Energy Conservation Program: Energy Conservation Standards for Battery Chargers
Federal RegisterJun 13, 2016
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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:
Final rule.
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 would 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. Responding to stakeholder comments, DOE updated its analysis and revised its proposed approach, resulting in a supplemental notice of proposed rulemaking (“SNOPR”) published on September 1, 2015. After considering all the stakeholder comments responding to the SNOPR, DOE is adopting the proposed energy conservation standards for battery chargers in this final rule. DOE has determined that these standards will result in the significant conservation of energy and are technologically feasible and economically justified.
DATES:
The effective date of this rule is August 12, 2016. Compliance with the adopted standards established for battery chargers in this final rule is required starting on June 13, 2018.
ADDRESSES:
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, such as those containing information that is exempt from public disclosure, may not be publicly available.
A link to the docket Web page can be found at:
http://www.regulations.gov/#!docketDetail;D=EERE-2008-BT-STD-0005
. The
www.regulations.gov
Web page will contain instructions on how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov
.
FOR FURTHER INFORMATION CONTACT:
Mr. Jeremy Dommu, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-2J, 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
.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Final Rule
A. 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. Federal Preemption and Compliance Date
D. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
E. Energy Savings
1. Determination of Savings
2. Significance of Savings
F. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
G. General Comments
1. Proposed Standard Levels
IV. Methodology and Discussion
A. Market and Technology Assessment
1. Products Included in This Rulemaking
a. Consumer Products
b. Basic Model of Battery Charger
c. Wireless Power
d. USB-Charged Devices
e. Spare and Replacement Parts for Battery Chargers
f. Medical Products
2. Market Assessment
3. Product Classes
a. Product Class 1
b. Product Classes 5 and 6
c. Product Classes 8, 9, 10a, and 10b
4. Technology Assessment
a. Battery Charger Modes of Operation and Performance Parameters
b. Battery Charger Technology Options
B. Screening Analysis
C. Engineering Analysis
1. Representative Units
2. Battery Charger Efficiency Metric
3. Calculation of Unit Energy Consumption
4. Battery Charger Efficiency Levels
5. Test and Teardowns
6. Manufacturer Interviews
7. Design Options
8. Cost Model
9. Battery Charger Engineering Results
a. Product Class 1
b. Product Class 2
c. Product Class 3
d. Product Class 4
e. Product Class 5 and 6
f. Product Class 7
10. Scaling of Battery Charger Candidate Standard Levels
D. Markups Analysis
E. Energy Use Analysis
F. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
a. Manufacturer Selling Price
b. Markups
c. Sales Tax
d. Product Price Forecast
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Maintenance and Repair Costs
6. Product Lifetime
7. Discount Rates
8. Sectors Analyzed
9. Efficiency Distribution in the No-Standards Case
10. Compliance Date
11. Payback Period Analysis
G. Shipments Analysis
1. Shipment Growth Rate
2. Product Class Lifetime
3. Forecasted Efficiency in the Base Case and Standards Cases
H. National Impact Analysis
1. Product Efficiency 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. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Manufacturer Production Costs
2. Shipment Projections
3. Markup Scenarios
4. Capital and Product Conversion Costs
5. Comments From Interested Parties
a. Manufacturer Interviews
b. TSL to EL Mapping
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Development of Social Cost of Carbon Values
c. Current Approach and Key Assumptions
2. Social Cost of Other Air Pollutants
M. Utility Impact Analysis
N. Employment Impact Analysis
O. Marking Requirements
P. Reporting Requirements
V. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Other Factors
8. Summary of National Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for Battery Charger Standards
2. Summary of Annualized Benefits and Costs of the Adopted Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description of the Need for and Objectives of, the Rule
2. Description of Significant Issues Raised by Public Comment
3. Description of Comments Submitted by the Small Business Administration
4. Description on Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
b. Manufacturer Participants
c. Industry Structure
d. Comparison Between Large and Small Entities
5. Description and Estimate of Compliance Requirements
6. Description of Steps Taken To Minimize Impacts to Small Businesses
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
M. Congressional Notification
VII. Approval of the Office of the Secretary
I. Synopsis of the Final Rule
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 Energy Efficiency Improvement Act of 2015, Public Law 114-11 (April 30, 2015).
Pursuant to EPCA, any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that DOE determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in the 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 (1) a notice of determination that standards for the product do not need to be amended or (2) 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. Consequently, DOE proposed new energy conservation standards for battery chargers in September 2015. See 80 FR 52850. (September 1, 2015). After evaluating the comments it received, DOE is adopting the energy conservation standards for battery chargers proposed in the SNOPR. These standards will apply to all products listed in Table I-1 and manufactured in, or imported into, the United States starting on June 13, 2018. This lead-in period, which is consistent with DOE's proposal, is based on information provided by commenters as well as research conducted by DOE with respect to the efforts made by battery charger manufacturers in response to the CEC energy conservation standards—both of which suggest that a two-year period would be sufficient to enable manufacturers to readily meet the standards adopted in this rule.
Table I-1—Energy Conservation Standards for Battery Chargers
[Compliance starting June 13, 2018]
Product
class
Product class description
Battery energy
Special characteristic or battery voltage
Adopted standard as a function of battery energy
(kWh/yr)
1
Low-Energy
≤5 Wh
Inductive Connection in Wet Environments
3.04
2
Low-Energy, Low-Voltage
<100 Wh
<4 V
0.1440 * E
batt
+ 2.95
3
Low-Energy, Medium-Voltage
4-10 V
For E
batt
<10Wh, UEC = 1.42 kWh/y
E
batt
≥10 Wh, UEC = 0.0255 * E
batt
+ 1.16
4
Low-Energy, High-Voltage
>10 V
0.11 * E
batt
+ 3.18
5
Medium-Energy, Low-Voltage
100-3000 Wh
<20 V
0.0257 * E
batt
+ .815
6
Medium-Energy, High-Voltage
≥20 V
0.0778 * E
batt
+ 2.4
7
High-Energy
>3000 Wh
0.0502 * E
batt
+ 4.53
A. Benefits and Costs to Consumers
Table I-2 presents DOE's evaluation of the economic impacts of the adopted 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 (“PC”) (see section IV.F.6).
3
The average LCC savings are measured relative to the efficiency distribution in the no-standards case, which depicts the market in the compliance year in the absence of standards (see section IV.F.10). The simple PBP, which is designed to compare specific efficiency levels, is measured relative to the baseline model (see section IV.C.1).
Table I-2—Impacts of Adopted Energy Conservation Standards on Consumers of Battery Chargers
Product class
Average LCC
savings
(2013$)
Simple
payback
period
(years)
Average
lifetime
(years)
PC 1—Low E, Inductive
0.71
1.5
5.0
PC 2—Low E, Low Voltage
0.07
0.6
4.0
PC 3—Low E, Medium Voltage
0.08
0.8
4.9
PC 4—Low E, High Voltage
0.11
1.4
3.7
PC 5—Medium E, Low Voltage
0.84
2.7
4.0
PC 6—Medium E, High Voltage
1.89
1.1
9.7
PC 7—High E
51.06
0.0
3.5
DOE's analysis of the impacts of the adopted standards on consumers is described in section IV.F of this document.
B. Impact on Manufacturers
The industry net present value (“INPV”) is the sum of the discounted cash flows to the industry from the reference 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 no-standards case is $79.9 billion in 2013$. Under the adopted standards, DOE expects that manufacturers may lose up to 0.7 percent of this INPV, which is approximately $529 million. Additionally, based on DOE's interviews with the domestic manufacturers of battery chargers, DOE does not expect significant impacts on manufacturing capacity or loss of employment for the industry as a whole to result from the standards for battery chargers.
DOE's analysis of the impacts of the adopted standards on manufacturers is described in section IV.J of this document.
C. National Benefits and Costs
4
4
All monetary values in this section are expressed in 2013 dollars and, where appropriate, are discounted to 2015 unless explicitly stated otherwise. Energy savings in this section refer to the full-fuel-cycle savings (see section IV.H for discussion).
DOE's analyses indicate that the adopted energy conservation standards for battery chargers would save a significant amount of energy. Relative to the case without new standards, the lifetime energy savings for battery chargers purchased in the 30-year period that begins in the anticipated year of compliance with the standards (2018-2047), amount to 0.173 quadrillion British thermal units (“Btu”), or “quads.”
5
This represents a savings of 11.2 percent relative to the energy use of these products in the case without adopted standards (referred to as the “no-standards case”).
5
A quad is equal to 10
15
Btu. The quantity refers to full-fuel-cycle (“FFC”) energy savings. FFC energy savings includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and, thus, presents a more complete picture of the impacts of energy efficiency standards. For more information on the FFC metric, see section IV.H.
The cumulative net present value (“NPV”) of total consumer costs and savings of the standards for battery chargers 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 standards for battery chargers are projected to yield significant environmental benefits. DOE estimates that the standards would result in cumulative greenhouse gas (“GHG”) emission reductions (over the same period as for energy savings) of 10.79 million metric tons (Mt)
6
of carbon dioxide (CO
2
), 6.58 thousand tons of sulfur dioxide (SO
2
), 18.83 thousand tons of nitrogen oxides (NO
X
), 43.6 thousand tons of methane (CH
4
), 0.136 thousand tons of nitrous oxide (N
2
O), and 0.024 tons of mercury (Hg).
7
The cumulative reduction in CO
2
emissions through 2030 amounts to 4.4 Mt, which is equivalent to the emissions resulting from the annual electricity use of approximately 600,000 homes.
6
A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO
2
are presented in short tons.
7
DOE calculated emissions reductions relative to the no-standards-case, which reflects key assumptions in the
Annual Energy Outlook 2015
(
AEO 2015)
Reference case, which generally represents current legislation and environmental regulations for which implementing regulations were available as of October 31, 2014.
