Energy Conservation Program: Energy Conservation Standards for Battery Chargers
Federal RegisterSep 1, 2015
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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.
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: BatteryChargersSTD0005@ee.doe.gov.
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
Chad_S_Whiteman@omb.eop.gov
.
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
energy.standards@atr.usdoj.gov
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:
battery_chargers_and_external_power_supplies@ee.doe.gov
.
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:
michael.kido@hq.doe.gov
.
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:
Brenda.Edwards@ee.doe.gov
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
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.
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).
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.
Table I-1—Proposed Energy Conservation Standards for Battery Chargers
Product class
Product class description
Proposed standard as a function of battery energy
(kWh/yr)
1
Low-Energy, Inductive Connection
3.04
2
Low-Energy, Low-Voltage <4V
0.1440 * E
batt
+ 2.95
3
Low-Energy, Medium-Voltage 4-10 V
For E
batt
<10Wh, 1.42 kWh/y
E
batt
≥10 Wh,
0.0255 * E
batt
+ 1.16
4
Low-Energy, High-Voltage >10V
0.11 * E
batt
+ 3.18
5
Medium-Energy, Low-Voltage <20 V
For E
batt
< 19 Wh,
1.32 kWh/yr
For E
batt
≥ 19 Wh,
0.0257 * E
batt
+ .815
6
Medium-Energy, High-Voltage ≥20 V
For E
batt
< 18 Wh
3.88 kWh/yr
For E
batt
≥ 18 Wh
0.0778 * E
batt
+ 2.4
7
High-Energy
0.0502 * E
batt
+ 4.53
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
Product class
CSL 0
CSL 1
CSL 2
CSL 3
CSL 4
Estimated shipments in 2018
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
a
This information was taken from DOE's NOPR that was issued on March 27, 2012.
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
Product class
CSL 0
CSL 1
CSL 2
CSL 3
CSL 4
Estimated shipments in 2018
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
8
Efficiency Distribution
UEC
9
Efficiency Distribution
No longer in scope
UEC
10
Efficiency Distribution
UEC
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.
Table I-4—Summary of DOE Market Examination of CEC Units by Application
Application
Product class
Percentage of total BC
shipments in
application
(%)
Retailers examined *
Percentage of models examined in cec database or sold in California
(%)
Smartphones
2
21
Amazon, Best Buy, Sears
100
Media Tablets
2
8
Amazon, Best Buy, Sears
93
MP3 Players
2
8
Amazon, Best Buy, Sears
93
Notebook Computers
4
8
Amazon, Best Buy, Sears
93
Digital Cameras
2
6
Amazon, Best Buy, Sears
97
Power Tools (includes DIY and professional)
2, 3, 4
2
Amazon, Home Depot, Sears
90
Toy Ride-On Vehicles
3, 5
1
Walmart, Toys R Us
93
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).
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
Product class
Average LCC savings
NOPR
(
2010$
)
SNOPR
(
2013$
)
Simple payback period (
years
)
NOPR
SNOPR
Average
lifetime
(
years
)
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
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
4
All monetary values in this section are expressed in 2013 dollars and, where appropriate, are discounted to 2015.
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).
5
A quad is equal to 10
15
British thermal units (Btu).
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
(Mt)
6
of carbon dioxide (CO
2
), 8.92 thousand tons of sulfur dioxide (SO
2
), 15.41 thousand tons of nitrogen oxides (NO
X
), 44.8 thousand tons of methane, 0.137 thousand tons of nitrous oxide (N
2
), and 0.027 tons of mercury (Hg).
3
The cumulative reduction in CO
2
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.
6
A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO
2
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.
The value of the CO
2
reductions is calculated using a range of values per metric ton of CO
2
(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 CO
2
emissions reductions (not including CO
2
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 NO
X
emissions reduction is $13.65 million at a 7-percent discount rate, and $24.43 million at a 3-percent discount rate.
8
Table I-6 summarizes the national economic benefits and costs expected to result from the proposed standards for battery chargers.
7
Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866.
Interagency Working Group on Social Cost of Carbon, United States Government. May 2013; revised November 2013. (Available at:
http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf
.)
8
DOE is currently investigating valuation of avoided SO
2
and Hg emissions.
