (OHA)
for exception relief or exemption from the standard pursuant to OHA's
authority under section 504 of the DOE Organization Act (42 U.S.C.
7194), as implemented at subpart B of 10 CFR part 1003. OHA has the
authority to grant such relief on a case-by-case basis if it determines
that a manufacturer has demonstrated that meeting the standard would
cause hardship, inequity, or unfair distribution of burdens.
8. Cost Model
This proposed rule continues to apply the same approach used in the
NOPR and preliminary analysis to generate the manufacturer selling
prices (MSPs) for the engineering analysis. For those product classes
other than Product Class 1, DOE's MSPs rely on the teardown results
obtained from IHS Technology. The bills of materials provided by IHS
Technology were multiplied by a markup based on product class. For
those product classes for which DOE could not estimate MSPs using the
IHS Technology teardowns-Product Class 1-DOE relied on aggregate
manufacturer interview data. Additional details regarding the cost
model and the markups assumed for each product class are presented in
Chapter 5 of the SNOPR TSD.
DOE's cost estimates reflect real world costs and have been updated
where necessary for this SNOPR. The CA IOUs asserted that the
methodology used to derive costs was fundamentally flawed and
overestimated BOM costs. (CA IOUs, No. 138 at p. 11) DOE disagrees. The
primary benefit to the teardown approach is that it relies on real-
world designs and reflects practices and approaches that manufacturers
are currently using to improve product performance. As a result, DOE's
estimates are based on actual pricing and cost data for the various
components and manufacturing technologies employed by industry.
Additionally, by applying this method, DOE can examine battery chargers
used in multiple applications, which allows its estimated costs to
reflect various constraints and manufacturer choices. All of these
factors weigh in favor of the teardown approach, which is more likely
to provide a reasonable approximation of the costs involved to produce
a given battery charger with a particular set of features and
efficiency level than other methods that do not account for these
factors.
DOE also received comments during the NOPR public meeting regarding
the possible decline in the cost of lithium batteries and the effects
that this decline could have on the cost model. NRDC asserted that DOE
had not factored in the rapid decline in the cost of lithium batteries
that DOE itself has shown in its own cost projections. (NRDC, Pub. Mtg.
Tr, No. 104 at p. 58) DOE understands that commodity prices fluctuate
for emerging technologies and they can decrease over time, perhaps even
during the course of the analysis period. However, lithium-based
battery chargers in consumer products have not experienced as sharp a
decline as the cost for lithium batteries in other applications, such
as those used for electric vehicles, mainly because of the scale and
size of those systems. Without more substantive data that specifically
addresses lithium batteries and lithium-based battery chargers for the
consumer market, DOE chose to base its analysis on stable indicators
rather than data prone to market fluctuations, such as lithium prices
are. Furthermore, commodity prices can fluctuate for any number of
reasons, potentially resulting in adverse effects on consumers.
9. Battery Charger Engineering Results
The results of the engineering analysis are reported as cost-
efficiency data (or ``curves'') in the form of MSP (in dollars) versus
unit energy consumption (in kWh/yr). These data form the basis for this
SNOPR analyses. This section illustrates the results that DOE obtained
for all seven product classes in its engineering analysis.
DOE received several comments supporting the Product Class 1
engineering results in the NOPR. (NRDC. No. 114 at p. 8; California
Energy Commission, No. 117 at p. 28) No changes were made to the
engineering results for Product Class 1 and the results are shown below
in Table IV-4.
Table IV-4--Product Class 1 (Inductive Chargers) Engineering Analysis Results
----------------------------------------------------------------------------------------------------------------
CSL 0 CSL 1 CSL 2 CSL 3
----------------------------------------------------------------------------------------------------------------
CSL Description................................. Baseline Intermediate Best in Market Max Tech
24-Hour Energy (Wh)............................. 26.7 19.3 10.8 5.9
Maintenance Mode Power (W)...................... 1.2 0.8 0.4 0.2
No-Battery Mode Power (W)....................... 0.5 0.4 0.2 0.1
[[Page 52879]]
Off-Mode Power (W).............................. 0.0 0.0 0.0 0.0
Unit Energy Consumption (kWh/yr)................ 8.73 6.10 3.04 1.29
MSP [$]......................................... $2.05 $2.30 $2.80 $6.80
----------------------------------------------------------------------------------------------------------------
DOE received several comments regarding costs for Product Class 2
in response to the NOPR. NRDC, CEC, and the CA IOUs all claimed that
the projected costs for Product Class 2 were incorrect and did not
reflect real world costs. (NRDC, No. 114 at p. 5; California Energy
Commission, No. 117 at p. 10, 11; CA IOUs, No. 138 at p. 4) DOE has
updated its analysis and discussion for this product class. See Chapter
5 of the accompanying Chapter 5 of the SNOPR TSD.
DOE also received specific comments about how it derived its costs
for Product Classes 2, 3, and 4. ASAP and NEEP requested that DOE
explain how these costs were derived and identify which units were
used. (ASAP, No. 162 at p. 2-7; NEEP, No. 160 at p. 1) For the SNOPR
analysis, DOE used the representative unit cost associated with a
single unit with a BOM that can be found in Appendix 5B of the SNOPR
TSD. For the instances where a representative unit was created to be
approximate to the CEC standard, BOM costs were used as well. Further
detail on these costs and representative units can be found in Chapter
5 and Appendix 5B of the accompanying SNOPR TSD.
Based on further analysis, DOE adjusted the results for Product
Class 2. These adjusted results are shown in the Table IV-5. More
details on these updates can be found in Chapter 5 of the accompanying
SNOPR TSD.
Table IV-5--Product Class 2 (Low-Energy, Low-Voltage) Engineering Analysis Results
----------------------------------------------------------------------------------------------------------------
CSL 0 CSL 1 CSL 2 CSL 3 CSL 4
----------------------------------------------------------------------------------------------------------------
CSL Description................. Baseline Intermediate 2nd Best in Market Max Tech
Intermediate
24-Hour Energy (Wh)............. 25.79 13.6 8.33 8.94 6.90
Maintenance Mode Power (W)...... 1.1 0.5 0.13 0.1 0.04
No-Battery Mode Power (W)....... 0.3 0.3 0.03 0.02 0.10
Off-Mode Power (W).............. 0.0 0.0 0.0 0.0 0.0
Unit Energy Consumption (kWh/yr) 5.33 3.09 1.69 1.58 1.11
MSP [$]......................... $1.16 $1.20 $1.49 $2.43 $4.31
----------------------------------------------------------------------------------------------------------------
DOE also received several comments regarding costs used in the
engineering analysis for Product Class 3. The CA IOUs noted that DOE
may have omitted a component in one of the BOMs used to derive this CSL
that may have led to the projected increase in cost between nickel and
lithium battery chargers in Product Class 3. They also noted that this
projected cost increase could have been part of the reason why costs
were overestimated. (CA IOUs, No. 138 at p. 7) DOE revisited the IHS
Technology data for these units and updated the cost data to include
the missing component. However, this unit is no longer being used in
the analysis. Additional testing and teardowns were completed for
Product Class 3 to replace the analysis that previously relied on this
no longer produced unit. Representative units and updated results for
Product Class 3 are shown in the Table IV-6.
Table IV-6--Product Class 3 (Low-Energy, Medium-Voltage) Engineering Analysis Results
----------------------------------------------------------------------------------------------------------------
CSL 0 CSL 1 CSL 2 CSL 3
----------------------------------------------------------------------------------------------------------------
CSL Description................................. Baseline Intermediate Best in Market Max Tech
24-Hour Energy (Wh)............................. 42.60 28.00 17.0 15.9
Maintenance Mode Power (W)...................... 1.70 0.50 0.26 0.26
No-Battery Mode Power (W)....................... 0.30 0.30 0.20 0.20
Off-Mode Power (W).............................. 0.0 0.0 0.0 0.0
Unit Energy Consumption (kWh/yr)................ 3.65 1.42 0.74 0.70
MSP [$]......................................... $1.12 $1.20 $4.11 $5.51
----------------------------------------------------------------------------------------------------------------
Regarding Product Class 4, NRDC, the CEC, ASAP, and the CA IOUs
argued that DOE overestimated the costs for some CSLs. (NRDC, No. 114
at p. 6; California Energy Commission, No. 117 at p. 14; ASAP, No. 162
at p. 7; CA IOUs, No. 138 at p. 8-9) ASAP urged DOE to remove the
results for the handheld vacuum unit from the test results, since the
costs for that unit are higher than the other products in that product
class and may not reflect the lowest cost design. (ASAP Et Al., No. 136
at p. 8)
DOE has conducted more tests and teardowns since the NOPR analysis
and has chosen single units as representative units for this product
class. DOE believes each CSL is representative of technology that can
be widely applied to all applications in this product class. The
updated costs can be seen in Table IV-7.
[[Page 52880]]
Table IV--7 Product Class 4 (Low-Energy, High-Voltage) Engineering Analysis Results
----------------------------------------------------------------------------------------------------------------
CSL 0 CSL 1 CSL 2 CSL 3
----------------------------------------------------------------------------------------------------------------
CSL Description................................. Baseline Intermediate Best in Market Max
24-Hour Energy (Wh)............................. 60.75 44.00 29.30 27.2
Maintenance Mode Power (W)...................... 2.40 0.50 0.50 0.4
No-Battery Mode Power (W)....................... 0.30 0.30 0.50 0.3
Off-Mode Power (W).............................. 0.0 0.0 0.0 0.0
Unit Energy Consumption (kWh/yr)................ 12.23 5.38 3.63 3.05
MSP [$]......................................... $1.79 $2.60 $5.72 $18.34
----------------------------------------------------------------------------------------------------------------
For Product Class 6, DOE performed additional product testing
during the NOPR stage, but did not obtain a complete data set upon
which to base its engineering analysis. This situation was due in large
part to DOE's inability to locate products with sufficiently similar
battery energies and the fact that the products tested did not span a
significant range of performance. DOE's test data for this product
class are available in Chapter 5 of the accompanying SNOPR TSD. To
develop an engineering analysis for this product class, DOE relied on,
among other things, the results gleaned from Product Class 5,
interviews with manufacturers, and its limited test data from Product
Class 6.
The difference between Product Class 5 and Product Class 6 is the
range of voltages that are covered. Product Class 5 covers low-voltage
(less than 20 V) and medium energy (100 Wh to 3,000 Wh) products, while
Product Class 6 covers high-voltage (greater than or equal to 20 V) and
medium energy (100 Wh to 3,000 Wh) products. The representative unit
examined for Product Class 5 is a 12 V, 800 Wh battery charger, while
the representative unit analyzed for Product Class 6 is a 24 V, 400 Wh
battery charger. Despite the change in voltage, DOE believes that
similar technology options and battery charging strategies are
available in both classes. Both chargers are used with relatively large
sealed, lead-acid batteries in products like electric scooters and
electric lawn mowers. However, since the battery chargers in Product
Class 6 work with higher voltages, current can be reduced for the same
output power, which creates the potential for making these devices
slightly more efficient because I\2\R losses\24\ will be reduced.
---------------------------------------------------------------------------
\24\ At a basic level, I\2\R losses are the power losses caused
by the flow of an electrical current through a component's
electrical resistance. In electrical circuits, I\2\R losses manifest
themselves as heat and are the result of high levels of current flow
through a device.
---------------------------------------------------------------------------
DOE examined as part of its NOPR and this SNOPR its Product Class 5
results and analyzed how the performance may be impacted if similar
technologies are used. The resulting performance parameters are shown
in Table IV-8. To account for the projected variation in energy
consumption, DOE used information on charge time and maintenance mode
power to adjust the corresponding values for 24-hour energy use.
Additionally, DOE discussed with manufacturers how costs may differ in
manufacturing a 12 V (Product Class 5) charger versus a 24 V (Product
Class 6) charger. Manufacturers indicated during manufacturer
interviews that, holding constant all other factors, there would likely
be minimal change, if any, in the cost. Therefore, because DOE scaled
performance assuming that the designs for corresponding CSLs in each
product class used the same design options and only differed in
voltage, DOE did not scale costs from Product Class 5. Rather than
scaling the Product Class 5 costs, DOE used the same MSPs for Product
Class 6 that were developed from IHS Technology teardown data for
Product Class 5. CEC and NRDC commented that while Product Classes 5
and 6 share the same costs, DOE should use lower cost estimates for
units that are less powerful. (California Energy Commission, No. 117 at
p. 16; NRDC, No. 114 at p. 7) DOE is not persuaded that lower cost
estimates for less powerful units would accurately reflect costs for
Product Classes 5 and 6 because this assertion is contrary to
statements made during interviews with manufacturers during the NOPR
stage of this analysis. Additionally, many of the battery chargers in
Product Classes 5 and 6 are multi-voltage, multi-capacity chargers,
therefore, costs typically reflecting component costs required to
achieve the higher power range. Consequently, varying cost by power
levels in the manner suggested by these commenters would be
inappropriate. DOE believes these costs are an accurate representation
of the MSPs, but seeks comment on its methodology in scaling the
results of Product Class 5 to Product Class 6, including the decision
to hold MSPs constant.
DOE received several comments in response to the NOPR regarding the
engineering results for Product Classes 5 and 6. The CEC argued that
manufacturers could meet CSL 3 without including a shut-off relay into
the charger design and therefore the costs associated with CSL 3 are
too high in DOE's analysis. (California Energy Commission, No. 117 at
p. 16) CEC also commented that for these product classes, DOE's results
show that units at the max tech levels, or CSL 3, perform worse in
active mode efficiency levels in units lower than CSL 2. (California
Energy Commission, No. 117 at p. 16)
For Product Classes 5 and 6, CSL 3 is the maximum technologically
feasible level analyzed by DOE. By definition, these products were not
found to be present in the market. The NOPR and Chapter 5 of the
accompanying SNOPR TSD both indicate that manufacturers support non-
novel improvements in improving the efficiency of the SCR
(semiconductor rectifier) and switch mode topologies. However, these
improvements would not result in compliance with CSL 3 and that only by
introducing a relay to bring the non-active and maintenance mode energy
use to zero could this level be met. Manufacturers and subject matter
experts were consulted to verify the costs with making these changes.
Concerning the drop in active mode efficiency identified by CEC, DOE
found a calculation error in E24 use for these products that caused
this error in the representative UEC values. The errors have been
corrected and updated results can be seen in Table IV-8 and Table IV-9.
[[Page 52881]]
Table IV-8--Product Class 5 (Medium-Energy, Low-Voltage) Engineering Analysis Results
----------------------------------------------------------------------------------------------------------------
CSL 0 CSL 1 CSL 2 CSL 3
----------------------------------------------------------------------------------------------------------------
CSL Description................................. Baseline Intermediate Best in Market Max Tech
24-Hour Energy (Wh)............................. 2036.9 1647.3 1292.00 1025.64
Maintenance Mode Power (W)...................... 21.2 11.9 0.50 0.0
No-Battery Mode Power (W)....................... 20.1 11.6 0.30 0.0
Off-Mode Power (W).............................. 0.0 0.0 0.0 0.0
Unit Energy Consumption (kWh/yr)................ 84.60 56.09 21.39 9.11
Incremental MSP [$]............................. $18.48 $21.71 $26.81 $127.00
----------------------------------------------------------------------------------------------------------------
Table IV-9--Product Class 6 (Medium-Energy, High-Voltage) Engineering Analysis Results
----------------------------------------------------------------------------------------------------------------
CSL 0 CSL 1 CSL 2 CSL 3
----------------------------------------------------------------------------------------------------------------
CSL Description................................. Baseline Intermediate Best in Market Max Tech
24-Hour Energy (Wh)............................. 891.6 786.1 652.00 466.20
Maintenance Mode Power (W)...................... 10.6 6.0 0.50 0.0
No-Battery Mode Power (W)....................... 10.0 5.8 0.30 0.0
Off-Mode Power (W).............................. 0.0 0.0 0.0 0.0
Unit Energy Consumption (kWh/yr)................ 120.60 81.72 33.53 8.15
Incremental MSP [$]............................. $18.48 $21.71 $26.81 $127.00
----------------------------------------------------------------------------------------------------------------
DOE received a comment from NRDC supporting the proposed standards
for Product Class 7. (NRDC, No. 114 at p. 8) No other comments specific
to DOE's costs for Product Class 7 were received and no changes were
made to its results, which are presented in Table IV-10.
Table IV-10--Product Class 7 (High-Energy) Engineering Analysis Results
----------------------------------------------------------------------------------------------------------------
CSL 0 CSL 1 CSL 2
----------------------------------------------------------------------------------------------------------------
CSL Description................................................. Baseline Intermediate Max Tech
24-Hour Energy (Wh)............................................. 5884.2 5311.1 4860.0
Maintenance Mode Power (W)...................................... 10.0 3.3 2.6
No-Battery Mode Power (W)....................................... 0.0 1.5 0.0
Off-Mode Power (W).............................................. 0.0 0.0 0.0
Unit Energy Consumption (kWh/yr)................................ 255.05 191.74 131.44
Incremental MSP [$]............................................. $88.07 $60.86 $164.14
----------------------------------------------------------------------------------------------------------------
DOE requests stakeholder comments on the updated engineering
analysis results presented in this analysis for Products Classes 2-6.
10. Scaling of Battery Charger Candidate Standard Levels
In preparing its proposed standards for products within a product
class (which would address all battery energies and voltages falling
within that class), DOE used a UEC scaling approach. After developing
the engineering analysis results for the representative units, DOE had
to determine a methodology for extending the UEC at each CSL to all
other ratings not directly analyzed for a given product class. In the
NOPR, DOE proposed making UEC a function of battery energy. DOE also
indicated that it based this proposed UEC function on the test data
that had been obtained up through the NOPR.
For Product Classes 2-7, DOE created equations for UEC that scale
with battery energy. In contrast, for Product Class 1, each CSL was
represented by one flat, nominal standard. For this product class, test
data showed that battery energy appeared to have little impact on UEC.
In response to these data, DOE received comment from several interested
parties, ITI, CEA, and NRDC, who requested that Product Class 1 be
scaled similarly to the other product classes by battery energy. (ITI,
No. 134 at p. 6, 7; ITI. Pub. Mtg. Tr., No. 104 at p. 46; CEA, No. 106
at p. 5; NRDC, No. 114 at p. 8) Similarly, Duracell suggested that if
DOE declined to update its usage profile assumptions, discussed later
in section IV.F, then DOE should maintain its current use assumptions
and adopt the formula for determining the maximum UEC limit that was
proposed for Product Class 2. (Duracell, No. 109 at p. 1) DOE found in
testing that UEC for Product Class 1 did not vary with battery energy
or voltage, so DOE opted to maintain its approach proposed in the NOPR
to adopt a constant standard across all battery energies. No changes
were made to the updated SNOPR TSD for the reasons stated above
regarding the impact of battery energy on UECs that were calculated for
Product Class 1.
Finally, when DOE was developing its CSL equations for UEC, it
found during testing that the correlation between points at low battery
energies was much worse than for the rest of the range of battery
energy, which indicated that the initial equations DOE had initially
planned to use did not match the test results. To address this
situation, DOE generated a boundary condition for its CSL equations,
which essentially flattens the UEC below a certain threshold of battery
energy to recognize that below certain values, fixed power components
of UEC, such as maintenance mode power, dominate UEC. Making this
change helped DOE to create a better-fitting equation to account for
these types of conditions to ensure that any standards that are set
better reflect the particular characteristics of a given product.
The CEC and the CA IOUs commented on the use of boundary conditions
in certain product classes. CEC requested that DOE, where
[[Page 52882]]
possible, reduce the number of product classes by creating a single
product class where the scaling and boundary condition transition
seamlessly from one product class to the other. (California Energy
Commission, No. 117 at p. 26, 29) While the CA IOUs were concerned that
the boundary condition creates a scenario where voltage can be adjusted
to exploit the standards for Product Classes 2-4, (CA IOUs, No. 138 at
p. 20), DOE's approach separates product classes as described in
Chapter 3 of the SNOPR TSD and section IV.A.3 of this SNOPR. When
setting standards, this segregation of product classes should
adequately address the natural groupings of products in the market.
Accordingly, DOE made no changes to its proposed product class
distinctions as part of its SNOPR analysis.
Concerning the scaling of specific product classes, DOE received
several comments. Duracell commented that the standards for Product
Class 1, inductive chargers, seem to underlay stricter standards than
comparable products that are galvanic-coupled, such as Product Class 2.
(Duracell, No. 109 at p. 1) NRDC and CEC both support DOE's engineering
results and proposed standard for Product Class 1. (NRDC, No. 114 at p.
8; California Energy Commission, No. 117 at p. 28) DOE notes that
Product Class 1, as stated above, is not scaled, which could give the
mistaken impression that Product Class 1 has a stricter standard
compared to other product class applications that allow for higher
energy consumption as battery energy increased. However, as indicated
in the NOPR, DOE determined that the UEC for this product class did not
vary with battery energy or voltage, thereby eliminating the need to
scale.
For additional details and the exact CSL equations developed for
each product class, please see Chapter 5 in the accompanying SNOPR TSD.
D. Markups Analysis
The markups analysis develops appropriate markups in the
distribution chain to convert the MSP estimates derived in the
engineering analysis to consumer prices. At each step in the
distribution channel, companies mark up the price of the product to
cover business costs and profit margin. Given the variety of products
that use battery chargers, distribution varies depending on the product
class and application. As such, similar to the approach used in the
NOPR, DOE assumed that the dominant path to market establishes the
retail price and, thus, the markup for a given application. The markups
applied to end-use products that use battery chargers are
approximations of the battery charger markups.
In the case of battery chargers, the dominant path to market
typically involves an end-use product manufacturer (i.e., an original
equipment manufacturer or ``OEM'') and retailer. DOE developed OEM and
retailer markups by examining annual financial filings, such as
Securities and Exchange Commission (SEC) 10-K reports, from more than
80 publicly traded OEMs, retailers, and distributors engaged in the
manufacturing and/or sales of consumer applications that use battery
chargers.
DOE calculated two markups for each product in the markups
analysis. A markup applied to the baseline component of a product's
cost (referred to as a baseline markup) and a markup applied to the
incremental cost increase that would result from energy conservation
standards (referred to as an incremental markup). The incremental
markup relates the change in the MSP of higher-efficiency models (the
incremental cost increase) to the change in the retailer's selling
price.
Commenting on retail markups, Phillips, Schumacher, and Wahl
Clipper stated that the concept of margins is very significant to
retailers, and it is not realistic to predict that retailers will
voluntarily reduce their profit margins. (Philips, No. 128 at p. 6;
Schumacher, No. 182 at p. 6; Wahl Clipper, No 153 at p. 2) Motorola
commented that retailers will not be willing to lower their markups
because product efficiency has increased. (Motorola Mobility, No. 121
at p. 4) In contrast, PTI stated that DOE's estimates of markups are
sufficient for the purposes of the analysis. (PTI, No. 133 at p. 6)
DOE recognizes that retailers may seek to preserve margins.
However, DOE's approach assumes that appliance retail markets are
reasonably competitive, so that an increase in the manufacturing cost
of appliances is not likely to contribute to a proportionate rise in
retail profits, as would be expected to happen if markups remained
constant. DOE's methodology for estimating markups is based on a mix of
economic theory, consultation with industry experts, and data from
appliance retailers.\25\ In conducting research, DOE has found that
empirical evidence is lacking with respect to appliance retailer markup
practices when a product increases in cost (due to increased efficiency
or other factors). DOE understands that real-world retailer markup
practices vary depending on market conditions and on the magnitude of
the change in cost of goods sold (CGS) associated with an increase in
appliance efficiency. DOE acknowledges that detailed information on
actual retail practices would be helpful in evaluating changes in
markups on products after appliance standards take effect. For this
rulemaking, DOE requested data from stakeholders in support of
alternative approaches to markups, as well as any data that shed light
on actual practices by retailers; however, no such data were provided.
Thus, DOE's analysis continues using an approach that is consistent
with the conventionally-accepted economic theory of firm behavior in
competitive markets.
---------------------------------------------------------------------------
\25\ An extensive discussion of the methodology and
justification behind DOE's general approach to markups calculation
is presented in Larry Dale, et al., ``An Analysis of Price
Determination and Markups in the Air-Conditioning and Heating
Equipment Industry.'' LBNL-52791 (2004). Available for download at
http://eetd.lbl.gov/sites/all/files/an_analysis_of_price_determiniation_and_markups_in_the_air_conditioning_and_heating_equipment_industry_lbnl-52791.pdf
---------------------------------------------------------------------------
Chapter 6 of the SNOPR TSD provides details on DOE's development of
markups for battery chargers.
E. Energy Use Analysis
The energy use analysis estimates the range of energy use of
battery chargers in the field, i.e., as they are actually used by
consumers. The energy use analysis provides the basis for the other
analyses DOE uses when assessing the costs and benefits of setting
standards for a given product. Particularly dependent on the energy
analysis are assessments of the energy savings and the savings in
consumer operating costs that could result from the adoption of new or
amended standards.
Battery chargers are power conversion devices that transform input
voltage to a suitable voltage for the battery they are powering. A
portion of the energy that flows into a battery charger flows out to a
battery and, thus, cannot be considered to be consumed by the battery
charger. However, to provide the necessary output power, other factors
contribute to the battery charger energy consumption, e.g., internal
losses and overhead circuitry.\26\ Therefore, the traditional method
for calculating energy consumption--by measuring the energy a product
draws from mains while performing its intended function(s)--is not
appropriate for a battery charger because that method would not factor
in the energy delivered
[[Page 52883]]
by the battery charger to the battery, and thus would overstate the
battery charger's energy consumption. Instead, DOE considered energy
consumption to be the energy dissipated by the battery chargers
(losses) and not delivered to the battery as a more accurate means to
determine the energy consumption of these products. Once the energy and
power requirements of those batteries were determined, DOE considered
them fixed, and DOE focused its analysis on how standards would affect
the energy consumption of battery chargers themselves.
---------------------------------------------------------------------------
\26\ Internal losses are energy losses that occur during the
power conversion process. Overhead circuitry refers to circuits and
other components of the battery charger, such as monitoring
circuits, logic circuits, and LED indicator lights, that consume
power but do not directly contribute power to the end-use
application.
---------------------------------------------------------------------------
Applying a single usage profile to each application, DOE calculated
the unit energy consumption for battery chargers. In addition, as a
sensitivity analysis, DOE examined the usage profiles of multiple user
types for applications where usage varies widely (for example, a light
user and a heavy user).
In response to the NOPR, stakeholders suggested alternative usage
profiles for two applications. Delta-Q recommended alternate usage
profiles for golf cart battery chargers used in the residential and
commercial sectors. These suggested usage profiles assumed higher
levels of time in active and maintenance modes and no time in unplugged
mode. (Delta-Q, No. 113 at p. 1) For the NOPR, DOE based its estimate
of the golf cart usage profile on responses from the manufacturer
interviews. The usage profile suggested by Delta-Q is consistent with
the stakeholder-provided data that currently underlie DOE's golf cart
battery charger usage profile. Based on these estimates, the usage
profiles developed for the NOPR have accurately described usage for
golf cart battery charges and no changes to the updated analysis were
required.
Duracell recommended that DOE adopt one of three alternative
approaches to capturing usage profiles and energy use for inductive
battery chargers. (Duracell, No. 109 at p. 1) First, it requested that
DOE allow each inductive battery charger manufacturer to apply use
conditions based on the typical use of its products. However, DOE
believes this approach to be infeasible, as it would be
administratively burdensome for DOE with its limited resources to
verify the individual usage profiles applied by each manufacturer for
each product to determine compliance with the given standard. DOE notes
that its proposed approach relies on usage profiles based on available
data and provides a reasonable average usage approximation of the
products falling within each proposed class. Second, Duracell asked DOE
to adopt a revised usage profile that it believed would be more
applicable to toothbrushes and shavers. DOE has based its estimate of
the usage profile on responses from the manufacturer interviews and
believes that it has accurately described usage for battery chargers in
Product Classes 1 and 2, and did not make changes to these usage
profiles for the SNOPR.
PTI and AHAM both voiced support for the usage profiles presented
by DOE in the NOPR. PTI commented that DOE accurately captured
variations in the commercial and residential use of power tools in its
product class average usage profiles. (PTI, No. 133 at p. 3) While AHAM
commented that DOE could more accurately capture the usage of
infrequently used product classes, AHAM supported DOE's efforts to
consider the variation in usage for battery chargers and recommended
that DOE reevaluate these usage profiles in the future to more
accurately quantify the usage profiles for infrequently charged
products. (AHAM, No. 124 at p. 7) Based on these comments, DOE saw no
need to alter its usage profiles.
Responding to the NOPR, the CEC submitted comments stating that it
found inconsistencies between the NOPR TSD, energy use spreadsheet, and
the NIA spreadsheet. These errors were with the CSL 0 and CSL 1 24-hour
energy assumption and the average unit energy consumption estimates,
particularly for battery charger Product Class 2. (California Energy
Commission, No. 117 at p. 9)
In light of the CEC's observation, DOE reviewed its spreadsheet and
confirmed that the energy use analysis contained an error in the 24-
hour energy values for CSLs 0 and 1 for Product Class 2. DOE has since
rectified this error, and revised the engineering and energy use
analyses in its updated SNOPR TSD. The corrected 24-hour energy values
resulted in a small increase in UECs in the energy use analysis.
F. Life-Cycle Cost and Payback Period Analyses
DOE conducted LCC and PBP analyses to evaluate the economic impacts
on individual consumers from potential battery charger energy
conservation standards. The effect of new or amended energy
conservation standards on individual consumers usually involves a
reduction in operating cost and an increase in purchase cost. DOE used
the following two metrics to measure consumer impacts:
The LCC (life-cycle cost) is the total consumer expense of
an appliance or product over the life of that product, consisting of
total installed cost (manufacturer selling price, distribution chain
markups, sales tax, and installation costs) plus operating costs
(expenses for energy use, maintenance, and repair). To compute the
operating costs, DOE discounts future operating costs to the time of
purchase and sums them over the lifetime of the product.
The PBP (payback period) is the estimated amount of time
(in years) it takes consumers to recover the increased purchase cost
(including installation) of a more-efficient product through lower
operating costs. DOE calculates the PBP by dividing the change in
purchase cost at higher efficiency levels by the change in annual
operating cost for the year that amended or new standards are assumed
to take effect.
For any given efficiency level, DOE measures the change in LCC
relative to an estimate of the base-case product efficiency
distribution. The base case distribution reflects the market in the
absence of new or amended energy conservation standards, including
market trends for products that exceed the current energy conservation
standards. In contrast, the PBP is measured relative to the baseline
product.
For each considered efficiency level in each product class, DOE
calculated the LCC and PBP for a nationally representative set of
consumers. For each sampled consumer, DOE determined the energy
consumption for the battery charger and the appropriate electricity
price. By developing a representative sample of consumers, the analysis
captured the variability in energy consumption and energy prices
associated with the use of battery chargers.
Inputs to the calculation of total installed cost include the cost
of the product--which includes MSPs, manufacturer markups, retailer and
distributor markups, and sales taxes--and installation costs. Inputs to
the calculation of operating expenses include annual energy
consumption, energy prices and price projections, repair and
maintenance costs, product lifetimes, and discount rates. DOE created
distributions of values for product lifetime, discount rates, and sales
taxes, with probabilities attached to each value, to account for their
uncertainty and variability.
The computer model DOE uses to calculate the LCC and PBP, which
incorporates Crystal Ball\TM\ (a commercially-available software
program), relies on a Monte Carlo simulation to incorporate uncertainty
and variability into the analysis. The Monte Carlo simulations randomly
[[Page 52884]]
sample input values from the probability distributions and battery
charger user samples. The model calculated the LCC and PBP for products
at each efficiency level for 10,000 consumers per simulation run.
DOE calculated the LCC and PBP for all consumers as if each were to
purchase a new product in the year that compliance with any amended
standards is expected to be required. Any national standards would
apply to battery chargers manufactured 2 years after the date on which
any final amended standard is published. For this SNOPR, DOE estimates
publication of a final rule in 2016. Therefore, for purposes of its
analysis, DOE used 2018 as the first year of compliance with any
amended standards.
Table IV-11 summarizes the approach and data that DOE used to
derive the inputs to the LCC and PBP calculations for the NOPR and the
changes made for this SNOPR. The subsections that follow provide
further discussion on these inputs and the comments DOE received
regarding its presentation of the LCC and PBP analyses in the NOPR, as
well as DOE's responses. Details of the spreadsheet model, and of all
the inputs to the LCC and PBP analyses, are contained in chapter 8 and
its appendices of the SNOPR TSD.
Table IV-11--Summary of Inputs and Methods for the NOPR and SNOPR LCC
and PBP Analyses
------------------------------------------------------------------------
Changes for the
Inputs March 2012 NOPR SNOPR
------------------------------------------------------------------------
Manufacturer Selling Price.. Derived from the Adjusted
Engineering Analysis component
through manufacturer breakdowns and
interviews and test/ prices based
teardown results. on updated
cost data from
IHS Technology
and SME
feedback for
Product
Classes 2
through 6.
Markups..................... Considered various No change.
distribution channel
pathways for different
applications. Applied a
reduced ``incremental''
markup to the portion of
the product price
exceeding the baseline
price. See Chapter 6 of
the SNOPR TSD for
details.
Sales Tax................... Derived weighted-average Updated the
tax values for each sales tax
Census division and using the
large state from data latest
provided by the Sales information
Tax Clearinghouse.\1\ from the Sales
Tax
Clearinghouse.
\2\
Installation Costs.......... Assumed to be zero....... No change.
Annual Energy Use........... Determined for each No change.
application based on
battery characteristics
and usage profiles..