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 working group.
8
The derivation of the SCC values is discussed in section IV.L. Using discount rates appropriate for each set of SCC values (see Table I-3), DOE estimates that the net present monetary value of the CO
2
emissions reduction (not including CO
2
-equivalent emissions of other gases with global warming potential) is between $0.086 billion and $1.121 billion, with a value of $0.370 billion using the central SCC case represented by $40.0/t in 2015. DOE also estimates that the net present monetary value of the NO
X
emissions reduction to be $20.84 million at a 7-percent discount rate, and $41.55 million at a 3-percent discount rate.
9
8
United States Government-Interagency Working Group on Social Cost of Carbon. Technical Support Document: Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. May 2013. Revised July 2015. Available at
https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf
.
9
DOE estimated the monetized value of NO
X
emissions reductions associated with electricity savings using benefit per ton estimates from the Regulatory Impact Analysis for the Clean Power Plan Final Rule, published in August 2015 by EPA's
Office of Air Quality Planning and Standards. Available at
www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis
. See section IV.L.2 for further discussion. The U.S. Supreme Court has stayed the rule implementing the Clean Power Plan until the current litigation against it concludes.
Chamber of Commerce, et al.
v.
EPA, et al.
, Order in Pending Case, 136 S.Ct. 999 (2016). However, the benefit-per-ton estimates established in the Regulatory Impact Analysis for the Clean Power Plan are based on scientific studies that remain valid irrespective of the legal status of the Clean Power Plan. DOE is primarily using a national benefit-per-ton estimate for NO
X
emitted from the Electricity Generating Unit sector based on an estimate of premature mortality derived from the ACS study (Krewski et al. 2009). If the benefit-per-ton estimates were based on the Six Cities study (Lepuele et al. 2011), the values would be nearly two-and-a-half times larger.
Table I-3 summarizes the economic benefits and costs expected to result from the adopted standards for battery chargers.
Table I-3—Summary of Economic Benefits and Costs of Adopted Energy Conservation Standards for Battery Chargers (TSL 2) *
Category
Present
value
(billion 2013$)
Discount
rate
(%)
Benefits
Consumer Operating Cost Savings
0.7
7
1.4
3
CO
2
Reduction Monetized Value ($12.2/t case) **
0.1
5
CO
2
Reduction Monetized Value ($40.0/t case) **
0.4
3
CO
2
Reduction Monetized Value ($62.3/t case) **
0.6
2.5
CO
2
Reduction Monetized Value ($117/t case) **
1.1
3
NO
X
Reduction Monetized Value †
0.02
7
0.04
3
Total Benefits ††
1.1
7
1.8
3
Costs
Consumer Incremental Installed Costs
0.1
7
0.2
3
Total Net Benefits
Including Emissions Reduction Monetized Value ††
1.0
7
1.6
3
* This table presents the costs and benefits associated with battery chargers shipped in 2018-2047. These results include benefits to consumers which accrue after 2047 from the products purchased in 2018-2047. The costs account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule.
** The CO
2
values represent global monetized values of the SCC, in 2013$, 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 NO
X
is the average of high and low values found in the literature.
† DOE estimated the monetized value of NO
X
emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule
, published in August 2015 by EPA's Office of Air Quality Planning and Standards. (Available at:
http://www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis
.) See section IV.L.2 for further discussion. DOE is primarily using a national benefit-per-ton estimate for NO
X
emitted from the Electricity Generating Unit sector based on an estimate of premature mortality derived from the ACS study (Krewski
et al.
, 2009). If the benefit-per-ton estimates were based on the Six Cities study (Lepuele
et al.
, 2011), the values would be nearly two-and-a-half times larger.
†† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC with 3-percent discount rate ($40.0/t case).
The benefits and costs of the adopted standards for battery chargers 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.
10
10
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,
11
the SCC values in future years reflect future
CO
2
-emissions impacts that continue beyond 2100.
11
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 adopted standards are shown in Table I-4. 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 that has a value of $40.0/t in 2015, the estimated 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 $1.92 million in reduced NO
X
emissions. In this case, the net benefit amounts to $81 million per year. Using a 3-percent discount rate for all benefits and costs and the SCC series has a value of $40.5/t in 2015, the estimated cost of the 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 $2.25 million in reduced NO
X
emissions. In this case, the net benefit amounts to $88 million per year.
Table I-4—Annualized Benefits and Costs of Standards for Battery Chargers (TSL 2)
Discount rate
Million 2013$/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 ($12.2/t case) **
5
6
6
6.
CO
2
Reduction Monetized Value ($40.0/t case) **
3
20
20
20.
CO
2
Reduction Monetized Value ($62.3/t case) **
2.5
29
29
29.
CO
2
Reduction Monetized Value ($117/t case) **
3
61
61
61.
NO
X
Reduction Monetized Value †
7
1.92
1.92
4.34.
3
2.25
2.25
5.13.
Total Benefits ††
7 plus CO
2
range
76 to 131
76 to 131
80 to 134.
7
90
90
94.
3 plus CO
2
range
82 to 136
82 to 136
83 to 138.
3
97
97
101.
Costs
Consumer Incremental Product Costs
7%
9
9
6.
3
10
10
6.
Net Benefits
Total ††
7% plus CO
2
range
67 to 122
67 to 121
73 to 128.
7
81
81
87.
3 plus CO
2
range
74 to 128
73 to 128
81 to 136.
3
88
87
95.
* This table presents the annualized costs and benefits associated with battery chargers shipped in 2018-2047. These results include benefits to consumers which accrue after 2047 from the products purchased in 2018-2047. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the Annual Energy Outlook for 2015 (“
AEO 2015
”) Reference case, Low Economic Growth case, and High Economic Growth case, respectively. Additionally, the High Benefits Estimates include a price trend on the incremental product costs.
** The CO
2
values represent global monetized values of the SCC, in 2013$ per metric ton (t), 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.
† DOE estimated the monetized value of NO
X
emissions reductions associated with electricity savings using benefit per ton estimates from the
Regulatory Impact Analysis for the Clean Power Plan Final Rule,
published in August 2015 by EPA's Office of Air Quality Planning and Standards. (Available at:
http://www.epa.gov/cleanpowerplan/clean-power-plan-final-rule-regulatory-impact-analysis
.) See section IV.L.2 for further discussion. For the Primary Estimate and Low Net Benefits Estimate, DOE used a national benefit-per-ton estimate for NO
X
emitted from the Electric Generating Unit sector based on an estimate of premature mortality derived from the ACS study (Krewski
et al.
, 2009). For DOE's High Net Benefits Estimate, the benefit-per-ton estimates were based on the Six Cities study (Lepuele
et al.
, 2011), which are nearly two-and-a-half times larger than those from the ACS study.
†† 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 ($40.0/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.
DOE's analysis of the national impacts of the adopted standards is described in sections IV.H, IV.K, and IV.L of this document.
D. Conclusion
Based on the analyses culminating in this final rule, DOE found the benefits to the Nation of the standards (energy savings, consumer LCC savings, positive NPV of consumer benefit, and emission reductions) outweigh the burdens (loss of INPV and LCC increases for some users of these products). DOE has concluded that the standards in this final rule represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in significant conservation of energy.
II. Introduction
The following section briefly discusses the statutory authority underlying this final 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 EPCA established the Energy Conservation Program for Consumer Products Other Than Automobiles,
12
a program covering most major household appliances (collectively referred to as “covered products”). Battery chargers are among the products affected by these provisions.
12
For editorial reasons, upon codification in the U.S. Code, Part B was redesignated as 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 procedures 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 Y.
DOE must follow specific statutory criteria for prescribing new or amended standards for covered products, including battery chargers. 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 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))
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. (42 U.S.C. 6295(o)(2)(B)(iii))
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 an amended or new 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 in 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))
Additionally, EPCA 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) C onsume 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 the Energy Independence and Security Act of 2007 (“EISA 2007”), Public Law 110-140, 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 new standards adopted in this final rule for battery chargers address standby mode and off mode energy use.
Section 135 of the Energy Policy Act of 2005 (“EPACT 2005”), Public Law 109-58 (Aug. 8, 2005), amended sections 321 (42 U.S.C. 6291) and 325 (42 U.S.C. 6295) 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))
B. Background
1. Current Standards
Currently, there are no Federal energy conservation standards for battery chargers.
2. History of Standards Rulemaking for Battery Chargers
On December 8, 2006, consistent with EPACT 2005, DOE published 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 CFR, included a definition and test procedures for battery chargers. The test procedures for these products are 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 EISA 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))
EISA 2007 (section 310) also 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 procedures for battery chargers. 74 FR 13318, 13334-13336 (March 27, 2009). Additionally, DOE amended the test procedures 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, after 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 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 and 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 technical support document (“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 establishing energy conservation standards for battery chargers according to the following classes:
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. All commenters, along with their corresponding abbreviations and organization type, are listed in Table II-2 of this section.
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 battery charger energy efficiency requirement that had been approved 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 took effect on February 1, 2013,
13
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 from 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 the CEC 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.
13
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
A4WP
Standard Development Organization
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 addressed these comments by updating and revising its analysis in the September 2015 SNOPR by considering, among other things, the impacts attributable to the standards issued by the 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 also showed that setting standards that approximated the CEC standards were technologically feasible and economically justified for the U.S. as a whole. Therefore, the SNOPR outlined standards that were approximately equivalent, or where justified, more stringent than the CEC standards. The revisions to the analysis, which addressed 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 its proposal to account for the impact of the CEC standards, DOE made several other changes in preparing these revised standards—including adjusting its analyses in line with updated information and data. These post-NOPR changes are presented in Table II-4.