Table I-6—Summary of National Economic Benefits and Costs of Proposed Energy Conservation Standards for Battery Chargers (TSL 2) *
Category
Present value
(
billion
2013$)
Discount rate
(%)
Benefits
Consumer Operating Cost Savings
0.7
7
1.4
3
CO
2
Reduction Monetized Value ($12.0/t case) **
0.1
5
CO
2
Reduction Monetized Value ($40.5/t case) **
0.4
3
CO
2
Reduction Monetized Value ($62.4/t case) **
0.6
2.5
CO
2
Reduction Monetized Value ($119/t case) **
1.1
3
NO
X
Reduction Monetized Value (at $2,684/ton) **
0.01
7
0.02
3
Total Benefits †
1.1
7
1.8
3
Costs
Consumer Incremental Installed Costs
0.1
7
0.2
3
Total Net Benefits
Including Emissions Reduction Monetized Value†
*1.0
7
1.6
3
* This table presents the costs and benefits associated with battery chargers shipped in 2018−2047. These results include benefits to consumers which accrue after 2047 from the products purchased in 2018−2047. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule.
** The CO
2
values represent global monetized values of the SCC, in 2013$, 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.
† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC with 3-percent discount rate ($40.5/t case).
Table I-7—Summary of National Economic Benefits and Costs of Energy Conservation Standards Proposed in the NOPR for Battery Chargers
Category
Present value
(
billion 2010$
)
Discount rate
(%)
Benefits
Consumer Operating Cost Savings
3.815
7
7.007
3
CO
2
Reduction Monetized Value ($4.9/t case) *
0.208
5
CO
2
Reduction Monetized Value (at $22.3/t case) *
1.025
3
CO
2
Reduction Monetized Value (at $36.5/t case) *
1.720
2.5
CO
2
Reduction Monetized Value (at $67.6/t case) *
3.127
3
NO
X
Reduction Monetized Value (at $2,537/ton) *
0.036
7
0.065
3
Total Benefits **
4.876
7
8.097
3
Costs
Consumer Incremental Installed Costs ‡
−1.435
7
−2.402
3
Net Benefits/Costs
Including Emissions Reduction Monetized Value **
6.311
7
10.498
3
Note:
As described in section IV.A.3 of this notice, the standards proposed in this SNOPR no longer consider product classes 8 and 10. Products that were found in product class 8 of the NOPR analysis were redistributed among other product classes for the SNOPR, and product class 10 was removed from consideration. Therefore, for comparison between the NOPR and SNOPR analyses, the results for product class 8 are included in the table above, while results for product class 10 are excluded.
* These values represent global values (in 2010$) of the social cost of CO
2
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 $67.6 per ton represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The value for NO
X
(in 2010$) 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 CO
2
emissions calculated at a 3% discount rate, which is equal to $22.3/ton in 2010 (in 2010$).
‡ 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 CO
2
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 CO
2
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 CO
2
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 CO
2
reductions is based on a global value. Second, the assessments of operating cost savings and CO
2
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 CO
2
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 CO
2
that continue beyond 2100.
10
The atmospheric lifetime of CO
2
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 CO
2
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 CO
2
reductions, and $1.26 million in reduced NO
X
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
estimated annual benefits are $75 million per year in reduced operating costs, $20 million in CO
2
reductions, and $1.32 million in reduced NO
X
emissions. In this case, the net benefit amounts to $86 million per year.
For comparative purposes, Table I-9 presents the annualized results from the March 27, 2012, NOPR for battery chargers shipped in 2013-2042. For the comparison between the NOPR and SNOPR analyses, products that were found in product class 8 of the NOPR analysis were redistributed among other product classes for the SNOPR, and product class 10 was removed from consideration in the SNOPR. As the CEC standards were effective since February 1, 2013, DOE did not specifically consider the annualized costs and benefits of achieving the CEC efficiency levels in the 2012 NOPR for the California market. For the SNOPR, DOE assumed that the CEC standards had moved the market not just in California, but for the remainder of the country. DOE therefore only considered the annualized costs and benefits of going beyond where the market efficiency levels had moved in response to the CEC standards, across the entire U.S. See 77 FR 18478 (March 27, 2012).