Energy Prices............... Price: Based on EIA's Updated to
2008 Form EIA-861 EIA's 2012
data.\3\ Variability: Form EIA-861
Regional energy prices data.\4\
determined for 13 Separated top
regions. DOE also tier and peak
considered subgroup time-of-use
analyses using consumers into
electricity prices for separate
low-income consumers and subgroup
top tier marginal price analyses.
consumers.
Energy Price Trends......... Forecasted with EIA's Updated with
Annual Energy Outlook EIA's Annual
2010 \5\. Energy Outlook
2014.\6\
Repair and Maintenance Costs Assumed to be zero....... No change.
Product Lifetime............ Determined for each No change.
application based on
multiple data sources
See chapter 3 of the
SNOPR TSD for details..
Discount Rates.............. Residential: Approach Residential:
based on the finance DOE updated
cost of raising funds to the
purchase and operate calculations
battery chargers either to consider
through the financial the geometric
cost of any debt means for all
incurred (based on the time-series
Federal Reserve's Survey data from 1984-
of Consumer Finances 2013. DOE
data \7\ for 1989, 1992, added data
1995, 1998, 2001, 2004, from the
and 2007) or the Federal
opportunity cost of any Reserve's
equity used. Time-series Survey of
data was based on Consumer
geometric means from Finances for
1980-2009. 2010.
Commercial: Derived Commercial: DOE
discount rates using the updated all
cost of capital of sources to the
publicly-traded firms most recent
based on data from version
Damodaran Online,\8\ the (Damodaran
Value Line Investment Online and the
survey,\9\ and the OMB Circular
Office of Management and No. A-94).
Budget (OMB) Circular
No. A-94.\10\ DOE used a
40-year average return
on 10-year treasury
notes to derive the risk-
free rate. DOE updated
the equity risk premium
to use the geometric
average return on the
S&P 500 over a 40-year
time period.
Sectors Analyzed............ All reference case No change.
results represent a
weighted average of the
residential and
commercial sectors.
Base Case Market Efficiency Where possible, DOE No change.
Distribution. derived market
efficiency distributions
for specific
applications within a
product class.
Compliance Date............. 2013..................... 2018.
------------------------------------------------------------------------
\1\ The four large States are New York, California, Texas, and Florida.
\2\ Sales Tax Clearinghouse, Aggregate State Tax Rates. Available at:
https://thestc.com/STRates.stm.
\3\ U.S. Department of Energy. Energy Information Administration. Form
EIA-861 Final Data File for 2008. May, 2014. Washington, D.C.
Available at: http://www.eia.doe.gov/cneaf/electricity/page/eia861.html.
\4\ U.S. Department of Energy. Energy Information Administration. Form
EIA-861 Final Data File for 2012. September, 2012. Washington, D.C.
Available at: http://www.eia.doe.gov/cneaf/electricity/page/eia861.html.
\5\ U.S. Department of Energy. Energy Information Administration. Annual
Energy Outlook 2010. November, 2010. Washington, D.C. Available at:
http://www.eia.doe.gov/oiaf/aeo/.
\6\ U.S. Department of Energy. Energy Information Administration. Annual
Energy Outlook 2014. April, 2014. Washington, D.C. Available at: http://www.eia.gov/forecasts/aeo/.
\7\ The Federal Reserve Board, Survey of Consumer Finances. Available
at: http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html.
\8\ Damodaran Online Data Page, Historical Returns on Stocks, Bonds and
Bills--United States, 2010. Available at: http://pages.stern.nyu.edu/
~adamodar.
\9\ Value Line. Value Line Investment Survey. Available at: http://www.valueline.com.
\10\ U.S. Office of Management and Budget. Circular No. A-94. Appendix
C. 2009. Available at: http://www.whitehouse.gov/omb/circulars_a094_a94_appx-c/.
[[Page 52885]]
1. Product Cost
a. Manufacturer Selling Price
In the preliminary analysis, DOE used a combination of test and
teardown results and manufacturer interview results to develop MSPs.
DOE conducted tests and teardowns on a large number of additional units
and applications for the NOPR, and incorporated these findings into the
MSP. For the SNOPR, DOE adjusted component breakdowns and prices based
on updated cost data from IHS Technology (formerly i-Suppli) and SME
feedback for Product Classes 2, 3, 4, 5 and 6. DOE adjusted its MSPs
based on these changes. Further detail on the MSPs can be found in
chapter 5 of the SNOPR TSD.
Examination of historical price data for a number of appliances
that have been subject to energy conservation standards indicates that
an assumption of constant real prices and costs may overestimate long-
term trends in appliance prices. Economic literature and historical
data suggest that the real costs of these products may in fact trend
downward over time according to ``learning'' or ``experience'' curves.
On February 22, 2011, DOE published a Notice of Data Availability
(NODA) stating that DOE may consider refining its analysis by
addressing equipment price trends. (76 FR 9696) It also raised the
possibility that once sufficient long-term data are available on the
cost or price trends for a given product subject to energy conservation
standards (such as battery chargers), DOE would consider these data to
forecast future trends.
To forecast a price trend for the NOPR, DOE considered the
experience curve approach, in which an experience rate parameter is
derived using two historical data series on price and cumulative
production. But in the absence of historical shipments of battery
chargers and sufficient historical Producer Price Index (PPI) data for
small electrical appliance manufacturing from the U.S. Department of
Labor's Bureau of Labor Statistics' (BLS),\27\ DOE could not use this
approach. This situation is partially due to the nature of battery
charger designs. Battery chargers are made up of many electrical
components whose size, cost, and performance rapidly change, which
leads to relatively short design lifetimes. DOE also considered
performing an exponential fit on the deflated AEO's Projected Price
Indexes that most narrowly include battery chargers. However, DOE
believes that these indexes are sufficiently broad that they may not
accurately capture the trend for battery chargers. Furthermore, battery
chargers are not typical consumer products; they more closely resemble
commodities that OEMs purchase.
---------------------------------------------------------------------------
\27\ Series ID PCU33521-33521; http://www.bls.gov/ppi/.
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Given the uncertainty involved with these products, DOE did not
incorporate product price changes into the NOPR analysis and is not
including them in this SNOPR. For the NIA, DOE also analyzed the
sensitivity of results to two alternative battery charger price
forecasts. Appendix 10-B of the SNOPR TSD describes the derivation of
alternative price forecasts.
b. Markups
DOE applies a series of markups to the MSP to account for the
various distribution chain markups applied to the analyzed product.
These markups are evaluated for each application individually,
depending on its path to market. Additionally, DOE splits its markups
into ``baseline'' and ``incremental'' markups. The baseline markup is
applied to the entire MSP of the baseline product. The incremental
markups are then applied to the marginal increase in MSP over the
baseline's MSP. Further detail on the markups can be found in chapter 6
of the SNOPR TSD.
c. Sales Tax
As in the NOPR, DOE obtained State and local sales tax data from
the Sales Tax Clearinghouse. The data represented weighted averages
that include county and city rates. DOE used the data to compute
population-weighted average tax values for each Census division and
four large States (New York, California, Texas, and Florida). For the
SNOPR, DOE retained this methodology and used updated sales tax data
from the Sales Tax Clearinghouse.\28\ DOE also obtained updated
population estimates from the U.S. Census Bureau for this SNOPR.\29\
---------------------------------------------------------------------------
\28\ Sales Tax Clearinghouse, Aggregate State Tax Rates. https://thestc.com/STRates.stm.
\29\ The U.S. Census Bureau. Annual Estimates of the Population
for the United States, Regions, States, and Puerto Rico: April 1,
2010 to July 1, 2013. http://www.census.gov/popest/data/state/totals/2013/tables/NST-EST2013-01.xls.
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d. Product Price Forecast
As noted in section IV.F, to derive its central estimates DOE
assumed no change in battery charger prices over the 2018-2047 period.
In addition, DOE conducted a sensitivity analysis using two alternative
price trends based on AEO price indexes. These price trends, and the
NPV results from the associated sensitivity cases, are described in
appendix 10-B of the SNOPR TSD.
2. Installation Cost
As detailed in the NOPR, DOE considered installation costs to be
zero for battery chargers because installation would typically entail a
consumer simply unpacking the battery charger from the box in which it
was sold and connecting the device to mains power and its associated
battery. Because the cost of this ``installation'' (which may be
considered temporary, as intermittently used devices might be unplugged
for storage) is not quantifiable in dollar terms, DOE considered the
installation cost to be zero.
DOE received comments responding to its installation cost
methodology. NEMA asserted that the results of the LCC cost and PBP
analysis did not accurately reflect the impact to industry as the cost
of implementation was consistently underestimated, resulting in an
overestimation of savings. NEMA noted that the LCC and PBP calculations
did not include installation costs and the cost of implementation
failed to include safety and reliability regression testing. In its
view, this testing ensures the long term intended efficiency gains
resulting from changes made to address the limits. NEMA criticized the
proposed scope as being too broad and the limits too severe, both of
which would force manufacturers to withdraw systems from the
marketplace until testing is concluded. NEMA asserted that shipping
cycle times also impact the availability in the marketplace; some of
these products are already sourced from Asia where a 90-day cycle time
for shipping by ocean is a necessity due to the low margins associated
with consumer products. (NEMA, No. 134 at p. 2) NEEA pointed out that
the LCC focuses on incremental costs, rather than overall costs. It
noted that it would be very difficult to find data supporting an
installation cost that increases with increasing efficiency levels.
(NEEA, Pub. Mtg. Transcript, No. 104 at p. 200)
NEMA did not give examples of systems which may be removed from the
market as a result of safety and reliability testing. In addition, LCC
analysis calculations only take into account the cost to consumers
across the lifetime of the product. Safety and reliability regression
testing would not be a cost to the consumer, but rather a cost to the
manufacturer. The MIA accounts for safety and reliability regression
testing as it is already incorporated into their product conversion
costs. Adding these costs to the LCC calculations would inaccurately
[[Page 52886]]
inflate the impact of these costs by effectively accounting for them
twice in the analysis. DOE agrees with the comments made by NEEA, as
any installation costs would likely be constant across all battery
charger efficiency levels and would have no impact when comparing LCCs
between CSLs in the analysis. Accordingly, DOE maintained its
assumption that zero installation costs would continue to apply.\30\
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\30\ DOE notes that ``installation costs'' are not the same as
``installed costs.'' ``Installation costs'' refer to the costs
incurred to install a given product--in this case, to plug the
charger into the electrical outlet in order to use it. In contrast,
``installed costs'' refer to the costs incurred to obtain and use
the product. These costs, as noted earlier, include the cost of the
product--which includes MSPs, manufacturer markups, retailer and
distributor markups, and sales taxes--as well as any installation
costs that might apply.
---------------------------------------------------------------------------
3. Annual Energy Consumption
The SNOPR analysis uses the same approach for determining UECs as
the approach used in the NOPR. The UEC was determined for each
application based on battery characteristics and usage profiles. As a
result of new testing and teardowns, described above, DOE updated some
or all of the UEC values for battery charger Product Classes 2, 3, 4, 5
and 6 for the SNOPR. The same approach and equations used to calculate
the representative unit UECs remain consistent with the NOPR. Further
detail on the UEC calculations can be found in section IV.E of this
notice and in chapter 7 of the SNOPR TSD.
4. Energy Prices
DOE determined energy prices by deriving regional average prices
for 13 geographic areas consisting of the nine U.S. Census divisions,
with four large States (New York, Florida, Texas, and California)
treated separately. The derivation of prices was based on the latest
available EIA data, covering 2012. In the NOPR analysis, DOE used data
from EIA's Annual Energy Outlook (AEO) 2010 to project electricity
prices to the end of the product lifetime.\31\ For this SNOPR, DOE used
the final release of the AEO2014,\32\ which contained reference, high-
and low-economic-growth scenarios. DOE received no comments on the
electricity price forecasts it used in its NOPR analyses.
---------------------------------------------------------------------------
\31\ U.S. Department of Energy. Energy Information
Administration. Annual Energy Outlook 2010. November, 2010.
Washington, DC http://www.eia.gov/forecasts/aeo/.
\32\ U.S. Department of Energy. Energy Information
Administration. Annual Energy Outlook 2014. May, 2014. Washington,
DC http://www.eia.gov/forecasts/aeo/.
---------------------------------------------------------------------------
5. Repair and Maintenance Costs
In the NOPR analysis, DOE did not consider repair or maintenance
costs for battery chargers. In making this decision, DOE recognized
that in some cases the service life of a stand-alone battery charger
typically exceeds that of the consumer product it powers. Furthermore,
DOE noted that the cost to repair the battery charger might exceed the
initial purchase cost, as these products are relatively low cost items.
Thus, DOE estimated that it would be extremely unlikely that a consumer
would incur repair or maintenance costs for a battery charger. Also, if
a battery charger failed, DOE expects that consumers would typically
discard the battery charger and purchase a replacement. DOE received no
comments challenging this assumption and has continued relying on this
assumption for purposes of calculating the SNOPR's potential costs and
benefits.
Although DOE did not assume any repair or maintenance costs would
apply generally to battery chargers, DOE included a maintenance cost
for the replacement of lithium ion batteries in certain battery charger
applications in the NOPR analysis. Through conversations with
manufacturers and subject matter experts, DOE learned that such
batteries would need replacing within the service life of the battery
charger for certain applications based on the battery lifetime and the
usage profile assigned to the application. Lithium ion batteries are
marginally more expensive than batteries with nickel chemistries (e.g.
``Ni-MH''), as explained in chapter 5 of accompanying SNOPR TSD. The
NOPR analysis accounted for this marginal cost increase of those
applications at CSLs that require the use of lithium batteries. This
maintenance cost only applied to applications where DOE believed the
lifetime of the application would surpass the lifetime of the battery.
DOE estimated the battery lifetime based on the total number of charges
the battery could handle divided by the number of charges per year
projected for the application. DOE relied on data provided by
manufacturers to estimate the total number of charges the battery could
undergo before expiring. See chapter 8, section 8.2.5 of the
accompanying SNOPR TSD.
For the SNOPR, DOE determined that the maintenance costs included
in the NOPR LCC analysis were not comparable to the costs associated
with those applications that had no maintenance costs. While the NOPR
costs considered the increase in price between repurchasing a lithium
battery instead of a nickel battery, the increase when purchasing the
initial battery was not considered for the analysis. Thus, DOE
determined that the maintenance cost did not apply to the battery
charger unit subject to the proposed standard, and removed all
maintenance costs from the SNOPR LCC analysis. Further detail on
maintenance costs can be found in chapter 8, section 8.2.5 of the SNOPR
TSD.
6. Product Lifetime
For the NOPR analysis, DOE considered the lifetime of a battery
charger to be from the moment it is purchased for end-use up until the
time when it is permanently retired from service. Because the typical
battery charger is purchased for use with a single associated
application, DOE assumed that it would remain in service for as long as
the application does. Even though many of the technology options to
improve battery charger efficiencies may result in an increased useful
life for the battery charger, the lifetime of the battery charger is
still directly tied to the lifetime of its associated application. The
typical consumer will not continue to use a battery charger once its
application has been discarded. For this reason, DOE used the same
lifetime estimate for the baseline and standard level designs of each
application for the LCC and PBP analyses.
Following the NOPR, Lester encouraged DOE to carefully consider
differences in product longevity in their LCC and PBP model. They noted
that in Product Class 7, CSL 0 and CSL 1 products employed
significantly different technologies that have considerably different
lifetimes; the difference in product longevity could result in major
changes to the DOE LCC and PBP model. (Lester Electrical, No. 139 at p.
3) DOE notes that because the lifetime of the battery charger is
directly tied to the lifetime of its associated application, improved
technologies affecting the lifetime of the battery charger will not
change the effective lifetime for the typical consumer. In the absence
of adverse comments to DOE's approach, DOE is continuing to use it in
the SNOPR analysis. Further detail on product lifetimes and how they
relate to applications can be found in chapter 3 of the SNOPR TSD.
7. Discount Rates
The NOPR analysis derived residential discount rates by identifying
all possible debt or asset classes that might be used to purchase and
operate products, including household assets that might be affected
indirectly. DOE
[[Page 52887]]
estimated the average shares of the various debt and equity classes in
the average U.S. household equity and debt portfolios using data from
the Survey of Consumer Finances (SCF) from 1989 to 2007.\33\ DOE used
the mean share of each class across the seven sample years as a basis
for estimating the effective financing rate for products. DOE estimated
interest or return rates associated with each type of equity using data
from the U.S. Federal Reserve \34\ and Damodaran. The analysis
calculates the risk-free rate using a 40-year average return on 10-year
U.S. Treasury notes, as reported by the U.S. Federal Reserve, and the
equity risk premium using the geometric average return on the S&P 500
over a 40-year time period. The mean real effective rate across the
classes of household debt and equity, weighted by the shares of each
class, was 5.1 percent.
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\33\ The Federal Reserve Board, Survey of Consumer Finances.
Available at: http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html
\34\ The Federal Reserve Board, Statistical Releases and
Historical Data, Selected Interest Rates (Daily)--H.15. http://www.federalreserve.gov/releases/H15/data.htm.
---------------------------------------------------------------------------
For the commercial sector, DOE derived the discount rate from the
cost of capital of publicly-traded firms that manufacture products that
involve the purchase of battery chargers. To obtain an average discount
rate value for the commercial sector, DOE used the share of each
industry category in total paid employees provided by BLS,\35\ as well
as employment data from both the U.S. Office of Personnel Management
\36\ and the U.S. Census Bureau.\37\ By multiplying the discount rate
for each industry category by its share of paid employees, DOE derived
a commercial discount rate of 7.1 percent.
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\35\ U.S. Bureau of Labor Statistics. Labor Force Statistics
from the Current Population Survey. Table 17--Employed persons by
Industry, Sex, Race, and Occupation. http://www.bls.gov/cps/cpsaat17.pdf.
\36\ U.S. Office of Personnel Management. Federal Employment
Reports. Historical Federal Workforce Tables. http://www.opm.gov/policy-data-oversight/data-analysis-documentation/federal-employment-reports/historical-tables/total-government-employment-since-1962.
\37\ U.S. Census Bureau. Government Employment and Payroll. 2012
State and Local Government. http://www2.census.gov/govs/apes/12stlall.xls.
---------------------------------------------------------------------------
For the SNOPR, DOE used the same methodology as the NOPR with
applicable updates to data sources. When deriving the residential
discount rates, DOE added the 2010 Survey of Consumer Finances to their
data set. For all time-series data, DOE evaluated rates over the 30-
year time period of 1984-2013. The new discount rates are estimated to
be 5.2 percent and 5.1 percent in the residential and commercial
sectors, respectively. For further details on discount rates, see
chapter 8 and appendix 8D of the SNOPR TSD.
8. Sectors Analyzed
The NOPR analysis included an examination of a weighted average of
the residential and commercial sectors as the reference case scenario.
Additionally, all application inputs were specified as either
residential or commercial sector data. Using these inputs, DOE then
sampled each application based on its shipment weighting and used the
appropriate residential or commercial inputs based on the sector of the
sampled application. This approach provided specificity as to the
appropriate input values for each sector, and permitted an examination
of the LCC results for a given product class in total. DOE maintained
this approach in the SNOPR. For further details on sectors analyzed,
see chapter 8 of the SNOPR TSD.
9. Base Case Market Efficiency Distribution
For purposes of conducting the LCC analysis, DOE analyzed CSLs
relative to a base case (i.e., a case without new Federal energy
conservation standards). This analysis required an estimate of the
distribution of product efficiencies in the base case (i.e., what
consumers would have purchased in 2018 in the absence of new Federal
standards). Rather than analyzing the impacts of a particular standard
level assuming that all consumers will purchase products at the
baseline efficiency level, DOE conducted the analysis by taking into
account the breadth of product energy efficiencies that consumers are
expected to purchase under the base case.
In preparing the NOPR analysis, DOE derived base case market
efficiency distributions that were specific to each application where
it had sufficient data to do so. This approach helped to ensure that
the market distribution for applications with fewer shipments was not
disproportionately skewed by the market distribution of the
applications with the majority of shipments. DOE factored into its
efficiency distributions the current efficiency regulations in
California. See section IV.G.3). For this SNOPR, DOE maintained the
methodology for generating base case market efficiency distributions
used in the NOPR analysis.
10. Compliance Date
The compliance date is the date when a new standard becomes
operative, i.e., the date by which battery charger manufacturers must
manufacture products that comply with the standard. DOE's publication
of a final rule in this standards rulemaking is scheduled for
completion by 2016. There are no requirements for the compliance date
for battery charger standards, but DOE has chosen a two-year time
period between publication and compliance for two reasons. First,
manufacturers are already complying with the current CEC standards,
which suggests that a two-year time frame would be reasonable. Second,
this time-frame is consistent with the one that DOE initially proposed
to apply for external power supplies, which were previously bundled
together with battery chargers as part of DOE's initial efforts to
regulate both of these products. DOE calculated the LCCs for all
consumers as if each would purchase a new product in the year that
manufacturers would be required to meet the new standard (2018).
However, DOE bases the cost of the equipment on the most recently
available data, with all dollar values expressed in 2013$.
11. Payback Period Inputs
The PBP is the amount of time it takes the consumer to recover the
additional installed cost of more-efficient products, compared to
baseline products, through energy cost savings. Payback periods are
expressed in years. Payback periods that exceed the life of the product
mean that the increased total installed cost is not recovered in
reduced operating expenses.
The inputs to the PBP calculation for each efficiency level are the
change in total installed cost of the product and the change in the
first-year annual operating expenditures relative to the baseline. The
PBP calculation uses the same inputs as the LCC analysis, except that
energy price trends and discount rates are not needed; only energy
prices for the year the standard becomes required for compliance (2018
in this case) are needed.
EPCA, as amended, establishes a rebuttable presumption that a
standard is economically justified if the Secretary finds that the
additional cost to the consumer of purchasing a product complying with
an energy conservation standard level will be less than three times the
value of the first year's energy savings resulting from the standard,
as calculated under the applicable test procedure. (42 U.S.C.
6295(o)(2)(B)(iii)) For each considered efficiency level, DOE
determined the value of the first year's energy savings by calculating
the energy savings in accordance with the applicable DOE test
procedure, and multiplying those savings by the average
[[Page 52888]]
energy price forecast for the year in which compliance with the
proposed standards would be required.
DOE received a comment from ITI on its PBP analysis. ITI pointed
out that the NOPR stated ``a standard is economically justified if the
Secretary finds that the additional cost to the consumer of purchasing
a product complying with an energy conservation standard level will be
less than three times the value of the energy savings during the first
year.'' (ITI, No. 131 at p. 6)
DOE's LCC and PBP analyses generate values that calculate the PBP
for consumers of products subject to potential energy conservation
standards, which includes, but is not limited to, the three-year PBP
contemplated under the rebuttable presumption test. However, DOE
routinely conducts a full economic analysis that considers the full
range of impacts, including those to the consumer, manufacturer,
Nation, and environment, as required under 42 U.S.C. 6295(o)(2)(B)(i)
and 42 U.S.C. 6316(e)(1). The results of this analysis serve as the
basis for DOE to definitively evaluate the economic justification for a
potential standard level (thereby supporting or rebutting the results
of any preliminary determination of economic justification).
G. Shipments Analysis
Projections of product shipments are needed to forecast the impacts
that standards are likely to have on the Nation. DOE develops shipment
projections based on an analysis of key market drivers for each
considered product. In DOE's shipments model, shipments of products
were calculated based on current shipments of product applications
powered by battery chargers. The inventory model takes an accounting
approach, tracking remaining shipments and the vintage of units in the
existing stock for each year of the analysis period.
Based on comments received on the Preliminary Analysis, DOE
conducted a sensitivity analysis to examine how increases in end-use
product prices resulting from standards might affect shipment volumes.
To DOE's knowledge, elasticity estimates are not readily available in
existing literature for battery chargers, or the end-use consumer
products that DOE is analyzing in this rulemaking. Because some
applications using battery chargers could be considered more
discretionary than major home appliances, which have an estimated
relative price elasticity of -0.34,\38\ DOE believed a higher
elasticity of demand was possible. In its sensitivity analysis, DOE
assumed a price elasticity of demand of -1, meaning a given percentage
increase in the final product price would be accompanied by that same
percentage decrease in shipments.
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\38\ See http://ees.ead.lbl.gov/publications/analysis-price-elasticity (last accessed January 13, 2015).
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Even under this relatively high assumption for price elasticity of
demand, DOE's battery charger standards are unlikely to have a
significant effect on the shipment volumes of those battery charger
applications mentioned by stakeholders, with forecasted effects ranging
from a decrease of 0.004 percent for electric shavers to a decrease of
0.1 percent for do-it-yourself (``DIY'') power tools with detachable
batteries. Results for all battery charger applications are contained
in appendix 9A to the SNOPR TSD. The corresponding impacts on national
energy savings (``NES'') and NPV are included in appendix 10A.
1. Shipment Growth Rate
In the NOPR, DOE noted that the market for battery chargers grew
tremendously in the previous ten years. Additionally, DOE found that
many market reports had predicted enormous future growth for the
applications that employ battery chargers. However, in projecting the
size of these markets over the next 30 years, DOE considered the
possibility that much of the market growth associated with battery
chargers had already occurred. In many reports predicting the growth of
applications that employ battery chargers, DOE noted that this growth
was predicted for new applications, but older applications were
generally not included. That is, battery charger demand did not grow,
but the products using these devices have transitioned to a new product
mix. For example, during its initial market assessment, DOE identified
mobile phones, digital cameras, personal digital assistants, and MP3
players as applications that use battery chargers. However, in the past
several years, the use of smart phones, which can function as all four
of these individual applications, has accelerated, and these individual
products may no longer be sold in large volumes in the near future. A
quantitative example of this is shown in Table IV-12. (See chapter 9 of
the SNOPR TSD.)
Table IV-12--Example of Product Transition
--------------------------------------------------------------------------------------------------------------------------------------------------------
Application 2007 Shipments 2008 Shipments 2009 Shipments 2011 Shipments
--------------------------------------------------------------------------------------------------------------------------------------------------------
Smart Phones........................................ 19,500,000 28,555,000 41,163,000 110,178,600
Mobile Phones....................................... 101,500,000 102,775,000 94,239,000 58,563,400
Personal Digital Assistants......................... 2,175,000 1,977,000 1,750,000 800,000
MP3 Players......................................... 48,020,000 43,731,000 40,101,000 40,696,691
---------------------------------------------------------------------------------------------------
Total........................................... 171,195,000 177,038,000 177,253,000 210,238,691
--------------------------------------------------------------------------------------------------------------------------------------------------------
With this in mind, DOE based its shipments projections such that
the per-capita consumption of battery chargers will remain steady over
time, and that the overall number of individual units that use battery
chargers will grow at the same rate as the U.S. population.
The NOPR analysis estimated future market size while assuming no
change in the per-capita battery charger purchase rate by using the
projected population growth rate as the compound annual market growth
rate. Population growth rate values were obtained from the U.S. Census
Bureau
[[Page 52889]]
2009 National Projections, which forecast U.S. resident population
through 2050. DOE took the average annual population growth rate, 0.75
percent, and applied this rate to all battery charger product classes.
For the SNOPR, DOE retained the same approach and updated the
growth rate from 0.75% to 0.62% using U.S. Census Bureau projections
released December 2012.
NRDC commented that battery chargers shipments had been growing
significantly faster than the growth shown in the NOPR, driven in part
by growth in consumer electronics and portable appliances over the
previous few years. They suggested using a growth rate of 4% in 2011,
gradually declining to 0.75% by 2028 (reduction of 0.2% per year). This
would lead to shipment projections which are 32% higher in 2042 than
what used in the NOPR analysis. (NRDC, No. 114 at p. 19) The CA IOUs
also asserted that battery chargers shipments would grow faster than
the population. These faster growth rates would increase the energy
savings attributable to the standards. The CA IOUs stated that they
supported the conclusions of NRDC, but did not present additional data
of their own. (CA IOUs, No. 138 at p. 20)
DOE recognizes that shipments for certain applications are
increasing very rapidly. However, DOE researched product growth trends
dating back to 2006 and found that other products, like digital
cameras, have seen flat shipments. Some critical applications have even
had shipments decline year-over-year. There is also significant
convergence in the consumer electronics industry, in which one new
device may replace multiple retired devices (such as a single smart
phone replacing a mobile phone, digital camera, GPS device, and PDA).
DOE seeks to forecast shipments for battery chargers as a whole, but
given the complexity of these markets, any attempts to forecast
behavior of the market will be inherently inexact. Therefore, in this
SNOPR, DOE decided to maintain its approach to use population growth to
project shipments, but updated the value to match the latest U.S.
Census information: from 0.75% growth per year from the NOPR to 0.62%
growth rate in this SNOPR. In its shipment forecasts, DOE projects that
by 2018, shipments of battery chargers will be 4.4% percent greater
than they were in 2011.
2. Product Class Lifetime
For the NOPR, DOE calculated product class lifetime profiles using
the percentage of shipments of applications within a given product
class, and the lifetimes of those applications. These values were
combined to estimate the percentage of units of a given vintage
remaining in use in each year following the initial year in which those
units were shipped and placed in service.
DOE received no comments regarding this methodology and maintained
this methodology for the SNOPR. For more information on the calculation
of product class lifetime profiles, see chapter 10 of the SNOPR TSD.
3. Forecasted Efficiency in the Base Case and Standards Cases
A key component of the NIA is the trend in energy efficiency
forecasted for the base case (without new and amended standards) and
each of the standards cases. To project the trend in efficiency over
the entire forecast period, DOE considered recent standards, voluntary
programs such as ENERGY STAR, and other trends.
For battery charger efficiency trends, DOE considered three key
factors: European standards, the EPA's ENERGY STAR program, and the
battery charger standards that took effect on February 1, 2013, in
California.
The EU included battery chargers in a preparatory study on eco-
design requirements that it published in January 2007.\39\ However, it
has not yet announced plans to regulate battery chargers. Thus, DOE did
not adjust the efficiency distributions that it calculated for battery
chargers between the present-day and the compliance date in 2018 to
account for European standards.
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\39\ Available here: http://www.eceee.org/ecodesign/products/battery_chargers/Final_Report_Lot7.
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DOE examined the ENERGY STAR voluntary program for battery charging
systems and found that as of October 19, 2012, less than 350 battery
charging systems had been qualified.\40\ PTI commented that its
members' products make up a significant portion of the ENERGY STAR
Battery Charging Systems listings. PTI claimed that, to the extent that
DOE's battery charger standard would impact future revisions to the
ENERGY STAR criteria, then it is possible that there would be
improvements in efficiency to some products in the market that already
meet the DOE standard. (PTI, No. 133 at p. 5)
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\40\ EPA, ``Qualified Product (QP) List for ENERGY STAR
Qualified Battery Charging Systems.'' Retrieved on October 18, 2012
from http://downloads.energystar.gov/bi/qplist/Battery_Charging_Systems_Product_List.xls?5728-8a42.
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DOE recognizes that unforeseen new or revised energy efficiency
specifications are a possibility and that these factors would impact
the distribution of efficiency in the market. It is also possible that
DOE's battery charger standards could cause other organizations to
tighten their efficiency specifications as well. However, EPA's ENERGY
STAR program for battery chargers ended on December 30, 2014, and the
ENERGY STAR label is no longer available for this product category.\41\
Thus, DOE did not adjust its battery charger efficiency distributions
to account for any potential market effects of a future ENERGY STAR
program.
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\41\ https://www.energystar.gov/sites/default/files/specs//BCS%20Final%20Decision%20Sunset%20Memo.pdf.
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The CEC battery charger standards that took effect in 2013, affect
most, if not all, of the battery chargers within the scope of DOE's
rulemaking. In the NOPR, DOE adjusted its base case efficiency
distributions for battery chargers to account for these standards by
assuming that, in the absence of Federal standards, all battery
chargers sold in California would meet the CEC standards. In the
absence of market share data, DOE assumed in the NOPR that California's
share of the U.S. battery charger market would be equivalent to its
share of U.S. GDP (13 percent).
Also in the NOPR, DOE recognized that the CEC standards may also
raise the efficiency of battery chargers sold outside of California.
However, the magnitude of this effect could not be determined.
Nevertheless, to explore the full range of possibilities, DOE also
evaluated the potential impacts of Federal standards under the
assumption that the CEC standards become the de facto standard for the
nation, i.e., all battery chargers sold in the United States just
before the Federal standard takes effect meet the CEC standards. This
scenario represented an upper bound on the possible impacts of the CEC
standards and a lower bound on the energy savings that could be
achieved by Federal standards.
Both during and after the NOPR public meeting, multiple
stakeholders provided input on how the CEC standards may impact
products in California and the rest of the Nation. The CEC commented
that California's standards, in the absence of national standards,
would become the ``de facto'' national standards. Thus, less stringent
standards--such as those proposed in the NOPR--would lead to greater
national energy consumption than if DOE took no action, which would
``run afoul'' of 42 U.S.C. 6295(o)(3), which mandates that DOE
prescribe standards that results in the significant conservation of
energy. The CEC further
[[Page 52890]]
argued that standards should be evaluated with a base case of no
action, in which case the adoption of California's standards and the
adoption of DOE's proposed standards would lead to an increase in
national energy consumption. The CEC also advised that products sold in
California that meet the CEC standards would regress to lower
efficiency levels should DOE adopt standards lower than those set by
the CEC because the CEC standards would be preempted. (California
Energy Commission, No. 117 at p. 2-6)
Earthjustice concurred with the CEC's claims, stating that DOE's
assumption that California's standards will not impact products sold
outside of California was arbitrary and contrary to evidence presented
for EPSs. With the CEC standards as the de facto national standards,
the adoption by DOE of weaker requirements would not save significant
energy and would be prohibited under EPCA. (Earthjustice, No. 118 at p.