Table II-4—Summary of Significant Changes Between NOPR and SNOPR
Item
NOPR
Changes for SNOPR
Proposed Standard Levels
Proposed Standard for PC 1
= 3.04
No Change.
Proposed Standard for PC 2
= 0.2095(E
batt
) + 5.87
0.1440(E
batt
) + 2.95.
Proposed Standard for PC 3
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 PC 4
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 PC 5
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 PC 6
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 PC 7
= 0.0502(E
batt
) + 4.53
No Change.
Proposed Standard for PC 8
= 0.1140(E
batt
)+ 0.42 For Ebatt < 1.17 Wh, = 0.55 kWh/yr
Removed, covered under PC 2 proposed standards.
Proposed Standard for PC 9
No Standard
No Change.
Proposed Standard for PC 10a
For Ebatt < 37.2 Wh, = 2.54 For Ebatt ≥ 37.2 Wh, = 0.0733(Ebatt)—0.18
Deferred to Future Rulemaking.
Proposed Standard for PC 10b
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.
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
14
published on July 11, 2014. DOE had planned to include uninterruptible power supplies (“UPSs”) within the scope of coverage of that rulemaking effort and as a result, DOE did not consider these products within the scope of the battery chargers rulemaking. However, since the publication of the SNOPR and Computer and Battery Backup Systems Framework document, DOE, after consideration of stakeholder comments, is now considering including UPSs within the scope of its battery charger regulations. Accordingly, DOE published a Notice of Proposed Test Procedure for Battery Chargers proposing specific testing requirements for UPSs on May 19, 2016. See 81 FR 31542. DOE is not finalizing standards for UPSs at this time, but will continue to conduct rulemaking activities to consider test procedures and energy conservation standards for UPSs as part of ongoing and future battery charger rulemaking proceedings.
14
http://www.regulations.gov/#!documentDetail;D=EERE-2014-BT-STD-0025-0001
.
Lastly, in the September 2015 SNOPR, DOE identified 10 specific issues on which it sought comments and views of interested parties.
Id.
at 52931-52932. DOE also held a public meeting in Washington, DC, on September 15, 2015, to receive public comments on its revised proposal. DOE also received written comments responding to the September 2015 SNOPR, which are further presented and addressed throughout this document. All commenters, along with their corresponding abbreviations and organization type, are listed in Table II-5 of this Preamble.
Table II-5—List of SNOPR Commenters
Organization
Abbreviation
Organization type
Comment
ARRIS Group, Inc. and Cisco Systems, Inc
ARRIS and Cisco
Manufacturer
250
Association of Home Appliance Manufacturers
AHAM
Standard Development Organization
246
California Energy Commission
CEC
State Agency
241
California Investor Owned Utilities
CA IOUs
Utility Association
251
Delta-Q Technologies Corp
Delta-Q Technologies
Manufacturer
238
Environmental Defense Fund, Institute for Policy Integrity at NYU School of Law, Natural Resources Defense Council, Union of Concerned Scientists
EDF, Institute for Policy Integrity, NRDC, UCS
Energy Efficiency Advocacy Group
239
Information Technology Industry Council
ITI
Trade Association
248
Ingersoll Rand
Ingersoll Rand
Manufacturer
240
iRobot Corporation
iRobot
Manufacturer
237
National Electrical Manufacturers Association
NEMA
Trade Association
246
Natural Resources Defense Council, Appliance Standards Awareness Project, Northwest Energy Efficiency Alliance
NRDC, ASAP, NEEA
Energy Efficiency Advocate Group
252
Philips Electronics North America Corporation
Philips
Manufacturer
245
People's Republic of China
P. R. China
Foreign Government
254
Power MergerCo, Inc
Power MergerCo
Standard Development Organization
247
Power Tool Institute, Inc
PTI
Trade Association
244
Schneider Electric
Schneider
Manufacturer
253
SNOPR Public Meeting Transcript, various parties
Pub. Mtg. Tr
Public Meeting
234
U.S. Chamber of Commerce, ACC, ACCCI, AF&PA, AFPM, API, BIA, CIBO, NAM, NMA, NOPA, PCA
U.S. Chamber of Commerce, et al
Trade Association
242
Wahl Clipper Corporation
Wahl Clipper
Manufacturer
243
After considering and responding to all comments submitted by these stakeholders, DOE is adopting the proposed standards for battery chargers from the SNOPR in this final rule. Table II-6 of this Preamble presents major changes between the SNOPR and the final rule.
Table II-6—Summary of Significant Changes Between SNOPR and Final Rule
Item
SNOPR
Changes for final rule
Standard for PC 1
= 3.04
No Change.
Standard for PC 2
0.1440(E
batt
) + 2.95
No Change.
Standard for PC 3
For E
batt
< 10Wh, = 1.42; E
batt
≥ 10 Wh, 0.0255(E
batt
) + 1.16
No Change.
Standard for PC 4
0.11(E
batt
) + 3.18
No Change.
Standard for PC 5
For E
batt
< 19 Wh, 1.32 kWh/yr; For E
batt
≥ 19 Wh, 0.0257(E
batt
) + .815
0.0257(E
batt
) + .815 (Removed Boundary Condition).
Standard for PC 6
For E
batt
< 18 Wh, 3.88 kWh/yr; For E
batt
≥ 18 Wh, 0.0778(E
batt
) + 2.4
0.0778(E
batt
) + 2.4 (Removed Boundary Condition).
Standard for PC 7
= 0.0502(E
batt
) + 4.53
No Change.
Standard for PC 8
Removed, covered under PC 2 proposed standards
No Change.
Standard for PC 9
No Standard
No Change.
Standard for PC 10a
No Standard
No Change.
Standard for PC 10b
No Standard
No Change.
III. General Discussion
DOE developed this final rule after considering verbal and written comments, data, and information from interested parties that represent a variety of interests. The following discussion addresses issues raised by these commenters.
A. Test Procedure
Prior to the publication of the SNOPR regarding energy conservation standards for battery chargers, DOE also published a NOPR proposing to clarify certain aspects related to the battery charger test procedure. These revisions include harmonizing with the instrumentation resolution and uncertainty requirements of the second edition of the International Electrotechnical Commission (“IEC”) 62301 standard for standby power measurements, updates to the battery selection criteria for multi-voltage, multi-capacity battery chargers to eliminate ambiguity, exclusion of back-up battery chargers from scope, a provision for the conditioning of lead acid batteries prior to testing and updates to the requirements for certification and enforcement testing of battery chargers. DOE has since finalized the proposed revisions and has updated the test procedures for battery chargers in Appendix Y to 10 CFR part 430 subpart B. DOE notes that none of the amendments to the battery charger test procedure will have an impact on the standards adopted in this document and advises stakeholders to review them in Appendix Y to 10 CFR part 430 subpart B.
15
15
DOE notes that its procedures found at 10 part CFR 430, subpart C, appendix A provide general procedures, interpretations, and policies to guide DOE in the consideration and promulgation of new or revised efficiency standards under EPCA for consumer products. While these procedures are a general guide to the steps DOE typically follows in promulgating energy conservation standards, appendix A recognizes that DOE can and will, on occasion deviate from the typical process. Accordingly, to the extent that such deviation may occur, such as with the publication timing of the relevant test procedure and standards final rule notices, DOE has concluded that there is no basis to delay the final rule adopting standards for battery chargers.
B. Product Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE often divides covered products into product classes by the type of energy used or by capacity or other performance-related features that justify 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))
C. Federal Preemption and Compliance Date
Since the publication of its SNOPR regarding energy conservation standards for battery chargers, DOE has received several stakeholder comments related to Federal preemption of the CEC's
standards for battery chargers and the compliance date of any new Federal energy conservation standards that DOE may adopt for these products. First, NRDC argued that DOE's adoption of the SNOPR standards as a final rule will preempt CEC's standard for UPSs, which, in its view, will result in a loss of potential energy savings. NRDC specifically requested either the removal of UPSs from covered products under this rulemaking or the adoption of standards proposed in the NOPR for UPSs. NRDC also requested that any final rule issued by DOE clarify the application of Federal preemption in such a way to ensure that UPSs will remain covered under the CEC standards until DOE sets standards for these devices. (NRDC, Pub. Mtg. Tr., No. 234, p. 22-24) Additionally, NEEA inquired if State standards for battery chargers are preempted at the publication of Federal final rule or when the Federal final rule becomes effective. (NEEA, Pub. Mtg. Tr., No. 234, p. 24-25) ITI submitted comments emphasizing the need for clarity in the scope of both the test procedures and energy conservation standards for battery chargers in terms of Federal preemption. (ITI, No. 248, p. 1) Similarly, iRobot recommended that DOE add clarifying language in this rulemaking stating that all battery chargers will be covered regardless of connectivity or use except where explicitly exempted. In iRobot's view, if a category of battery charger is not covered, preemption would not apply and States could then develop their own efficiency standards. (iRobot, No. 237, p. 1) PTI inquired whether Product Class 9 is still subject to Federal preemption even if DOE is proposing a no-standard standard for it. (PTI, Pub. Mtg. Tr., No. 234, p. 19).
DOE notes that under 42 U.S.C. 6295(ii), the preemption of any State or local energy conservation standard that has already been prescribed or enacted for battery chargers prior to DOE's issuance of energy conservation standards for these products shall not apply until the DOE standards take effect. In DOE's view, the standards for these products do not take effect until the compliance date has been reached. Accordingly, the CEC standards, along with any other State or local standards, including for back-up battery chargers and UPSs, prescribed or enacted before publication of this final rule, will not be preempted until the compliance date of Federal energy conservation standards for battery chargers—in this case, 2018. (42 U.S.C. 6295(ii)(1)).