Table I-8—Annualized Benefits and Costs of Proposed Energy Conservation Standards for Battery Chargers (TSL 2)
Discount rate
(%)
(Million 2013$/year)
Primary estimate *
Low net benefits
estimate *
High net benefits
estimate *
Benefits
Consumer Operating Cost Savings
7
68
68
69
3
75
74
76
CO
2
Reduction Monetized Value ($12.0/t case) *
5
6
6
6
CO
2
Reduction Monetized Value ($40.5/t case) *
3
20
20
20
CO
2
Reduction Monetized Value ($62.4/t case) *
2.5
28
28
28
CO
2
Reduction Monetized Value ($119/t case) *
3
60
60
60
NO
X
Reduction Monetized Value (at $2,684/ton) **
7
3
1.26
1.32
1.26
1.32
1.26
1.32
Total Benefits †
7 plus CO
2
range
76 to 130
75 to 130
76 to 131
7
89
89
90
3 plus CO
2
range
82 to 136
82 to 136
83 to 138
3
96
95
97
Costs
Consumer Incremental Product Costs
7
3
9
10
9
10
6
6
Net Benefits
Total †
7 plus CO
2
range
66 to 120
66 to 120
70 to 124
7
80
79
84
3 plus CO
2
range
73 to 127
72 to 126
77 to 132
3
86
86
91
* This table presents the annualized costs and benefits associated with battery chargers shipped in 2018−2047. These results include benefits to consumers which accrue after 2047 from the products purchased in 2018−2047. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the Annual Energy Outlook for 2014 (“
AEO2014”)
Reference case, Low Economic Growth case, and High Economic Growth case, respectively. Additionally, the High Benefits Estimates include a price trend on the incremental product costs.
** The CO
2
values represent global monetized values of the SCC, in 2013$, 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.
† 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 ($40.5/t case). In the rows labeled “7% plus CO
2
range” and “3% plus CO
2
range,” the operating cost and NO
X
benefits are calculated using the labeled discount rate, and those values are added to the full range of CO
2
values.
Table I-9—Annualized Benefits and Costs of Energy Conservation Standards Proposed in the NOPR for Battery Chargers
Discount rate
Monetized (Million 2010$/year)
Primary estimate *
Low net benefits
estimate *
High net benefits
estimate *
Benefits
Consumer Operating Cost Savings
7%
352.0
335.4
368.6
3%
379.2
359.8
399.2
CO
2
Reduction Monetized Value ($4.9/t case) **
5%
14.9
14.9
14.9
CO
2
Reduction Monetized Value ($22.3/t case) **
3%
55.5
55.5
55.5
CO
2
Reduction Monetized Value ($36.5/t case) **
2.5%
86.3
86.3
86.3
CO
2
Reduction Monetized Value ($67.6/t case) **
3%
169.3
169.3
169.3
NO
X
Reduction Monetized Value ($2,537/ton) **
7%
3.3
3.3
3.3
3%
3.5
3.5
3.5
Total Benefits ††
7% plus CO
2
range
370.2 to 524.6
353.6 to 508.0
386.9 to 541.2
7%
410.8
394.2
427.4
3%
438.2
418.8
458.2
3% plus CO
2
range
397.7 to 552.1
378.2 to 532.6
417.7 to 572.0
Costs
Consumer Incremental Product Costs †
7%
(132.4)
(132.4)
(132.4)
3%
(130.0)
(130.0)
(130.0)
Net Benefits
Total ††
7% plus CO
2
range
502.7 to 657.0
486.1 to 640.4
519.3 to 673.6
7%
543.2
526.6
559.8
3%
568.2
548.8
588.2
3% plus CO
2
range
527.7 to 682.0
508.2 to 662.6
547.7 to 702.0
Note:
As described in section IV.A.3 of this notice, the standards proposed in this SNOPR no longer consider product classes 8 and 10. Products that were found in product class 8 of the NOPR analysis were redistributed among other product classes for the SNOPR, and product class 10 was removed from consideration. Therefore, for comparison between the NOPR and SNOPR analyses, the results for product class 8 are included in the table above, while results for product class 10 are excluded.
* The results include benefits to consumers which accrue after 2042 from the products purchased from 2013 through 2042. Costs incurred by manufacturers, some of which may be incurred prior to 2013 in preparation for the rule, are indirectly included as part of incremental equipment costs. The Primary, Low Benefits, and High Benefits Estimates utilize forecasts of energy prices from the
AEO2010
Reference case, Low Estimate, and High Estimate, respectively.
** The CO
2
values represent global monetized values (in 2010$) of the social cost of CO
2
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 $67.6 per ton represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The value for NO
X
(in 2010$) is the average of the low and high values used in DOE's NOPR analysis.
† 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.
†† 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 CO
2
range” and “3% plus CO
2
range,” the operating cost and NO
X
benefits are calculated using the labeled discount rate, and those values are added to the full range of CO
2
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
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,
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
Product class
Product class description
Proposed standard as a function of battery energy (kWh/yr)
1
Low-Energy, Inductive
3.04
2
Low-Energy, Low-Voltage
0.2095 * (E
batt
) + 5.87
3
Low-Energy, Medium-Voltage
For E
batt
< 9.74 Wh, 4.68; For E
batt
≥ 9.74 Wh, = 0.0933 * (E
batt
) + 3.77
4
Low-Energy, High-Voltage
For E
batt
< 9.71 Wh, 9.03; For E
batt
≥ 9.71 Wh, = 0.2411 * (E
batt
) + 6.69
5
Medium-Energy, Low-Voltage
For E
batt
< 355.18 Wh, 20.06; For E
batt
≥ 355.18 Wh, = 0.0219 * (E
batt
) + 12.28
6
Medium-Energy, High-Voltage
For E
batt
< 239.48 Wh, 30.37; For E
batt
≥ 239.48 Wh, = 0.0495 * (E
batt
) + 18.51
7
High-Energy
0.0502 * (E
batt
) + 4.53
8
Low-Voltage DC Input
0.1140 * (E
batt)
+ 0.42; For E
batt
< 1.17 Wh, 0.55 kWh/yr
9
High-Voltage DC Input
No Standard.