3) Panasonic also claimed that the CEC standards would become de facto
national standards in the absence of Federal regulations. (Panasonic,
No. 120 at p. 5) The Appliance Standards Awareness Project agreed that
DOE's proposal risked increasing national energy consumption. They
recommended that, to fully understand the potential impacts of
California's standards, DOE should explore scenarios in which 100%,
75%, and 50% of products sold outside of California comply with
California's standard.
AHAM suggested that DOE overestimated the amount of the market that
would shift to comply with the CEC standards, because not all products
will be able to meet those efficiency levels, even in California.
However, AHAM suggested that DOE leave its analysis unchanged. (AHAM,
No. 124 at p. 2) PTI commented that within the standard levels that DOE
proposed, market elasticity is not an issue. However, it noted that at
the CEC standard levels, there is a higher cost of compliance that
would impact market elasticity. (PTI, No. 133 at p. 5)
The CEC also approximated CSLs that would be equivalent to its
standard levels and inputted those CSLs into DOE's NIA model. It
concluded that doing so yielded an additional 1.06 quads of energy
savings and $3.8 billion of net social benefits nationally, when
compared to DOE's proposal. Given these additional potential savings,
the CEC recommended that DOE revise its analyses and adopt standards at
least as stringent as those adopted in California. (California Energy
Commission, No. 117 at p. 32) Citing an analysis performed by the
Berkeley Research Group, PTI agreed with DOE that the CEC's adopted
standards for Product Classes 2-4 would not be cost effective for the
nation. (PTI, No. 133 at p. 2)
For this SNOPR, DOE has revised its base case efficiency
distributions and now assumes that 95% of the market meets the CEC
standards. DOE based this assumption on a review of the existing
market, both online and via in-store visits, and found that retailers
nationwide, and not just in California, are selling units complying
with the CEC standards. DOE acknowledges, however, that units not
complying with the current CEC standards can still be sold outside of
California, but believes the percentage of such units is small. For
this analysis, DOE assumed 5% of units sold do not meet the CEC
standards. DOE's testing conducted for this SNOPR focused on improving
baseline unit efficiency. In examining these units, DOE found that they
complied with the CEC standards--including CEC-marked units purchased
outside of California. While this resulted in assumptions of nearly all
units sold nationally as meeting or exceeding the CEC standards, DOE
recognizes that there are some units that could be sold outside of
California and not through common channels and/or large retailers
either online or in stores. DOE assumes that the volume of such non-
CEC-compliant units is small. Using all of these assumptions, DOE
developed its revised base case efficiency distribution using the CEC
database \42\ of battery charger models sold in California combined
with DOE's usage profiles as described earlier in Section IV.C.4. See
chapter 9 of the SNOPR TSD for more details.
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\42\ http://www.appliances.energy.ca.gov/AdvancedSearch.aspx.
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To estimate efficiency trends in the standards cases, DOE has used
``roll-up'' and/or ``shift'' scenarios in its standards rulemakings.
Under the ``roll-up'' scenario, DOE assumes: (1) Product efficiencies
in the base case that do not meet the standard level under
consideration would ``roll-up'' to meet the new standard level; and (2)
product efficiencies above the standard level under consideration would
not be affected. Under the ``shift'' scenario, DOE reorients the
distribution above the new minimum energy conservation standard. For
this rule, DOE proposed use of the ``roll-up'' scenario and has
maintained this approach for the SNOPR. This approach was supported by
Delta-Q Technologies in its public comments following publication of
the NOPR. (Delta-Q Technologies, No. 113 at p. 1).
For further details about the forecasted efficiency distributions,
see chapter 9 of the SNOPR TSD. DOE seeks comments on its approach in
updating the base case efficiency distributions for this rule using the
CEC database.
H. National Impacts Analysis
The NIA assesses the national energy savings (NES) and the NPV of
total consumer costs and savings that would be expected to result from
new and amended standards at specific efficiency levels. DOE calculates
the NES and NPV based on projections of annual unit shipments, along
with the annual energy consumption and total installed cost data from
the energy use and LCC analyses. DOE projected the energy savings,
operating cost savings, product costs, and NPV of net consumer benefits
for products sold over a 30-year period--from 2018 through 2047.
CEA commented that it is unreasonable for DOE to project shipments,
energy savings, and emissions reductions over a 30-year period. Product
lifecycles for many of the covered products are typically measured in
months, so it can be difficult to make projections years out. (CEA, No.
106 at p. 9) Although the 30-year analysis period is longer than the
average lifetime of battery chargers, DOE estimates that the considered
standard levels analyzed will transform the market to higher energy
efficiencies than in the base-case, resulting in energy and emission
savings throughout the analysis period. Further, DOE has conducted a
sensitivity analysis that projects NIA results out over nine years of
shipments instead of 30 years. Results of this sensitivity analysis are
available in section V.B.3 of this notice.
As in the LCC analysis, DOE evaluates the national impacts of new
and amended standards by comparing base-case projections with
standards-case projections. The base-case projections characterize
energy use and consumer costs for each product class in the absence of
new and amended energy conservation standards. DOE compares these
projections with projections characterizing the market for each product
class if DOE adopted new and amended standards at specific energy
efficiency levels (i.e., the TSLs or standards cases) for that class.
To make the analysis more accessible and transparent to all
interested parties, DOE used an MS Excel spreadsheet model to calculate
the energy savings and the national consumer costs and savings from
each TSL. The SNOPR TSD, and other supplemental
[[Page 52891]]
documentation DOE releases, collectively explain the models and how to
use them. Interested parties can review DOE's analyses by changing
various input quantities within the spreadsheet models that DOE
releases. The NIA spreadsheet model uses average values as inputs (as
opposed to probability distributions).
For this SNOPR, the NIA used projections of energy prices from the
AEO2014 Reference case. In addition, DOE analyzed scenarios that used
inputs from the AEO2014 High Economic Growth, and Low Economic Growth
cases. These cases have higher or lower energy price trends compared to
the Reference case. NIA results based on these cases are presented in
appendix 10A to the SNOPR TSD.
Table IV-13 summarizes the inputs and key assumptions DOE used in
the NIA. Discussion of these inputs and changes follows the table. See
chapter 10 of the SNOPR TSD for further details.
Table IV-13--Summary of Inputs, Sources and Key Assumptions for the
National Impact Analysis
------------------------------------------------------------------------
Changes for SNOPR
Inputs NOPR Description rule
------------------------------------------------------------------------
Base Year Shipments........... Annual shipments No change in
from Market methodology.
Assessment. Includes updated
data from 2011.
Shipment Growth Rate.......... 0.75 percent Updated to 0.62
annually, equal percent using
to population revised U.S. Census
growth. projections (2012).
Lifetimes..................... Battery charger No changes in
lifetime is methodology. Product
equal to the Class lifetimes were
lifetime of the revised based on
end-use product removal of medical
it powers.. products.
Base Year Efficiencies........ From Market Obtained from the
Assessment. CEC's database of
Small Battery
Chargers (2014)
Base-Case Forecasted Efficiency No change.
Efficiencies. distributions
remain unchanged
throughout the
forecast period.
Standards-Case Forecasted ``Roll-up'' No change.
Efficiencies. scenario.
Annual Energy Consumption per Annual shipment No change in the
Unit. weighted-average methodology. Inputs
marginal energy to the calculation
consumption were revised based
values for each on removal of
product class. medical products.
Improvement Cost per Unit..... From the No change.
Engineering
Analysis.
Markups....................... From Markups No change.
Analysis.
Repair and Maintenance Cost Assumed to be No change.
per Unit. zero.
Energy Prices................. AEO2010 Updated to AEO2014.
projections (to
2035) and
extrapolation
for 2044 and
beyond.
Electricity Site-to-Source Based on AEO 2010 Updated to AEO2014.
Conversion Factor.
Present Year.................. 2011............. 2015
Discount Rate................. 3% and 7% real... No change.
Compliance Date of Standard 2013............. 2018
(Start of Analysis Period).
------------------------------------------------------------------------
1. Product Price Trends
As noted in section IV.F.1, DOE assumed no change in battery
charger pricing over the 2018-2047 period in the reference case. AHAM
commented that it opposes the use of price trends and agreed that DOE
should not use that approach. (AHAM, No. 124 at p. 9) In contrast, PG&E
and SDG&E supported the consideration of price trends as an NIA
sensitivity and recommended that price trends be incorporated into the
reference case, given past declines in the costs of electronic
products. (PG&E and SDG&E, No. 163 at pp. 1-2) The Power Sources
Manufacturers Association (PSMA) agreed, stating that while
improvements to overall battery charger efficiency do entail cost
premiums, these premiums are often reduced as volumes increase and
manufacturing technologies improve. (PSMA, No. 147 at p. 2)
As discussed in section IV.G.1, it is difficult to predict the
consumer electronics market far in advance. To derive a price trend for
battery chargers, DOE did not have any historical shipments data or
sufficient historical Producer Price Index (PPI) data for the small
electrical appliance manufacturing industry from BLS.\43\ Therefore,
DOE examined a projection based on the price indexes that were
projected for AEO2014. DOE performed an exponential fit on two deflated
projected price indexes that may include the products that battery
chargers are components of: information equipment (Chained price
index--investment in non-residential equipment and software--
information equipment), and consumer durables (Chained price index--
other durable goods). However, DOE believes that these indexes are too
broad to accurately capture the trend for battery chargers.
Furthermore, most battery chargers are unlike typical consumer products
in that they are typically not purchased independently by consumers.
Instead, they are similar to other commodities and typically bundled
with end-use products.
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\43\ Series ID PCU33521-33521; http://www.bls.gov/ppi/.
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Given the above considerations, DOE decided to use a constant price
assumption as the default price factor index to project future battery
charger prices in 2018 and out to 2047. While a more conservative
method, following this approach helped ensure that DOE did not
understate the incremental impact of standards on the consumer purchase
price. Thus, DOE's product prices forecast for the LCC, PBP, and NIA
analyses for the SNOPR were held constant for each efficiency level in
each product class. DOE also conducted a sensitivity analysis using
alternative price trends based on AEO indexes. These price trends, and
the NPV results from the associated sensitivity cases, are described in
Appendix 10B of the SNOPR TSD.
2. Unit Energy Consumption and Savings
DOE uses the efficiency distributions for the base case along with
the annual unit energy consumption values to estimate shipment-weighted
average unit energy consumption under the base and standards cases,
which are then
[[Page 52892]]
compared against one another to yield unit energy savings values for
each considered efficiency level.
As discussed in section IV.G.3, DOE assumes that energy efficiency
will not improve after 2018 in the base case. Therefore, the projected
UEC values in the analysis, as well as the unit energy savings values,
do not vary over time. Consistent with the roll-up scenario, the
analysis assumes that manufacturers would respond to a standard by
improving the efficiency of underperforming products but not those that
already meet or exceed the standard.
DOE received no comments on its methodology for calculating unit
energy consumption and savings in the NOPR and maintained its
methodology in the SNOPR. For further details on the calculation of
unit energy savings for the NIA, see chapter 10 of the SNOPR TSD.
3. Unit Costs
DOE uses the efficiency distributions for the base case along with
the unit cost values to estimate shipment-weighted average unit costs
under the base and standards cases, which are then compared against one
another to give incremental unit cost values for each TSL. DOE received
no comments on its methodology for calculating unit costs in the NOPR
and maintained its methodology in the SNOPR. For further details on the
calculation of unit costs for the NIA, see chapter 10 of the SNOPR TSD.
4. Repair and Maintenance Cost per Unit
In the NOPR, DOE considered the incremental maintenance cost for
the replacement of lithium ion batteries in certain applications. After
examining the possible impact of this cost in the LCC and PBP analyses,
DOE determined that the actual impact at the product class level would
most likely be negligible. Thus, DOE opted not to retool its NIA model
to account for this cost. For further discussion of this issue, see
section IV.F.3 above. DOE received no comments on this approach, and
maintained this assumption for the SNOPR.
5. Energy Prices
While the focus of this rulemaking is on consumer products found in
the residential sector, DOE is aware that many products that employ
battery chargers are located within commercial buildings. Given this
fact, the NOPR analysis relied on calculated energy cost savings from
such products using commercial sector electricity rates, which are
lower in value than residential sector rates. DOE used this approach so
as to not overstate energy cost savings in calculating the NIA.
In order to determine the energy usage split between the
residential and commercial sector, DOE first separated products into
residential-use and commercial-use categories. Then, for each product
class, using shipment values for 2018, average lifetimes, and base-case
unit energy consumption values, DOE calculated the approximate annual
energy use split between the two sectors. DOE applied the resulting
ratio to the electricity pricing to obtain a sector-weighted energy
price for each product class. This ratio was held constant throughout
the period of analysis.
DOE received no comments on its methodology for calculating energy
costs in the NOPR and maintained its approach for the SNOPR. For
further details on the determination of energy prices for the NIA, see
chapter 10 of the SNOPR TSD.
6. National Energy Savings
The national energy savings analysis involves a comparison of
national energy consumption of the considered products in each
potential standards case with consumption in the base case with no new
or amended energy conservation standards. DOE calculated the national
energy consumption by multiplying the number of units (stock) of each
product (by vintage or age) by the unit energy consumption (also by
vintage). DOE calculated annual NES based on the difference in national
energy consumption for the base case (without amended efficiency
standards) and for each higher efficiency standard. DOE estimated
energy consumption and savings based on site energy and converted the
electricity consumption and savings to primary energy (i.e., the energy
consumed by power plants to generate site electricity) using annual
conversion factors derived from AEO2014. Cumulative energy savings are
the sum of the NES for each year over the timeframe of the analysis.
In 2011, in response to the recommendations of a committee on
``Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy
Efficiency Standards'' appointed by the National Academy of Sciences,
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 51281 (Aug. 18, 2011). After
evaluating the approaches discussed in the August 18, 2011 notice, DOE
published a statement of amended policy in which DOE explained its
determination that EIA's National Energy Modeling System (NEMS) is the
most appropriate tool for its FFC analysis and its intention to use
NEMS for that purpose. 77 FR 49701 (Aug. 17, 2012). NEMS is a public
domain, multi-sector, partial equilibrium model of the U.S. energy
sector. EIA uses NEMS to prepare its Annual Energy Outlook.
For further details about the calculation of national energy
savings, see chapter 10 of the SNOPR TSD. The approach used for
deriving FFC measures of energy use and emissions is described in
appendix 10B of the SNOPR TSD.
7. Discount Rates
The inputs for determining the NPV of the total costs and benefits
experienced by consumers of battery chargers are: (1) total increased
product cost, (2) total annual savings in operating costs, and (3) a
discount factor. For each standards case, DOE calculated net savings
each year as total savings in operating costs, less total increases in
product costs, relative to the base case. DOE calculated operating cost
savings over the life of each product shipped from 2018 through 2047.
DOE multiplied the net savings in future years by a discount factor
to determine their present value. DOE estimated the NPV of consumer
benefits using both a 3-percent and a 7-percent real discount rate. DOE
uses these discount rates in accordance with guidance provided by the
Office of Management and Budget (OMB) to Federal agencies on the
development of regulatory analysis.\44\ The 7-percent real value is an
estimate of the average before-tax rate of return to 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.
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\44\ OMB Circular A-4 (Sept. 17, 2003), section E, ``Identifying
and Measuring Benefits and Costs. Available at: http://www.whitehouse.gov/omb/memoranda/m03-21.html.
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For further details about the calculation of net present value, see
chapter 10 of the SNOPR TSD.
I. Consumer Subgroup Analysis
In analyzing the potential impacts of new or amended standards, DOE
evaluates the impacts on the LCC of identifiable subgroups of consumers
that may be disproportionately affected by a national standard. In the
NOPR,
[[Page 52893]]
DOE analyzed four consumer subgroups of interest--low-income consumers,
small businesses, top marginal electricity price tier consumers, and
consumers of specific applications within a product class. In this
SNOPR, DOE maintains the same subgroups; however, DOE separates the top
marginal electricity price tier consumers into two subgroups because
further analysis showed that these consumers were two distinct groups.
The two new subgroups are top tier electricity price consumers and peak
time-of-use electricity price consumers. For each subgroup, DOE
considered variations on the standard inputs to the general LCC model.
DOE defined low-income consumers as residential consumers with
incomes at or below the poverty line, as defined by the U.S. Census
Bureau. In the NOPR stage, DOE found from 2005 Residential Energy
Consumption Survey (RECS) data \45\ that these consumers face
electricity prices that are 0.2 cents per kWh lower, on average, than
the prices faced by consumers above the poverty line. In the SNOPR
stage, DOE found that the updated 2009 RECS data \46\ no longer showed
a significant difference in electricity price between low-income and
general consumers. Instead, DOE used the same source to identify
population distributions of low-income consumers among regions of the
U.S. to distinguish low-income consumers from the general population.
DOE requests comment on the new methodology of filtering RECS data to
obtain a population distribution of low-income consumers.
---------------------------------------------------------------------------
\45\ U.S. Department of Energy-Energy Information
Administration. RECS Public Use Microdata Files, calendar year 2005.
2009. Washington, DC. http://205.254.135.7/consumption/residential/data/2005/index.cfm?view=microdata
\46\ U.S. Department of Energy-Energy Information
Administration. RECS Public Use Microdata Files, calendar year 2009.
2013. Washington, DC. http://205.254.135.7/consumption/residential/data/2009/index.cfm?view=microdata
---------------------------------------------------------------------------
For small businesses, DOE analyzed the potential impacts of
standards by conducting the analysis with a different discount rate
applicable to this subgroup, as small businesses do not have the same
access to capital as larger businesses. DOE estimated that for
businesses purchasing battery chargers, small companies have an average
discount rate that is 4.16 percent higher than the industry average.
In the NOPR, DOE identified the highest rates for top tier marginal
electricity price consumers using both tiered rates and time of usage.
DOE found that top tier marginal rates for general usage in the
residential and commercial sectors were $0.310 and $0.225,
respectively. In the SNOPR stage, DOE divided this subgroup into two
new subgroups because further analysis showed that these consumers were
two distinct groups. For top tier electricity price consumers, DOE
researched tiered electricity rates for general usage in the
residential sector, and found the highest price to be $0.359. For peak
time-of-use electricity price consumers, DOE researched prices that
varied with the time of day for both the residential and commercial
sectors, obtaining peak values of $0.514 and $.494, respectively.
Lastly, for the application-specific subgroup, DOE used the inputs
from each application for lifetime, markups, market efficiency
distribution, and UEC to calculate LCC and PBP results.
In response to the NOPR, Nokia noted that DOE should consider life-
cycle costs when deciding standards. In the case of mobile phones, it
argued that standards could not be justified on the basis of life-cycle
costs (Nokia, No. 132 at p. 1).
Mobile phone battery chargers fall into Product Class 2. The
selected CSL for Product Class 2 exhibits a positive LCC savings of
$0.06 over the lifetime of a given mobile phone battery charger. DOE
notes that the standards and life-cycle costs are for the battery
chargers, and not for end-use products. Looking across all of Product
Class 2, the standards proposed will be beneficial to consumers, on
average. For this reason, DOE believes that standards are justified at
the current proposed levels for mobile phones on the basis of life-
cycle costs.
DOE's subgroup analysis for consumers of specific applications
considered the LCC impacts of each application within a product class.
This approach allowed DOE to consider the LCC impacts of individual
applications when choosing the proposed standard level, regardless of
the application's weighting in the calculation of average impacts. The
impacts of the standard on the cost of the battery charger as a
percentage of the application's total purchase price are not relevant
to DOE's LCC analysis. DOE used the cost of the battery charger
component, not the final price of the application, in the LCC.
Therefore, a $2,000 and $20 product are assumed to have the same cost
for a battery charger (e.g., $5) if they are within the same CSL of the
same product class. The application-specific subgroup analyses
represent an estimate of the marginal impacts of standards on consumers
of each application within a product class.
DOE maintained its approach to the application specific consumer
subgroup in the SNOPR. Chapter 11 of the SNOPR TSD contains further
information on the LCC analyses for all subgroups.
J. Manufacturer Impact Analysis
DOE conducted a manufacturer impact analysis (MIA) on battery
chargers to estimate the financial impact of new energy conservation
standards on this industry. The MIA is both a quantitative and
qualitative analysis. The quantitative part of the MIA relies on the
Government Regulatory Impact Model (GRIM), an industry cash flow model
customized for applications that include battery chargers covered in
this rulemaking. The key MIA output is industry net present value
(INPV). DOE used the GRIM to calculate cash flows using standard
accounting principles and to compare the changes in INPV resulting from
the base case and various TSLs (the standards case). The difference in
INPV between the base and standards cases represents the financial
impact of the new standards on manufacturers. Different sets of
assumptions (scenarios) produce different results.
DOE calculated the MIA impacts of new energy conservation standards
by creating a GRIM for battery charger application manufacturers. In
the GRIM, DOE grouped similarly impacted products to better analyze the
effects new standards will have on the industry. DOE presented the
battery charger application impacts by product class groups (Product
Class 1; Product Classes 2, 3, and 4; Product Classes 5 and 6; and
Product Class 7) and by TSL. DOE also presented the results for Product
Classes 2, 3, and 4 by manufacturer industry (consumer electronics,
small appliance, and power tool manufacturers). This is necessary
because the impacts in this product class group vary significantly by
industry type. Therefore, grouping all industries together could
overlook the potential negative impacts that manufacturers of a
specific industry face. By segmenting the results into these
industries, DOE is also able to discuss how each subgroup of battery
charger application manufacturers will be impacted by new energy
conservation standards.
DOE outlined its complete methodology for the MIA in the NOPR. 77
FR 18478, 18549-59 (March 27, 2012). The complete MIA is presented in
chapter 12 of the accompanying SNOPR TSD.
1. Manufacturer Production Costs
Through the MIA, DOE attempts to model how changes in efficiency
impact manufacturer production costs
[[Page 52894]]
(``MPCs''). DOE used two critical inputs to calculate manufacturer
impacts at the OEM level. The first input is the price that the
application OEM charges for its finished product, used to calculate
revenue. The second input is the portion of that price represented by
its battery charger, used to calculate costs, at each CSL.
For the first component, DOE determined representative retail
prices for each application by surveying popular online retailer Web
sites to sample a number of price points of the most commonly sold
products for each application. The price of each application can vary
greatly depending on many factors (such as the features of each
individual product). For each application, DOE used the average
application price found in the product survey. DOE then discounted this
representative retail price back to the application MSP using the
retail markups derived from annual SEC 10-K reports in the Markups
Analysis, as discussed in section IV.D.
DOE calculated the second figure--the price of the battery charger
itself at each CSL--in the engineering analysis. In this analysis, DOE
calculated a separate cost efficiency curve for each of the seven
battery charger product classes. Based on product testing data, tear-
down data and manufacturer feedback, DOE created a BOM at the original
device manufacturer (ODM) level to which markups were applied to
calculate the MSP of the battery charger at each CSL. DOE then
allocated the battery charger MSPs of each product class to all the
applications within each product class. In this way, DOE arrived at the
cost to the application OEM of the battery charger for each
application.
NRDC commented that DOE overestimated the incremental MPCs in the
NOPR analysis for battery chargers, which caused DOE to overstate the
negative financial impacts reported in the NOPR MIA. (NRDC, No. 114 at
p. 21) NRDC did not give any specific data to support their claim that
DOE overestimated the incremental MPCs in the NOPR analysis. As part of
the SNOPR analysis, DOE did conduct another round of product
purchasing, testing, and tear downs to update the MPCs for the SNOPR
analysis to account for the most recent pricing trends for each
product. For some products, the incremental MPCs increased and for
others the incremental MPCs decreased compared to the NOPR analysis
incremental MPCs. DOE used a similar methodology for tear downs in the
SNOPR as it did in the NOPR; however, the changes in incremental MPC
from the NOPR to the SNOPR reflect the most recent battery charger
pricing trends and changes in material costs from the previous
analysis.
2. Product and Capital Conversion Costs
New energy conservation standards will cause manufacturers to incur
one-time conversion costs to bring their production facilities and
product designs into compliance with the new standards. For the MIA,
DOE classified these one-time conversion costs into two major groups:
(1) Product conversion costs and (2) capital conversion costs. Product
conversion costs are one-time investments in research, development,
testing, marketing, and other non-capitalized costs focused on making
product designs comply with the new energy conservation standards.
Capital conversion costs are one-time investments in property, plant,
and equipment to adapt or change existing production facilities so that
new product designs can be fabricated and assembled.
NRDC commented that DOE overestimated the conversion costs
associated with battery charger standards and caused the MIA results to
overstate the negative financial impacts on battery charger
manufacturers. NRDC believes the changes required by the selected
standards for battery chargers are simple and will only require limited
capital conversion costs. (NRDC, No. 114 at p. 21) After reviewing the
battery charger conversion costs, DOE believes that the values listed
in the NOPR are accurate based on the available data and is declining
to alter the battery charger conversion cost methodology for this
SNOPR.
3. Comments From Interested Parties Related to Battery Chargers
Several stakeholders commented on DOE's NOPR MIA. These comments
centered on compliance-related issues, employment impacts, and the
MIA's scope.
a. Compliance Date and Implementation Period
Interested parties expressed concern regarding the proposed
timeline for an appropriate compliance date to DOE's battery charger
standard. They supported DOE's proposal to set a compliance date as
soon as possible but not later than July 1, 2013 for battery charger
products classes 2, 3, and 4. The industry also argued that since the
CEC battery charger standards for these product classes are more
stringent and would be effective in February 2013, setting an earlier
compliance date for the standard would enable manufacturers to avoid
performing two rounds of testing, labeling, and compliance with two
different standards in a very short period of time. (AHAM, No. 124 at
p. 5) (CEA, No. 106 at p. 3) (Motorola, No. 121 at p. 11) (Nintendo of
America, No. 135 at p. 2) (Panasonic, No. 120 at p. 5) (Philips, No.
128 at p. 7) (PTI, No. 133 at p. 2 & 6) (Wahl, No. 153 at p. 1) (Pub.
Mtg. Tr., No. 104 at p. 251-254) Additionally, ITI supported a
compliance period of less than two years for Product Class 5 in
addition to Product Classes 2, 3, and 4. It also asserted that
manufacturers will be ready to meet DOE's proposed battery charger
standards for all these product classes in the very near term and will
not require the full two-year compliance period. (ITI, No. 131 at p. 2
& 6)
Other commenters urged DOE to adopt at least a two-year compliance
period for all battery charger product classes. These commenters stated
manufacturers must be allowed sufficient time to redesign and conduct
thorough testing on their products in order to manufacture adequately
safe and reliable products that comply with DOE's battery charger
standards. (Flextronics, No. 145 at p.1) (Microsoft, No. p. 110)
(Nebraska Energy Office, No. 98 at p. 2) (Nokia, No. 132 at p. 2)
(Salcomp Plc, No. 73 at p. 2) (Schneider, No. 119 at p. 6)
Additionally, some manufacturers supported a compliance date of at
least 18 months or two years just for Product Classes 5, 6, and/or 7.
(Actuant Electric, No. 146 at p. 2) (Lester Electrical, No. 139 at p.
2) (Lester Electrical, No. 87 at p. 1) (Schumacher, No. 143 at p. 2)
(Pub. Mtg. Tr., No. 104 at p. 30)
Since the CEC battery charger standard has already been implemented
at the time of this SNOPR publication and available data indicate that
manufacturers are already complying with that standard, DOE is
proposing to use a compliance date of two years after the publication
of the final rule for this rulemaking.
b. Employment Impacts
Some manufacturers expressed concern that this rulemaking could
lead to a loss of domestic jobs. Lester Electrical stated that the
proposed standard level for Product Class 7 will lead to job losses in
its domestic manufacturing plant. (Lester Electrical, No. 139 at p. 2)
(Pub. Mtg. Tr., No. 104 at p. 31) The Nebraska Energy Office also
commented that the proposed standard is not economically justified and
would contribute an unacceptable level of regulatory burden. (Nebraska
Energy Office, No. 98 at p. 2) DOE estimates that Lester Electrical
employs
[[Page 52895]]
approximately 100 domestic production workers that produce a wide
variety of covered and non-covered battery chargers. The direct
employment analysis indicates that a maximum of 100 domestic jobs could
be lost as a result of DOE's proposed battery charger standards due to
the projected impacts on Lester Electrical. This estimate of 100
domestic jobs lost represents the upper-bound of potential job loss,
since it is likely that Lester Electrical will at least continue to
produce the battery chargers not covered by this proposed standard
domestically. Relocating a company's manufacturing facility is a
complex business decision and not a decision mandated by any government
action. Since one path to compliance is as likely as the next, it is
difficult to accurately predict how Lester Electrical would respond to
the proposed battery charger standards.
c. Scope of the MIA
A few manufacturers stated that they believe the MIA did not
include all parties affected by DOE's battery charger standard.
Duracell commented that DOE should specifically account for the impacts
on battery manufacturers, especially those who design battery chargers
around the batteries they manufacture. (Duracell, No. 109 at p. 4) The
MIA focused on battery charger and battery charger application
manufacturers only. DOE believes the MIA should only focus on
businesses that are directly impacted by DOE's standards and does not
believe that battery manufacturers fall into this category. While DOE
acknowledges that battery manufacturers could be indirectly affected by
the proposed standard, those impacts fall outside the scope of this
rulemaking.
4. Manufacturer Interviews
DOE conducted additional interviews with manufacturers following
the preliminary analysis in preparation for the NOPR analysis. These
interviews were separate from those DOE conducted as part of the
engineering analysis. DOE did not conduct additional interviews between
the publication of the NOPR and this SNOPR. DOE outlined the key issues
for this rulemaking for manufacturers in the NOPR. See 77 FR at 18558-
18559. DOE did not receive any further comments on the key issues
listed in the NOPR.
K. Emissions Analysis
In the emissions analysis, DOE estimated the reduction in power
sector emissions of carbon dioxide (CO2), nitrogen oxides
(NOX), sulfur dioxide (SO2), and mercury (Hg)
from potential energy conservation standards for battery chargers. In
addition, DOE estimated emissions impacts in production activities
(extracting, processing, and transporting fuels) that provide the
energy inputs to power plants. These are referred to as ``upstream''
emissions. Together, these emissions account for the full-fuel-cycle
(FFC). In accordance with DOE's FFC Statement of Policy (76 FR 51282
(Aug. 18, 2011)), the FFC analysis includes impacts on emissions of
methane (CH4) and nitrous oxide (N2O), both of
which are recognized as greenhouse gases.
DOE primarily conducted the emissions analysis using emissions
factors for CO2 and most of the other gases derived from
data in AEO2014. Combustion emissions of CH4 and
N2O were estimated using emissions intensity factors
published by the Environmental Protection Agency (EPA), GHG Emissions
Factors Hub.\47\ DOE developed separate emissions factors for power
sector emissions and upstream emissions. The method that DOE used to
derive emissions factors is described in chapter 13 of the SNOPR TSD.
---------------------------------------------------------------------------
\47\ http://www.epa.gov/climateleadership/inventory/ghg-emissions.html.
---------------------------------------------------------------------------
For CH4 and N2O, DOE calculated emissions
reduction in tons and also in terms of units of carbon dioxide
equivalent (CO2eq). Gases are converted to CO2eq
by multiplying the physical units (i.e., tons) by the gas' global
warming potential (GWP) over a 100-year time horizon. Based on the
Fifth Assessment Report of the Intergovernmental Panel on Climate
Change,\48\ DOE used GWP values of 28 for CH4 and 265 for
N2O.
---------------------------------------------------------------------------
\48\ IPCC, 2013: Climate Change 2013: The Physical Science
Basis. Contribution of Working Group I to the Fifth Assessment
Report of the Intergovernmental Panel on Climate Change [Stocker,
T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A.
Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge
University Press, Cambridge, United Kingdom and New York, NY, USA.
Chapter 8.
---------------------------------------------------------------------------
EIA prepares the Annual Energy Outlook using the National Energy
Modeling System (NEMS). Each annual version of NEMS incorporates the
projected impacts of existing air quality regulations on emissions.
AEO2014 generally represents current legislation and environmental
regulations, including recent government actions, for which
implementing regulations were available as of October 31, 2013.
SO2 emissions from affected electric generating units
(EGUs) are subject to nationwide and regional emissions cap-and-trade
programs. 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 (DC). SO2 emissions from 28 eastern
states and DC were also limited under the Clean Air Interstate Rule
(CAIR; 70 FR 25162 (May 12, 2005)), which created an allowance-based
trading program that operates along with the Title IV program. CAIR was
remanded to the U.S. Environmental Protection Agency (EPA) by the U.S.
Court of Appeals for the District of Columbia Circuit but it remained
in effect.\49\ In 2011 EPA issued a replacement for CAIR, the Cross-
State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). On
April 29, 2014, the U.S. Supreme Court reversed the judgment of the
D.C. Circuit and remanded the case for further proceedings consistent
with the Supreme Court's opinion.\50\ On October 23, 2014, the D.C.
Circuit lifted the stay of CSAPR.\51\ Pursuant to this action, CSAPR
went into effect (and CAIR ceased to be in effect) as of January 1,
2015.
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\49\ See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008);
North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008).
\50\ See EPA v. EME Homer City Generation, 134 S.Ct. 1584, 1610
(U.S. 2014). The Supreme Court held in part that EPA's methodology
for quantifying emissions that must be eliminated in certain States
due to their impacts in other downwind States was based on a
permissible, workable, and equitable interpretation of the Clean Air
Act provision that provides statutory authority for CSAPR.