DOE also received stakeholder comments on the compliance date of energy conservation standards for battery chargers. AHAM supported a compliance date of two (2) years after the publication of any final rule establishing energy conservation standards for battery chargers provided that the adopted levels do not exceed EL 1 for PC 1, and EL 2 for PCs 2,3, and 4. If DOE adopts anything more stringent than these levels, AHAM requested that a second SNOPR be issued seeking comments on the newly proposed levels and accompanying compliance date. Lastly, in the absence of an opportunity to comment on levels other than EL 2 for PCs 2, 3, 4 and EL 0 or EL 1 for PC 1, AHAM opposed a compliance date lead-time of only two years but offered no alternative and accompanying rationale for DOE to consider. (AHAM, No. 249, p. 4)
DOE has made an effort to consider candidate standards levels for battery chargers that closely approximate the CEC standards and as a result, for PCs 2 through 6, the standards DOE is adopting for these classes are approximately equivalent to the corresponding CEC standards. DOE's efficiency distribution analysis for the SNOPR also shows that 95 percent of battery chargers sold in the United States already meet the CEC standards. Therefore, for PCs 2 through 6, a vast majority (95 percent) of the battery chargers sold in the United States will already comply with the standards DOE is adopting for these battery charger classes.
For PCs 1 and 7, DOE is adopting standards more stringent than the comparable CEC standards. These more stringent levels were determined to be both technically feasible and economically justified under DOE's detailed analysis. This analysis also indicates that the battery charger industry is characterized by rapid product development lifecycles. These rapid development lifecycles have led DOE to conclude that a two-year lead-time is sufficient to enable manufacturers of battery chargers that do not currently comply with the standards that DOE is adopting in this rule (
i.e.
PCs 1 and 7 and the remaining 5 percent of battery chargers falling under PCs 2 through 6 that do not meet the current CEC standards) to satisfy these new standards by the time the 2018 compliance date is reached.
D. Technological Feasibility
The following sections address the manner in which DOE assessed the technological feasibility of the new standards adopted in this final rule. Energy conservation standards promulgated by DOE must be technologically feasible.
1. General
In each energy conservation 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 considers technologies incorporated in commercially-available products or in working prototypes to be technologically feasible. See,
e.g.
10 CFR part 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, and service; (2) adverse impacts on product utility or availability; and (3) adverse impacts on health or safety. See 10 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 (“EL”). Section I.B of this final rule 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 standards considered in this rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the final rule 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 its September 2015 supplemental proposal, which this rule adopts. At this time, based on the information analyzed and relied on in support of this rulemaking, DOE believes that the standards adopted in this rule will not require the use of any such technologies.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class of covered product, it 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)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficiency for battery chargers by examining a variety of relevant sources of information, including the design parameters used by the most efficient products available on the market, conducting interviews with manufacturers, vetting available manufacturer data with subject matter experts, and obtaining public feedback on DOE's analytical results.
In preparing this final rule, which incorporates into its analysis the 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 had previously not generated 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 final rule TSD.) Table III-1 of this Preamble shows the reduction in energy consumption when increasing efficiency from the no-standards 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 no-standards case
(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 can be found in the discussion of efficiency levels (“ELs”) in Section IV.C.4. Specific details regarding which design options were considered for the max-tech efficiency levels (and all other ELs) can be found in Chapter 5, Section 5.4 of the accompanying final rule TSD, which has been developed as a stand-alone document for this final rule and supports all of the standard levels adopted.
E. Energy Savings
1. Determination of Savings
For each trial standard level (“TSL”), DOE projected energy savings from application of the TSL to battery chargers purchased in the 30-year period that begins in the year of compliance with any adopted standards (2018-2047). The savings are measured over the entire lifetime of products purchased in the 30-year analysis period.
16
DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the no-standards case. The no-standards 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.
16
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 national impact analysis (“NIA”) spreadsheet models to estimate energy savings from potential new standards for battery chargers. The NIA spreadsheet model (described in section I.H of this final rule) calculates 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 the site electricity. 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 and notice of policy amendment, the FFC metric includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of energy conservation standards. 76 FR 51281 (August 18, 2011), as amended at 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 standards for a covered product, DOE must determine that such action would result in significant energy savings. (42 U.S.C. 6295(o)(3)(B)) Although the term “significant” is not defined in the Act, the U.S. Court of Appeals, for the District of Columbia 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 the context of EPCA to be savings that are not “genuinely trivial.” The energy savings for all the TSLs considered in this rulemaking, including the adopted standards, are nontrivial, and, therefore, DOE considers them “significant” within the meaning of section 325 of EPCA.
F. 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 an 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 (
i.e.
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 LCC and PBP (
i.e.
the payback period) 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 LCC impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a national 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 cost (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 discount rates appropriate for consumers. 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.
The PBP is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost (including installation) of a more-efficient product through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost due to a more-stringent standard by the change in annual operating cost for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will purchase the covered products in the first year of compliance with the new standards. The LCC savings for the considered efficiency levels are calculated relative to the case that reflects projected market trends in the absence of new standards. DOE's LCC and PBP analysis is discussed in further detail in section I.F.
c. Energy Savings
Although the significant conservation of energy is a separate statutory requirement for adopting 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 I.H, DOE uses the NIA spreadsheet models 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 adopted in this final rule would not reduce the utility or performance of the products under consideration in this rulemaking. DOE received no comments that these standards would increase battery charger 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 the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from DOE's adoption of a given standard. (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. DOE transmitted a copy of its proposed rule to the Attorney General with a request that the Department of Justice (DOJ) provide its determination on this issue. DOE also provided DOJ with a copy of its supplemental proposal in September 2015. DOE received no adverse comments from DOJ regarding either proposal.
f. Need for National Energy Conservation
In general, 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)) Consistent with this result, the energy savings from the adopted standards are also 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 M.
Additionally, apart from the savings described above, the adopted standards 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 I.K; the emissions impacts are reported in section 6 of this final rule. DOE also estimates the economic value of emissions reductions resulting from the considered TSLs, as discussed in section I.L.
g. Other Factors
In determining whether an energy conservation standard is economically justified, DOE may consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To the extent interested parties submit any relevant information regarding economic justification that does not fit into the other categories described above, DOE could consider such information under “other factors.”
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 (or amended) 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 final rule.
G. General Comments
During the September 15, 2015, public meeting, and in subsequent written comments responding to the SNOPR, stakeholders provided input regarding general issues pertinent to the rulemaking, such as issues regarding the proposed standard levels. These issues are discussed in this section.
1. Proposed Standard Levels
In response to the standard level proposed for product class (“PC”) 1, AHAM suggested that DOE update its analysis by further interviewing manufacturers and conducting more testing. AHAM suggested setting a standard at CSL 0. (AHAM, No. 249, p. 4) Philips did not support DOE's proposed standard for PC 1 and asserted that the standard for inductive chargers in PC 1 should be less stringent than for direct connect chargers in PC 2. (Philips, No. 245, p. 2) DOE notes that its analysis is based on the latest available data, which includes manufacturer interviews, testing, and product tear downs. DOE's analysis shows that the standard levels adopted for each product class are economically justified. PC 1 has only two applications, whereas PC 2 has many applications with a variety of usage profiles. The standard for PC 1 that DOE is adopting in this final rule specifically targets the two analyzed applications of PC 1 to capture maximum energy savings while being technically feasible and economically justified for both applications. The standard for PC 2 that DOE is adopting in this final rule covers numerous applications and captures maximum energy savings while being technically feasible and economically justified for all applications, which have varying levels of fixed energy loss. Stakeholders did not provide DOE with any additional data that could be used to update the analysis.
In response to the standard level proposed for PC 2, the CEC, CA IOUs, NRDC, ASAP, and NEEA urged DOE to consider setting a standard at CSL 2 instead of CSL 1, based on the LCC results for PC 2. (CEC, No. 241, p. 2-3; CA IOUs, No. 251, p. 2-4; NRDC, ASAP, NEEA, No. 252, p. 4-6) In contrast, AHAM, PTI, and ITI supported DOE's proposal of CSL 1 for PC 2. (AHAM, No. 249, p. 2-3; PTI, No. 244, p. 2; ITI, No. 248, p. 5)
In response to the standard levels proposed for PCs 4, 5, and 6, Ingersoll Rand supported DOE's proposed standard levels. (Ingersoll Rand, No. 240, p. 2)
The Department appreciates the stakeholder comments with regard to its proposed standards. In selecting a given standard, DOE must choose the level that achieves the maximum energy savings that is determined to be technologically feasible and economically justified. In making such a determination, DOE must consider, to the extent practicable, the benefits and burdens based on the seven criteria described in EPCA (see 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII)). DOE's weighing of the benefits and burdens based on the final rule analysis and rationale for the standard selection is discussed in section V.
With regard to PC 2 specifically, DOE notes that the SNOPR analysis showed that the distribution of impacts at CSL 2 is such that a small proportion of consumers experience a very positive LCC result, skewing the average to appear nearly as favorable as CSL 1, despite significantly more consumers being negatively impacted. Additionally, the application-specific LCC results for PC 2 show that half of all applications analyzed, including the two applications with the largest shipments (smartphones and mobile phones), have negative average LCC results. At CSL 1, no application in PC 2 has a negative average LCC. Finally, in the SNOPR consumer subgroup analysis, DOE identified the small business subgroup as being negatively impacted by a standard set at CSL 2 for PC 2, whereas no subgroup is negatively impacted by a standard set at CSL 1. For these reasons, DOE determined that CSL 2 for PC 2 was not economically justified in the SNOPR. DOE's analysis and determination have not changed for the final rule. Results are discussed further in section V of this document and in Chapter 11 of the final rule TSD.