10a
AC Output, VFD (Voltage and Frequency Dependent)
For Ebatt < 37.2 Wh, 2.54; For Ebatt ≥ 37.2 Wh, 0.0733 * (E
batt
)—0.18
10b
AC Output, VI (Voltage Independent)
For Ebatt < 37.2 Wh, 6.18; For Ebatt ≥ 37.2 Wh, 0.0733 * (E
batt
) + 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 Advocates
162
ASAP, ASE, ACEEE, CFA, NEEP, and NEEA
ASAP,
et al.
Energy Efficiency Advocates
136
Association of Home Appliance Manufacturers
AHAM
Industry Trade Association
124
Brother International Corporation
Brother International
Manufacturer
111
California Building Industry Association
CBIA
Industry Trade Association
126
California Energy Commission
California Energy Commission
State Entity
117
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 Association
106
Delta-Q Technologies Corp
Delta-Q Technologies
Manufacturer
113
Duracell
Duracell
Manufacturer
109
Earthjustice
Earthjustice
Energy Efficiency Advocates
118
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 Association
131
Korean Agency for Technology and Standards
Republic of Korea
Foreign Government
148
Lester Electrical
Lester
Manufacturer
87, 139
Microsoft Corporation
Microsoft
Manufacturer
110
Motorola Mobility, Inc
Motorola Mobility
Manufacturer
121
National Electrical Manufacturers Association
NEMA
Industry Trade Association
134
Natural Resources Defense Council
NRDC
Energy Efficiency Advocate
114
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 Partnerships
NEEP
Energy Efficiency Advocate
144, 160
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 Association
147
Power Tool Institute, Inc.
PTI
Industry Trade Association
133
Power Tool Institute, Inc., Association of Home Appliance Manufacturers, Consumer Electronics Association
PTI, AHAM, CEA
Industry Trade Association
161
NOPR Public Meeting Transcript, various parties
Pub. Mtg. Tr
Public Meeting
104
Representatives of Various State Legislatures
States
State Government
159
Salcomp Plc
Salcomp Plc
Manufacturer
73
Schneider Electric
Schneider Electric
Manufacturer
119
Schumacher Electric
Schumacher Electric
Manufacturer
143
Southern California Edison
SCE
Utility
164
Telecommunications Industry Association
TIA
Industry Trade Association
127
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 Association
203
Alliance for Wireless Power
ASAP
Energy Efficiency Advocates
196
ASAP, NRDC, ACEEE, CFA, NCLC, NEEA, NPCC Joint Comments
ASAP, NRDC, ACEEE, CFA, NCLC, NEEA, NPCC
Energy Efficiency Advocates
206
Association of Home Appliance Manufacturers
AHAM
Industry Trade Association
202
Brother International Corporation
Brother International
Manufacturer
204
California Energy Commission
California Energy Commission
State Entity
199
California IOUs
CA IOUs
Utilities
197
Consumer Electronics Association
CEA
Industry Trade Association
208
Dual-Lite, a division of Hubbell Lighting
Dual-Lite
Manufacturer
189
Energizer Holdings
Energizer
Manufacturer
213
Garmin International
Garmin
Manufacturer
194
Information Technology Industry Council
ITI
Industry Trade Association
201
Ingersoll Rand (Club Car)
Ingersoll Rand
Manufacturer
195
Jerome Industries, a subsidiary of Astrodyne
Jerome
Manufacturer
191
Mercury Marine
Mercury
Manufacturer
212
National Marine Manufacturers Association
NMMA
Industry Trade Association
190
NEEA and NPCC
NEEA and NPCC
Industry Trade Association
200
P&G (Duracell)
Duracell
Manufacturer
193
Panasonic
Panasonic
Manufacturer
210
Philips
Philips
Manufacturer
198
Power Tool Institute
PTI
Industry Trade Association
207
Schneider Electric
Schneider Electric
Manufacturer
211
Schumacher Electric
Schumacher Electric
Manufacturer
192
Telecommunications Industry Association
TIA
Industry Trade Association
205
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
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(E
batt
) + 5.87
0.1440(E
batt
) + 2.95.