\51\ See Georgia v. EPA, Order (D.C. Cir. filed October 23,
2014) (No. 11-1302),
---------------------------------------------------------------------------
Because AEO2014 was prepared prior to the Supreme Court's opinion,
it assumed that CAIR remains a binding regulation through 2040. Thus,
DOE's analysis used emissions factors that assume that CAIR, not CSAPR,
is the regulation in force. However, the difference between CAIR and
CSAPR is not relevant for the purpose of DOE's analysis of emissions
impacts from energy conservation standards.
The attainment of emissions caps is typically flexible among EGUs
and is enforced 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 adoption of an efficiency standard could be used to permit
offsetting increases in SO2 emissions by any regulated EGU.
In past rulemakings, DOE recognized that there was uncertainty about
the effects of efficiency standards on SO2 emissions covered
by the existing cap-and-trade system, but it concluded that negligible
reductions in power sector SO2 emissions would occur as a
result of standards.
[[Page 52896]]
Beginning in 2016, however, SO2 emissions will fall as a
result of the Mercury and Air Toxics Standards (MATS) for power plants.
77 FR 9304 (Feb. 16, 2012). In the final MATS rule, EPA established a
standard for hydrogen chloride as a surrogate for acid gas hazardous
air pollutants (HAP), and also established a standard for
SO2 (a non-HAP acid gas) as an alternative equivalent
surrogate standard for acid gas HAP. The same controls are used to
reduce HAP and non-HAP acid gas; thus, SO2 emissions will be
reduced as a result of the control technologies installed on coal-fired
power plants to comply with the MATS requirements for acid gas. AEO2014
assumes that, in order to continue operating, coal plants must have
either flue gas desulfurization or dry sorbent injection systems
installed by 2016. Both technologies are used to reduce acid gas
emissions, and they also reduce SO2 emissions. Under the
MATS, emissions will be far below the cap established by CAIR, so it is
unlikely that excess SO2 emissions allowances resulting from
the lower electricity demand would be needed or used to permit
offsetting increases in SO2 emissions by any regulated EGU.
Therefore, DOE believes that efficiency standards will generally reduce
SO2 emissions in 2016 and beyond.
CAIR established a cap on NOX emissions in 28 eastern
States and the District of Columbia.\52\ Energy conservation standards
are expected to have little effect on NOX emissions in those
States covered by CAIR because excess NOX emissions
allowances resulting from the lower electricity demand could be used to
permit offsetting increases in NOX emissions. However,
standards would be expected to reduce NOX emissions in the
States not affected by the caps, so DOE estimated NOX
emissions reductions from the standards considered in this SNOPR for
these States.
---------------------------------------------------------------------------
\52\ CSAPR also applies to NOx and it would supersede the
regulation of NOX under CAIR. As stated previously, the
current analysis assumes that CAIR, not CSAPR, is the regulation in
force. The difference between CAIR and CSAPR with regard to DOE's
analysis of NOX emissions is slight.
---------------------------------------------------------------------------
The MATS limit mercury emissions from power plants, but they do not
include emissions caps and, as such, DOE's energy conservation
standards would likely reduce Hg emissions. DOE estimated mercury
emissions reduction using emissions factors based on AEO2014, which
incorporates the MATS.
For this SNOPR, DOE did not receive any comments on this section of
the analysis and retained the same approach as in the NOPR.
L. Monetizing Carbon Dioxide and Other Emissions Impacts
As part of the development of the proposed rule, DOE considered the
estimated monetary benefits from the reduced emissions of
CO2 and NOX that are expected to result from each
of the TSLs considered. In order to make this calculation analogous to
the calculation of the NPV of consumer benefits, DOE considered the
reduced emissions expected to result over the lifetime of products
shipped in the forecast period for each TSL. This section summarizes
the basis for the monetary values used for each of these emissions
reduction estimates and presents the values considered in this SNOPR.
For this SNOPR, DOE did not receive any comments on this section of
the analysis and retained the same approach as in the NOPR. DOE relied
on a set of values for the social cost of carbon (SCC) that was
developed by a Federal interagency process. The basis for these values
is summarized below, and a more detailed description of the
methodologies used is provided as an appendix to chapter 14 of the
SNOPR TSD.
1. Social Cost of Carbon
The SCC is an estimate of the monetized damages associated with an
incremental increase in carbon emissions in a given year. It is
intended to include (but is not limited to) changes in net agricultural
productivity, human health, property damages from increased flood risk,
and the value of ecosystem services. Estimates of the SCC are provided
in dollars per metric ton of CO2. A domestic SCC value is
meant to reflect the value of damages in the United States resulting
from a unit change in CO2 emissions, while a global SCC
value is meant to reflect the value of damages worldwide.
Under section 1(b) of Executive Order 12866, agencies must, to the
extent permitted by law, ``assess both the costs and the benefits of
the intended regulation and, recognizing that some costs and benefits
are difficult to quantify, propose or adopt a regulation only upon a
reasoned determination that the benefits of the intended regulation
justify its costs.'' The purpose of the SCC estimates presented here is
to allow agencies to incorporate the monetized social benefits of
reducing CO2 emissions into cost-benefit analyses of
regulatory actions. The estimates are presented with an acknowledgement
of the many uncertainties involved and with a clear understanding that
they should be updated over time to reflect increasing knowledge of the
science and economics of climate impacts.
As part of the interagency process that developed the SCC
estimates, technical experts from numerous agencies met on a regular
basis to consider public comments, explore the technical literature in
relevant fields, and discuss key model inputs and assumptions. The main
objective of this process was to develop a range of SCC values using a
defensible set of input assumptions grounded in the existing scientific
and economic literatures. In this way, key uncertainties and model
differences transparently and consistently inform the range of SCC
estimates used in the rulemaking process.
a. Monetizing Carbon Dioxide Emissions
When attempting to assess the incremental economic impacts of
CO2 emissions, the analyst faces a number of challenges. A
report from the National Research Council \53\ points out that any
assessment will suffer from uncertainty, speculation, and lack of
information about: (1) Future emissions of GHGs; (2) the effects of
past and future emissions on the climate system; (3) the impact of
changes in climate on the physical and biological environment; and (4)
the translation of these environmental impacts into economic damages.
As a result, any effort to quantify and monetize the harms associated
with climate change will raise questions of science, economics, and
ethics and should be viewed as provisional.
---------------------------------------------------------------------------
\53\ National Research Council. Hidden Costs of Energy: Unpriced
Consequences of Energy Production and Use (2009). National Academies
Press: Washington, DC.
---------------------------------------------------------------------------
Despite the limits of both quantification and monetization, SCC
estimates can be useful in estimating the social benefits of reducing
CO2 emissions. The agency can estimate the benefits from
reduced (or costs from increased) emissions in any future year by
multiplying the change in emissions in that year by the SCC values
appropriate for that year. The NPV of the benefits can then be
calculated by multiplying each of these future benefits by an
appropriate discount factor and summing across all affected years.
It is important to emphasize that the interagency process is
committed to updating these estimates as the science and economic
understanding of climate change and its impacts on society improves
over time. In the meantime, the interagency group will continue to
explore the issues raised by this analysis and consider public comments
as part of the ongoing interagency process.
[[Page 52897]]
b. Development of Social Cost of Carbon Values
In 2009, an interagency process was initiated to offer a
preliminary assessment of how best to quantify the benefits from
reducing carbon dioxide emissions. To ensure consistency in how
benefits are evaluated across Federal agencies, the Administration
sought to develop a transparent and defensible method, specifically
designed for the rulemaking process, to quantify avoided climate change
damages from reduced CO2 emissions. The interagency group
did not undertake any original analysis. Instead, it combined SCC
estimates from the existing literature to use as interim values until a
more comprehensive analysis could be conducted. The outcome of the
preliminary assessment by the interagency group was a set of five
interim values: global SCC estimates for 2007 (in 2006$) of $55, $33,
$19, $10, and $5 per metric ton of CO2. These interim values
represented the first sustained interagency effort within the U.S.
government to develop an SCC for use in regulatory analysis. The
results of this preliminary effort were presented in several proposed
and final rules.
c. Current Approach and Key Assumptions
After the release of the interim values, the interagency group
reconvened on a regular basis to generate improved SCC estimates.
Specifically, the group considered public comments and further explored
the technical literature in relevant fields. The interagency group
relied on three integrated assessment models commonly used to estimate
the SCC: The FUND, DICE, and PAGE models. These models are frequently
cited in the peer-reviewed literature and were used in the last
assessment of the Intergovernmental Panel on Climate Change (IPCC).
Each model was given equal weight in the SCC values that were
developed.
Each model takes a slightly different approach to model how changes
in emissions result in changes in economic damages. A key objective of
the interagency process was to enable a consistent exploration of the
three models, while respecting the different approaches to quantifying
damages taken by the key modelers in the field. An extensive review of
the literature was conducted to select three sets of input parameters
for these models: Climate sensitivity, socio-economic and emissions
trajectories, and discount rates. A probability distribution for
climate sensitivity was specified as an input into all three models. In
addition, the interagency group used a range of scenarios for the
socio-economic parameters and a range of values for the discount rate.
All other model features were left unchanged, relying on the model
developers' best estimates and judgments.
The interagency group selected four sets of SCC values for use in
regulatory analyses. Three sets of values are based on the average SCC
from three integrated assessment models, at discount rates of 2.5, 3,
and 5 percent. The fourth set, which represents the 95th percentile SCC
estimate across all three models at a 3-percent discount rate, is
included to represent higher-than-expected impacts from climate change
further out in the tails of the SCC distribution. The 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 to calculate domestic effects,\54\ although
preference is given to consideration of the global benefits of reducing
CO2 emissions. Table IV-14 presents the values in the 2010
interagency group report,\55\ which is reproduced in appendix 14-A of
the SNOPR TSD.
---------------------------------------------------------------------------
\54\ It is recognized that this calculation for domestic values
is approximate, provisional, and highly speculative. There is no a
priori reason why domestic benefits should be a constant fraction of
net global damages over time.
\55\ Social Cost of Carbon for Regulatory Impact Analysis Under
Executive Order 12866. Interagency Working Group on Social Cost of
Carbon, United States Government (February 2010) (Available at:
http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf).
TABLE IV-14--Annual SCC Values From 2010 Interagency Report, 2010-2050
[2007$ per Metric Ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate
---------------------------------------------------------------
5% 3% 2.5% 3%
Year ---------------------------------------------------------------
95th
Average Average Average percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 4.7 21.4 35.1 64.9
2015............................................ 5.7 23.8 38.4 72.8
2020............................................ 6.8 26.3 41.7 80.7
2025............................................ 8.2 29.6 45.9 90.4
2030............................................ 9.7 32.8 50.0 100.0
2035............................................ 11.2 36.0 54.2 109.7
2040............................................ 12.7 39.2 58.4 119.3
2045............................................ 14.2 42.1 61.7 127.8
2050............................................ 15.7 44.9 65.0 136.2
----------------------------------------------------------------------------------------------------------------
The SCC values used for this notice were generated using the most
recent versions of the three integrated assessment models that have
been published in the peer-reviewed literature.\56\
---------------------------------------------------------------------------
\56\ Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866, Interagency
Working Group on Social Cost of Carbon, United States Government
(May 2013; revised November 2013) (Available at: http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf).
---------------------------------------------------------------------------
Table IV-15 shows the updated sets of SCC estimates in 5-year
increments from 2010 to 2050. The full set of annual SCC estimates
between 2010 and 2050 is reported in appendix 14B of the SNOPR TSD. The
central value that emerges is the average SCC across models at the 3-
percent discount rate. However, for purposes of capturing the
uncertainties involved in regulatory impact analysis, the interagency
group emphasizes the importance of including all four sets of SCC
values.
[[Page 52898]]
Table IV-15--Annual SCC Values From 2013 Interagency Report, 2010-2050
[2007$ per Metric Ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate
---------------------------------------------------------------
5% 3% 2.5% 3%
Year ---------------------------------------------------------------
95th
Average Average Average percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 11 32 51 89
2015............................................ 11 37 57 109
2020............................................ 12 43 64 128
2025............................................ 14 47 69 143
2030............................................ 16 52 75 159
2035............................................ 19 56 80 175
2040............................................ 21 61 86 191
2045............................................ 24 66 92 206
2050............................................ 26 71 97 220
----------------------------------------------------------------------------------------------------------------
It is important to recognize that a number of key uncertainties
remain, and that current SCC estimates should be treated as provisional
and revisable since they will evolve with improved scientific and
economic understanding. The interagency group also recognizes that the
existing models are imperfect and incomplete. The 2009 National
Research Council report mentioned above points out that there is
tension between the goal of producing quantified estimates of the
economic damages from an incremental ton of carbon and the limits of
existing efforts to model these effects. There are a number of
analytical challenges that are being addressed by the research
community, including research programs housed in many of the Federal
agencies participating in the interagency process to estimate the SCC.
The interagency group intends to periodically review and reconsider
those estimates to reflect increasing knowledge of the science and
economics of climate impacts, as well as improvements in modeling.
In summary, in considering the potential global benefits resulting
from reduced CO2 emissions, DOE used the values from the
2013 interagency report, adjusted to 2013$ using the implicit price
deflator for GDP from the Bureau of Economic Analysis. For each of the
four sets of SCC values, the values for emissions in 2015 were $12.0,
$40.5, $62.4, and $119 per metric ton avoided (values expressed in
2013$). DOE derived values after 2050 using the relevant growth rate
for the 2040-2050 period in the interagency update.
DOE multiplied the CO2 emissions reduction estimated for
each year by the SCC value for that year in each of the four cases. To
calculate a present value of the stream of monetary values, DOE
discounted the values in each of the four cases using the specific
discount rate that had been used to obtain the SCC values in each case.
2. Social Cost of Other Air Pollutants
As noted above, DOE has taken into account how amended energy
conservation standards would reduce site NOX emissions
nationwide and decrease power sector NOX emissions in those
22 States not affected by the CAIR. DOE estimated the monetized value
of NOX emissions reductions resulting from each of the TSLs
considered for this SNOPR based on estimates found in the relevant
scientific literature. Estimates of the monetary value for reducing
NOX from stationary sources range from $476 to $4,893 per
ton (in 2013$).\57\ DOE calculated monetary benefits using an average
value for NOX emissions of $2,684 per short ton (in 2013$),
and real discount rates of 3 percent and 7 percent.
---------------------------------------------------------------------------
\57\ U.S. Office of Management and Budget, 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 (2006) (Available at: www.whitehouse.gov/sites/default/files/omb/assets/omb/inforeg/2006_cb/2006_cb_final_report.pdf).
---------------------------------------------------------------------------
DOE is evaluating appropriate monetization of avoided
SO2 and Hg emissions in energy conservation standards
rulemakings. DOE has not included monetization of those emissions in
the current analysis.
The CA IOUs and ECOVA asked that DOE take into account the
decreased cost of complying with sulfur dioxide emission regulations as
a result of standards. (CA IOUs, No. 138 at p. 19; ECOVA, Pub. pp. 292-
293) As discussed in section IV.K, under the MATS, SO2
emissions are expected to be well below the cap established by CAIR.
Thus, it is unlikely that the reduction in electricity demand resulting
from energy efficiency standards would have an impact on the cost of
complying with the regulations.
For the SNOPR, DOE retained the same approach as in the NOPR for
monetizing the emissions reductions from the proposed standards.
M. Utility Impact Analysis
The utility impact analysis estimates several effects on the
electric power industry that would result from the adoption of new and
amended energy conservation standards. In the utility impact analysis,
DOE analyzes the changes in installed electrical capacity and
generation that would result for each trial standard level. The
analysis is based on published output from NEMS, which is updated
annually to produce the AEO Reference case as well as a number of side
cases that estimate the economy-wide impacts of changes to energy
supply and demand. DOE uses those published side cases that incorporate
efficiency-related policies to estimate the marginal impacts of reduced
energy demand on the utility sector. The output of this analysis is a
set of time-dependent coefficients that capture the change in
electricity generation, primary fuel consumption, installed capacity
and power sector emissions due to a unit reduction in demand for a
given end use. These coefficients are multiplied by the stream of
electricity savings calculated in the NIA to provide estimates of
selected utility impacts of new or amended energy conservation
standards. Chapter 15 of the SNOPR TSD describes the utility impact
analysis in further detail.
N. Employment Impact Analysis
DOE considers employment impacts in the domestic economy as one
factor in selecting a proposed standard. Employment impacts include
both direct and indirect impacts. Direct employment impacts are any
changes in the number of employees of manufacturers of the products
subject to standards, their suppliers, and related
[[Page 52899]]
service firms. The MIA addresses those impacts. Indirect employment
impacts from standards consist of the net jobs created or eliminated in
the national economy, other than in the manufacturing sector being
regulated, caused by: (1) Reduced spending by end users on energy; (2)
reduced spending on new energy supplies by the utility industry; (3)
increased spending on new products to which the new standards apply;
and (4) the effects of those three factors throughout the economy.
One method for assessing the possible effects on the demand for
labor of such shifts in economic activity is to compare sector
employment statistics developed by BLS.\58\ Data from BLS indicate that
expenditures in the utility sector generally create fewer jobs (both
directly and indirectly) than expenditures in other sectors of the
economy.\59\ There are many reasons for these differences, including
wage differences and the fact that the utility sector is more capital-
intensive and less labor-intensive than other sectors. Energy
conservation standards have the effect of reducing consumer utility
bills. Because reduced consumer expenditures for energy likely lead to
increased expenditures in other sectors of the economy, the general
effect of efficiency standards is to shift economic activity from a
less labor-intensive sector (i.e., the utility sector) to more labor-
intensive sectors (e.g., the retail and service sectors). Thus, based
on the BLS data alone, DOE believes net national employment may
increase due to shifts in economic activity resulting from energy
conservation standards.
---------------------------------------------------------------------------
\58\ Data on industry employment, hours, labor compensation,
value of production, and the implicit price deflator for output for
these industries are available upon request by calling the Division
of Industry Productivity Studies (202-691-5618) or by sending a
request by email to [email protected]. Available at: www.bls.gov/news.release/prin1.nr0.htm.
\59\ See Bureau of Economic Analysis, Regional Multipliers: A
User Handbook for the Regional Input-Output Modeling System (RIMS
II). Washington, DC. U.S. Department of Commerce, 1992.
---------------------------------------------------------------------------
DOE estimated indirect national employment impacts for the standard
levels considered in this SNOPR using an input/output model of the U.S.
economy called Impact of Sector Energy Technologies version 3.1.1
(ImSET).\60\ ImSET is a special-purpose version of the ``U.S. Benchmark
National Input-Output'' (I-O) model, which was designed to estimate the
national employment and income effects of energy-saving technologies.
The ImSET software includes a computer-based I-O model having
structural coefficients that characterize economic flows among 187
sectors most relevant to industrial, commercial, and residential
building energy use.
---------------------------------------------------------------------------
\60\ J.M. Roop, M.J. Scott, and R.W. Schultz, ImSET 3.1: Impact
of Sector Energy Technologies, PNNL-18412, Pacific Northwest
National Laboratory, 2009. Available at: www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf.
---------------------------------------------------------------------------
DOE notes that ImSET is not a general equilibrium forecasting
model, and understands the uncertainties involved in projecting
employment impacts, especially changes in the later years of the
analysis. Because ImSET does not incorporate price changes, the
employment effects predicted by ImSET may over-estimate actual job
impacts over the long run for this rule. Therefore, DOE generated
results for near-term timeframes, where these uncertainties are
reduced. For more details on the employment impact analysis, see
chapter 16 of the SNOPR TSD.
The CEC disagreed with DOE's NOPR employment impact analysis,
which, in its view, shows that increasing energy efficiency causes U.S.
job losses. (California Energy Commission, No. 117 at p. 33) It based
its view on an assumed ratio of jobs in the consumer goods sector
versus the utility sector. The CEC did not provide independent data
sources or references to support the assumption. Nevertheless, DOE
reviewed its inputs to estimate employment impacts. Because nearly all
battery chargers are imported, DOE reports the employment impacts as a
range, with the low end assuming all equipment cost increases remain in
the manufacturing country and the high end assuming all equipment cost
increases are returned to the United States economy via trade. DOE
assumed 50%-75% of increased costs to return to the United States so
the employment impacts fall near the middle of the reported range. The
results of DOE's revised analysis are presented in section V.B.3.c.
O. Marking Requirements
Under 42 U.S.C. 6294(a)(5), Congress granted DOE with the authority
to establish labeling or marking requirements for a number of consumer
products. Among these products are battery chargers.
In this SNOPR, DOE is not proposing to establish marking
requirements for battery chargers. DOE arrived at this decision after
considering all of the public comments it received on this subject and
weighing the expected benefits and burdens of marking requirements for
battery chargers. These public comments are summarized here.
DOE received comments requesting that it not extend marking
requirements to products for which such requirements do not already
exist. AHAM opposed any marking requirement, noting that these types of
requirements are used to (1) inform consumers who can then make
educated choices, (2) differentiate between products where there are
two standards (e.g., UL/CSA); and/or (3) differentiate products that
use a voluntary standard. According to AHAM, none of these purposes
would be served in the context of a mandatory standard with which
manufacturers will need to demonstrate compliance to DOE through its
certification requirements. In AHAM's view, a marking requirement would
add cost and burden without a corresponding benefit. (AHAM, No. 124 at
p. 8) ITI made similar arguments and noted that consumers are likely to
ignore these marks. (ITI, No. 131 at p. 8) Panasonic commented that
efficiency marking requirements for battery chargers and EPSs are
unnecessary and superfluous as the covered products must comply with
standards as a condition of sale in the United States. (Panasonic, No.
120 at pp. 3, 4)
DOE acknowledges that manufacturers are required to certify
compliance with standards using the Compliance Certification Management
System (``CCMS'') database. Under these requirements, battery charger
manufacturers, like other manufacturers of regulated products, would
need to follow the CCMS submission requirements as well if DOE adopts
standards for these products. While DOE also acknowledges that the use
of general markings may have certain limitations in ensuring
compliance, DOE also recognizes that manufacturers and retailers could
use efficiency markings or labels to help ensure that the end-use
consumer products they sell comply with all applicable standards.
However, DOE has not received requests from such parties requesting
additional marking requirements for such purposes.
AHAM, ITI, and Panasonic further requested that if DOE were to
require an efficiency marking for battery chargers, that marking should
be the ``BC'' mark already required by the CEC rather than a Roman
numeral, as proposed by DOE. Brother International also commented in
support of the ``BC'' mark already required by the CEC. The commenters
asserted that the transition from the CEC's scheme to DOE's [Roman
numeral] scheme would be very difficult and costly and could
necessitate the wasteful scrapping of improperly marked devices. They
also asserted that adopting the ``BC'' mark would avoid any potential
confusion created by products bearing two
[[Page 52900]]
markings during the transition period. (AHAM, No. 124 at p. 8; Brother
International, No. 111 at p. 2; ITI, No. 131 at p. 8; Panasonic, No.
120 at p. 3, 4)
NRDC, CEC, CA IOUs, and Delta-Q Technologies all supported a multi-
level, national or international marking protocol for battery chargers
like the scheme proposed by DOE. NRDC strongly encouraged DOE to adopt
its own marking requirements for battery chargers, rather than adopting
the CEC's, and commented that doing so would (1) create a simple
vocabulary for all stakeholders, especially between manufacturers,
retailers and government enforcement agents; (2) facilitate
enforcement, as it drives accountability from the retailer to its
supply-chain; (3) facilitate international adoption by offering a
flexible multi-level scheme that allows adoption of different levels;
(4) facilitate market transformation by encouraging voluntary programs
such as ENERGY STAR to require higher efficiency levels; and (5) create
a longer lived policy with more opportunity for differentiation and
future improvement. NRDC further encouraged DOE to initiate discussions
with the CEC regarding marking as early as possible in order to give
parties enough time to plan and implement any potential changes before
CEC's marking requirement goes into effect on February 1, 2013. (NRDC,
No. 114 at pp. 16-17) The CEC supported DOE's labeling proposal and
suggested that if DOE finalizes a rule that differs in stringency and
construction from the California standards, DOE should include a mark
to represent the California standard levels or set an effective date
for marking that is equivalent to DOE's earliest effective date for
battery charger standards. (California Energy Commission, No. 117 at p.
30) The California IOUs commented that they contributed to and support
the conclusions in the CEC and NRDC comments, including specifically
that ``battery charger and EPS marking should [be] harmonize[d]
internationally.'' (CA IOUs, No. 138 at p. 20) Finally, Delta-Q
Technologies commented that any markings DOE decides to require should
be consolidated with California so products do not have to be labeled
twice and incur double the cost. (Delta-Q Technologies, No. 113 at p.
2)
After considering all of these comments and weighing the expected
benefits and burdens of marking requirements for battery chargers, DOE
is declining to propose marking requirements for battery chargers in
this SNOPR.
DOE received comments from two interested parties requesting that
it not view the CEC-mandated ``BC '' mark as a violation of Federal
law. AHAM commented that DOE should ``address how it will view products
that contain marks indicating compliance with CEC standards. DOE should
minimize burden on manufacturers who decide to sell product in
California after the California standard goes into effect, but are not
yet preempted by DOE's standards by not considering it a violation to
bear the California mark on a product for a reasonable time after DOE's
standard becomes mandatory.'' (AHAM, No. 124 at p. 9) Panasonic also
expressed its concern that a product bearing the California marking
would not comply with Federal requirements once the DOE's regulation
became effective. It sought DOE's guidance on how to treat ``BC''-
marked products and suggested that a grace period to be provided to
manufacturers to adjust to whatever new requirements DOE establishes.
(Panasonic, No. 120 at pp. 3, 4)
In light of DOE's decision not to propose battery charger marking
requirements, manufacturers need not be concerned that marking devices
in accordance with the CEC's present requirements will be a violation
of Federal law. The battery charger standards being proposed in this
notice will become effective two years after the publication of a final
rule, at which time the CEC will no longer be able to compel a
manufacturer to mark its product with a ``BC'' to signal that product's
compliance with the applicable CEC standard. (42 U.S.C. 6297) However,
DOE is not aware of any provisions in law that would prohibit a
manufacturer from voluntarily marking its battery charger with a ``BC''
before or after this time.
P. Reporting Requirements
Upon request from Panasonic, DOE confirms that the CCMS online
compliance process will be required for this rulemaking. (Panasonic,
No. 120 at p. 6)
V. Analytical Results
The following section addresses the results from DOE's analyses
with respect to potential energy conservation standards for battery
chargers. It addresses the TSLs examined by DOE and the projected
impacts of each of these levels if adopted as energy conservation
standards for battery chargers. Additional details regarding DOE's
analyses are contained in the SNOPR TSD supporting this notice.
A. Trial Standards Levels
DOE analyzed the benefits and burdens of four TSLs for battery
chargers. These TSLs were developed using combinations of efficiency
levels for the product classes analyzed by DOE. DOE presents the
results for those TSLs in this proposed rule. The results for all
efficiency levels that DOE analyzed are in the SNOPR TSD. Table V-1
presents the TSLs and the corresponding efficiency levels for battery
chargers. TSL 4 represents the maximum technologically feasible (``max-
tech'') improvements in energy efficiency for all product classes.
While DOE examined most product classes individually, there were two
groups of product classes that use generally similar technology options
and cover the exact same range of battery energies. Because of this
situation, DOE grouped all three low-energy, non-inductive, product
classes (i.e., 2, 3, and 4) together and examined the results.
Similarly, DOE grouped the two medium energy product classes, Product
Classes 5 and 6, together when it examined those results.
Table V-1--Trial Standard Levels for Battery Chargers
------------------------------------------------------------------------
Trial standard level
Product Class -----------------------------------
TSL 1 TSL 2 TSL 3 TSL 4
------------------------------------------------------------------------
PC1--Low E, Inductive............... CSL 1 CSL 2 CSL 2 CSL 3
PC2--Low E, Low Voltage............. CSL 1 CSL 1 CSL 2 CSL 4
PC3--Low E, Medium Voltage.......... CSL 1 CSL 1 CSL 2 CSL 3
PC4--Low E, High Voltage............ CSL 1 CSL 1 CSL 2 CSL 3
PC5--Medium E, Low Voltage.......... CSL 1 CSL 2 CSL 3 CSL 3
PC6--Medium E, High Voltage......... CSL 1 CSL 2 CSL 3 CSL 3
[[Page 52901]]
PC7--High E......................... CSL 1 CSL 1 CSL 2 CSL 2
------------------------------------------------------------------------
For battery charger Product Class 1 (low-energy, inductive), DOE
examined trial standard levels corresponding to each of three CSLs
developed in the engineering analysis. TSL 1 is an intermediate level
of performance above the baseline. TSLs 2 and 3 are equivalent to the
best-in-market and corresponds to the maximum consumer NPV. TSL 4 is
the max-tech level and corresponds to the greatest NES.
For its second set of TSLs, which covers Product Classes 2 (low-
energy, low-voltage), 3 (low-energy, medium-voltage), and 4 (low-
energy, high-voltage), DOE examined four TSLs of different combinations
of the various efficiency levels found for each product class in the
engineering analysis. In this grouping, TSLs 1 and 2 are intermediate
efficiency levels above the baseline for each product class and
corresponds to the maximum consumer NPV. TSL 3 corresponds to an
incremental efficiency level below best-in-market for Product Class 2,
and the best-in-market efficiency level for Product Classes 3 and 4.
Finally, TSL 4 corresponds to the max-tech efficiency level for all
product classes and therefore, the maximum NES. Note that for Product
Class 2 only, CSL 3 (corresponding to a best-in-market efficiency
level) was not analyzed in a given TSL due to the negative LCC savings
results for this product class at CSL 3 and the fact that only four
TSLs were analyzed.
DOE's third set of TSLs corresponds to the grouping of Product
Classes 5 (medium-energy, low-voltage) and 6 (medium-energy, high-
voltage). For both product classes, TSL 1 is an intermediate efficiency
level above the baseline. TSL 2 corresponds to the best-in-market
efficiency level for both product classes and is the level with the
highest consumer NPV. Finally, TSLs 3 and 4 correspond to the max-tech
efficiency level for both product classes and the maximum NES.
For Product Class 7 (high-energy), DOE examined only two CSLs
because of the paucity of products available on the market. TSLs 1 and
2 correspond to an efficiency level equivalent to the best-in-market
and maximizes consumer NPV. TSLs 3 and 4 comprise the max-tech level
corresponding to the level with the maximum NES.
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
DOE analyzed the economic impacts on battery charger consumers by
looking at the effects potential national standards at each TSL would
have on the LCC and PBP. DOE also examined the impacts of potential
standards on consumer subgroups. These analyses are discussed below.
a. Life-Cycle Cost and Payback Period
In general, higher-efficiency products affect consumers in two
ways: (1) Purchase price increases, and (2) annual operating costs
decrease. Inputs used for calculating the LCC and PBP include total
installed costs (i.e., product price plus installation costs), and
operating costs (i.e., annual energy use, energy prices, energy price
trends, repair costs, and maintenance costs). The LCC calculation also
uses product lifetime and a discount rate. Chapter 8 of the SNOPR TSD
provides detailed information on the LCC and PBP analyses.
The key outputs of the LCC analysis are average LCC savings for
each product class for each TSL, relative to the base case, as well as
the percentage of consumers for which the LCC will increase relative to
the base case. Battery chargers are used in applications that can have
a wide range of operating hours. Battery chargers that are used more
frequently will tend to have a larger net LCC benefit than those that
are used less frequently because of the large operating cost savings.
The key output of the PBP analysis is the median PBP at each TSL.
DOE presents the median PBP rather than the mean PBP because it is more
robust in the presence of outliers in the data.\61\ These outliers can
skew the mean PBP calculation but have little effect on the median PBP
calculation. A small change in operating costs, which derive the
denominator of the PBP calculation, can sometimes result in a very
large PBP, which would skew the mean PBP calculation. For example,
consider a sample of PBPs of 2, 2, 2, and 20 years, where 20 years is
an outlier. The mean PBP would return a value of 6.5 years, whereas the
median PBP would return a value of 2 years. Therefore, DOE considers
the median PBP, which is not susceptible to skewing by occasional
outliers.
---------------------------------------------------------------------------
\61\ DOE notes that it uses the median payback period to reduce
the effect of outliers on the data. This method, however, does not
eliminate the outliers from the data.
---------------------------------------------------------------------------
Table V-2 through Table V-15 show the LCC and PBP results for the
TSL efficiency levels considered for each product class. In the first
of each pair of tables, the simple payback is measured relative to the
baseline product. In the second table, the LCC savings are measured
relative to the base-case efficiency distribution in the compliance
year (see section IV.F.9 of this notice).
Table V-2--Average LCC and PBP Results by TSL for Product Class 1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2013$)
---------------------------------------------------------------- Simple Average
TSL CSL First year's Lifetime payback years lifetime
Installed cost operating cost operating cost LCC years
--------------------------------------------------------------------------------------------------------------------------------------------------------
-....................................... 0 4.39 1.08 4.71 9.10 - 5.0
1....................................... 1 4.72 0.76 3.29 8.01 1.1 5.0
2....................................... 2 5.37 0.38 1.64 7.01 1.5 5.0
3....................................... 2 5.37 0.38 1.64 7.01 1.5 5.0
[[Page 52902]]
4....................................... 3 10.62 0.16 0.69 11.32 7.4 5.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each TSL are calculated assuming that all consumers use products at that efficiency level. The PBP is measured relative to the
baseline product.
Table V-3--Average LCC Savings Relative to the Base-Case Efficiency Distribution for Product Class 1
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------
TSL CSL % of consumers Average
that experience savings *
net cost 2013$
----------------------------------------------------------------------------------------------------------------
1............................................................. 1 0.0 0.08
2............................................................. 2 0.0 0.71
3............................................................. 2 0.0 0.71
4............................................................. 3 96.3 -3.44
----------------------------------------------------------------------------------------------------------------
* The calculation includes households with zero LCC savings (no impact).