IV. Methodology and Discussion
This section addresses the analyses DOE has 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 considered in this document. First, DOE used a spreadsheet that calculates the LCC and PBP of the new energy conservation standards. Second, the NIA uses a second spreadsheet that provides shipments forecasts and calculates national energy savings and net present value of total consumer costs and savings expected to result 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 in the docket for this rulemaking:
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 in the market and technology assessment that provides an overall picture of the market for the products concerned, including the purpose of the products, the industry structure, manufacturers, market characteristics, and technologies used in the products. 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: (1) A determination of the scope of the rulemaking and product classes; (2) manufacturers and industry structure; (3) existing efficiency programs; (4) shipments information; (5) market and industry trends; and (6) technologies or design options that could improve the energy efficiency of battery chargers. See chapter 3 of the final rule TSD for further discussion of the market and technology assessment.
1. Products Included in This Rulemaking
This section addresses the scope of coverage for this final rule and details which products are subject to the standards adopted in this document. The 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 charging the battery. 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 that are only powered from AC mains (or “mains”)—
i.e.
products that plug into a wall outlet. Further, battery chargers 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 setting standards for all battery chargers. The following subsections summarize and address stakeholder comments received on the SNOPR regarding the scope of this rulemaking.
a. Consumer Products
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 of battery chargers are advised to use this definition (in conjunction with the battery charger definition) to determine whether a given device is subject to the battery charger standards adopted in this final rule. Consistent with these definitions, any battery charger that is of a type that is capable of charging batteries for a consumer product is 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 those battery chargers that have identifiable design characteristics that would make them incapable of charging batteries for a consumer product would be considered to not meet EPCA's definition of a battery charger. DOE considers the inability 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 not capable of charging the batteries of a consumer product.
DOE received comments on the SNOPR from Delta Q requesting that DOE follow the CEC's lead in setting energy conservation standards for non-consumer and high-power (above 2 kW input power or with higher input voltages) battery chargers. Delta Q also suggested that DOE explicitly specify that the CEC's standards for non-consumer and high-power battery chargers will not be preempted in case DOE decides not to regulate these battery chargers. (Delta Q, No. 238, p. 2) DOE's authority to establish energy conservation standards for battery chargers comes from Title III, Part B of EPCA, which empowers DOE to establish energy conservation standards for consumer products other than automobiles. As such, DOE does not have the statutory authority to establish energy conservation standards for battery chargers that do not meet the definition prescribed by EPCA. See 42 U.S.C. 6291(1). Furthermore, this final rule does not set, nor does it rely on, minimum or maximum input power restrictions for its scope of covered consumer products. A product that meets the definition of a battery charger as stated in 10 CFR 430.2 (and that charges a product that is consistent with EPCA's consumer product definition) is a covered product under the scope of this rulemaking and subject to Federal preemption in a manner consistent with 42 U.S.C. 6295(ii) and 6297. DOE notes that some of the products that meet these conditions can also be employed in commercial applications and as such, DOE's analysis has taken into consideration the impact of this regulation on commercial entities that are affected by it.
b. Basic Model of Battery Charger
This rule requires manufacturers to certify compliance of the basic models of their battery chargers to the energy conservation standards DOE is adopting. In response to the SNOPR, DOE received comments from AHAM highlighting that the definition of basic model in 10 CFR 430.2 indicates that manufacturers may group into one basic model products having “essentially identical electrical, physical, and functional . . . characteristics that affect . . . energy efficiency”. AHAM requested DOE to expressly indicate in this rulemaking or in the definition of basic model that in determining whether a product has the same electrical or physical characteristics that affect energy efficiency, the battery charging phase is the relevant phase, not the usage phase. (AHAM. No. 249, p. 7)
DOE believes it is sufficiently unambiguous that a basic model as defined in 10 CFR 430.2 applies solely to the covered product, regardless of whether or not that product is embedded in another end-use product. Since the energy conservation standards set forth in this final rule pertains only to battery chargers, it is the charging components that must meet the criteria of a basic model as defined in 10 CFR 430.2.
c. Wireless Power
Although DOE's May 15, 2014 NODA (79 FR 27774) sought input on wireless charging stations that are specifically designed to operate in dry environments, DOE did not explicitly consider these products when first developing the battery charger test procedures. In the battery charger test procedure NOPR, DOE stated that it planned to address wireless chargers designed for dry environments in a separate rulemaking. See 80 FR 46855 (August 6, 2015). DOE received comments on the SNOPR from ITI and Power MergerCo requesting that DOE
promptly issue a determination for wireless charging systems such that, under section 6295(o)(3)(B), establishment of energy conservation standards for wireless charging systems designed to operate in dry environments will not result in significant conservation of energy or that the establishment of such a standard is not technologically feasible or economically justified at this time. (ITI, No. 248, p. 3, Power MergerCo, No. 247, p. 4) Similarly, DOE received comments from iRobot recommending that DOE expressly state that PCs 2 through 7 are specific to galvanic coupled battery chargers. (iRobot, No. 237, p. 1)
DOE reiterates that only battery chargers with inductive connections that are designed to operate in wet conditions are addressed by the standards laid out for PC 1 devices in this final rule. In making this determination, DOE considered the loss of utility and performance likely to result from the promulgation of a standard for a nascent technology such as wireless charging. This approach allows DOE to set standards for the mature technology found in electric toothbrushes while avoiding unintentional restrictions on the development of new inductively-charged products. In response to iRobot's comment, DOE interprets `Non-galvanic coupled' chargers to be wireless battery chargers. As such, wireless battery chargers that do not meet the scope of PC 1 will not be subject to any other standard adopted in this final rule.
d. USB-Charged Devices
DOE received comments on the SNOPR from ITI claiming there are a number of USB-charged devices peripheral to computers, televisions and other consumer products where the burden of testing and certifying the products exceeds any possible energy efficiency benefits. ITI argued these USB-charged devices are not dependent on AC mains input and will have significant margins when compared to battery chargers covered under the regulation with alternating current/direct current (“AC/DC”) power supplies. In its view, regulation of these products at either the federal or state level would not be economically justified. (ITI, No. 248, p. 4)
The peripheral USB-charged devices mentioned by ITI fall both into Product Classes 2 and 8. While PC 8 covers products that require a DC input, these devices can also be operated using an EPS, which reclassifies these products as having an AC input and DC output and essentially also places them into PC 2. As described in the SNOPR, DOE has determined that there are no products falling into PC 8 that do not also fall into PC 2 and that the battery chargers previously analyzed in PC 8 do not technically or functionally differ from those found in PC 2. ITI's claim that these USB-charged devices are not dependent on mains input is true but it does not refute DOE's determination that these devices can be operated using an EPS. Furthermore, DOE's battery charger test procedure requires that all battery chargers be tested using an external power supply, and provides sufficient instructions in section 3.4(c) of Appendix Y to Subpart B of Part 430 in the event the required external power supply is either not packaged with the battery charger or a suitable one is not recommended by the manufacturer. The test procedure indicates that in such an event, the battery charger shall be tested with either 5.0V DC for products drawing power from a computer USB port or the mid-point of the rated input voltage range for all other products. Hence, the peripheral devices in ITI's comment will be tested using an EPS, which makes them comparable to all other battery chargers using an EPS, and subject to the standard adopted for PC 2. Furthermore, DOE's engineering, manufacturer impact and national impact analyses show that the adopted standard for PC 2 is technologically feasible and economically justified.
e. Spare and Replacement Parts for Battery Chargers
ITI asked that DOE provide a 7-year exemption for spare and replacement parts for battery chargers once the final rule is issued. ITI argued that the requested exemption will allow manufacturer compliance with State parts retention laws and avoid premature disposal of functional equipment already in the marketplace. (ITI, No. 248, p. 4) Congress has not provided any exemptions for spare and replacement parts for battery chargers nor has Congress given DOE the authority to do so as it did with EPSs. See EPS Service Parts Act of 2014, Public Law 113-263 (December 18, 2014) (codified in relevant part at 42 U.S.C. 6295(u)(5)). Furthermore, in the case of battery chargers embedded in end-use products, it is not clear which applications would be involved. Therefore, DOE is unable to provide any exemptions for spare and replacement parts for battery chargers.
f. Medical Products
In the SNOPR, DOE decided to refrain from setting standards for medical devices 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)). 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 and stakeholder comments 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 is finalizing its decision of refraining from setting standards for medical device battery chargers that require FDA listing and approval as a life-sustaining or life-supporting device at this time.
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 final rule 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 Table I-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 is not 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 the final rule, 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. The complete shipment analysis can be found in Chapter 9 of the final rule TSD.