Proposed Standard for PC3
For E
batt
< 9.74 Wh, = 4.68 For E
batt
≥ 9.74 Wh, = 0.0933(E
batt
) + 3.77
For E
batt
< 10Wh, = 1.42; E
batt
≥ 10 Wh, 0.0255(E
batt
) + 1.16.
Proposed Standard for PC4
For E
batt
< 9.71 Wh, = 9.03 For E
batt
≥ 9.71 Wh, = 0.2411(E
batt
) + 6.69
0.11(E
batt
) + 3.18.
Proposed Standard for PC5
For E
batt
< 355.18 Wh, = 20.06 For E
batt
≥ 355.18 Wh, = 0.0219(E
batt
) + 12.28
For E
batt
< 19 Wh, 1.32 kWh/yr; For E
batt
≥ 19 Wh, 0.0257(E
batt
) + .815.
Proposed Standard for PC6
For E
batt
< 239.48 Wh, = 30.37 For E
batt
≥ 239.48 Wh, = 0.0495(E
batt
) + 18.51
For E
batt
< 18 Wh, 3.88 kWh/yr; For E
batt
≥ 18 Wh, 0.0778(E
batt
) + 2.4.
Proposed Standard for PC7
= 0.0502(E
batt
) + 4.53
No Change.
Proposed Standard for PC8
= 0.1140(E
batt
)+ 0.42 For Ebatt < 1.17 Wh, = 0.55 kWh/yr
Removed, covered under PC2 proposed standards.
Proposed Standard for PC9
No Standard
No Change.
Proposed Standard for PC10a
For Ebatt < 37.2 Wh, = 2.54 For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt)—0.18
Deferred to Future Rulemaking.
Proposed Standard for PC10b
For Ebatt < 37.2 Wh, = 6.18 For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt) + 3.45
Deferred to Future Rulemaking.
Changes in Analysis
Engineering Analysis—Representative Units
Combination of test data and manufacturer inputs
Used new or updated units in PC 2, PC 3, PC 4, 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 of application specific usage
PC 2, PC 3, PC 4, PC 5, and PC 6 usage profiles updated based on new shipment data (See Section IV.F.3).
Efficiency Distributions
From Market Assessment
Obtained from the 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
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
Product class
Max-tech
unit energy
consumption
(kWh/yr)
Reduction of
energy
consumption
relative to
the 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
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
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
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
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.
,
inductive charging capabilities),
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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.
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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
Product class No.
Input/output type
Battery energy
(Wh)
Special characteristic or 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
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.
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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).
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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.)
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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
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
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
Product class No.
Input/Output type
Battery energy
(Wh)
Special characteristic or battery voltage
Rep. unit battery voltage
(V)
Rep. unit battery energy
(Wh)
1
AC In, DC Out
<100
Inductive Connection
3.6
1.5
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(E
24
−P
m
(24−t
c
)−E
batt
) + (P
m
(t
a&m
−(t
c
n))) + (P
sb
t
sb
) + (P
off
t
off
))
Where
E
24
= 24-hour energy
E
batt
= Measured battery energy
P
m
= Maintenance mode power
P
sb
= Standby mode power
P
off
= Off mode power
t
c
= Time to completely charge a fully discharged battery
n = Number of charges per day
t
a&m
= Time per day spent in active and maintenance mode
t
sb
= Time per day spent in standby mode
t
off
= 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.
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(E
24
−P
m
(24−t
c
)−E
batt
) = E
Active 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 (E
24
) 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
(P
m
(t
a&m
−(t
c
n))) = E
Maintenance Mode
/day
In the second segment of DOE's equation, shown above, maintenance mode power, time spent in active and maintenance mode per day (t
a&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 t
a&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 (t
a
and t
m
) 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 t
a
and t
m
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, E
24
. 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
(P
sb
t
sb
) = E
Standby 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
(P
off
t
off
) = E
No_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(E
24
−E
batt
) + (P
m
(t
a&m
−(24n))) + (P
sb
t
sb
) + (P
off
t
off
))
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
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, t
cd
, 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, t
cd
, can then be used to approximate the portion of time that a device is assumed to spend in active and maintenance mode per day (t
a&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 (t
cd
− 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 t
a&m
. That difference is an approximation for maintenance mode time per day.
Primary Equation (i)
EP01SE15.000
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 (t
a&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)
EP01SE15.001
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
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
Product class
CSL
approximate to CEC
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
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