Table V-4--Average LCC and PBP Results by TSL for Product Class 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2013$)
---------------------------------------------------------------- Simple Average
TSL CSL First year's Lifetime payback years lifetime
Installed cost operating cost operating cost LCC years
--------------------------------------------------------------------------------------------------------------------------------------------------------
-....................................... 0 2.62 0.43 1.43 4.05 - 4.0
1....................................... 1 2.68 0.27 0.86 3.54 0.6 4.0
2....................................... 1 2.68 0.27 0.86 3.54 0.6 4.0
3....................................... 2 3.11 0.16 0.45 3.57 2.5 4.0
4....................................... 4 7.31 0.11 0.31 7.62 19.5 4.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-5--Average LCC Savings Relative to the Base-Case Efficiency Distribution for Product Class 2
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------
TSL CSL % of consumers Average
that experience savings *
net cost 2013$
----------------------------------------------------------------------------------------------------------------
1............................................................. 1 1.2 0.07
2............................................................. 1 1.2 0.07
3............................................................. 2 33.1 0.06
4............................................................. 4 73.8 -2.79
----------------------------------------------------------------------------------------------------------------
Table V-6--Average LCC and PBP Results by TSL for Product Class 3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2013$)
---------------------------------------------------------------- Simple Average
TSL CSL First year's Lifetime payback years lifetime
Installed cost operating cost operating cost LCC years
--------------------------------------------------------------------------------------------------------------------------------------------------------
-....................................... 0 2.59 0.52 2.30 4.89 - 4.9
1....................................... 1 2.70 0.18 0.82 3.52 0.8 4.9
2....................................... 1 2.70 0.18 0.82 3.52 0.8 4.9
3....................................... 2 6.84 0.10 0.43 7.27 21.6 4.9
4....................................... 3 8.83 0.09 0.41 9.24 31.2 4.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 52903]]
Table V-7--Average LCC Savings Relative to the Base-Case Efficiency Distribution for Product Class 3
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------
TSL CSL % of consumers Average
that experience savings *
net cost 2013$
----------------------------------------------------------------------------------------------------------------
1............................................................. 1 0.6 0.08
2............................................................. 1 0.6 0.08
3............................................................. 2 39.0 -1.36
4............................................................. 3 40.8 -2.17
----------------------------------------------------------------------------------------------------------------
Table V-8--Average LCC and PBP Results by TSL for Product Class 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2013$)
---------------------------------------------------------------- Simple payback Average
TSL CSL First year's Lifetime years lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
-....................................... 0 3.75 1.61 5.62 9.37 .............. 3.7
1....................................... 1 4.89 0.67 2.28 7.17 1.4 3.7
2....................................... 1 4.89 0.67 2.28 7.17 1.4 3.7
3....................................... 2 9.29 0.45 1.55 10.84 5.2 3.7
4....................................... 3 27.06 0.38 1.30 28.36 20.7 3.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-9--Average LCC Savings Relative to the Base-Case Efficiency Distribution for Product Class 4
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------
TSL CSL % of consumers Average
that experience savings *
net cost 2013$
----------------------------------------------------------------------------------------------------------------
1............................................................. 1 1.3 0.11
2............................................................. 1 1.3 0.11
3............................................................. 2 12.6 -0.38
4............................................................. 3 25.8 -4.91
----------------------------------------------------------------------------------------------------------------
Table V-10--Average LCC and PBP Results by TSL for Product Class 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2013$)
---------------------------------------------------------------- Simple Average
TSL CSL First year's Lifetime payback years lifetime years
Installed cost operating cost operating cost LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
-....................................... 0 46.58 11.68 68.85 115.43 .............. 4.0
1....................................... 1 51.37 7.74 45.38 96.75 2.3 4.0
2....................................... 2 58.94 2.87 16.36 75.30 2.7 4.0
3....................................... 3 207.68 1.26 7.10 214.77 29.1 4.0
4....................................... 3 207.68 1.26 7.10 214.77 29.1 4.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-11--Average LCC Savings Relative to the Base-Case Efficiency Distribution for Product Class 5
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------
TSL CSL % of consumers Average
that experience savings *
net cost 2013$
----------------------------------------------------------------------------------------------------------------
1............................................................. 1 0.0 0.00
2............................................................. 2 0.6 0.84
3............................................................. 3 99.7 -138.63
4............................................................. 3 99.7 -138.63
----------------------------------------------------------------------------------------------------------------
[[Page 52904]]
Table V-12--Average LCC and PBP Results by TSL for Product Class 6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2013$)
---------------------------------------------------------------- Simple Average
TSL CSL First year's Lifetime payback years lifetime
Installed cost operating cost operating cost LCC years
--------------------------------------------------------------------------------------------------------------------------------------------------------
-....................................... 0 45.39 15.93 113.08 158.47 .............. 9.7
1....................................... 1 50.14 10.81 77.60 127.74 1.0 9.7
2....................................... 2 57.64 4.45 33.33 90.98 1.1 9.7
3....................................... 3 205.07 2.24 16.94 222.01 12.5 9.7
4....................................... 3 205.07 2.24 16.94 222.01 12.5 9.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-13--Average LCC Savings Relative to the Base-Case Efficiency Distribution for Product Class 6
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------
TSL CSL % of consumers Average
that experience savings *
net cost 2013$
----------------------------------------------------------------------------------------------------------------
1............................................................. 1 0.0 0.00
2............................................................. 2 0.0 1.89
3............................................................. 3 100.0 -129.15
4............................................................. 3 100.0 -129.15
----------------------------------------------------------------------------------------------------------------
Table V-14--Average LCC and PBP Results by TSL for Product Class 7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2013$)
---------------------------------------------------------------- Simple Average
TSL CSL First year's Lifetime payback years lifetime
Installed cost operating cost operating cost LCC years
--------------------------------------------------------------------------------------------------------------------------------------------------------
-....................................... 0 221.94 29.42 95.03 316.97 .............. 3.5
1....................................... 1 181.55 22.09 70.81 252.36 0.0 3.5
2....................................... 1 181.55 22.09 70.81 252.36 0.0 3.5
3....................................... 2 334.87 15.14 48.60 383.47 8.1 3.5
4....................................... 2 334.87 15.14 48.60 383.47 8.1 3.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-15--Average LCC Savings Relative to the Base-Case Efficiency Distribution for Product Class 7
----------------------------------------------------------------------------------------------------------------
Life-cycle cost savings
---------------------------------
TSL CSL % of consumers Average
that experience savings *
net cost 2013$
----------------------------------------------------------------------------------------------------------------
1............................................................. 1 0.0 51.06
2............................................................. 1 0.0 51.06
3............................................................. 2 100.0 -80.05
4............................................................. 2 100.0 -80.05
----------------------------------------------------------------------------------------------------------------
The LCC results for battery chargers depend on the product class
being considered. See Table V-2 through Table V-15. LCC savings results
for Product Class 1 are positive through TSL 3. For the low-energy
product classes (Product Classes 2, 3, and 4), LCC results are positive
through TSL 2 and become negative at TSL 3, with Product Class 2
becoming negative at TSL 4. The medium-energy product classes (Product
Classes 5 and 6) are positive through TSL 2 but become negative at TSL
3. The high-energy product class (Product Class 7) has positive LCC
savings through TSL 2, and then becomes negative at TSL 3.
b. Consumer Subgroup Analysis
Certain consumer subgroups may be disproportionately affected by
standards. DOE performed LCC subgroup analyses in this SNOPR for low-
income consumers, small businesses, residential top tier electricity
price consumers, time-of-use peak electricity price consumers, and
consumers of specific applications. See section IV.F of this SNOPR for
a review of the inputs to the LCC analysis. LCC and PBP results for
consumer subgroups are presented in Table V-16 through Table V-22. The
abbreviations are described after Table V-22. The ensuing discussion
presents the most significant results from the LCC subgroup analysis.
[[Page 52905]]
Table V-16--Comparison of LCC Savings and PBP for Consumer Subgroups and All Households for Product Class 1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2013$) Simple payback period (years)
TSL -------------------------------------------------------------------------------------------------------------
LI SB TT P-TOU All LI SB TT P-TOU All
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 0.08 0.00 0.26 0.39 0.08 1.1 0.0 0.3 0.2 1.1
2......................................... 0.71 0.00 2.88 4.31 0.71 1.5 0.0 0.5 0.3 1.5
3......................................... 0.71 0.00 2.88 4.31 0.71 1.5 0.0 0.5 0.3 1.5
4......................................... (3.46) 0.00 0.44 3.00 (3.44) 7.4 0.0 2.3 1.6 7.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-17--Comparison of LCC Savings and PBP for Consumer Subgroups and All Households for Product Class 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2013$) Simple payback period (years)
TSL -------------------------------------------------------------------------------------------------------------
LI SB TT P-TOU All LI SB TT P-TOU All
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 0.06 0.08 0.17 0.29 0.07 0.5 0.6 0.2 0.1 0.6
2......................................... 0.06 0.08 0.17 0.29 0.07 0.5 0.6 0.2 0.1 0.6
3......................................... 0.05 (0.01) 0.58 0.96 0.06 2.4 3.8 0.9 0.6 2.5
4......................................... (2.76) (3.29) (2.05) (1.56) (2.79) 18.6 25.2 6.9 4.8 19.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-18--Comparison of LCC Savings and PBP for Consumer Subgroups and All Households for Product Class 3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2013$) Simple payback period (years)
TSL -------------------------------------------------------------------------------------------------------------
LI SB TT P-TOU All LI SB TT P-TOU All
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 0.07 0.14 0.23 0.36 0.08 0.8 0.2 0.2 0.2 0.8
2......................................... 0.07 0.14 0.23 0.36 0.08 0.8 0.2 0.2 0.2 0.8
3......................................... (1.38) (1.10) (0.86) (0.43) (1.36) 22.0 4.8 6.9 4.8 21.6
4......................................... (2.19) (1.85) (1.65) (1.20) (2.17) 31.3 6.6 10.0 7.0 31.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-19--Comparison of LCC Savings and PBP for Consumer Subgroups and All Households for Product Class 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2013$) Simple payback period (years)
TSL -------------------------------------------------------------------------------------------------------------
LI SB TT P-TOU All LI SB TT P-TOU All
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 0.15 0.06 0.57 0.68 0.11 0.9 1.5 0.3 0.3 1.4
2......................................... 0.15 0.06 0.57 0.68 0.11 0.9 1.5 0.3 0.3 1.4
3......................................... (0.49) (0.27) 0.07 0.53 (0.38) 4.0 5.5 1.2 1.1 5.2
4......................................... (5.80) (3.83) (5.07) (3.79) (4.91) 15.6 21.7 4.7 4.3 20.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-20--Comparison of LCC Savings and PBP for Consumer Subgroups and All Households for Product Class 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2013$) Simple payback period (years)
TSL -------------------------------------------------------------------------------------------------------------
LI SB TT P-TOU All LI SB TT P-TOU All
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 0.00 0.00 0.00 0.00 0.00 2.3 0.0 0.8 0.5 2.3
2......................................... 0.84 0.00 3.14 4.64 0.84 2.7 0.0 0.9 0.6 2.7
3......................................... (138.81) 0.00 (118.82) (105.75) (138.63) 29.1 0.0 9.8 6.8 29.1
4......................................... (138.81) 0.00 (118.82) (105.75) (138.63) 29.1 0.0 9.8 6.8 29.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 52906]]
Table V-21--Comparison of LCC Savings and PBP for Consumer Subgroups and All Households for Product Class 6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2013$) Simple payback period (years)
TSL -------------------------------------------------------------------------------------------------------------
LI SB TT P-TOU All LI SB TT P-TOU All
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 0.00 0.00 0.00 0.00 0.00 1.0 0.0 0.3 0.2 1.0
2......................................... 1.87 0.00 6.24 9.10 1.89 1.1 0.0 0.4 0.3 1.1
3......................................... (129.38) 0.00 (93.98) (70.73) (129.15) 12.6 0.0 4.0 2.8 12.5
4......................................... (129.38) 0.00 (93.98) (70.73) (129.15) 12.6 0.0 4.0 2.8 12.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-22--Comparison of LCC Savings and PBP for Consumer Subgroups and All Households for Product Class 7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average life-cycle cost savings (2013$) Simple payback period (years)
TSL -------------------------------------------------------------------------------------------------------------
LI SB TT P-TOU All LI SB TT P-TOU All
--------------------------------------------------------------------------------------------------------------------------------------------------------
1......................................... 51.88 49.36 89.56 116.93 51.06 0.0 0.0 0.0 0.0 0.0
2......................................... 51.88 49.36 89.56 116.93 51.06 0.0 0.0 0.0 0.0 0.0
3......................................... (93.28) (82.08) (39.75) 62.98 (80.05) 20.1 8.0 6.4 1.6 8.1
4......................................... (93.28) (82.08) (39.75) 62.98 (80.05) 20.1 8.0 6.4 1.6 8.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Where:
LI = Low-income consumers
SB = Small businesses
TT = Top tier electricity price consumers
P-TOU = Peak time-of-use electricity price consumers
All = Entire population
Low-Income Consumers
For low-income consumers, the LCC impacts and PBPs are different
from the general population. This subgroup considers only the
residential sector, and uses an adjusted population distribution from
the reference case scenario. Using 2009 RECS data, DOE determined that
low-income consumers have a different population distribution than the
general population. To account for this difference, DOE adjusted
population distributions for each region analyzed according to the
shift between general and low-income populations.
The LCC savings and PBPs of low-income consumers are similar to
that of the total population of consumers. In general, low-income
consumers experience slightly reduced LCC savings, with the exceptions
of TSL 4 of Product Class 2 and TSLs 1 and 2 of Product Classes 4 and
7. None of the changes in LCC savings move a TSL from positive to
negative LCC savings, or vice versa.
Small Businesses
For small business customers, the LCC impacts and PBPs are
different from the general population. This subgroup analysis considers
only the commercial sector, and uses an adjusted discount rate from the
reference case scenario. DOE found that small businesses typically have
a cost of capital that is 4.16 percent higher than the industry
average, which was applied to the discount rate for the small business
consumer subgroup analysis.
The small business consumer subgroup LCC results are not directly
comparable to the reference case LCC results because this subgroup only
considers commercial applications. In the reference case scenario, the
LCC results are strongly influenced by the presence of residential
applications, which typically comprise the majority of application
shipments. Note that Product Classes 1, 5, and 6 have no results for
small businesses because there are no commercial applications for these
product classes. No LCC results that were positive for all consumers
become negative in the small business subgroup analysis, with the
exception of Product Class 2, which became -$0.01 at TSL 3. No negative
LCC results for all consumers became positive for small businesses.
These observations indicate that small business consumers would
experience similar LCC impacts as the general population.
Top Tier Electricity Price Consumers
For top tier electricity price consumers, the LCC impacts and PBPs
are different from the general population. Tiered pricing is generally
only used for residential electricity rates, so the analysis for this
subgroup only considers the residential sector. DOE researched upper
tier inclined marginal block rates for the electricity, resulting in a
price of $0.359 per kWh.
Consumers in the top tier electricity price bracket generally
experience greater LCC savings than those in the reference case
scenario. This result occurs because these consumers pay more for their
electricity than other consumers, and, therefore, experience greater
savings when using products that are more energy efficient. This
subgroup analysis changed the negative LCC savings for Product Class 1
at TSL 4 and Product Class 4 at TSL 3 to positive LCC savings.
Peak Time-of-Use Electricity Price Consumers
For peak time-of-use electricity price consumers, the LCC impacts
and PBPs are different from the general population. Time-of-use pricing
is available for both residential and commercial electricity rates, so
both sectors were considered. DOE researched upper tier inclined
marginal block rates for electricity, resulting in adjusted electricity
prices of $0.514 per kWh for residential and $0.494 for commercial
consumers.
This subgroup analysis increased the LCC savings of most of the
representative units significantly. This subgroup analysis changed the
following negative LCC results to positive savings: Product Class 1 at
TSL 4, Product Class 4 at TSL 3, and Product Class 7 at TSLs 3 and 4.
Some product classes would still have negative LCC savings, which
indicates that these product classes have increasing installed costs
(purchase price plus installation costs, the latter of which are
assumed to be zero) at higher TSLs that cannot be overcome through
operating cost savings using peak time-of-use electricity prices.
[[Page 52907]]
Consumers of Specific Applications
DOE performed an LCC and PBP analysis on every application within
each product class. This subgroup analysis used each application's
specific inputs for lifetime costs, markups, base case market
efficiency distribution, and UEC. Many applications in each product
class experienced LCC impacts and PBPs that were different from the
average results across the product class. Because of the large number
of applications considered in the analysis, some of which span multiple
product classes, DOE did not present application-specific LCC results
here. Detailed results on each application are available in chapter 11
of the SNOPR TSD.
DOE noted a few trends highlighted by the application-specific
subgroup. For Product Class 2, the top two application LCC savings
representing 46 percent of shipments are negative beyond TSL 1, but
frequently used applications within that class--e.g., answering
machines, cordless phones, and home security systems--experience
positive LCC savings. Because these applications have significantly
positive LCC savings, they balance out the negative savings from the
top two applications. Some Product Class 4 applications at TSLs 1
through 3 featured results that were positive where the shipment-
weighted results were negative, or vice versa. However, shipments and
magnitude of the LCC savings were not enough to change the overall
direction (positive or negative) of the weighted average. In the other
battery charger product classes, the individual application results
reflected the same trend as the overall results for the product class.
See chapter 11 of the SNOPR TSD for further detail.
c. Rebuttable Presumption Payback
As discussed in section III.E.2, EPCA establishes a rebuttable
presumption that an energy conservation standard is economically
justified if the increased purchase cost for a product that meets the
standard is less than three times the value of the first-year energy
savings resulting from the standard. As required by EPCA, DOE based the
energy use calculation on the DOE test procedures for battery chargers.
Table V-23 presents the rebuttable-presumption PBPs for the considered
TSLs. While DOE examined the rebuttable-presumption criterion, it
considered whether the standard levels considered for this rule are
economically justified through a more detailed analysis of the economic
impacts of those levels, pursuant to 42 U.S.C. 6295(o)(2)(B)(i), that
considers the full range of impacts to the consumer, manufacturer,
Nation, and environment. The results of that analysis serve as the
basis for DOE to definitively evaluate the economic justification for a
potential standard level, thereby supporting or rebutting the results
of any preliminary determination of economic justification. Table V-23
shows considered TSLs for the battery charger product classes where the
rebuttable presumption PBPs show they are economically justified.
Because a PBP of less than three years indicates that the increased
purchase cost is less than three times the value of the first-year
energy savings for that efficiency level, this table highlights product
class TSLs where the PBP is less than three years.
Table V-23--Trial Standard Levels With Rebuttable Payback Period Less Than Three Years
----------------------------------------------------------------------------------------------------------------
Trial Candidate Rebuttable
Product class Description standard standard presumption
level level PBP years
----------------------------------------------------------------------------------------------------------------
1..................................... Low-Energy, Inductive... 1 1 1.1
2 2 1.5
3 2 1.5
2..................................... Low-Energy, Low-Voltage. 1 1 0.6
2 1 0.6
3 2 2.5
3..................................... Low-Energy, Medium- 1 1 0.8
Voltage.
2 1 0.8
4..................................... Low-Energy, High-Voltage 1 1 1.4
2 1 1.4
5..................................... Medium-Energy, Low- 1 1 2.3
Voltage.
2 2 2.7
6..................................... Medium-Energy, High- 1 1 1.0
Voltage.
2 2 1.1
7..................................... High-Energy............. 1 1 0.0
2 1 0.0
----------------------------------------------------------------------------------------------------------------
2. Economic Impact on Manufacturers
DOE performed an MIA to estimate the impact of new energy
conservation standards on battery charger application manufacturers.
The following sections describe the expected impacts on battery charger
application manufacturers at each TSL. Chapter 12 of this SNOPR TSD
explains the MIA in further detail.
a. Industry Cash-Flow Analysis Results
The INPV results refer to the difference in industry value between
the base case and the standards case, which DOE calculated by summing
the discounted industry cash flows from the base year (2015) through
the end of the analysis period. The discussion also notes the
difference in the annual cash flow between the base case and the
standards case in the year before the compliance date of new energy
conservation standards. This figure provides a proxy for the magnitude
of the required conversion costs, relative to the cash flow generated
by the industry in the base case.
DOE reports INPV impacts at each TSL for the four product class
groupings. When appropriate, DOE also discusses the results for groups
of related applications that would experience impacts significantly
different from the overall product class group to which they belong.
In general, two major factors drive the INPV results: (1) the
relative difference between a given applications' MSP and the
incremental cost of improving its battery charger; and (2) the dominant
base case battery charger technology that a given application uses,
which is approximated by the application's efficiency distribution.
[[Page 52908]]
With respect to the first factor, the higher the MSP of the
application relative to the battery charger cost, the lower the impacts
of battery charger standards on OEMs of the application. For example,
an industry that sells an application for $500 would be less affected
by a $2 increase in battery charger costs than one that sells its
application for $10. On the second factor regarding base case
efficiency distribution, some industries, such as producers of laptop
computers, already incorporate highly efficient battery chargers.
Therefore, a higher standard would be unlikely to impact the laptop
industry as it would other applications using baseline technology in
the same product class.
DOE analyzed three markup scenarios--constant price, pass-through,
and flat markup. The constant price scenario analyzes the situation in
which application manufacturers are unable to pass on any incremental
costs of more efficient battery chargers to their customers. This
scenario generally results in the most significant negative impacts
because no incremental costs added to the application--whether driven
by higher battery charger component costs or depreciation of required
capital investments--can be recouped.
In the pass-through scenario, DOE assumes that manufacturers are
able to pass the incremental costs of more efficient battery chargers
through to their customers, but not with any markup to cover overhead
and profit. Therefore, though less severe than the constant price
scenario in which manufacturers absorb all incremental costs, this
scenario results in negative cash flow impacts due to margin
compression and greater working capital requirements.
Finally, DOE considers a flat markup scenario to analyze the upper
bound (most positive) of profitability impacts. In this scenario,
manufacturers are able to maintain their base case gross margin, as a
percentage of revenue, at higher CSLs, despite the higher product costs
associated with more efficient battery chargers. In other words,
manufacturers can fully pass on--and markup--the higher incremental
product costs associated with more efficient battery chargers.
Product Class 1
Table V-24 through Table V-27 summarize information related to the
analysis performed to project the potential impacts on Product Class 1
battery charger application manufacturers.
Table V-24--Applications in Product Class 1
------------------------------------------------------------------------
Product class 1
-------------------------------------------------------------------------
Rechargeable Toothbrushes
Rechargeable Water Jets
------------------------------------------------------------------------
Table V-25--Manufacturers Impact Analysis for Product Class 1 Battery Charger Applications--Flat Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 497 497 496 496 519
Change in INPV............................ 2013$ Millions.............. .............. 0 (1) (1) 22
(%)......................... .............. 0.0 (0.1) (0.1) 4.5
Product Conversion Costs.................. 2013$ Millions.............. .............. 0.1 1.7 1.7 5.1
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.0 1.5 1.5 2.3
Total Investment Required................. 2013$ Millions.............. .............. 0.1 3.2 3.2 7.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-26--Manufacturers Impact Analysis for Product Class 1 Battery Charger Applications--Pass Through Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 497 491 470 470 348
Change in INPV............................ 2013$ Millions.............. .............. (6) (27) (27) (149)
(%)......................... .............. (1.1) (5.4) (5.4) (29.9)
Product Conversion Costs.................. 2013$ Millions.............. .............. 0.1 1.7 1.7 5.1
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.0 1.5 1.5 2.3
Total Investment Required................. 2013$ Millions.............. .............. 0.1 3.2 3.2 7.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-27--Manufacturers Impact Analysis for Product Class 1 Battery Charger Applications--Constant Price Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 497 478 412 412 122
Change in INPV............................ 2013$ Millions.............. .............. (18) (84) (84) (375)
(%)......................... .............. (3.7) (16.9) (16.9) (75.5)
Product Conversion Costs.................. 2013$ Millions.............. .............. 0.1 1.7 1.7 5.1
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.0 1.5 1.5 2.3
Total Investment Required................. 2013$ Millions.............. .............. 0.1 3.2 3.2 7.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 52909]]
Product Class 1 has only two applications: rechargeable
toothbrushes and water jets. Rechargeable toothbrushes represent over
99 percent of the Product Class 1 shipments. DOE found the majority of
these models include Ni-Cd battery chemistries, although products with
NiMH and Li-ion chemistries exist in the market. During interviews,
manufacturers indicated that energy efficiency was not a primary
selling point in this market. As a consequence, manufacturers expect
that stringent standards would likely impact the low-end of the market,
where price competition is most fierce and retail selling prices are
lowest.
TSL 1 sets the efficiency level at CSL 1 for Product Class 1. At
TSL 1, DOE estimates impacts on the change in INPV to range from -$18
million to less than one million dollars, or a change in INPV of -3.7
percent to less than 0.1 percent. At TSL 1, industry free cash flow
(operating cash flow minus capital expenditures) is estimated to
decrease by less than one million dollars, which corresponds to less
than one percent in 2017, the year leading up to new energy
conservation standards.
Percentage impacts on INPV are slightly negative at TSL 1. DOE does
not anticipate that Product Class 1 battery charger application
manufacturers would lose a significant portion of their INPV at this
TSL. DOE projects that in the expected year of compliance, 2018, 93
percent of all Product Class 1 battery charger applications would meet
or exceed the efficiency levels required at TSL 1. Consequently, DOE
expects conversion costs to be small at TSL 1, since so many
applications already meet or exceed this requirement.
TSL 2 and TSL 3 set the efficiency level at CSL 2 for Product Class
1. At TSL 2 and TSL 3, DOE estimates impacts on the change in INPV to
range from -$84 million to -$1 million, or a change in INPV of -16.9
percent to -0.1 percent. At TSL 2 and TSL 3, industry free cash flow is
estimated to decrease to $38 million, or a drop of 4 percent, compared
to the base-case value of $39 million in 2017.
Percentage impacts on INPV range from slightly negative to
moderately negative at these TSLs. DOE does not anticipate that Product
Class 1 battery charger application manufacturers would lose a
significant portion of their INPV at these TSLs. DOE projects that in
the expected year of compliance, 2018, 37 percent of all Product Class
1 battery charger applications would meet or exceed the efficiency
levels required at TSL 2 and TSL 3. DOE expects conversion costs to
increase from $0.1 million at TSL 1 to $3.2 million at TSL 2 and TSL 3.
This is still a relatively modest amount compared to the base case INPV
of $497 million and annual cash flow of $39 million for Product Class 1
battery charger applications.
TSL 4 sets the efficiency level at CSL 3 for Product Class 1. This
represents max tech for Product Class 1. At TSL 4, DOE estimates
impacts on the change in INPV to range from -$375 million to $22
million, or a change in INPV of -75.5 percent to 4.5 percent. At TSL 4,
industry free cash flow is estimated to decrease to $36 million, or a
drop of 8 percent, compared to the base-case value of $39 million in
2017.
Percentage impacts on INPV range from significantly negative to
slightly positive at TSL 4. DOE anticipates that some Product Class 1
battery charger application manufacturers could lose a significant
portion of their INPV at TSL 4. DOE projects that in the expected year
of compliance, 2018, 4 percent of all Product Class 1 battery charger
applications would meet the efficiency levels required at TSL 4. DOE
expects conversion costs to increase from $3.2 million at TSL 2 and TSL
3 to $7.4 million at TSL 4. This is still relatively a modest amount
compared to the base case INPV of $497 million and annual cash flow of
$39 million for Product Class 1 battery charger applications. At TSL 4,
the battery charger MPC increases to $6.80 compared to the baseline MPC
value of $2.05. This represents a moderate increase in the application
price when compared to the shipment-weighted average application MPC of
$40.06.
Product Classes 2, 3, and 4
The following tables (Table V-28 through Table V-34) summarize
information related to the analysis performed to project the potential
impacts on manufacturers of devices falling into Product Classes 2, 3,
and 4.
Table V-28--Applications in Product Classes 2, 3, and 4
------------------------------------------------------------------------
Product class 2 Product class 3 Product class 4
------------------------------------------------------------------------
Answering Machines Air Mattress Pumps DIY Power Tools
(External)
Baby Monitors Blenders Flashlights/Lanterns
Beard and Moustache Camcorders Handheld Vacuums
Trimmers
Bluetooth Headsets DIY Power Tools Netbooks
(External)
Can Openers DIY Power Tools Notebooks
(Integral)
Consumer Two-Way Radios Handheld Vacuums Portable Printers
Cordless Phones LAN Equipment Professional Power
Tools
Digital Cameras Mixers Rechargeable Garden
Care Products
DIY Power Tools Portable DVD Players Robotic Vacuums
(Integral)
E-Books Portable Printers Stick Vacuums
Hair Clippers RC Toys Universal Battery
Chargers
Handheld GPS Stick Vacuums
Home Security Systems Toy Ride-On Vehicles
In-Vehicle GPS Universal Battery
Chargers
Media Tablets Wireless Speakers
Mobile Internet
Hotspots
Mobile Phones
MP3 Players
MP3 Speaker Docks
Personal Digital
Assistants
Portable Video Game
Systems
Shavers
Smartphone
Universal Battery
Chargers
Video Game Consoles
Wireless Headphones
------------------------------------------------------------------------
[[Page 52910]]
Table V-29--Manufacturers Impact Analysis for Product Class 2, 3, and 4 Battery Charger Applications--Flat Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 76,791 76,782 76,782 76,774 77,290
Change in INPV............................ 2013$ Millions.............. .............. (10) (10) (17) 499
(%)......................... .............. (0.0) (0.0) (0.0) 0.6
Product Conversion Costs.................. 2013$ Millions.............. .............. 11.5 11.5 90.1 280.5
Capital Conversion Costs.................. 2013$ Millions.............. .............. 1.8 1.8 25.6 67.3
Total Investment Required................. 2013$ Millions.............. .............. 13.4 13.4 115.7 347.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-30--Manufacturers Impact Analysis for Product Class 2, 3, and 4 Battery Charger Applications--Pass Through Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 76,791 76,740 76,740 76,322 71,407
Change in INPV............................ 2013$ Millions.............. .............. (51) (51) (469) (5,384)
(%)......................... .............. (0.1) (0.1) (0.6) (7.0)
Product Conversion Costs.................. 2013$ Millions.............. .............. 11.5 11.5 90.1 280.5
Capital Conversion Costs.................. 2013$ Millions.............. .............. 1.8 1.8 25.6 67.3
Total Investment Required................. 2013$ Millions.............. .............. 13.4 13.4 115.7 347.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-31--Manufacturers Impact Analysis for Product Class 2, 3, and 4 Battery Charger Applications--Constant Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 76,791 76,650 76,650 75,392 62,307
Change in INPV............................ 2013$ Millions.............. .............. (141) (141) (1,400) (14,484)
(%)......................... .............. (0.2) (0.2) (1.8) (18.9)
Product Conversion Costs.................. 2013$ Millions.............. .............. 11.5 11.5 90.1 280.5
Capital Conversion Costs.................. 2013$ Millions.............. .............. 1.8 1.8 25.6 67.3
Total Investment Required................. 2013$ Millions.............. .............. 13.4 13.4 115.7 347.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Taken together, Product Classes 2, 3, and 4 include the greatest
number of applications and account for approximately 96 percent of all
battery charger application shipments in 2018, the anticipated
compliance year for new energy conservation standards.
TSL 1 and TSL 2 set the efficiency level at CSL 1 for all product
classes in this grouping. At TSL 1 and TSL 2, DOE estimates impacts on
the change in INPV to range from -$141 million to -$10 million, or a
change in INPV of -0.2 percent to less than -0.1 percent. At TSL 1 and
TSL 2, industry free cash flow is estimated to decrease to $6,018
million, or a drop of less than one percent, compared to the base-case
value of $6,024 million in 2017.
Percentage impacts on INPV are slightly negative at TSL 1 and TSL
2. DOE does not anticipate that most Product Class 2, 3, and 4 battery
charger application manufacturers would lose a significant portion of
their INPV at TSL 1 or TSL 2. DOE projects that in the expected year of
compliance, 2018, 91 percent of all Product Class 2 battery charger
applications, 94 percent of all Product Class 3 battery charger
applications, and 94 percent of all Product Class 4 battery charger
applications would meet or exceed the efficiency levels required at TSL
1 and TSL 2. Consequently, DOE expects conversion costs to be small at
TSL 1 and TSL 2, approximately $13.4 million since so many applications
already meet or exceed this requirement.
TSL 3 sets the efficiency level at CSL 2 for all product classes in
this grouping. At TSL 3, DOE estimates impacts on the change in INPV to
range from -$1,400 million to $17 million, or a change in INPV of -1.8
percent to less than -0.1 percent. At TSL 3, industry free cash flow is
estimated to decrease to $5,973 million, or a drop of 1 percent,
compared to the base-case value of $6,024 million in 2017.
Percentage impacts on INPV are slightly negative at this TSL. DOE
does not anticipate that Product Class 2, 3, and 4 battery charger
application manufacturers would lose a significant portion of their
INPV at this TSL. DOE projects that in the expected year of compliance,
2018, 49 percent of all Product Class 2 battery charger applications,
60 percent of all Product Class 3 battery charger applications, and 86
percent of all Product Class 4 battery charger applications would meet
or exceed the efficiency levels required at TSL 3. DOE expects
conversion costs to increase from $13.4 million at TSL 1 and TSL 2 to
$115.7 million at TSL 3. This represents a relatively modest amount
compared to the base case INPV of $76.8 billion and annual cash flow of
$6,02 billion for Product Class 2, 3, and 4 battery charger
applications.