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. Product Class 1
DOE has received stakeholder comments on the SNOPR from PTI, OPEI and iRobot expressing concerns regarding the range of PC 1. PTI, OPEI and iRobot noted that all the products evaluated for the establishment of an energy conservation standard for PC 1 fell in the low range of battery energy (0.5Wh to 1.8Wh); yet, the proposed standard based upon the evaluation of these low battery energy products extends to 100Wh, which, in their view, raised questions regarding the proposed standard. These stakeholders expressed further concern that the proposed standard for PC 1 can potentially undermine the development of new inductively-charged products with battery energies greater than those of electric toothbrushes. (PTI and OPEI, No. 244, p. 3, iRobot, No. 237, p. 2)
PC 1 covers battery chargers with low battery energy and inductive charging capability, which is a utility-related characteristic designed to promote safe and clean operation of a battery charger in a wet environment. In a wet environment, these inductive battery chargers ensure that the user is isolated from AC mains by transferring power to the battery through induction rather than conduction. When developing the energy conservation standard for PC 1, DOE considered two applications—electric toothbrushes and water jets. DOE believes that the technology deployed in these two applications are sufficiently mature, such that establishing an energy conservation standard for them would not hinder their further technological development. DOE was not able to identify any other battery charger application specifically designed for wet environments. While DOE primarily found devices in these two applications with battery energies ranging from 0.5 to 1.8 Wh, the CEC database of compliant small battery chargers includes electric toothbrushes with battery energies up to 3.84 Wh. An overall analysis of the electric toothbrush marketplace and existing battery technology leads DOE to believe that the battery energy of electric toothbrushes will not exceed 5 Wh. Therefore, DOE agrees with the stakeholder concern that the proposed range for the PC 1 standard may unintentionally undermine the development of new 1:1 inductively-charged products with battery energies greater than those of electric toothbrushes. To mitigate this risk, DOE is limiting the range of PC 1 to less than and equal to 5 Wh. This approach allows DOE to focus its efforts on setting standards for the mature technology already found in electric toothbrushes and water jets without unintentionally imposing restrictions on the development of new inductively-charged products.
b. Product Classes 5 and 6
DOE received comments during the SNOPR public meeting held on September 15, 2015 as well as written comments from the People's Republic of China seeking to clarify the boundary conditions for the proposed standards for PCs 5 and 6. Specifically, the SNOPR proposed boundary conditions at 19Wh and 18Wh (so that a different unit energy consumption (“UEC”) equation was used for battery chargers above and below the respected boundary condition) for PCs 5 and 6, respectively, while the product classes themselves only cover products having battery energies greater than 100Wh. (Philips Chloride, Pub. Mtg. Tr., No. 234, p. 12-13; P. R. China, No. 254, p. 3)
DOE generated boundary conditions for its conservation standards to fix the UEC requirement below a certain threshold of battery energy and recognized that below these thresholds the fixed components of the UEC equation, such as maintenance mode power, become an increasingly bigger percentage of the device's overall power consumption that may not diminish with decreasing battery energy. Including these boundary conditions allows DOE to account for the fact that even if the battery energy approaches zero, the device will continue to consume a finite amount of non-zero power. Accordingly, these boundary conditions help create better fitting equations and enable DOE to promulgate standards that more accurately reflect the characteristics of a given product class.
For PCs 5 and 6, the derived boundary conditions begin at 19 Wh and 18 Wh respectively. However, in response to the comments received, DOE recognizes that PCs 5 and 6 cover battery chargers with battery energies ranging from 100-3000 Wh and that the boundary conditions at 19 Wh and 18 Wh for these two classes become unnecessary and will never be used. While the presence of these boundary conditions does not affect covered products in PC 5 and 6, DOE realizes that it may lead to misinterpretation and ambiguity. Therefore, DOE is removing these boundary conditions from the final rule.
c. Product Classes 8, 9, 10a, and 10b
Compared to the NOPR, DOE reduced the number of product classes for which it is adopting energy conservation standards in this final rule. Specifically, DOE is not adopting standards for battery chargers falling into PCs 8, 9, 10a, and 10b as initially proposed in its NOPR. DOE chose to reduce the number of affected classes in response to comments on the SNOPR from ITI, Schneider, NRDC, ASAP and NEEA opposing the exclusion of PCs 8, 9 and 10 from the scope of this rulemaking. ITI expressed concern regarding DOE's unknown future plans for regulating products in these classes and about the potential loss of energy savings resulting from the exclusion of PCs 8, 9 and 10. (ITI, No. 248, p. 1) Schneider requested that DOE adopt the energy conservation standards set by the CEC for PCs 10a and 10b, and in particular, a no-standards standard for PC 10b. (Schneider, No. 253, p. 1) Additionally, the CEC, NRDC, ASAP and NEEA
requested DOE to explicitly exclude PCs 10a and 10b from the scope of this rulemaking rather than setting a no-standards standard for these product classes. These stakeholders argued that this approach will prevent confusion regarding coverage of PCs 10a and 10b, and avoid potential backsliding on energy savings from standards set by the CEC. (CEC, No. 241, p. 4-5, NRDC, ASAP, NEEA, No, 252, p. 3-4)
DOE notes that products falling into PC 8 from the NOPR are still covered under the scope of this rulemaking and subject to the standards adopted in this rule. DOE has determined that the battery chargers previously analyzed in PC 8 do not technically differ from those found in PC 2 and that there are no products falling into PC 8 that do not also fall into PC 2. For this reason, DOE has combined all previously analyzed products, and related shipments in PC 8 with PC 2. Consequently, what were previously PC 8 devices are now subject only to the energy conservation standard of PC 2.
Regarding the absence of a standard for PC 9, DOE directs the reader to the March 2012 NOPR LCC results where DOE ran a number of analyses in an attempt to ascertain whether an appropriate efficiency level could be created for PC 9. The engineering and LCC analyses found no efficiency level to exhibit positive LCC savings and DOE has not received any evidence since that time suggesting otherwise. This fact, combined with the minimal UECs found for products in this category indicated that setting a standard for PC 9 at this time would not be economically justifiable under the framework set out by EPCA. As such, DOE has determined that the legal requirements necessary for setting standards for PC 9 could not be met. While products falling into this category are still covered under the scope of this rulemaking and are subject to federal preemption, DOE is not promulgating a standard for chargers that would have fallen into PC 9 at this time.
Lastly, DOE has determined that the current battery charger test procedure does not adequately capture the energy consumption of products in PCs 10a and 10b, which include UPSs. DOE has proposed to amend the test procedure for battery chargers to include a specific test for UPSs to capture their energy consumption. Issued April 29, 2016 UPS TP NOPR. DOE will not establish a standard for Product Class 10a and 10b until a test procedure for these products has been prescribed.
DOE received further comments on the SNOPR from Emerson, ITI, NEMA and Schneider requesting DOE to ensure that direct current UPSs are not unintentionally regulated under PC 7 if UPSs are excluded from the scope of this rulemaking. (Emerson, Pub. Mtg. Tr., No. 234, p. 24; ITI, No. 248, p. 4; NEMA, No. 246 p. 2; Schneider, No. 253, p. 1) Direct current (“DC”) UPSs meet the definition of uninterruptible power supplies proposed in the battery charger test procedure NOPR, which proposed a specific test for UPSs. Under that proposal, the existing testing requirements for battery chargers would apply to battery chargers other than UPSs, and separate testing requirements would apply to UPSs. Issued April 29, 2016 UPS TP NOPR DOE will not establish standards for UPSs until a test procedure for these products has been prescribed.
4. Technology Assessment
In the technology assessment, DOE identifies technology options that appear to be feasible for improving 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 final rule 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.
17
17
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 procedures have 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 procedures. When performing a test in accordance with these procedures, 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, and off-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 the 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 in duration. Next, is maintenance mode power, which is a measurement of the average power consumed while a battery charger is 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).
18
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.)
18
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, 10 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 can decrease battery charger energy consumption in no-battery and maintenance modes (and off mode, if applicable), while those options used to increase EPS conversion efficiency can decrease battery charger 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, describes technology options that DOE evaluated during the NOPR, the SNOPR and again in this final rule. 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.
19
Therefore, in the list below, the options are grouped with the charger type where they would be most practical.
19
The distinction between the two types of battery chargers is based on the charge rate (also referred to as C-rate). DOE considers battery chargers with charge rates less than 0.2C to be slow chargers and anything above that rate to be fast chargers. Please refer to Chapter 3 of the accompanying Technical Support Document for further detail.
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 for traditional 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 final rule TSD.
B. Screening Analysis
DOE uses the following four screening criteria to determine which design options are suitable for further consideration in an energy conservation 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 commercially-available consumer 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.
Impacts on product utility or product availability.
If it is determined that a technology would have significant 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 be considered 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 final rule TSD.
C. Engineering Analysis
In the engineering analysis (detailed in Chapter 5 of the final rule TSD), DOE establishes the 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 no-standards case) 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 EL—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 ELs that set discrete levels of improved battery charger performance in terms of energy consumption. Subsequently, for each EL, DOE used either teardown data or information gained from manufacturer interviews to generate costs corresponding to each EL 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.
The following sections discuss the engineering analysis in detail. Submitted comments regarding the various aspects of the analysis are noted in each section.
1. Representative Units
For each product class, DOE selected a representative unit on 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-1 shows the representative units for each product class that DOE analyzed.
Table IV-1—Battery Charger Representative Units for Each Product Class
Product class #
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
≤10
Inductive Connection
3.6
1.5
2
<100
<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
During the public meeting for the SNOPR, Dell inquired whether DOE looked at multi-voltage, multi-capacity battery chargers when selecting representative units. (Dell, Pub. Mtg. Tr., No. 234, p. 50-51) DOE confirms that in the course of the engineering analysis, several lithium and nickel multi-voltage, multi-capacity battery chargers were tested, torn down and compared against similar single-voltage units. The recently amended battery charger test procedure prescribes that a multi-voltage charger be tested at its highest output power, which is also its most efficient operating point. Issued May 6, 2016. At this level, DOE could not find any appreciable difference in efficiency between the multi-voltage, multi-capacity units versus single-voltage devices operating at similar output powers and employing similar power conversion and charge termination technology. Additional details on the battery charger representative units can be found in Chapter 5 of the accompanying final rule TSD.