TSL 4 sets the efficiency level at CSL 3 for Product Classes 3 and
4 and CSL 4 for Product Class 2. These efficiency levels represent max
tech for all the product classes in this grouping. At TSL 4, DOE
estimates impacts on the change in INPV to range from -$14.48 billion
to $499 million, or a change in INPV of -18.9 percent to 0.6 percent.
At TSL 4,
[[Page 52911]]
industry free cash flow is estimated to decrease to $5.87 billion, or a
drop of 3 percent, compared to the base-case value of $6.02 billion in
2017.
Percentage impacts on INPV range from moderately negative to
slightly positive at TSL 4. DOE anticipates that some Product Class 2,
3, and 4 battery charger application manufacturers could lose a
significant portion of their INPV at TSL 4. DOE projects that in the
expected year of compliance, 2018, 25 percent of all Product Class 2
battery charger applications, 58 percent of all Product Class 3 battery
charger applications, and 74 percent of all Product Class 4 battery
charger applications would meet the efficiency levels required at TSL
4. DOE expects conversion costs to significantly increase from $115.7
million at TSL 3 to $347.8 million at TSL 4. At TSL 4, the Product
Class 2 battery charger MPC increases to $4.31 compared to the baseline
MPC value of $1.16. This represents a small application price increase
considering that the shipment-weighted average Product Class 2 battery
charger application MPC is $127.73. For Product Class 3, the MPC
increases to $5.51 compared to the baseline MPC value of $1.12. This
estimate also represents a small application price increase since the
shipment-weighted average Product Class 3 battery charger application
MPC is $61.11. For Product Class 4, the battery charger MPC increases
to $18.34 compared to the baseline battery charger MPC of $1.79. While
DOE recognizes that this projected increase of $16.55 in the battery
charger MPC from the baseline to the max tech may seem significant, its
impact is modest when compared to the shipment-weighted average Product
Class 4 battery charger application MPC of $192.40--in essence, it
represents a 8.6 percent increase in the average battery charger
application MPC.
These product classes also include a wide variety of applications,
characterized by differing shipment volumes, base case efficiency
distributions, and MSPs. Because of this variety, this product class
grouping, more than any other, requires a greater level of
disaggregation to evaluate specific industry impacts. Presented only on
a product class basis, industry impacts are effectively shipment-
weighted and mask impacts on certain industry applications that vary
substantially from the aggregate results. Therefore, in addition to the
overall product class group results, DOE also presents results by
industry subgroups--consumer electronics, power tools, and small
appliances--in the pass-through scenario, which approximates the mid-
point of the potential range of INPV impacts. These results highlight
impacts at various TSLs.
As discussed in the previous section, these aggregated results can
mask differentially impacted industries and manufacturer subgroups.
Nearly 90 percent of shipments in Product Classes 2, 3 and 4 fall under
the broader consumer electronics category, with the remaining share
split between small appliances and power tools. Consumer electronics
applications have a much higher shipment-weighted average MPC ($147.29)
than the other product categories ($58.32 for power tools and $43.63
for small appliances). Consequently, consumer electronics manufacturers
are better able to absorb higher battery charger costs than small
appliance and power tool manufacturers. Further, consumer electronics
typically incorporate higher efficiency battery chargers already, while
small appliances and power tool applications tend to cluster around
baseline and CSL 1 efficiencies. These factors lead to proportionally
greater impacts on small appliance and power tool manufacturers in the
event they are not able to pass on and markup higher battery charger
costs.
Table V-32 through Table V-34 present INPV impacts in the pass-
through markup scenario for consumer electronic, power tool, and small
appliance applications, respectively (for only those applications
incorporating battery chargers in Product Classes 2, 3 or 4). The
results indicate manufacturers of power tools and small appliances
would face disproportionately adverse impacts, especially at the higher
TSLs, as compared to consumer electronics manufacturers and the overall
product group's results (shown in Table V-29 through Table V-31), if
they are not able to mark up the incremental product costs.
Table V-32--Manufacturers Impact Analysis for Product Class 2, 3, and 4 Battery Charger Applications--Pass Through Markup Scenario--Consumer Electronics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 73,840 73,805 73,805 73,511 69,568
Change in INPV............................ 2013$ Millions.............. .............. (36) (36) (329) (4,272)
(%)......................... .............. (0.0) (0.0) (0.4) (5.8)
Product Conversion Costs.................. 2013$ Millions.............. .............. 10.2 10.2 77.6 242.2
Capital Conversion Costs.................. 2013$ Millions.............. .............. 1.7 1.7 20.0 56.3
Total Investment Required................. 2013$ Millions.............. .............. 11.9 11.9 97.6 298.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-33--Manufacturers Impact Analysis for Product Class 2, 3, and 4 Battery Charger Applications--Pass Through Markup Scenario--Power Tools
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 2,190 2,179 2,179 2,102 1,351
Change in INPV............................ 2013$ Millions.............. .............. (11) (11) (88) (839)
(%)......................... .............. (0.5) (0.5) (4.0) (38.3)
Product Conversion Costs.................. 2013$ Millions.............. .............. 0.9 0.9 7.3 22.3
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.0 0.0 3.3 5.5
Total Investment Required................. 2013$ Millions.............. .............. 1.0 1.0 10.6 27.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 52912]]
Table V-34--Manufacturers Impact Analysis for Product Class 2, 3, and 4 Battery Charger Applications--Pass Through Markup Scenario--Small Appliances
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 761 756 756 709 487
Change in INPV............................ 2013$ Millions.............. .............. (5) (5) (52) (273)
(%)......................... .............. (0.6) (0.6) (6.8) (35.9)
Product Conversion Costs.................. 2013$ Millions.............. .............. 0.4 0.4 5.1 16.0
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.1 0.1 2.4 5.5
Total Investment Required................. 2013$ Millions.............. .............. 0.5 0.5 7.5 21.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Product Classes 5 and 6
The following tables (Table V-35 through Table V-38) summarize
information related to the analysis performed to project the potential
impacts on manufacturers of devices falling into Product Classes 5 and
6.
Table V-35--Applications in Product Classes 5 and 6
------------------------------------------------------------------------
Product class 5 Product class 6
------------------------------------------------------------------------
Marine/Automotive/RV Chargers Electric Scooters
Mobility Scooters Lawn Mowers
Toy Ride-On Vehicles Motorized Bicycles
Wheelchairs Wheelchairs
------------------------------------------------------------------------
Table V-36--Manufacturers Impact Analysis for Product Class 5 and 6 Battery Charger Applications--Flat Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 1,493 1,493 1,493 2,065 2,065
Change in INPV............................ 2013$ Millions.............. .............. 0 0 572 572
(%)......................... .............. 0.0 0.0 38.3 38.3
Product Conversion Costs.................. 2013$ Millions.............. .............. 0.0 1.1 33.1 33.1
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.0 0.2 6.4 6.4
Total Investment Required................. 2013$ Millions.............. .............. 0.0 1.3 39.6 39.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-37--Manufacturers Impact Analysis for Product Class 5 and 6 Battery Charger Applications--Pass Through Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 1,493 1,491 1,370 878 878
Change in INPV............................ 2013$ Millions.............. .............. (2) (123) (615) (615)
(%)......................... .............. (0.2) (8.2) (41.2) (41.2)
Product Conversion Costs.................. 2013$ Millions.............. .............. 0.0 1.1 33.1 33.1
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.0 0.2 6.4 6.4
Total Investment Required................. 2013$ Millions.............. .............. 0.0 1.3 39.6 39.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-38--Manufacturers Impact Analysis for Product Class 5 and 6 Battery Charger Applications--Constant Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 1,493 1,486 1,145 586 586
Change in INPV............................ 2013$ Millions.............. .............. (7) (348) (907) (907)
(%)......................... .............. (0.5) (23.3) (60.8) (60.8)
Product Conversion Costs.................. 2013$ Millions.............. .............. 0.0 1.1 33.1 33.1
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.0 0.2 6.4 6.4
Total Investment Required................. 2013$ Millions.............. .............. 0.0 1.3 39.6 39.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Product Classes 5 and 6 together comprise seven unique
applications. Toy ride-on vehicles represent over 70 percent of the
Product Class 5 and 6 shipments. DOE found that all Product Class 5 and
6 shipments are at either CSL 1 or CSL 2. The battery charger cost
associated with each CSL is the same for Product Class 5 and 6
applications, but the energy usage profiles are different.
TSL 1 sets the efficiency level at CSL 1 for Product Classes 5 and
6. At TSL
[[Page 52913]]
1, DOE estimates impacts on the change in INPV to range from -$7
million to no change at all, or a change in INPV of -0.5 percent to no
change at all. At TSL 1, industry free cash flow is estimated to remain
at $117 million in 2017.
Percentage impacts on INPV range from slightly negative to
unchanged at TSL 1. DOE does not anticipate that Product Class 5 and 6
battery charger application manufacturers would lose a significant
portion of their INPV at TSL 1. DOE projects that in the expected year
of compliance, 2018, all Product Class 5 and 6 battery charger
applications would meet or exceed the efficiency levels required at TSL
1. Consequently, DOE does not expect there to be any conversion costs
at TSL 1.
TSL 2 sets the efficiency level at CSL 2 for Product Classes 5 and
6. At TSL 2, DOE estimates impacts on the change in INPV to range from
-$348 million to less than one million dollars, or a change in INPV of
-23.3 percent to less than 0.1 percent. At TSL 2, industry free cash
flow is estimated to decrease to $117 million, or a drop of less than
one percent, compared to the base-case value of $117 million in 2017.
Percentage impacts on INPV range from moderately negative to
slightly positive at TSL 2. DOE projects that in the expected year of
compliance, 2018, 95 percent of all Product Class 5 battery charger
applications and 95 percent of all Product Class 6 battery charger
applications would meet or exceed the efficiency levels required at TSL
2. DOE expects conversion costs to slightly increase to $1.3 million at
TSL 2.
TSL 3 and TSL 4 set the efficiency level at CSL 3 for Product
Classes 5 and 6. This efficiency level represents max tech for Product
Classes 5 and 6. At TSL 3 and TSL 4, DOE estimates impacts on the
change in INPV to range from -$907 million to $572 million, or a change
in INPV of -60.8 percent to 38.3 percent. At TSL 3 and TSL 4, industry
free cash flow is estimated to decrease to $100 million, or a drop of
15 percent, compared to the base-case value of $117 million in 2017.
Percentage impacts on INPV range from significantly negative to
significantly positive at TSL 3 and TSL 4. This large INPV range is
related to the significant increase in battery charger MPC required at
TSL 3 and TSL 4. DOE believes that it is unlikely battery charger
application manufacturers would be able to pass on this larger increase
in the MPC of the battery charger, which would imply that the negative
INPV impact is a more realistic scenario than the positive INPV impact
scenario. DOE anticipates that most Product Class 5 and 6 battery
charger application manufacturers could lose a significant portion of
their INPV at TSL 3 and TSL 4. DOE projects that in the expected year
of compliance, 2018, no Product Class 5 or 6 battery charger
applications would meet the efficiency levels required at TSL 3 and TSL
4. DOE expects conversion costs to significantly increase from $1.3
million at TSL 2 to $39.6 million at TSL 3 and TSL 4. At TSL 3 and TSL
4, the Product Class 5 and 6 battery charger MPC increases to $127.00
compared to the baseline battery charger MPC value of $18.48. This
represents a huge application price increase considering that the
shipment-weighted average Product Class 5 and 6 battery charger
application MPC, with no standards, is $131.14 and $262.21
respectively.
Product Class 7
The following tables (Table V-39 through Table V-42) summarize
information related to the analysis performed to project the potential
impacts on manufacturers of devices falling into Product Class 7.
Table V-39--Applications in Product Class 7
------------------------------------------------------------------------
Product class 7
-------------------------------------------------------------------------
Golf Cars
------------------------------------------------------------------------
Table V-40--Manufacturers Impact Analysis for Product Class 7 Battery Charger Applications--Flat Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 1,124 1,116 1,116 1,143 1,143
Change in INPV............................ 2013$ Millions.............. .............. (8) (8) 20 20
(%)......................... .............. (0.7) (0.7) 1.7 1.7
Product Conversion Costs.................. 2013$ Millions.............. .............. 1.3 1.3 3.3 3.3
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.4 0.4 1.8 1.8
Total Investment Required................. 2013$ Millions.............. .............. 1.7 1.7 5.1 5.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-41--Manufacturers Impact Analysis for Product Class 7 Battery Charger Applications--Pass Through Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 1,124 1,134 1,134 1,091 1,091
Change in INPV............................ 2013$ Millions.............. .............. 11 11 (32) (32)
(%)......................... .............. 0.9 0.9 (2.9) (2.9)
Product Conversion Costs.................. 2013$ Millions.............. .............. 1.3 1.3 3.3 3.3
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.4 0.4 1.8 1.8
Total Investment Required................. 2013$ Millions.............. .............. 1.7 1.7 5.1 5.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 52914]]
Table V-42--Manufacturers Impact Analysis for Product Class 7 Battery Charger Applications--Constant Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case ---------------------------------------------------------------
1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2013$ Millions.............. 1,124 1,168 1,168 998 998
Change in INPV............................ 2013$ Millions.............. .............. 44 44 (126) (126)
(%)......................... .............. 3.9 3.9 (11.2) (11.2)
Product Conversion Costs.................. 2013$ Millions.............. .............. 1.3 1.3 3.3 3.3
Capital Conversion Costs.................. 2013$ Millions.............. .............. 0.4 0.4 1.8 1.8
Total Investment Required................. 2013$ Millions.............. .............. 1.7 1.7 5.1 5.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Golf cars are the only application in Product Class 7.
Approximately 80 percent of the market incorporates baseline battery
charger technology--the remaining 20 percent employs technology that
meets the efficiency requirements at CSL 1. The cost of a battery
charger in Product Class 7, though higher relative to other product
classes, remains a small portion of the overall selling price of a golf
cart. This analysis, however, focuses on the application manufacturer
(OEM). DOE identified one small U.S. manufacturer of golf cart battery
chargers. The impacts of standards on these small businesses is
addressed in the Regulatory Flexibility Analysis (see section VI.B for
the results of that analysis).
TSL 1 and TSL 2 set the efficiency level at CSL 1 for Product Class
7. At TSL 1 and TSL 2, DOE estimates impacts on the change in INPV to
range from -$8 million to $44 million, or a change in INPV of -0.7
percent to 3.9 percent. At TSL 1 and TSL 2, industry free cash flow is
estimated to decrease to $87 million, or a drop of 1 percent, compared
to the base-case value of $88 million in 2017.
Percentage impacts on INPV range from slightly negative to slightly
positive at TSL 1 and TSL 2. DOE does not anticipate that Product Class
7 battery charger application manufacturers, the golf car
manufacturers, would lose a significant portion of their INPV at this
TSL. DOE projects that in the expected year of compliance, 2018, 20
percent of all Product Class 7 battery charger applications would meet
or exceed the efficiency levels required at TSL 1 and TSL 2. DOE
expects conversion costs to be $1.7 million at TSL 1 and TSL 2.
TSL 3 and TSL 4 set the efficiency level at CSL 2 for Product Class
7. This represents max tech for Product Class 7. At TSL 3 and TSL 4,
DOE estimates impacts on the change in INPV to range from -$126 million
to $20 million, or a change in INPV of -11.2 percent to 1.7 percent. At
TSL 3 and TSL 4, industry free cash flow is estimated to decrease to
$86 million, or a drop of 3 percent, compared to the base-case value of
$88 million in 2017.
Percentage impacts on INPV range from moderately negative to
slightly positive at TSL 3 and TSL 4. DOE projects that in the expected
year of compliance, 2018, no Product Class 7 battery charger
applications would meet the efficiency levels required at TSL 3 and TSL
4. DOE expects conversion costs to increase from $1.7 million at TSL 1
and TSL 2 to $5.1 million at TSL 3 and TSL 4. This represents a
relatively modest amount compared to the base case INPV of $1,124
million and annual cash flow of $88 million for Product Class 7 battery
charger applications. At TSL 3 and TSL 4 the battery charger MPC
increases to $164.14 compared to the baseline battery charger MPC value
of $88.07. This change represents only a moderate increase in the
application price since the shipment-weighted average application MPC
is $2,608.09.
b. Impacts on Employment
DOE attempted to quantify the number of domestic workers involved
in battery charger production. Based on manufacturer interviews and
reports from vendors such as Hoovers, Dun and Bradstreet, and Manta,
the vast majority of all small appliance and consumer electronic
applications are manufactured abroad. When looking specifically at the
battery charger component, which is typically designed by the
application manufacturer but sourced for production, the same dynamic
holds to an even greater extent. That is, in the rare instance when an
application's production occurs domestically, it is very likely that
the battery charger component is still produced and sourced overseas.
For example, DOE identified several power tool applications with some
level of domestic manufacturing. However, based on more detailed
information obtained during interviews, DOE believes the battery
charger components for these applications are sourced from abroad.
Also, DOE was able to find a few manufacturers of medium and high
power applications with facilities in the U.S. However, only a limited
number of these companies produce battery chargers domestically for
these applications. Therefore, based on manufacturer interviews and
DOE's research, DOE believes that golf cars are the only application
with U.S.-based battery charger manufacturing. Any change in U.S.
production employment due to new battery charger energy conservation
standards is likely to come from changes involving these particular
products. DOE seeks comment on the presence of any domestic battery
charger manufacturing outside of the golf car industry and beyond
prototyping for R&D purposes.
At the proposed efficiency levels, domestic golf car manufacturers
will need to decide whether to attempt to manufacture more efficient
battery chargers in-house and try to compete with a greater level of
vertical integration than their competitors, move production to lower-
wage regions abroad, or outsource their battery charger manufacturing.
DOE believes one of the latter two strategies would be more likely for
domestic golf car manufacturers. DOE describes the major implications
for golf car employment in the regulatory flexibility act section,
VI.B, because the major domestic manufacturer is also a small business
manufacturer. DOE does not anticipate any major negative changes in the
domestic employment of the design, technical support, or other
departments of battery charger application manufacturers located in the
U.S. in response to new energy conservation standards. Standards may
require some companies to redesign their battery chargers, change
marketing literature, and train some technical and sales support staff.
However, during interviews, manufacturers generally agreed these
changes would not lead to positive or negative changes in employment,
outside of the golf car battery charger industry.
[[Page 52915]]
c. Impacts on Manufacturing Capacity
DOE does not anticipate that the standards proposed in this SNOPR
would adversely impact manufacturer capacity. The battery charger
application industry is characterized by rapid product development
lifecycles. While there is no specific statutory compliance date for
battery charger standards, DOE believes a compliance date of two years
after the publication of the final rule would provide sufficient time
for manufacturers to ramp up capacity to meet the proposed standards
for battery chargers. DOE requests comment on the appropriate
compliance date for battery charger.
d. Impacts on Sub-Group of Manufacturers
Using average cost assumptions to develop an industry cash-flow
estimate is not adequate for assessing differential impacts among
manufacturer subgroups. Small manufacturers, niche equipment
manufacturers, and manufacturers exhibiting a cost structure
substantially different from the industry average could be affected
disproportionately. DOE addressed manufacturer subgroups in the battery
charger MIA, by breaking out manufacturers by application grouping
(consumer electronics, small appliances, power tools, and high energy
application). Because certain application groups are disproportionately
impacted compared to the overall product class groupings, DOE reports
those manufacturer application group results individually so they can
be considered as part of the overall MIA. For the results of this
manufacturer subgroup, see section V.B.2.a.
DOE also identified small businesses as a manufacturer subgroup
that could potentially be disproportionally impacted. DOE discusses the
impacts on the small business subgroup in the regulatory flexibility
analysis, section VI.B.
e. Cumulative Regulatory Burden
One aspect of assessing manufacturer burden involves looking at the
cumulative impact of multiple DOE standards and the regulatory actions
of other Federal agencies and States that affect the manufacturers of a
covered product or equipment. DOE believes that a standard level is not
economically justified if it contributes to an unacceptable cumulative
regulatory burden. While any one regulation may not impose a
significant burden on manufacturers, the combined effects of recent or
impending regulations may have serious consequences for some
manufacturers, groups of manufacturers, or an entire industry.
Assessing the impact of a single regulation may overlook this
cumulative regulatory burden. In addition to energy conservation
standards, other regulations can significantly affect manufacturers'
financial operations. Multiple regulations affecting the same
manufacturer can strain profits and lead companies to abandon product
lines or markets with lower expected future returns than competing
products. For these reasons, DOE conducts an analysis of cumulative
regulatory burden as part of its rulemakings pertaining to product
efficiency.
For the cumulative regulatory burden analysis, DOE looks at other
regulations that could affect battery charger application manufacturers
that will take effect approximately three years before or after the
compliance date of new energy conservation standards for these
products. The compliance years and expected industry conversion costs
of relevant new energy conservation standards are indicated in Table V-
43.
Table V-43--Compliance Dates and Expected Conversion Expenses of Federal Energy Conservation Standards Affecting
Battery Charger Application Manufacturers
----------------------------------------------------------------------------------------------------------------
Approximate
Federal energy conservation standards compliance Estimated total industry conversion expense
date
----------------------------------------------------------------------------------------------------------------
External Power Supplies 79 FR 7846 (February 2016 $43.4 million (2012$)
10, 2014).
Computer and Battery Backup Systems.......... * 2019 N/A [dagger]
----------------------------------------------------------------------------------------------------------------
* The dates listed are an approximation. The exact dates are pending final DOE action.
[dagger] For energy conservation standards for rulemakings awaiting DOE final action, DOE does not have a
finalized estimated total industry conversion cost.
DOE is aware that the CEC already has energy conservation standards
in place for battery chargers. DOE assumes that this rulemaking will
preempt the CEC battery charger standards when finalized. Therefore,
DOE did not consider the CEC standards as contributing to the
cumulative regulatory burden of this rulemaking. DOE seeks comment on
the compliance costs of any other regulations battery charger and
battery charger application manufacturers must make.
3. National Impact Analysis
a. Significance of Energy Savings
For each TSL, DOE projected energy savings for battery chargers
purchased in the 30-year period that begins in the year of compliance
with amended standards (2018-2047). The savings are measured over the
entire lifetime of products purchased in the 30-year period. DOE
quantified the energy savings attributable to each TSL as the
difference in energy consumption between each standards case and the
base case. Table V-44 and Table V-45 present the estimated primary and
full-fuel cycle energy savings, respectively, for each considered TSL.
The approach used is further described in section IV.H.\62\
---------------------------------------------------------------------------
\62\ Chapter 10 of the SNOPR TSD presents tables that show the
magnitude of the energy savings discounted at rates of 3 percent and
7 percent. Discounted energy savings represent a policy perspective
in which energy savings realized farther in the future are less
significant than energy savings realized in the nearer term.
[[Page 52916]]
Table V-44--Battery Chargers: Cumulative Primary National Energy Savings for Products Shipped in 2018-2047
(quads)
----------------------------------------------------------------------------------------------------------------
Trial standard level
Product class ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
1............................................... 0.004 0.047 0.047 0.084
2, 3, 4......................................... 0.087 0.087 0.307 0.423
5, 6............................................ 0.000 0.017 0.130 0.130
7............................................... 0.012 0.012 0.026 0.026
----------------------------------------------------------------------------------------------------------------
Table V-45--Battery Chargers: Cumulative FFC National Energy Savings for Products Shipped in 2018-2047 (quads)
----------------------------------------------------------------------------------------------------------------
Trial standard level
Product class ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
1............................................... 0.004 0.049 0.049 0.088
2, 3, 4......................................... 0.091 0.091 0.321 0.442
5, 6............................................ 0.000 0.018 0.136 0.136
7............................................... 0.013 0.013 0.028 0.028
----------------------------------------------------------------------------------------------------------------
OMB Circular A-4 requires agencies to present analytical results,
including separate schedules of the monetized benefits and costs that
show the type and timing of benefits and costs. \63\ Circular A-4 also
directs agencies to consider the variability of key elements underlying
the estimates of benefits and costs. For this rulemaking, DOE undertook
a sensitivity analysis using nine, rather than 30, years of product
shipments. The choice of a 9-year period is a proxy for the general
timeline in EPCA for the review of certain energy conservation
standards and potential revision of, and compliance with, such revised
standards.\64\ The review timeframe established in EPCA is generally
not synchronized with the product lifetime, product manufacturing
cycles, or other factors specific to battery chargers. Thus, such
results are presented for informational purposes only and are not
indicative of any change in DOE's analytical methodology. The NES
sensitivity analysis results based on a nine-year analytical period are
presented in Table V-46. The impacts are counted over the lifetime of
products purchased in 2018-2026.
---------------------------------------------------------------------------
\63\ U.S. Office of Management and Budget, Circular A-4:
Regulatory Analysis (Sept. 17, 2003) (Available at: http://www.whitehouse.gov/omb/circulars_a004_a-4/).
\64\ Section 325(m) of EPCA requires DOE to review its standards
at least once every 6 years, and requires, for certain products, a
3-year period after any new standard is promulgated before
compliance is required, except that in no case may any new standards
be required within 6 years of the compliance date of the previous
standards. While adding a 6-year review to the 3-year compliance
period adds up to 9 years, DOE notes that it may undertake reviews
at any time within the 6 year period and that the 3-year compliance
date may yield to the 6-year backstop. A 9-year analysis period may
not be appropriate given the variability that occurs in the timing
of standards reviews and the fact that for some consumer products,
the compliance period is 5 years rather than 3 years.
Table V-46--Battery Chargers: Cumulative FFC National Energy Savings for Products Shipped in 2018-2026 (quads)
----------------------------------------------------------------------------------------------------------------
Trial standard level
Product class ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
1............................................... 0.001 0.015 0.015 0.027
2, 3, 4......................................... 0.028 0.028 0.097 0.134
5, 6............................................ 0.000 0.005 0.041 0.041
7............................................... 0.004 0.004 0.008 0.008
----------------------------------------------------------------------------------------------------------------
b. Net Present Value of Consumer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
customers that would result from the TSLs considered for battery
chargers. In accordance with OMB's guidelines on regulatory
analysis,\65\ DOE calculated the NPV using both a 7-percent and a 3-
percent real discount rate. The 7-percent rate is an estimate of the
average before-tax rate of return on private capital in the U.S.
economy, and reflects the returns on real estate and small business
capital as well as corporate capital. This discount rate approximates
the opportunity cost of capital in the private sector. (OMB analysis
has found the average rate of return on capital to be near this rate.)
The 3-percent rate reflects the potential effects of standards on
private consumption (e.g., through higher prices for products and
reduced purchases of energy). This rate represents the rate at which
society discounts future consumption flows to their present value. It
can be approximated by the real rate of return on long-term government
debt (i.e., yield on United States Treasury Notes), which has averaged
about 3 percent for the past 30 years.
---------------------------------------------------------------------------
\65\ OMB Circular A-4, section E (Sept. 17, 2003). Available at:
http://www.whitehouse.gov/omb/circulars_a004_a-4.
---------------------------------------------------------------------------
Table V-47 shows the customer NPV results for each TSL considered
for battery chargers. The impacts cover the
[[Page 52917]]
lifetime of products purchased in 2018-2047.
Table V-47--Battery Chargers: Cumulative Net Present Value of Consumer Benefits for Products Shipped in 2018-
2047
[2013$ billions]
----------------------------------------------------------------------------------------------------------------
Trial standard level (billion 2013$)
Discount rate ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
3 percent....................................... 0.9 1.2 -16.2 -47.9
7 percent....................................... 0.5 0.6 -9.5 -27.9
----------------------------------------------------------------------------------------------------------------
The NPV results based on the aforementioned 9-year analytical
period are presented in Table V-48. The impacts are counted over the
lifetime of products purchased in 2018-2026. As mentioned previously,
this information is presented for informational purposes only and is
not indicative of any change in DOE's analytical methodology or
decision criteria.
Table V-48--Battery Chargers: Cumulative Net Present Value of Consumer Benefits for Products Shipped in 2018-
2026
[2013$ billions]
----------------------------------------------------------------------------------------------------------------
Trial standard level (billion 2013$)
Discount rate ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
3 percent....................................... 0.3 0.4 -6.2 -18.1
7 percent....................................... 0.2 0.3 -4.8 -14.1
----------------------------------------------------------------------------------------------------------------
c. Indirect Impact on Employment
DOE expects energy conservation standards for battery chargers to
reduce energy bills for consumers of these products, and the resulting
net savings to be redirected to other forms of economic activity. These
expected shifts in spending and economic activity could affect the
demand for labor. As described in section IV.N, DOE used an input/
output model of the U.S. economy to estimate indirect employment
impacts of the TSLs that DOE considered in this rulemaking. DOE
understands that there are uncertainties involved in projecting
employment impacts, especially changes in the later years of the
analysis. Therefore, DOE generated results for near-term timeframes,
where these uncertainties are reduced.
DOE reviewed its inputs and determined that the indirect employment
impacts will be positive at TSL 1 (in 2018 and 2023) and TSL 2 (in 2023
only), while at TSL 3 and TSL 4, the increased equipment costs are far
larger than the operating cost savings. The magnitude of the estimated
effect is very small, however. The results suggest that the proposed
standards are likely to have negligible impact on the net demand for
labor in the economy. The net change in jobs is so small that it would
be imperceptible in national labor statistics and might be offset by
other, unanticipated effects on employment. Chapter 16 of the SNOPR TSD
presents more detailed results.
4. Impact on Utility and Performance of the Products
Based on testing conducted in support of this proposed rule,
discussed in section IV.C.5 of this notice, DOE concluded that the
standards proposed in this SNOPR would not reduce the utility or
performance of the battery chargers under consideration in this
rulemaking. Manufacturers of these products currently offer units that
meet or exceed these proposed standards. DOE has also declined to
propose battery charger marking requirements as part of today's SNOPR,
providing manufacturers with more flexibility in the way that they
design, label, and market their products.
5. Impact on Any Lessening of Competition
DOE has also considered any lessening of competition that is likely
to result from the proposed standards. The Attorney General determines
the impact, if any, of any lessening of competition likely to result
from a proposed standard, and transmits such determination to DOE,
together with an analysis of the nature and extent of such impact. (42
U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii))
To keep the Attorney General informed of DOE's rulemaking efforts
with respect to battery chargers, DOE will transmit a copy of this
SNOPR and the accompanying SNOPR TSD to the Attorney General. DOE will
consider DOJ's comments, if any, on this supplemental proposal in
determining whether to proceed with the proposed energy conservation
standards. DOE will also publish and respond to DOJ's comments in the
Federal Register.
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the Nation's energy security, strengthens the economy, and reduces the
environmental impacts of energy production. Reduced electricity demand
due to energy conservation standards is also likely to reduce the cost
of maintaining the reliability of the electricity system, particularly
during peak-load periods. As a measure of this reduced demand, chapter
15 in the SNOPR TSD presents the estimated reduction in generating
capacity for the TSLs that DOE considered in this rulemaking.
Energy savings from standards for battery chargers are expected to
yield environmental benefits in the form of reduced emissions of air
pollutants and greenhouse gases. Table V-49 provides DOE's estimate of
cumulative emissions reductions to result from the TSLs considered in
this rulemaking. The table
[[Page 52918]]
includes both power sector emissions and upstream emissions. DOE
reports annual emissions reductions for each TSL in chapter 13 of the
SNOPR TSD.
Table V-49--Battery Chargers: Cumulative Emissions Reduction for Products Shipped in 2018-2047
----------------------------------------------------------------------------------------------------------------
Trial standard level
---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 6.29 9.92 31.03 40.41
SO2 (thousand tons)............................. 5.62 8.82 27.56 35.92
NOX (thousand tons)............................. 5.01 7.88 24.64 32.10
Hg (tons)....................................... 0.017 0.027 0.085 0.111
CH4 (thousand tons)............................. 0.583 0.922 2.886 3.757
N2O (thousand tons)............................. 0.084 0.132 0.413 0.538
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 0.335 0.530 1.659 2.159
SO2 (thousand tons)............................. 0.060 0.095 0.296 0.385
NOX (thousand tons)............................. 4.75 7.52 23.57 30.67
Hg (tons)....................................... 0.000 0.000 0.001 0.001
CH4 (thousand tons)............................. 27.7 43.8 137.3 178.7
N2O (thousand tons)............................. 0.003 0.005 0.015 0.019
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 6.63 10.45 32.69 42.57
SO2 (thousand tons)............................. 5.68 8.92 27.86 36.30
NOX (thousand tons)............................. 9.76 15.41 48.21 62.77
Hg (tons)....................................... 0.017 0.027 0.086 0.112
CH4 (thousand tons)............................. 28.3 44.8 140.2 182.4
CH4 (thousand tons CO2eq) *..................... 791 1253 3925 5108
N2O (thousand tons)............................. 0.086 0.137 0.428 0.557
N2O (thousand tons CO2eq) *..................... 22.9 36.2 113.4 147.6
----------------------------------------------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
As part of the analysis for this proposed rule, DOE estimated
monetary benefits likely to result from the reduced emissions of
CO2 and NOX that DOE estimated for each of the
considered TSLs. As discussed in section IV.L of this notice, for
CO2, DOE used the most recent values for the SCC developed
by an interagency process. The four sets of SCC values for
CO2 emissions reductions in 2015 resulting from that process
(expressed in 2013$) are represented by $12.0/metric ton (the average
value from a distribution that uses a 5-percent discount rate), $40.5/
metric ton (the average value from a distribution that uses a 3-percent
discount rate), $62.4/metric ton (the average value from a distribution
that uses a 2.5-percent discount rate), and $119/metric ton (the 95th-
percentile value from a distribution that uses a 3-percent discount
rate). The values for later years are higher due to increasing damages
(emissions-related costs) as the projected magnitude of climate change
increases.