2. Battery Charger Efficiency Metric
In the NOPR and SNOPR regarding energy conservation standards for battery chargers, DOE introduced and used the UEC metric to represent the efficiency of battery chargers. AHAM supported the use of UEC as a single metric to represent the energy consumption of battery chargers, (AHAM, No. 249, p. 4-5), but Ingersoll Rand opposed it. In particular, Ingersoll Rand argued that the usage of battery chargers is highly dependent on the target market for a given product and varies across segments, which makes the determination of product efficiency levels, and possibly even class definitions, unnecessarily difficult. Ingersoll Rand recommended that DOE adopt the metrics used by the CEC, as manufacturers are already familiar with the CEC metrics and it would, in its view, be easier to implement and enforce standards based on those metrics. (Ingersoll Rand, No. 240, p. 2-3)
EPCA requires DOE to regulate standby and off modes in 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 user-oriented or protective functions such as facilitating the activation or deactivation of other functions (including active mode) by a remote switch (including remote control), internal sensor, or timer. See 42 U.S.C. 6295(gg)(1)(A)(iii). Maintenance mode, as used in this final rule, meets the statutory definition of standby mode and DOE must incorporate maintenance and off mode into a single metric. The CEC standards for small battery charger systems use two standards for regulation. The first standard collectively regulates the maximum 24-hour charge and maintenance energy and the second standard collectively regulates the maximum maintenance mode and standby mode power. Hence, adopting the CEC approach would be inconsistent with the single metric approach laid out by Congress, as the CEC uses two standards that both separately incorporate maintenance mode.
Further, DOE notes that aggregating the performance parameters of battery chargers into one metric and applying a usage profile will allow manufacturers more flexibility in terms of improving performance during 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, in certain cases, a power tool battery charger may be in standby mode, also referred to as the no-battery mode in this final rule, for longer periods of time during the day than a battery charger used for a cordless house phone, which is likely to spend a significant portion of every day in maintenance mode. Consequently, in light of these differences, consumers would see greater energy savings if power tool battery charger manufacturers improved standby mode efficiency and home phone battery charger manufacturers improved maintenance mode efficiency. Because the UEC metric is indifferent to
how a manufacturer implements changes to improve efficiency, a manufacturer can tailor its battery chargers to better fit the individual conditions that its particular charger is likely to face. For these reasons, DOE is adopting the UEC metric in this final rule to help ensure that manufacturers have sufficient flexibility in improving the energy efficiency performance of their battery chargers.
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. The UEC of a battery charger basic model is calculated using one of the following equations:
Primary Equation
ER13JN16.000
Secondary Equation
For some battery chargers, the equation described above is not appropriate and an alternative calculation is necessary. Specifically, in 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 multiplied by the number of charges per day (n) is greater than the time assumed in active and maintenance mode (t
a&m
), an inconsistency is seen between the measurements for the test product and DOE's usage profile assumptions. To avoid this inconsistency, DOE requires that the following secondary equation be used to calculate UEC for such devices at the threshold:
ER13JN16.001
The threshold criteria to determine when to use the secondary equation itself can be summarized as follows:
ER13JN16.002
In the battery charger NOPR from 2012, DOE calculated and published the threshold Charge Time (t
a&m
/n) for each product class. These values were brought forward unchanged from the NOPR to the September 2015 SNOPR. DOE has since revisited these published numbers and discovered calculation and rounding errors in computing the threshold value (t
a&m
/n). While the final presented values for Threshold Charge Time (t
a&m
/n) were calculated using unrounded numbers, the values for t
a&m
and n were shown in rounded form. This left the reader unable to replicate the final values themselves using the above equation. Therefore, DOE has updated the table to present final values that are properly calculated according to the threshold equation without any rounding errors. For PC 2, there was a typographical error which has also been corrected. The difference between the previously published values and what the values should have been is shown in Table IV-2 below. It is important to note that neither the criteria used nor the values for t
a&m
or n has changed. DOE has corrected the tables in this final rule.
Table IV-2—Threshold Charge Times
Product class
T
a&m
(time spent in active and maintenance mode
n
(number of
full charges
per day)
Incorrectly
calculated
SNOPR
threshold
charge time
(hr)
Correctly
calculated
final rule
threshold
charge time
(hr)
1
20.66
0.15
135.41
137.73
2
7.82
0.54
19.00
14.48
3
6.42
0.1
67.21
64.20
4
16.84
0.5
33.04
33.68
5
6.52
0.11
56.83
59.27
6
17.15
0.34
50.89
50.44
7
8.14
0.32
25.15
25.44
In the battery charger energy conservation standards SNOPR, DOE proposed to add the above mentioned UEC equations and the associated battery charger usage profiles in 10 CFR 430.32(z). See 80 FR 52932. However, as explained in the recent battery charger test procedure final rulemaking, DOE is instead including the above mentioned UEC equations and the associated battery charger usage profiles in the battery charger test procedure codified at appendix Y to subpart B of 10 CFR part 430. Issued May 6, 2016.
4. Battery Charger Efficiency Levels
After selecting its representative units for battery chargers, DOE examined the cost-efficiency relationship of each representative unit to evaluate 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 ELs along that continuum.
ELs are often based on (1) efficiencies already 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.
20
20
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 federal energy conservation standards for battery chargers. Therefore, DOE based the ELs 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. See 71 FR 31750 (June 1, 2011). For each representative unit, DOE then selected ELs 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 no-standards case (EL 0) unit to be the one with the highest calculated unit energy consumption, and the best-in-market (EL 2) to be the one with the lowest. Where possible, the energy consumption of an intermediate model was selected as the basis for EL 1 to provide additional resolution to the analysis.
Unlike the previous three ELs, EL 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 levels 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 EL unit analyzed.
In analyzing potential efficiency levels, DOE examined, among other things, the California standards for small battery chargers,
21
which are based on two metrics—one for 24-hour energy use and one for the combined maintenance mode and standby mode power usage. Using the usage profiles it developed to translate these standards into a UEC value, DOE compared its ELs with the California levels and found that, in most cases, the California standards generally corresponded closely with one of DOE's ELs for each product class when the standards were converted into a UEC value (using DOE's usage profile assumptions). However, once compliance with the CEC standards was required, DOE again analyzed the market and found new technology options that have been widely adopted by battery charger manufacturers to meet the CEC standards. DOE accounted for these results and the changes in technology within the marketplace when developing ELs for each product class. This methodology is outlined in more detail in Chapter 5 of the accompanying TSD.
21
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 car battery charger systems regardless of the output power.” 20 Cal. Code 1602(w) (2014).
Table IV-3 below shows which EL aligns most closely with the California standards for each product class.
Table IV-3—ELs Approximate to California Standards
Product class
EL
approximate to CEC
standard
1 (Low-Energy, Inductive)
EL 0
2 (Low-Energy, Low-Voltage)
EL 1
3 (Low-Energy, Medium-Voltage)
EL 1
4 (Low-Energy, High-Voltage)
EL 1
5 (Medium-Energy, Low-Voltage)
EL 2
6 (Medium-Energy, High-Voltage)
EL 2
7 (High-Energy)
EL 1
With the exception of the max tech level, the ELs presented in the March 2012 NOPR for all product classes were based on commercially-available products and the costs to reach these levels were independently verified by manufacturers and subject matter experts. For the SNOPR and this final rule, DOE attempted to align at least one EL in each product class subject to this final rule as closely as possible to the CEC standards to address comments to the NOPR suggesting that DOE create a new EL that more closely aligns with the CEC levels.
DOE has also received stakeholder comments from PTI and OPEI expressing concern that multi-port battery chargers are not treated any differently than single-port battery chargers under the proposed standard levels, which according to these commenters, creates disincentive for more efficient multi-port battery chargers. PTI and OPEI recommended that DOE provide an allowance of 0.25W per additional port in standby power for multi-port battery chargers. PTI and OPEI further noted that the above requested allowance in standby power for multi-port battery chargers equates to 0.08 kWh/yr increase in the proposed standard levels for PC 4. (PTI and OPEI, No. 244, p. 3) In DOE's engineering analysis, DOE evaluated, tested and performed tear downs on numerous multi-port battery chargers but did not find sufficient reason to treat multi-port battery chargers differently from single-port battery chargers. The adopted standards for these products already accommodate multi-port battery chargers because they scale with the battery energy of the additional batteries that may be charged with multi-port battery chargers. Further, the increase in UEC resulting from the recommended allowance in standby power is minute and will not have a significant impact on the represented value of UEC for multi-port battery chargers. As such, DOE is not adopting the additional allowance suggested by PTI and OPEI.
5. Manufacturer Interviews
The engineering analysis also relies in part on information obtained through interviews with several battery charger manufacturers. These manufacturers consisted of companies that manufacture battery chargers and original equipment manufacturers (“OEMs”) of battery-operated products who package (and sometimes design, manufacture, and package) battery chargers with their end-use products. DOE followed this interview approach to obtain data on the possible efficiencies and resultant costs of consumer battery chargers. Aggregated information from these interviews is provided in Chapter 5 of the final rule TSD. The interviews also provided manufacturer inputs and comments in preparing the manufacturer impact analysis, which is discussed in detail in section IV.J.
DOE attempted to obtain teardown results for all of its product classes, but encountered difficulties in obtaining
useful and accurate teardown results for one of its products classes—namely, PC 1 (
e.g.,
electric toothbrushes). For this product class, DOE relied heavily on information obtained from manufacturer interviews. DOE found that when it attempted to teardown PC 1 devices, most contained potting (
i.e.,
material used to waterproof internal electronics). Removal of the potting also removed the identifying markings that IHS Technology (formerly i-Suppli)—DOE's technical consultant—needed to estimate a cost for the components. As a result, manufacturer interview data helped furnish the necessary information to assist DOE in estimating these costs.
6. Design Options
Design options are technology options that remain viable for use in the engineering analysis after applying the screening criteria as discussed above in section IV.B. DOE notes that all technology options that are not eliminated in the screening analysis (see section IV.B) become design options that are considered in the engineering analysis. Most ELs, except for those related to max-tech units and chargers falling into product classes for which DOE did not tear down units (
i.e.
PC 1 and PC 6), are based on actual teardowns of units manufactured and sold in today's battery charger market. Consequently, DOE did not control which design options were used at each EL. No technology options were preemptively eliminated from use with a particular product class. Similarly, if products are being manufactured and sold using these technology options, that fact indicates that the use of these options is unlikely to cause any significant loss in utility, such as an extremely limited operating temperature range or shortened cycle-life. Accordingly, the available facts indicate that all ELs can be met with technologies that are technologically feasible and that fit the intended application. Details on the technology associated with each EL can be found in Chapter 5 of the accompanying final rule TSD.