Table V-50 presents the global value of CO2 emissions
reductions at each TSL. For each of the four cases, DOE calculated a
present value of the stream of annual values using the same discount
rate as was used in the studies upon which the dollar-per-ton values
are based. DOE calculated domestic values as a range from 7 percent to
23 percent of the global values; these results are presented in chapter
14 of the SNOPR TSD.
Table V-50--Battery Chargers: Estimates of Global Present Value of CO2 Emissions Reduction for Products Shipped
in 2018-2047
----------------------------------------------------------------------------------------------------------------
SCC Case * (million 2013$)
---------------------------------------------------------------
TSL 3% Discount
5% Discount 3% Discount 2.5% Discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 50.7 218.6 342.7 673.1
2............................................... 79.4 343.5 538.7 1058.1
3............................................... 247.7 1072.5 1682.4 3304.0
4............................................... 322.9 1397.6 2192.3 4305.4
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 2.6 11.4 18.0 35.3
[[Page 52919]]
2............................................... 4.1 18.1 28.4 55.8
3............................................... 12.9 56.5 88.8 174.4
4............................................... 16.8 73.6 115.7 227.0
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 53.3 230.1 360.7 708.5
2............................................... 83.5 361.6 567.1 1113.8
3............................................... 260.5 1129.0 1771.3 3478.4
4............................................... 339.7 1471.2 2307.9 4532.5
----------------------------------------------------------------------------------------------------------------
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.0, $40.5, $62.4, and $119
per metric ton (2013$).
DOE is well aware that scientific and economic knowledge about the
contribution of CO2 and other GHG emissions to changes in
the future global climate and the potential resulting damages to the
world economy continues to evolve rapidly. Thus, any value placed on
reducing CO2 emissions in this rulemaking is subject to
change. DOE, together with other Federal agencies, will continue to
review various methodologies for estimating the monetary value of
reductions in CO2 and other GHG emissions. This ongoing
review will consider the comments on this subject that are part of the
public record for this and other rulemakings, as well as other
methodological assumptions and issues. However, consistent with DOE's
legal obligations, and taking into account the uncertainty involved
with this particular issue, DOE has included in this proposed rule the
most recent values and analyses resulting from the ongoing interagency
review process.
DOE also estimated the cumulative monetary value of the economic
benefits associated with NOX emissions reductions
anticipated to result from the considered TSLs for battery chargers.
The dollar-per-ton value that DOE used is discussed in section IV.L of
this notice. Table V-51 presents the cumulative present values for each
TSL calculated using 7-percent and 3-percent discount rates.
Table V-51--Battery Chargers: Estimates of Present Value of NOX
Emissions Reduction for Products Shipped in 2018-2047
------------------------------------------------------------------------
Million 2013$
-------------------------------
TSL 3% Discount 7% Discount
rate rate
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
1....................................... 8.2 4.8
2....................................... 12.8 7.4
3....................................... 39.9 22.9
4....................................... 52.1 29.9
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1....................................... 7.4 4.0
2....................................... 11.6 6.3
3....................................... 36.3 19.5
4....................................... 47.3 25.5
------------------------------------------------------------------------
Total FFC Emissions
------------------------------------------------------------------------
1....................................... 15.6 8.8
2....................................... 24.4 13.6
3....................................... 76.2 42.4
4....................................... 99.3 55.4
------------------------------------------------------------------------
7. Other Factors
The Secretary of Energy, in determining whether a standard is
economically justified, may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) DOE
did not consider any other factors with respect to the specific
standards proposed in this SNOPR. As for those particular battery
chargers that DOE is declining to regulate at this time, the reasons
underlying that decision are discussed above.
8. Summary of National Economic Impacts
The NPV of the monetized benefits associated with emissions
reductions
[[Page 52920]]
can be viewed as a complement to the NPV of the consumer savings
calculated for each TSL considered in this rulemaking. Table V-52
presents the NPV values that result from adding the estimates of the
potential economic benefits resulting from reduced CO2 and
NOX emissions in each of four valuation scenarios to the NPV
of consumer savings calculated for each TSL considered for battery
chargers, at both a 7-percent and a 3-percent discount rate. The
CO2 values used in the columns of each table correspond to
the four sets of SCC values discussed above.
Table V-52--Battery Chargers: Net Present Value of Consumer Savings Combined With Present Value of Monetized
Benefits From CO2 and NOX Emissions Reductions
----------------------------------------------------------------------------------------------------------------
Billion 2013$
---------------------------------------------------------------
TSL SCC Case $12.0/ SCC Case $40.5/ SCC Case $62.4/ SCC Case $119/
t and medium t and medium t and medium t and medium
NOX value NOX value NOX value NOX value
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 3% Discount Rate added with:
----------------------------------------------------------------------------------------------------------------
1............................................... 0.9 1.1 1.2 1.6
2............................................... 1.3 1.6 1.8 2.3
3............................................... -15.9 -15.0 -14.4 -12.6
4............................................... -47.5 -46.4 -45.5 -43.3
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 7% Discount Rate added with:
----------------------------------------------------------------------------------------------------------------
1............................................... 0.5 0.7 0.8 1.2
2............................................... 0.7 1.0 1.2 1.8
3............................................... -9.2 -8.4 -7.7 -6.0
4............................................... -27.5 -26.4 -25.5 -23.3
----------------------------------------------------------------------------------------------------------------
Although adding the value of consumer savings to the values of
emission reductions provides a valuable perspective, two issues should
be considered. First, the national operating cost savings are domestic
U.S. monetary savings that occur as a result of market transactions,
while the value of CO2 reductions is based on a global
value. Second, the assessments of operating cost savings and the SCC
are performed with different methods that use different time frames for
analysis. The national operating cost savings is measured for the
lifetime of products shipped in 2018 to 2047. Because CO2
emissions have a very long residence time in the atmosphere,\66\ the
SCC values in future years reflect future climate-related impacts
resulting from the emission of CO2 that continue well beyond
2100.
---------------------------------------------------------------------------
\66\ The atmospheric lifetime of CO2 is estimated of
the order of 30-95 years. Jacobson, MZ (2005). ``Correction to
`Control of fossil-fuel particulate black carbon and organic matter,
possibly the most effective method of slowing global warming.' '' J.
Geophys. Res. 110. pp. D14105.
---------------------------------------------------------------------------
C. Conclusions
When considering proposed standards, the new or amended energy
conservation standard that DOE adopts for any type (or class) of
covered product must be designed to achieve the maximum improvement in
energy efficiency that the Secretary determines is technologically
feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In
determining whether a standard is economically justified, the Secretary
must determine whether the benefits of the standard exceed its burdens,
considering to the greatest extent practicable the seven statutory
factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i)) The new or
amended standard must also result in a significant conservation of
energy. (42 U.S.C. 6295(o)(3)(B))
The Department considered the impacts of standards at each TSL,
beginning with a maximum technologically feasible level, to determine
whether that level was economically justified. Where the max-tech level
was not justified, DOE then considered the next most efficient level
and undertook the same evaluation until it reached the highest
efficiency level that would be both technologically feasible and
economically justified and save a significant amount of energy.
To aid the reader as DOE discusses the benefits and/or burdens of
each TSL, DOE has included a series of tables presenting a summary of
the results of DOE's quantitative analysis for each TSL. In addition to
the quantitative results presented in the tables, DOE also considers
other burdens and benefits that affect economic justification. Those
include the impacts on identifiable subgroups of consumers who may be
disproportionately affected by a national standard. Section V.B.1.b of
this notice presents the estimated impacts of each TSL for these
subgroups.
DOE also notes that the economics literature provides a wide-
ranging discussion of how consumers trade off upfront costs and energy
savings in the absence of government intervention. Much of this
literature attempts to explain why consumers appear to undervalue
energy efficiency improvements. This undervaluation suggests that
regulation that promotes energy efficiency can produce significant net
private gains (as well as producing social gains by, for example,
reducing pollution). There is evidence that consumers undervalue future
energy savings as a result of (1) a lack of information; (2) a lack of
sufficient salience of the long-term or aggregate benefits; (3) a lack
of sufficient savings to warrant delaying or altering purchases; (4)
excessive focus on the short term, in the form of inconsistent
weighting of future energy cost savings relative to available returns
on other investments; (5) computational or other difficulties
associated with the evaluation of relevant tradeoffs; and (6) a
divergence in incentives (between renters and owners, or builders and
purchasers). Having less than perfect foresight and a high degree of
uncertainty about the future, consumers may trade off these types of
investments at a higher than expected rate between current consumption
and uncertain future energy cost savings.
In DOE's current regulatory analysis, potential changes in the
benefits and costs of a regulation due to changes in consumer purchase
decisions are included in two ways. First, if consumers forego a
purchase of a product in the standards case, this
[[Page 52921]]
decreases sales for product manufacturers, and the impact on
manufacturers attributed to lost revenue is included in the MIA.
Second, DOE accounts for energy savings attributable only to products
actually used by consumers in the standards case; if a regulatory
option decreases the number of products used by consumers, this
decreases the potential energy savings from an energy conservation
standard. DOE provides estimates of shipments and changes in the volume
of product purchases in chapter 9 and appendix 9A of the SNOPR TSD.
However, DOE's current analysis does not explicitly control for
heterogeneity in consumer preferences, preferences across subcategories
of products or specific features, or consumer price sensitivity
variation according to household income.\67\
---------------------------------------------------------------------------
\67\ P.C. Reiss and M.W. White. Household Electricity Demand,
Revisited. Review of Economic Studies (2005) 72, 853-883.
---------------------------------------------------------------------------
While DOE is not prepared at present to provide a fuller
quantifiable framework for estimating the benefits and costs of changes
in consumer purchase decisions due to an energy conservation standard,
DOE is committed to developing a framework that can support empirical
quantitative tools for improved assessment of the consumer welfare
impacts of appliance standards. DOE has posted a paper that discusses
the issue of consumer welfare impacts of appliance energy efficiency
standards, and potential enhancements to the methodology by which these
impacts are defined and estimated in the regulatory process.\68\ DOE
welcomes comments on how to more fully assess the potential impact of
energy conservation standards on consumer choice and how to quantify
this impact in its regulatory analysis in future rulemakings.
---------------------------------------------------------------------------
\68\ Alan Sanstad, Notes on the Economics of Household Energy
Consumption and Technology Choice. Lawrence Berkeley National
Laboratory. 2010. Available online at: www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf
---------------------------------------------------------------------------
1. Benefits and Burdens of TSLs Considered for Battery Chargers
Table V-53 and Table V-54 summarize the quantitative impacts
estimated for each TSL for battery chargers. The efficiency levels
contained in each TSL are described in section V.A of this notice.
Table V-53--Battery Chargers: Summary of National Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4
----------------------------------------------------------------------------------------------------------------
Cumulative FFC Energy Savings (quads)
----------------------------------------------------------------------------------------------------------------
0.108 0.170 0.534 0.695
----------------------------------------------------------------------------------------------------------------
NPV of Consumer Costs and Benefits (2013$ billion)
----------------------------------------------------------------------------------------------------------------
3% discount rate................................ 0.9 1.2 -16.2 -47.9
7% discount rate................................ 0.5 0.6 -9.5 -27.9
----------------------------------------------------------------------------------------------------------------
Cumulative FFC Emissions Reduction
----------------------------------------------------------------------------------------------------------------
CO2 million metric tons......................... 6.63 10.45 32.69 42.57
SO2 thousand tons............................... 5.68 8.92 27.86 36.30
NOX thousand tons............................... 9.76 15.41 48.21 62.77
Hg tons......................................... 0.017 0.027 0.086 0.112
CH4 thousand tons............................... 28.3 44.8 140.2 182.4
CH4 thousand tons CO 2eq*....................... 791 1253 3925 5108
N2O thousand tons............................... 0.086 0.137 0.428 0.557
N2O thousand tons CO2eq*........................ 22.9 36.2 113.4 147.6
----------------------------------------------------------------------------------------------------------------
Value of Emissions Reduction
----------------------------------------------------------------------------------------------------------------
CO2 2013$ billion**............................. 0.053 to 0.708 0.084 to 1.114 0.261 to 3.478 0.340 to 4.532
NOX--3% discount rate 2013$ million............. 15.60 24.43 76.19 99.34
NOX--7% discount rate 2013$ million............. 8.80 13.65 42.41 55.38
----------------------------------------------------------------------------------------------------------------
Parentheses indicate negative (-) values.
* CO2eq is the quantity of CO2 that would have the same GWP.
** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2
emissions.
Table V-54--Battery Chargers: Summary of Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1\*\ TSL 2\*\ TSL 3\*\ TSL 4\*\
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Industry NPV (2013$ million) (Base Case INPV = 79,782-79,887 79,375-79,887 77,387-80,479 64,012-81,017
79,904)........................................
Industry NPV (% change)......................... (0.2)-(0.0) (0.7)-(0.0) (3.2)-0.7 (19.9)-1.4
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings (2013$)
----------------------------------------------------------------------------------------------------------------
PC1--Low E, Inductive*.......................... 0.08 0.71 0.71 (3.44)
PC2--Low E, Low-Voltage......................... 0.07 0.07 0.06 (2.79)
PC3--Low E, Medium-Voltage...................... 0.08 0.08 (1.36) (2.17)
PC4--Low E, High-Voltage........................ 0.11 0.11 (0.38) (4.91)
PC5--Medium E, Low-Voltage*..................... 0.00 0.84 (138.63) (138.63)
PC6--Medium E, High-Voltage*.................... 0.00 1.89 (129.15) (129.15)
[[Page 52922]]
PC7--High E..................................... 51.06 51.06 (80.05) (80.05)
----------------------------------------------------------------------------------------------------------------
Consumer Simple PBP (years)
----------------------------------------------------------------------------------------------------------------
PC1--Low E, Inductive*.......................... 1.1 1.5 1.5 7.4
PC2--Low E, Low-Voltage......................... 0.6 0.6 2.5 19.5
PC3--Low E, Medium-Voltage...................... 0.8 0.8 21.6 31.2
PC4--Low E, High-Voltage........................ 1.4 1.4 5.2 20.7
PC5--Medium E, Low-Voltage*..................... 2.3 2.7 29.1 29.1
PC6--Medium E, High-Voltage*.................... 1.0 1.1 12.5 12.5
PC7--High E..................................... 0.0 0.0 8.1 8.1
----------------------------------------------------------------------------------------------------------------
% of Consumers that Experience Net Cost
----------------------------------------------------------------------------------------------------------------
PC1--Low E, Inductive*.......................... 0.0 0.0 0.0 96.3
PC2--Low E, Low-Voltage......................... 1.2 1.2 33.1 73.8
PC3--Low E, Medium-Voltage...................... 0.6 0.6 39.0 40.8
PC4--Low E, High-Voltage........................ 1.3 1.3 12.6 25.8
PC5--Medium E, Low-Voltage*..................... 0.0 0.6 99.7 99.7
PC6--Medium E, High-Voltage*.................... 0.0 0.0 100.0 100.0
PC7--High E..................................... 0.0 0.0 100.0 100.0
----------------------------------------------------------------------------------------------------------------
\*\ Parentheses indicate negative (-) values.
DOE first considered TSL 4, which represents the max-tech
efficiency levels. TSL 4 would save 0.695 quads of energy, an amount
DOE considers significant. Under TSL 4, the NPV of consumer benefit
would be -$27.9 billion using a discount rate of 7 percent, and -$47.9
billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 4 are 42.57 Mt of
CO2, 62.77 thousand tons of NOX, 36.30 thousand
tons of SO2, 0.112 ton of Hg, 182.4 thousand tons of
CH4, and 0.557 thousand tons of N2O. The
estimated monetary value of the CO2 emissions reduction at
TSL 4 ranges from $0.340 billion to $4.532 billion.
At TSL 4, the average LCC impact is a cost of $3.44 for PC1, $2.79
for PC2, $2.17 for PC3, $4.91 for PC4, $138.63 for PC5, $129.15 for
PC6, and $80.05 for PC7. The simple payback period is 7.4 years for
PC1, 19.5 years for PC2, 31.2 years for PC3, 20.7 years for PC4, 29.1
years for PC5, 12.5 years for PC6, and 8.1 years for PC7. The fraction
of consumers experiencing a net LCC cost is 96.3 percent for PC1, 73.8
percent for PC2, 40.8 percent for PC3, 25.8 percent for PC4, 99.7
percent for PC5, 100 percent for PC6, and 100 percent for PC7.
At TSL 4, the projected change in INPV ranges from a decrease of
$15,892 million to an increase of $1,113 million, equivalent to -19.9
percent and 1.4 percent, respectively.
The Secretary tentatively concludes that at TSL 4 for battery
chargers, the benefits of energy savings, emission reductions, and the
estimated monetary value of the CO2 emissions reductions
would be outweighed by the economic burden on consumers (demonstrated
by a negative NPV and LCC for all product classes), and the impacts on
manufacturers, including the conversion costs and profit margin impacts
that could result in a large reduction in INPV. Consequently, the
Secretary has tentatively concluded that TSL 4 is not economically
justified.
DOE then considered TSL 3. TSL 3 would save 0.534 quads of energy,
an amount DOE considers significant. Under TSL 3, the NPV of consumer
benefit would be -$9.5 billion using a discount rate of 7 percent, and
-$16.2 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 32.69 Mt of
CO2, 48.21 thousand tons of NOX, 27.86 thousand
tons of SO2, 0.086 ton of Hg, 140.2 thousand tons of
CH4, and 0.428 thousand tons of N2O. The
estimated monetary value of the CO2 emissions reduction at
TSL 3 ranges from $0.261 billion to $3.478 billion.
At TSL 3, the average LCC impact is a savings of $0.71 for PC1 and
$0.06 for PC2, and a cost of $1.36 for PC3, $0.38 for PC4, $138.63 for
PC5, $129.15 for PC6, and $80.05 for PC7. The simple payback period is
1.5 years for PC1, 2.5 years for PC2, 21.6 years for PC3, 5.2 years for
PC4, 29.1 years for PC5, 12.5 years for PC6, and 8.1 years for PC7. The
fraction of consumers experiencing a net LCC cost is 0.0 percent for
PC1, 33.1 percent for PC2, 39.0 percent for PC3, 12.6 percent for PC4,
99.7 percent for PC5, 100 percent for PC6, and 100 percent for PC7.
At TSL 3, the projected change in INPV ranges from a decrease of
$2,517 million to an increase of $574 million, equivalent to -3.2
percent and 0.7 percent, respectively.
The Secretary tentatively concludes that at TSL 3 for battery
chargers, the benefits of energy savings, emission reductions, and the
estimated monetary value of the CO2 emissions reductions
would be outweighed by the economic burden on consumers (demonstrated
by a negative NPV and LCC for most product classes), and the impacts on
manufacturers, including the conversion costs and profit margin impacts
that could result in a large reduction in INPV. Consequently, the
Secretary has tentatively concluded that TSL 3 is not economically
justified.
DOE then considered TSL 2. TSL 2 would save 0.170 quads of energy,
an amount DOE considers significant. Under TSL 2, the NPV of consumer
benefit would be $0.6 billion using a discount rate of 7 percent, and
$1.2 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 2 are 10.45 Mt of
CO2, 15.41 thousand tons of NOX, 8.92 thousand
tons of SO2, 0.027 ton of Hg, 44.8 thousand tons of
CH4, and 0.137 thousand tons of N2O. The
estimated monetary value of the CO2 emissions reduction at
TSL 2 ranges from $0.084 billion to $1.114 billion.
At TSL 2, the average LCC impact is a savings of $0.71 for PC1,
$0.07 for PC2, $0.08 for PC3, $0.11 for PC4, $0.84 for PC5, $1.89 for
PC6, and $51.06 for PC7. The simple payback period is 1.5 years for
PC1, 0.6 years for PC2, 0.8
[[Page 52923]]
years for PC3, 1.4 years for PC4, 2.7 years for PC5, 1.1 years for PC6,
and 0.0 years for PC7. The fraction of consumers experiencing a net LCC
cost is 0.0 percent for PC1, 1.2 percent for PC2, 0.6 percent for PC3,
1.3 percent for PC4, 0.6 percent for PC5, 0.0 percent for PC6, and 0.0
percent for PC7.
At TSL 2, the projected change in INPV ranges from a decrease of
$529 million to a decrease of $18 million, equivalent to -0.7 percent
and less than -0.1 percent, respectively.
The Secretary tentatively concludes that at TSL 2 for battery
chargers, the benefits of energy savings, positive NPV of consumer
benefits, emission reductions, and the estimated monetary value of the
CO2 emissions reductions, and positive average LCC savings
would outweigh the negative impacts on some consumers and on
manufacturers, including the conversion costs that could result in a
reduction in INPV for manufacturers.
After considering the analysis and the benefits and burdens of TSL
2, the Secretary tentatively concludes that this TSL will offer the
maximum improvement in efficiency that is technologically feasible and
economically justified, and will result in the significant conservation
of energy. Therefore, DOE proposes TSL 2 for battery chargers. The
proposed amended energy conservation standards for battery chargers are
shown in Table V-55.
Table V-55--Proposed Energy Conservation Standards for Battery Chargers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Product class Description Maximum unit energy consumption (kWh/yr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1..................................... Low-Energy, Inductive.................................... 3.04
2..................................... Low-Energy, Low-Voltage.................................. 0.1440 * Ebatt + 2.95
3..................................... Low-Energy, Medium-Voltage............................... For Ebatt < 10Wh,
UEC = 1.42 kWh/y
Ebatt >= 10 Wh,
= 0.0255 * Ebatt + 1.16
4..................................... Low-Energy, High-Voltage................................. = 0.11 * Ebatt + 3.18
5..................................... Medium-Energy, Low-Voltage............................... For Ebatt < 19 Wh,
= 1.32 kWh/yr
For Ebatt >= 19 Wh,
= 0.0257 * Ebatt + .815
6..................................... Medium-Energy, High-Voltage.............................. For Ebatt < 18 Wh
= 3.88 kWh/yr
For Ebatt >= 18 Wh
= 0.0778 * Ebatt + 2.4
7..................................... High-Energy.............................................. = 0.0502(Ebatt) + 4.53
--------------------------------------------------------------------------------------------------------------------------------------------------------
2. Annualized Benefits and Costs of the Proposed Standards
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The annualized monetary values
are the sum of (1) the annualized national economic value of the
benefits from operating products that meet the proposed standards
(consisting of operating cost savings from using less energy, minus
increases in product purchase costs, which is another way of
representing consumer NPV), and (2) the monetary value of the benefits
of CO2 and NOX emission reductions.\69\
---------------------------------------------------------------------------
\69\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2014, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(2020, 2030, etc.), and then discounted the present value from each
year to 2015. The calculation uses discount rates of 3 and 7 percent
for all costs and benefits except for the value of CO2
reductions, for which DOE used case-specific discount rates. Using
the present value, DOE then calculated the fixed annual payment over
a 30-year period, starting in the compliance year that yields the
same present value.
---------------------------------------------------------------------------
Table V-56 shows the annualized values for battery chargers under
TSL 2, expressed in 2013$. The results under the primary estimate are
as follows. Using a 7-percent discount rate for benefits and costs
other than CO2 reductions, for which DOE used a 3-percent
discount rate along with the SCC series corresponding to a value of
$40.5/ton in 2015 (in 2013$), the cost of the standards for battery
chargers in the proposed rule is $9 million per year in increased
equipment costs, while the annualized benefits are $68 million per year
in reduced equipment operating costs, $20 million in CO2
reductions, and $1.26 million in reduced NOX emissions. In
this case, the net benefit amounts to $80 million per year. Using a 3-
percent discount rate for all benefits and costs and the SCC series
corresponding to a value of $40.5/ton in 2015 (in 2013$), the cost of
the standards for battery chargers in the proposed rule is $10 million
per year in increased equipment costs, while the benefits are $75
million per year in reduced operating costs, $20 million in
CO2 reductions, and $1.32 million in reduced NOX
emissions. In this case, the net benefit amounts to $86 million per
year.
Table V-56--Annualized Benefits and Costs of New and Amended Standards for Battery Chargers
----------------------------------------------------------------------------------------------------------------
(Million 2013$/year)
-----------------------------------------------------------
Discount rate Low net benefits High net benefits
Primary estimate * estimate * estimate *
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings.......... 7%................ 68................ 68................ 69
3%................ 75................ 74................ 76
[[Page 52924]]
CO2 Reduction Monetized Value 5%................ 6................. 6................. 6
($12.0/t case)*.
CO2 Reduction Monetized Value 3%................ 20................ 20................ 20
($40.5/t case)*.
CO2 Reduction Monetized Value 2.5%.............. 28................ 28................ 28
($62.4/t case)*.
CO2 Reduction Monetized Value 3%................ 60................ 60................ 60
($119/t case)*.
NOX Reduction Monetized Value 7%................ 1.26.............. 1.26.............. 1.26
(at $2,684/ton)**.
3%................ 1.32.............. 1.32.............. 1.32
Total Benefits [dagger]..... 7% plus CO2 range. 76 to 130......... 75 to 130......... 76 to 131
7%................ 89................ 89................ 90
3% plus CO2 range. 82 to 136......... 82 to 136......... 83 to 138
3%................ 96................ 95................ 97
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Consumer Incremental Product 7%................ 9................. 9................. 6
Costs.
3%................ 10................ 10................ 6
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Total [dagger].............. 7% plus CO2 range. 66 to 120......... 66 to 120......... 70 to 124
7%................ 80................ 79................ 84
3% plus CO2 range. 73 to 127......... 72 to 126......... 77 to 132
3%................ 86................ 86................ 91
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with battery chargers shipped in 2018-2047.
These results include benefits to consumers which accrue after 2047 from the products purchased in 2018-2047.
The results account for the incremental variable and fixed costs incurred by manufacturers due to the
standard, some of which may be incurred in preparation for the rule. The Primary, Low Benefits, and High
Benefits Estimates utilize projections of energy prices from the AEO2014 Reference case, Low Estimate, and
High Estimate, respectively. Additionally, the High Benefits Estimates include a price trend on the
incremental product costs.
** The CO2 values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the
updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and
2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution
calculated using a 3% discount rate. The SCC time series incorporate an escalation factor. The value for NOX
is the average of high and low values found in the literature.
[dagger] Total Benefits for both the 3% and 7% cases are derived using the series corresponding to the average
SCC with 3-percent discount rate ($40.5/t case). In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2
range,'' the operating cost and NOX benefits are calculated using the labeled discount rate, and those values
are added to the full range of CO2 values.
3. Stakeholder Comments on Standards Proposed in NOPR
In addition to the issues addressed above, DOE received a number of
general comments on the appropriateness of the battery charger
standards proposed in the NOPR. The CEC, CBIA, ASAP, and NRDC, NEEP,
and PSMA--along with a number of representatives from a variety of
State legislatures \70\ and the City of Cambridge, Massachusetts--all
supported DOE's proposed levels for Product Classes 1, 7, 8, and 10 but
urged DOE to adopt the more stringent levels proposed in California for
Product Classes 2, 3, 4, 5, and 6. These interested parties provided a
number of justifications for harmonizing with California that are
addressed in detail elsewhere. The CEC and ASAP urged DOE to take the
time to fully analyze the more stringent levels, even if it means a
later effective date for the standards, while both the City of
Cambridge and the various State legislators urged DOE to adopt levels
similar to those already in place in California. (CEC, No. 117 at p. 6;
CBIA, No. 126 at p. 2; ASAP Et Al., No. 136 at p. 2; NEEP, No. 160 at
p.1; States, No. 159 at p. 1; City of Cambridge, MA, No. 155 at p. 1;
PSMA, No. 147 at p. 1)
---------------------------------------------------------------------------
\70\ Comments were received in the form of a letter from Senator
Jackie Dingfelder of the Oregon State Senate. Representatives of the
following States also signed onto that letter: Alaska, Arkansas,
Colorado, Illinois, Iowa, Maine, Maryland, Minnesota, Montana,
Nebraska, New Mexico, New York, North Carolina, Ohio, Oregon,
Pennsylvania, Rhode Island, Utah, Washington, and Wisconsin.
---------------------------------------------------------------------------
In addition, manufacturers, including AHAM, PTI, CEA, Motorola, and
Philips, generally opposed harmonization with California for Product
Classes 2 through 6, arguing that DOE's proposed levels are
technologically feasible and economically justified while California's
are not. (AHAM, No. 124 at p. 4; PTI, No. 133 at p. 3; CEA, No. 106 at
p. 2; Motorola Mobility, No. 121 at p. 6; Philips, No. 128 at p. 6) For
Product Class 7, Delta-Q Technologies found that the proposed standard
was acceptable, while Lester Electrical opposed the proposed level.
(Delta-Q Technologies, No. 113 at p. 2; Lester Electrical, No. 139 at
p. 2). Panasonic commented that the proposed standard for Product Class
1 was too stringent. (Panasonic, No. 120 at p. 2)
DOE has addressed the specific points underpinning these general
comments in the preceding sections of this SNOPR. The proposed standard
levels would, if adopted, save a significant amount of energy, are
technologically feasible, and are economically justified.
[[Page 52925]]
The CEC commented that failing to set standards for Product Class 9
would create a category of unregulated products that could lead to
compliance and enforcement loopholes in the future. It stated that
battery chargers with DC input greater than 9V are regulated under the
California standards and will remain so if the DOE does not adopt
standards, but expressed concern that this may lead to industry
confusion. (California Energy Commission, No. 117 at p. 7) While it is
technically possible that a product that is not an in-vehicle charger
could meet the parameters of Product Class 9, no such products existed
when DOE conducted its analysis. DOE can only evaluate whether
standards are justified based on the products currently on the market.
If new products come on the market in the future, DOE can revisit
whether to set standards for Product Class 9 as part of a future
rulemaking.
Regarding California's assertions related to preemption, DOE notes
that under 42 U.S.C. 6297, which lays out the process by which State
and local energy conservation standards are preempted, once DOE sets
standards for a product any State or local standards for that product
are preempted. In the case of battery chargers, preemption does not
apply until the Federal standards are required for compliance. See 42
U.S.C. 6295(ii)(1). In particular, under this provision, any State or
local standard prescribed or enacted for battery chargers before the
date on which the final rule is issued shall not be preempted ``until
the energy conservation standard that has been established [under the
appropriate statutory provision] for the product takes effect.'' While
this provision has clear implications regarding the timing of
preemption, it does not alter the scope of its application by narrowing
the range of products that would be affected by preemption once DOE has
set standards for ``the product'' at issue. Accordingly, in DOE's view,
once the Agency sets standards for battery chargers and the compliance
date for those standards has been reached, all State and local energy
conservation standards for battery chargers would be preempted. With
respect to any labeling requirements, DOE notes that 42 U.S.C. 6297
already prescribes that States and local jurisdictions may not require
the disclosure of information other than that required by DOE or FTC.
Since DOE is not proposing to require that manufacturers label their
battery chargers, those labeling requirements would also be preempted.
See 42 U.S.C. 6297(a). An individual manufacturer would be free,
however, to voluntarily use the ``BC'' mark if it chose to do so.
Cobra Electronics commented that the ENERGY STAR program is an
effective means for encouraging the development of more efficient
technologies. Furthermore, the use of a voluntary program would allow
DOE to comply with Executive Order 13563, which directed Federal
agencies to ``identify and assess available alternatives to direct
regulation.'' (Cobra Electronics, No. 130 at p. 8) DOE notes that
Executive Order 13563 also stated that regulations should be adopted
``only upon a reasoned determination that its benefits justify its
costs.'' Because the selected standard levels are technologically
feasible and economically justified, DOE has fulfilled its statutory
obligations as well as the directives in Executive Order 13563. In
addition, DOE considered the impacts of a voluntary program as part of
the Regulatory Impact Analysis and found that such a program would save
less energy than the proposed standards, especially since the ENERGY
STAR program for battery chargers has already ended. See Chapter 17 of
the SNOPR TSD.
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
Section 1(b)(1) of Executive Order 12866, ``Regulatory Planning and
Review,'' 58 FR 51735 (Oct. 4, 1993), requires each agency to identify
the problem that it intends to address, including, where applicable,
the failures of private markets or public institutions that warrant new
agency action, as well as to assess the significance of that problem.
The problems that the proposed standards address are as follows:
(1) Insufficient information and the high costs of gathering and
analyzing relevant information leads some consumers to miss
opportunities to make cost-effective investments in energy efficiency.
(2) In some cases the benefits of more efficient equipment are not
realized due to misaligned incentives between purchasers and users. An
example of such a case is when the equipment purchase decision is made
by a building contractor or building owner who does not pay the energy
costs.
(3) There are external benefits resulting from improved energy
efficiency of appliances and equipment that are not captured by the
users of such products. These benefits include externalities related to
public health, environmental protection, and national security that are
not reflected in energy prices, such as reduced emissions of air
pollutants and greenhouse gases that impact human health and global
warming.
In addition, DOE has determined that this proposed regulatory
action is not a ``significant regulatory action'' under Executive Order
12866. Therefore, DOE did not present for review to the Office of
Information and Regulatory Affairs (OIRA) in the OMB the draft rule and
other documents prepared for this rulemaking, including a regulatory
impact analysis (RIA).