For the max-tech designs, which are not commercially-available, DOE developed these levels in part with a focus on maintaining product utility as projected energy efficiency improved. Although some features, such as decreased charge time, were considered as added utilities, DOE did not assign any monetary value to such features. Additionally, DOE did not assume that such features were undesirable, particularly if the incremental improvement in performance causes a significant savings in energy costs. Finally, to the extent possible, DOE considered durability, reliability, and other performance and utility-related features that affect consumer behavior. See final rule TSD, Chapter 5 for additional details.
7. Cost Model
This final rule continues to apply the same approach used in the SNOPR, NOPR and preliminary analysis to generate the MSPs for the engineering analysis. For those product classes other than PC 1, DOE's MSPs rely on the teardown results obtained from IHS Technology. The bills of materials provided by IHS Technology were multiplied by a markup based on product class. For those product classes for which DOE could not estimate MSPs using the IHS Technology teardowns—
i.e.
PC 1—DOE relied on aggregate manufacturer interview data. Additional details regarding the cost model and the markups assumed for each product class are presented in Chapter 5 of the final rule TSD. DOE's cost estimates reflect real world costs and have been updated where necessary for the final rule. The Department did not receive any further stakeholder comments on this aspect of its analysis.
8. Battery Charger Engineering Results
The results of the engineering analysis are reported as cost-efficiency data (or “curves”) in the form of MSP (in dollars) versus unit energy consumption (in kWh/yr). These data form the basis for this final rule's analyses and this section illustrates the results that DOE obtained for all seven product classes in its engineering analysis. The Department did not receive any stakeholder comments on this aspect of its analysis.
a. Product Class 1
No changes were made to the engineering results for PC 1 since the publication of the SNOPR. These results are shown below in Table IV-4. More details on these engineering analysis results can be found in Chapter 5 of the final rule TSD.
Table IV-4—Product Class 1 (Inductive Chargers) Engineering Analysis Results
EL Description
EL 0
Baseline
EL 1
Intermediate
EL 2
Best in market
EL 3
Max tech
24-Hour Energy (Wh)
26.7
19.3
10.8
5.9
Maintenance Mode Power (W)
1.2
0.8
0.4
0.2
No-Battery Mode Power (W)
0.5
0.4
0.2
0.1
Off-Mode Power (W)
0.0
0.0
0.0
0.0
Unit Energy Consumption (kWh/yr)
8.73
6.10
3.04
1.29
MSP [$]
$2.05
$2.30
$2.80
$6.80
b. Product Class 2
No changes were made to the engineering results for PC 2 since the publication of the SNOPR. These results are shown below in Table IV-5. More details on these engineering analysis results can be found in Chapter 5 of the final rule TSD.
Table IV-5—Product Class 2 (Low-Energy, Low-Voltage) Engineering Analysis Results
EL description
EL 0
Baseline
EL 1
Intermediate
EL 2
2nd
intermediate
EL 3
Best in market
EL 4
Max tech
24-Hour Energy (Wh)
25.79
13.6
8.33
8.94
6.90
Maintenance Mode Power (W)
1.1
0.5
0.13
0.1
0.04
No-Battery Mode Power (W)
0.3
0.3
0.03
0.02
0.10
Off-Mode Power (W)
0.0
0.0
0.0
0.0
0.0
Unit Energy Consumption (kWh/yr)
5.33
3.09
1.69
1.58
1.11
MSP [$]
$1.16
$1.20
$1.49
$2.43
$4.31
c. Product Class 3
No changes were made to the engineering results for PC 3 since the publication of the SNOPR. These results are shown below in Table IV-6. More details on these engineering analysis results can be found in Chapter 5 of the final rule TSD.
Table IV-6—Product Class 3 (Low-Energy, Medium-Voltage) Engineering Analysis Results
EL description
EL 0
Baseline
EL 1
Intermediate
EL 2
Best in market
EL 3
Max tech
24-Hour Energy (Wh)
42.60
28.00
17.0
15.9
Maintenance Mode Power (W)
1.70
0.50
0.26
0.26
No-Battery Mode Power (W)
0.30
0.30
0.20
0.20
Off-Mode Power (W)
0.0
0.0
0.0
0.0
Unit Energy Consumption (kWh/yr)
3.65
1.42
0.74
0.70
MSP [$]
$1.12
$1.20
$4.11
$5.51
d. Product Class 4
No changes were made to the engineering results for PC 4 since the publication of the SNOPR. These results are shown below in Table IV-7. More details on these engineering analysis results can be found in Chapter 5 of the final rule TSD.
Table IV-7—Product Class 4 (Low-Energy, High-Voltage) Engineering Analysis Results
EL description
EL 0
Baseline
EL 1
Intermediate
EL 2
Best in market
EL 3
Max tech
24-Hour Energy (Wh)
60.75
44.00
29.30
27.2
Maintenance Mode Power (W)
2.40
0.50
0.50
0.4
No-Battery Mode Power (W)
0.30
0.30
0.50
0.3
Off-Mode Power (W)
0.0
0.0
0.0
0.0
Unit Energy Consumption (kWh/yr)
12.23
5.38
3.63
3.05
MSP [$]
$1.79
$2.60
$5.72
$18.34
e. Product Class 5
No changes were made to the engineering results for PC 5 since the publication of the SNOPR. These results are shown below in Table IV-8. More details on these engineering analysis results can be found in Chapter 5 of the final rule TSD.
Table IV-6—Product Class 5 (Low-Energy, Medium-Voltage) Engineering Analysis Results
EL description
EL 0
Baseline
EL 1
Intermediate
EL 2
Best in market
EL 3
Max tech
24-Hour Energy (Wh)
2036.9
1647.3
1292.00
1025.64
Maintenance Mode Power (W)
21.2
11.9
0.50
0.0
No-Battery Mode Power (W)
20.1
11.6
0.30
0.0
Off-Mode Power (W)
0.0
0.0
0.0
0.0
Unit Energy Consumption (kWh/yr)
84.60
56.09
21.39
9.11
Incremental MSP [$]
$18.48
$21.71
$26.81
$127.00
f. Product Class 6
No changes were made to the engineering results for PC 6 since the publication of the SNOPR. These results are shown below in Table IV-9. More details on these engineering analysis results can be found in Chapter 5 of the final rule TSD.
Table IV-9—Product Class 6 (Medium-Energy, High-Voltage) Engineering Analysis Results
EL description
EL 0
Baseline
EL 1
Intermediate
EL 2
Best in market
EL 3
Max tech
24-Hour Energy (Wh)
891.6
786.1
652.00
466.20
Maintenance Mode Power (W)
10.6
6.0
0.50
0.0
No-Battery Mode Power (W)
10.0
5.8
0.30
0.0
Off-Mode Power (W)
0.0
0.0
0.0
0.0
Unit Energy Consumption (kWh/yr)
120.60
81.72
33.53
8.15
Incremental MSP [$]
$18.48
$21.71
$26.81
$127.00
g. Product Class 7
For PC 7, DOE's SNOPR contained a typographical error that presented the proposed standard for PC 7 as “0.502 * E
Batt
+ 4.53” rather than “0.0502 * E
Batt
+ 4.53.” The SNOPR TSD, along with the earlier NOPR and SNOPR public meeting presentations, all contained the correct standard. DOE's analyses were all based on the correct standard. DOE acknowledges this typographical error and reiterates that the adopted standard for PC 7 is “0.0502 * E
Batt
+ 4.53”. The engineering results for PC 7 are shown below in Table IV-10.
Table IV-10—Product Class 7 (High-Energy) Engineering Analysis Results
EL description
EL 0
Baseline
EL 1
Intermediate
EL 2
Max tech
24-Hour Energy (Wh)
5884.2
5311.1
4860.0
Maintenance Mode Power (W)
10.0
3.3
2.6
No-Battery Mode Power (W)
0.0
1.5
0.0
Off-Mode Power (W)
0.0
0.0
0.0
Unit Energy Consumption (kWh/yr)
255.05
191.74
131.44
Incremental MSP [$]
$88.07
$60.86
$164.14
9. Scaling of Battery Charger Efficiency Levels
In preparing its standards for products within a product class (which would address all battery energies and voltages falling within that class), DOE used a UEC-based scaling approach. After developing the engineering analysis results for the representative units, DOE had to determine a methodology for extending the UEC at each EL to all other ratings not directly analyzed for a given product class. In the NOPR, DOE proposed making UEC a function of battery energy. DOE also indicated that it based this proposed UEC function on the test data that had been obtained up through the NOPR. See 77 FR 18478.
For PCs 2-7, DOE created equations for UEC that scale with battery energy. Specifically, as explained in the recent battery charger test procedure final rulemaking, the maximum allowed UEC for PCs 2-7 scales with the rated battery discharge energy, as determined by the statistical requirements outlined in 10 CFR 429.39(a). See Issued May 6, 2016. In contrast, for PC 1, each EL was represented by one flat, nominal standard. For this product class, DOE found in testing that the UEC did not vary with battery energy or voltage. As a result, while DOE opted to maintain its approach from the NOPR to adopt a constant standard across all battery energies for PC 1, the analysis limited the scope of the product class to battery energies of less than or equal to 5 Wh.
DOE generated boundary conditions for its efficiency levels to make the UEC requirement constant below a certain threshold of battery energy. Including these boundary conditions allows DOE to account for the fact that even if the battery energy approaches zero, the battery charger will continue to consume a finite amount of non-zero power. As explained in section IV.A.3.b, DOE notes that PCs 5 and 6 cover battery chargers with battery energies
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