DOE has also reviewed this regulation pursuant to Executive Order
13563. 76 FR 3281 (Jan. 21, 2011). Executive Order 13563 is
supplemental to and explicitly reaffirms the principles, structures,
and definitions governing regulatory review established in Executive
Order 12866. To the extent permitted by law, agencies are required by
Executive Order 13563 to: (1) Propose or adopt a regulation only upon a
reasoned determination that its benefits justify its costs (recognizing
that some benefits and costs are difficult to quantify); (2) tailor
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations; (3) select, in choosing among alternative regulatory
approaches, those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity); (4) to the extent
feasible, specify performance objectives, rather than specifying the
behavior or manner of compliance that regulated entities must adopt;
and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies
to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible. In its
guidance, the Office of Information and Regulatory Affairs has
emphasized that such techniques may include identifying changing future
compliance costs that might result from technological innovation or
anticipated behavioral changes. For the reasons stated in the preamble,
DOE believes that this proposed rule is consistent with these
principles, including the
[[Page 52926]]
requirement that, to the extent permitted by law, benefits justify
costs and that net benefits are maximized.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601, et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990. DOE has made its
procedures and policies available on the Office of the General
Counsel's Web site (http://energy.gov/gc/office-general-counsel). DOE
has prepared the following IRFA for the products that are the subject
of this rulemaking.
As a result of this review, DOE has prepared an IRFA addressing the
impacts on small manufacturers. DOE will transmit a copy of the IRFA to
the Chief Counsel for Advocacy of the Small Business Administration
(SBA) for review under 5 U.S.C 605(b). As presented and discussed in
the following sections, the IFRA describes potential impacts on small
business manufacturers of battery chargers associated with the required
capital and product conversion costs at each TSL and discusses
alternatives that could minimize these impacts.
A statement of the reasons and objectives of the proposed rule,
along with its legal basis, are set forth elsewhere in the preamble and
not repeated here.
1. Description on Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
For manufacturers of battery chargers, the SBA has set a size
threshold, which defines those entities classified as ``small
businesses'' for the purposes of the statute. DOE used the SBA's small
business size standards to determine whether any small entities would
be subject to the requirements of the rule. 65 FR 30836, 30848 (May 15,
2000), as amended at 65 FR 53533, 53544 (Sept. 5, 2000) and codified at
13 CFR part 121. The size standards are listed by North American
Industry Classification System (NAICS) code and industry description
and are available at http://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf. Battery charger manufacturing is classified
under NAICS 335999, ``All Other Miscellaneous Electrical Equipment and
Component Manufacturing.'' The SBA sets a threshold of 500 employees or
less for an entity to be considered as a small business for this
category.
To estimate the number of companies that could be small business
manufacturers of products covered by this rulemaking, DOE conducted a
market survey using all available public information to identify
potential small battery charger manufacturers. DOE's research involved
industry trade association membership directories, product databases,
individual company Web sites, and the SBA's Small Business Database to
create a list of every company that could potentially manufacture
products covered by this rulemaking. DOE also asked stakeholders and
industry representatives if they were aware of any other small
manufacturers during manufacturer interviews and at previous DOE public
meetings. DOE contacted companies on its list, as necessary, to
determine whether they met the SBA's definition of a small business
manufacturer of covered battery chargers. DOE screened out companies
that did not offer products covered by this rulemaking, did not meet
the definition of a ``small business,'' or are foreign-owned and
operated.
Based on this screening, DOE identified 30 companies that could
potentially manufacture battery chargers. DOE eliminated most of these
companies from consideration as small business manufacturers based on a
review of product literature and Web sites. When those steps yielded
inconclusive information, DOE contacted the companies directly. As part
of these efforts, DOE identified Lester Electrical, Inc. (Lincoln,
Nebraska), a manufacturer of golf car battery chargers, as the only
small business that appears to produce covered battery chargers
domestically.
b. Manufacturer Participations
Before issuing this proposed rule, DOE contacted the potential
small business manufacturers of battery chargers it had identified. One
small business consented to being interviewed during the MIA interviews
conducted prior to the publication of the NOPR. DOE also obtained
information about small business impacts while interviewing large
manufacturers.
c. Industry Structure
With respect to battery chargers, industry structure is typically
defined by the characteristics of the industry of the application(s)
for which the battery chargers are produced. In the case of the small
business DOE identified, however, the battery charger itself is the
product the small business produces. That is, the company does not also
produce the applications with which the battery charger is intended to
be used--in this case, battery chargers predominantly intended for golf
cars (Product Class 7).
A high level of concentration exists in both battery charger
markets. Two golf car battery charger manufacturers account for the
vast majority of the golf car battery charger market and each have a
similar share. Both competitors in the golf car battery charger market
are, in terms of the number of their employees, small entities: one is
foreign-owned and operated, while the other is a domestic small
business, as defined by SBA. Despite this concentration, there is
considerable competition for three main reasons. First, each golf car
battery charger manufacturer sells into a market that is almost as
equally concentrated: three golf car manufacturers supply the majority
of the golf cars sold domestically and none of them manufactures golf
car battery chargers. Second, while there are currently only two major
suppliers of golf car battery chargers to the domestic market, the
constant prospect of potential entry from other foreign countries has
ceded substantial buying power to the three golf car OEMs. Third, golf
car manufacturers can choose not to build electric golf cars
(eliminating the need for the battery charger) by opting to build gas-
powered products. DOE examines a price elasticity sensitivity scenario
for this in chapter 12 of the SNOPR TSD to assess this possibility.
Currently, roughly three-quarters of the golf car market is electric-
based, with the remainder gas-powered.
The majority of industry shipments flow to the ``fleet'' segment--
i.e. battery chargers sold to golf car manufacturers who then lease the
cars to golf courses. Most cars are leased for the first few years
before being sold to smaller golf courses or other individuals for
personal use. A smaller portion of golf cars are sold as new through
dealer distribution.
Further upstream, approximately half of the battery chargers
intended for golf car use is manufactured domestically, while the other
half is foreign-sourced. During the design cycle of the golf car, the
battery charger supplier and OEM
[[Page 52927]]
typically work closely together when designing the battery charger.
The small business manufacturer is also a relatively smaller player
in the markets for wheelchair and industrial lift battery chargers.
Most wheelchair battery chargers and the wheelchairs themselves are
manufactured overseas. Three wheelchair manufacturers supply the
majority of the U.S. market, but do not have domestic manufacturing.
d. Comparison Between Large and Small Entities
As discussed in the previous section, there are two major suppliers
in the golf car battery charger market. Both are small entities,
although one is foreign-owned and operated and does not qualify as a
small business per the SBA definition. These two small entities have a
similar market share and sales volumes. DOE did not identify any large
businesses with which to compare the projected impacts on small
businesses.
2. Description and Estimate of Compliance Requirements
The U.S.-owned small business DOE identified manufacturers of
battery chargers for golf cars (Product Class 7). DOE anticipates the
proposed rule will require both capital and product conversion costs to
achieve compliance. The CSLs proposed for Product Classes 5, 6, and 7
will drive different levels of small business impacts. The compliance
costs associated with the proposed TSLs are present in Table VI-1
through Table VI-3.
DOE does not expect the proposed TSL to require significant capital
expenditures. Although some replacement of fixtures, new assembly
equipment and tooling would be required, the magnitude of these
expenditures would be unlikely to cause significant adverse financial
impacts. Product Class 7 drives the majority of these costs. See Table
VI-1 for the estimated capital conversion costs for a typical small
business.
Table VI-1--Estimated Capital Conversion Costs for a Small Business
----------------------------------------------------------------------------------------------------------------
Product class and estimated capital
conversion cost TSL 1 TSL 2 * TSL 3 TSL 4
----------------------------------------------------------------------------------------------------------------
Product Classes 5 and 6..................... CSL 1 CSL 2 CSL 3 CSL 3
Product Class 7............................. CSL 1 CSL 1 CSL 2 CSL 2
Estimated Capital Conversion Costs (2013$).. $0.1 $0.1 $0.2 $0.2
----------------------------------------------------------------------------------------------------------------
* This is the TSL proposed in this SNOPR rulemaking.
The product conversion costs associated with standards are more
significant for the small business manufacturer at issue than the
projected capital conversion costs. TSL 2 for Product Class 7 reflects
a technology change from a linear battery charger or less efficient
high-frequency design battery charger at the baseline to a more
efficient switch-mode or high-frequency design battery charger. This
change would require manufacturers that produce linear or less
efficient high-frequency design battery chargers to invest in the
development of a new product design, which would require investments in
engineering resources for R&D, testing and certification, and marketing
and training changes. Again, the level of expenditure at each TSL is
driven almost entirely by the changes required for Product Class 7 at
each TSL. Additionally, based on market research conducted during the
analysis period of this SNOPR, DOE has found that manufacturers
(including those based domestically) who previously sold exclusively,
or primarily, linear battery chargers, are now selling switch-mode
battery chargers, which are capable of charging batteries equal to
similar batteries charged by linear battery chargers offered by the
same manufacturer. See Table VI-2 for the estimated product conversion
costs for a typical small business.
Table VI-2--Estimated Product Conversion Costs for a Small Business
----------------------------------------------------------------------------------------------------------------
Product class and estimated product
conversion cost TSL 1 TSL 2 * TSL 3 TSL 4
----------------------------------------------------------------------------------------------------------------
Product Classes 5 and 6..................... CSL 1 CSL 2 CSL 3 CSL 3
Product Class 7............................. CSL 1 CSL 1 CSL 2 CSL 2
Estimated Product Conversion Costs (2013$).. $1.8 $2.0 $5.1 $5.1
----------------------------------------------------------------------------------------------------------------
* This is the TSL proposed in this SNOPR rulemaking.
Table VI-3 displays the total capital and product conversion costs
associated with each TSL.
Table VI-3--Estimated Total Conversion Costs for a Small Business
----------------------------------------------------------------------------------------------------------------
Product class and estimated total conversion
cost TSL 1 TSL 2 * TSL 3 TSL 4
----------------------------------------------------------------------------------------------------------------
Product Classes 5 and 6..................... CSL 1 CSL 2 CSL 3 CSL 3
Product Class 7............................. CSL 1 CSL 1 CSL 2 CSL 2
Estimated Total Conversion Costs (2013$).... $1.9 $2.1 $4.3 $4.3
----------------------------------------------------------------------------------------------------------------
* This is the TSL proposed in this SNOPR rulemaking.
[[Page 52928]]
Based on its engineering analysis, manufacturer interviews and
public comments, DOE believes TSL 2 for Product Class 7 would establish
an efficiency level that standard linear battery chargers could not
cost-effectively achieve. Not only would the size and weight of such
chargers potentially conflict with end-user preferences, but the
additional steel and copper requirements would make such chargers cost-
prohibitive in the marketplace. Baseline linear designs are already
significantly more costly to manufacture than the more-efficient
switch-mode designs, as DOE's cost efficiency curve shows in the
engineering section (see Table IV-10). While the majority of the
battery chargers manufactured by the one small business DOE identified,
that would be affected by the proposed battery charger standards, would
need to be modified to meet the proposed standards for Product Class 7,
this manufacturer has the capability to manufacture switch-mode battery
chargers. Therefore, DOE anticipates that this manufacturer could
comply with the proposal by modifying their existing switch-mode
battery charger specifications. This would require significantly fewer
R&D resources than completely redesigning all of their production line.
Additionally, DOE acknowledges that some or all existing domestic
linear battery charger manufacturing could be lost due to the proposed
standards, since it is likely that switch-mode battery charger
manufacturing would likely be manufactured abroad.
3. Duplication, Overlap and Conflict With Other Rules and Regulations
Since the CEC battery charger standards would be preempted by a
battery charger energy conservation standard set by DOE, DOE is not
aware of any rules or regulations that duplicate, overlap, or conflict
with the rule being considered in this notice.
4. Significant Alternatives to the Proposed Rule
The discussion in the previous sections analyzes impacts on small
businesses that would result from the other TSLs DOE considered. Though
TSLs lower than the proposed TSL are expected to reduce the impacts on
small entities, DOE is required by EPCA to establish standards that
achieve the maximum improvement in energy efficiency that are
technically feasible and economically justified, and result in a
significant conservation of energy. Once DOE determines that a
particular TSL meets those requirements, DOE adopts that TSL in
satisfaction of its obligations under EPCA.
In addition to the other TSLs being considered, the SNOPR TSD for
this proposed rule includes an analysis of non-regulatory alternatives
in chapter 17. For battery chargers, these policy alternatives
included: (1) No standard, (2) consumer rebates, (3) consumer tax
credits, (4) manufacturer tax credits, and (5) early replacement. While
these alternatives may mitigate to some varying extent the economic
impacts on small entities compared to the proposed standards, DOE does
not intend to consider these alternatives further because in several
cases, they would not be feasible to implement without authority and
funding from Congress, and in all cases, DOE has determined that the
energy savings of these alternatives are significantly smaller than
those that would be expected to result from adoption of the proposed
standard levels. Accordingly, DOE is declining to adopt any of these
alternatives and is proposing the standards set forth in this
rulemaking. (See chapter 17 of the SNOPR TSD for further detail on the
policy alternatives DOE considered.)
DOE continues to seek input from businesses that would be affected
by this rulemaking and will consider comments received in the
development of any final rule.
C. Review Under the Paperwork Reduction Act
If DOE adopts standards for battery chargers, manufacturers of
these products would need to certify to DOE that their products comply
with the applicable energy conservation standards. In certifying
compliance, manufacturers must test their products according to the DOE
test procedures for battery chargers, including any amendments adopted
for those test procedures. DOE has established regulations for the
certification and recordkeeping requirements for all covered consumer
products and commercial equipment, including battery chargers. (76 FR
12422 (March 7, 2011); 80 FR 5099 (Jan. 30, 2015). The collection-of-
information requirement for the certification and recordkeeping is
subject to review and approval by OMB under the Paperwork Reduction Act
(PRA). This requirement has been approved by OMB under OMB control
number 1910-1400. Public reporting burden for the certification is
estimated to average 30 hours per response, including the time for
reviewing instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act (NEPA) of 1969,
DOE has determined that this proposal would fit within the category of
actions included in Categorical Exclusion (CX) B5.1 and otherwise meets
the requirements for application of a CX. See 10 CFR part 1021, App. B,
B5.1(b); 1021.410(b) and Appendix B, B1-B5. This proposal fits within
this category of actions because it would establish energy conservation
standards for consumer products or industrial equipment, and for which
none of the exceptions identified in CX B5.1(b) apply. Therefore, DOE
has made a CX determination for this rulemaking, and DOE does not need
to prepare an Environmental Assessment or Environmental Impact
Statement for this rule. DOE's CX determination for this rule is
available at http://cxnepa.energy.gov.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism.'' 64 FR 43255 (Aug. 10, 1999)
imposes certain requirements on Federal agencies formulating and
implementing policies or regulations that preempt State law or that
have Federalism implications. The Executive Order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit the policymaking discretion of the States and
to carefully assess the necessity for such actions. The Executive Order
also requires agencies to have an accountable process to ensure
meaningful and timely input by State and local officials in the
development of regulatory policies that have Federalism implications.
On March 14, 2000, DOE published a statement of policy describing the
intergovernmental consultation process it will follow in the
development of such regulations. 65 FR 13735. DOE has examined this
proposed rule and has tentatively determined that it would not have a
substantial direct effect on the States, on the relationship between
the national government and the States, or on the distribution of power
and responsibilities among the various
[[Page 52929]]
levels of government. EPCA governs and prescribes Federal preemption of
State regulations as to energy conservation for the products that are
the subject of this proposed rule. States can petition DOE for
exemption from such preemption to the extent, and based on criteria,
set forth in EPCA. (42 U.S.C. 6297) Therefore, no further action is
required by Executive Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' imposes on Federal agencies the general duty
to adhere to the following requirements: (1) Eliminate drafting errors
and ambiguity; (2) write regulations to minimize litigation; (3)
provide a clear legal standard for affected conduct rather than a
general standard; and (4) promote simplification and burden reduction.
61 FR 4729 (Feb. 7, 1996). Regarding the review required by section
3(a), section 3(b) of Executive Order 12988 specifically requires that
Executive agencies make every reasonable effort to ensure that the
regulation: (1) Clearly specifies the preemptive effect, if any; (2)
clearly specifies any effect on existing Federal law or regulation; (3)
provides a clear legal standard for affected conduct while promoting
simplification and burden reduction; (4) specifies the retroactive
effect, if any; (5) adequately defines key terms; and (6) addresses
other important issues affecting clarity and general draftsmanship
under any guidelines issued by the Attorney General. Section 3(c) of
Executive Order 12988 requires Executive agencies to review regulations
in light of applicable standards in section 3(a) and section 3(b) to
determine whether they are met or it is unreasonable to meet one or
more of them. DOE has completed the required review and determined
that, to the extent permitted by law, this proposed rule meets the
relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely to result in a rule that may
cause the expenditure by State, local, and Tribal governments, in the
aggregate, or by the private sector of $100 million or more in any one
year (adjusted annually for inflation), section 202 of UMRA requires a
Federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of State, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect them. On March 18, 1997, DOE published
a statement of policy on its process for intergovernmental consultation
under UMRA. 62 FR 12820. DOE's policy statement is also available at
http://energy.gov/sites/prod/files/gcprod/documents/umra_97.pdf.
Although this proposed rule does not contain a Federal
intergovernmental mandate, it may require expenditures of $100 million
or more by the private sector. Specifically, the proposed rule would
likely result in a final rule that could require expenditures of $100
million or more. Such expenditures may include: (1) Investment in
research and development and in capital expenditures by battery charger
manufacturers in the years between the final rule and the compliance
date for the new standards, and (2) incremental additional expenditures
by consumers to purchase higher-efficiency battery chargers, starting
at the compliance date for the applicable standard.
Section 202 of UMRA authorizes a Federal agency to respond to the
content requirements of UMRA in any other statement or analysis that
accompanies the proposed rule. (2 U.S.C. 1532(c)). The content
requirements of section 202(b) of UMRA relevant to a private sector
mandate substantially overlap the economic analysis requirements that
apply under section 325(o) of EPCA and Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of the proposed rule and the
``Regulatory Impact Analysis'' section of the SNOPR TSD for this
proposed rule respond to those requirements.
Under section 205 of UMRA, the Department is obligated to identify
and consider a reasonable number of regulatory alternatives before
promulgating a rule for which a written statement under section 202 is
required. (2 U.S.C. 1535(a)). DOE is required to select from those
alternatives the most cost-effective and least burdensome alternative
that achieves the objectives of the proposed rule unless DOE publishes
an explanation for doing otherwise, or the selection of such an
alternative is inconsistent with law. As required by 42 U.S.C. 6295(o),
this proposed rule would establish energy conservation standards for
battery chargers that are designed to achieve the maximum improvement
in energy efficiency that DOE has determined to be both technologically
feasible and economically justified. A full discussion of the
alternatives considered by DOE is presented in the ``Regulatory Impact
Analysis'' section of the SNOPR TSD for this proposed rule.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This proposed rule would not have any impact on the autonomy or
integrity of the family as an institution. Accordingly, DOE has
concluded that it is not necessary to prepare a Family Policymaking
Assessment.
I. Review Under Executive Order 12630
Pursuant to Executive Order 12630, ``Governmental Actions and
Interference with Constitutionally Protected Property Rights,'' 53 FR
8859 (March 15, 1988), DOE has determined that this proposed rule would
not result in any takings that might require compensation under the
Fifth Amendment to the U.S. Constitution.
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note) provides for Federal agencies to
review most disseminations of information to the public under
information quality guidelines established by each agency pursuant to
general guidelines issued by OMB. OMB's guidelines were published at 67
FR 8452 (Feb. 22, 2002), and DOE's guidelines were published at 67 FR
62446 (Oct. 7, 2002). DOE has reviewed this proposed rule under the OMB
and DOE guidelines and has concluded that it is consistent with
applicable policies in those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires Federal agencies to
[[Page 52930]]
prepare and submit to OIRA at OMB, a Statement of Energy Effects for
any proposed significant energy action. A ``significant energy action''
is defined as any action by an agency that promulgates or is expected
to lead to promulgation of a final rule, and that: (1) Is a significant
regulatory action under Executive Order 12866, or any successor order;
and (2) is likely to have a significant adverse effect on the supply,
distribution, or use of energy, or (3) is designated by the
Administrator of OIRA as a significant energy action. For any proposed
significant energy action, the agency must give a detailed statement of
any adverse effects on energy supply, distribution, or use should the
proposal be implemented, and of reasonable alternatives to the action
and their expected benefits on energy supply, distribution, and use.
DOE has tentatively concluded that this regulatory action, which
proposes energy conservation standards for battery chargers, is not a
significant energy action because the proposed standards are not likely
to have a significant adverse effect on the supply, distribution, or
use of energy, nor has it been designated as such by the Administrator
at OIRA. Accordingly, DOE has not prepared a Statement of Energy
Effects on this proposed rule.
L. Review Under the Information Quality Bulletin for Peer Review
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as ``scientific information
the agency reasonably can determine will have, or does have, a clear
and substantial impact on important public policies or private sector
decisions.'' 70 FR 2667.
In response to OMB's Bulletin, DOE conducted formal in-progress
peer reviews of the energy conservation standards development process
and analyses and has prepared a Peer Review Report pertaining to the
energy conservation standards rulemaking analyses. Generation of this
report involved a rigorous, formal, and documented evaluation using
objective criteria and qualified and independent reviewers to make a
judgment as to the technical/scientific/business merit, the actual or
anticipated results, and the productivity and management effectiveness
of programs and/or projects. The ``Energy Conservation Standards
Rulemaking Peer Review Report,'' dated February 2007, has been
disseminated and is available at the following Web site:
www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.
VII. Public Participation
A. Attendance at the Public Meeting
The time, date, and location of the public meeting are listed in
the DATES and ADDRESSES sections at the beginning of this notice. If
you plan to attend the public meeting, please notify Ms. Brenda Edwards
at (202) 586-2945 or [email protected].
Please note that foreign nationals visiting DOE Headquarters are
subject to advance security screening procedures which require advance
notice prior to attendance at the public meeting. If a foreign national
wishes to participate in the public meeting, please inform DOE of this
fact as soon as possible by contacting Ms. Regina Washington at (202)
586-1214 or by email: [email protected] so that the
necessary procedures can be completed.
DOE requires visitors to have laptops and other devices, such as
tablets, checked upon entry into the building. Any person wishing to
bring these devices into the Forrestal Building will be required to
obtain a property pass. Visitors should avoid bringing these devices,
or allow an extra 45 minutes to check in. Please report to the
visitor's desk to have devices checked before proceeding through
security.
Due to the REAL ID Act implemented by the Department of Homeland
Security (DHS), there have been recent changes regarding ID
requirements for individuals wishing to enter Federal buildings from
specific states and U.S. territories. Driver's licenses from the
following states or territory will not be accepted for building entry
and one of the alternate forms of ID listed below will be required. DHS
has determined that regular driver's licenses (and ID cards) from the
following jurisdictions are not acceptable for entry into DOE
facilities: Alaska, American Samoa, Arizona, Louisiana, Maine,
Massachusetts, Minnesota, New York, Oklahoma, and Washington.
Acceptable alternate forms of Photo-ID include: U.S. Passport or
Passport Card; an Enhanced Driver's License or Enhanced ID-Card issued
by the states of Minnesota, New York or Washington (Enhanced licenses
issued by these states are clearly marked Enhanced or Enhanced Driver's
License); a military ID or other Federal government issued Photo-ID
card.
In addition, you can attend the public meeting via webinar. Webinar
registration information, participant instructions, and information
about the capabilities available to webinar participants will be
published on DOE's Web site at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx?productid=84. Participants are
responsible for ensuring their systems are compatible with the webinar
software.
B. Procedure for Submitting Prepared General Statements for
Distribution
Any person who has plans to present a prepared general statement
may request that copies of his or her statement be made available at
the public meeting. Such persons may submit requests, along with an
advance electronic copy of their statement in PDF (preferred),
Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to
the appropriate address shown in the ADDRESSES section at the beginning
of this notice. The request and advance copy of statements must be
received at least one week before the public meeting and may be
emailed, hand-delivered, or sent by mail. DOE prefers to receive
requests and advance copies via email. Please include a telephone
number to enable DOE staff to make follow-up contact, if needed.
C. Conduct of the Public Meeting
DOE will designate a DOE official to preside at the public meeting
and may also use a professional facilitator to aid discussion. The
meeting will not be a judicial or evidentiary-type public hearing, but
DOE will conduct it in accordance with section 336 of EPCA (42 U.S.C.
6306). A court reporter will be present to record the proceedings and
prepare a transcript. DOE reserves the right to schedule the order of
presentations and to establish the procedures governing the conduct of
the public meeting. After the public meeting, interested parties may
submit further comments on the proceedings as well as on any aspect of
the rulemaking until the end of the comment period.
The public meeting will be conducted in an informal, conference
style. DOE will present summaries of comments received before the
public meeting,
[[Page 52931]]
allow time for prepared general statements by participants, and
encourage all interested parties to share their views on issues
affecting this rulemaking. Each participant will be allowed to make a
general statement (within time limits determined by DOE), before the
discussion of specific topics. DOE will allow, as time permits, other
participants to comment briefly on any general statements.
At the end of all prepared statements on a topic, DOE will permit
participants to clarify their statements briefly and comment on
statements made by others. Participants should be prepared to answer
questions by DOE and by other participants concerning these issues. DOE
representatives may also ask questions of participants concerning other
matters relevant to this rulemaking. The official conducting the public
meeting will accept additional comments or questions from those
attending, as time permits. The presiding official will announce any
further procedural rules or modification of the above procedures that
may be needed for the proper conduct of the public meeting.
A transcript of the public meeting will be included in the docket,
which can be viewed as described in the Docket section at the beginning
of this notice. In addition, any person may buy a copy of the
transcript from the transcribing reporter.
D. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule before or after the public meeting, but no later than the
date provided in the DATES section at the beginning of this proposed
rule. Interested parties may submit comments, data, and other
information using any of the methods described in the ADDRESSES section
at the beginning of this notice.
Submitting comments via regulations.gov. The regulations.gov Web
page will require you to provide your name and contact information.
Your contact information will be viewable to DOE Building Technologies
staff only. Your contact information will not be publicly viewable
except for your first and last names, organization name (if any), and
submitter representative name (if any). If your comment is not
processed properly because of technical difficulties, DOE will use this
information to contact you. If DOE cannot read your comment due to
technical difficulties and cannot contact you for clarification, DOE
may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to regulations.gov information for which disclosure
is restricted by statute, such as trade secrets and commercial or
financial information (hereinafter referred to as Confidential Business
Information (CBI)). Comments submitted through regulations.gov cannot
be claimed as CBI. Comments received through the Web site will waive
any CBI claims for the information submitted. For information on
submitting CBI, see the Confidential Business Information section
below.
DOE processes submissions made through regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery/courier, or mail.
Comments and documents submitted via email, hand delivery, or mail also
will be posted to regulations.gov. If you do not want your personal
contact information to be publicly viewable, do not include it in your
comment or any accompanying documents. Instead, provide your contact
information in a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. The cover
letter will not be publicly viewable as long as it does not include any
comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via mail or hand
delivery/courier, please provide all items on a CD, if feasible. It is
not necessary to submit printed copies. No facsimiles (faxes) will be
accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. According to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
one copy of the document marked confidential including all the
information believed to be confidential, and one copy of the document
marked non-confidential with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure; (6) when such information might lose its
confidential character due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
1. DOE requests stakeholder comment on the proposed elimination of
Product Classes 8, 9, 10a, and 10b from the analysis. (See section
IV.A.3.b)
[[Page 52932]]
2. DOE requests stakeholder comments on the updated engineering
analysis results presented in this analysis for products classes 2-6.
(See section IV.C.9)
3. DOE requests comment on the new methodology of shifting CSLs in
Product Classes 2-6 to more closely align with the CEC standards. (See
section IV.C.4)
4. DOE seeks comment on its methodology in scaling the results of
Product Class 5 to Product Class 6, including the decision to hold MSPs
constant. (See section IV.C.9)
5. DOE requests comment on the new methodology for determining the
base case efficiency distributions using the CEC database of battery
charger models sold in California combined with DOE's usage profiles.
(See section IV.G.3)
6. DOE requests comment on the methodology of filtering RECS data
to obtain a population distribution of low-income consumers that was
used for the low-income consumers LCC subgroup analysis. (See section
V.B.1)
7. DOE seeks comments on its approach in updating the base case
efficiency distributions for this rule using the CEC database. (See
section IV.G.3)
8. DOE seeks comment on the potential domestic employment impacts
to battery charger manufacturers at the proposed efficiency levels.
(See section V.B.2.b and section VI.B).
9. DOE seeks comment on the compliance costs of any other
regulations battery charger and battery charger application
manufacturers must make, especially if compliance with those other
regulations is required three years before or after the estimated
compliance date of this proposed standard (2018) (see section V.B.2.e).
10. DOE seeks comments on the existence of any small business
battery charger or battery charger application manufacturers other than
the one identified by DOE. DOE also requests comments on the impacts of
the proposed efficiency levels on any small businesses manufacturing
battery chargers that would be subject to the proposed standards or
applications that would use these chargers. (See section VI.B).
VIII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this proposed
rule.
List of Subjects in 10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Intergovernmental relations, Reporting and recordkeeping requirements,
and Small businesses.
Issued in Washington, DC, on July 30, 2015.
David T. Danielson,
Assistant Secretary, Energy Efficiency and Renewable Energy.
For the reasons set forth in the preamble, DOE proposes to amend
part 430 of chapter II, subchapter D, of title 10 of the Code of
Federal Regulations, as set forth below:
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
0
1. The authority citation for part 430 continues to read as follows:
Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.
0
2. Section 430.32 is amended by adding paragraph (z) to read as
follows:
Sec. 430.32 Energy and water conservation standards and their
effective dates.
* * * * *
(z) Battery Chargers. (1) Battery chargers manufactured starting on
the date corresponding to two years after the publication of the final
rule for this rulemaking, shall have a unit energy consumption (UEC)
less than or equal to the prescribed ``Maximum UEC'' standard when
using the equations for the appropriate product class and corresponding
measured battery energy as shown in the following table:
----------------------------------------------------------------------------------------------------------------
Special
Product class No. Input/Output type Battery energy characteristic or Maximum UEC (kWh/
(Wh) battery voltage yr)
----------------------------------------------------------------------------------------------------------------
1............................... AC In, DC Out..... < 100............. Inductive 3.04.
Connection *.
2............................... .................. .................. < 4 V............. 0.1440 * Ebatt +
2.95.
3............................... .................. .................. 4-10 V............ For Ebatt < 10Wh,
1.42 kWh/yr;
Ebatt >= 10 Wh,
0.0255 * Ebatt +
1.16.
4............................... .................. .................. > 10 V............ 0.11 * Ebatt +
3.18.
5............................... .................. 100-3000.......... < 20 V............ For Ebatt < 19 Wh,
1.32 kWh/yr; For
Ebatt >= 19 Wh,
0.0257 * Ebatt +
.815.
6............................... .................. .................. >= 20 V........... For Ebatt < 18 Wh,
3.88 kWh/yr; For
Ebatt >= 18 Wh,
0.0778 * Ebatt +
2.4.
7............................... .................. > 3000............ .................. 0.0502 * Ebatt +
4.53.
----------------------------------------------------------------------------------------------------------------
* Inductive connection and designed for use in a wet environment (e.g. electric toothbrushes).
** Ebatt = Measured battery energy as determined in section 5.6 of appendix Y to subpart B of this part.
(2) Unit energy consumption shall be calculated for a device
seeking certification as being compliant with the relevant standard
using one of the two equations (equation (i) or equation (ii)) listed
below. If a device is tested and its charge test duration as determined
in section 5.2 of appendix Y to subpart B of this part minus 5 hours
exceeds the threshold charge time listed in the table below, equation
(ii) shall be used to calculate UEC; otherwise a device's UEC shall be
calculated using equation (i).
[[Page 52933]]
[GRAPHIC] [TIFF OMITTED] TP01SE15.002
Where:
E24 = 24-hour energy as determined in Sec. 429.39(a) of
this chapter,
Ebatt = Measured battery energy as determined in Sec.
429.39(a) of this chapter,
Pm = Maintenance mode power as determined in Sec.
429.39(a) of this chapter,
Psb = Standby mode power as determined in Sec. 429.39(a)
of this chapter,
Poff = Off mode power as determined in Sec. 429.39(a) of
this chapter,
tcd = Charge test duration as determined in Sec.
429.39(a) of this chapter,
and
ta&m, n, tsb, and toff, are
constants used depending upon a device's product class and found in
the following table:
----------------------------------------------------------------------------------------------------------------
Active +
Product class maintenance Standby (tsb) Off (toff) Charges (n) Threshold
(ta&m) charge time *
----------------------------------------------------------------------------------------------------------------
Hours per Day ** Number per Day Hours
----------------------------------------------------------------------------------------------------------------
1............................... 20.66 0.10 0.00 0.15 135.41
2............................... 7.82 5.29 0.00 0.54 19.00
3............................... 6.42 0.30 0.00 0.10 67.21
4............................... 16.84 0.91 0.00 0.50 33.04
5............................... 6.52 1.16 0.00 0.11 56.83
6............................... 17.15 6.85 0.00 0.34 50.89
7............................... 8.14 7.30 0.00 0.32 25.15
----------------------------------------------------------------------------------------------------------------
* If the duration of the charge test (minus 5 hours) as determined in section 5.2 of appendix Y to subpart B of
this part exceeds the threshold charge time, use equation (ii) to calculate UEC otherwise use equation (i).
** If the total time does not sum to 24 hours per day, the remaining time is allocated to unplugged time, which
means there is 0 power consumption and no changes to the UEC calculation is needed.
(3) A battery charger shall not be subject to the standards in
paragraph (z)(1) of this section if it is a device that requires
Federal Food and Drug Administration (FDA) listing and approval as a
life-sustaining or life-supporting device in accordance with section
513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360(c)).
[FR Doc. 2015-20218 Filed 8-31-15; 8:45 am]
BILLING CODE 6450-01-P