Energy Conservation Program: Energy Conservation Standards for Battery Chargers

Federal RegisterMar 15, 2023

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DEPARTMENT OF ENERGY

10 CFR Part 430

[EERE-2020-BT-STD-0013]

RIN 1904-AE50

Energy Conservation Program: Energy Conservation Standards for Battery Chargers

AGENCY:

Office of Energy Efficiency and Renewable Energy, Department of Energy.

ACTION:

Notice of proposed rulemaking; announcement of public meeting.

SUMMARY:

The Energy Policy and Conservation Act, as amended (“EPCA”), 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 “Department”) to periodically determine whether more-stringent, standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice of proposed rulemaking (“NOPR”), DOE proposes amended energy conservation standards for battery chargers, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.

DATES:

Meeting:

DOE will hold a public meeting via webinar on Thursday, April 27, 2023, from 1:00 p.m. to 4:00 p.m. See section VII, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants.

Comments:

DOE will accept comments, data, and information regarding this NOPR no later than May 15, 2023.

Comments regarding the likely competitive impact of the proposed standard should be sent to the Department of Justice contact listed in the

ADDRESSES

section on or before April 14, 2023.

ADDRESSES:

Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at

www.regulations.gov,

under docket number EERE-2020-BT-STD-0013. Follow the instructions for submitting comments. Alternatively, interested persons may submit comments, identified by docket number EERE-2020-BT-STD-0013, by any of the following methods:

Email: batterychargers2020STD0013@ee.doe.gov.

Include the docket number EERE-2020-BT-STD-0013 in the subject line of the message.

Postal Mail:

Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, Mailstop EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 287-1445. If possible, please submit all items on a compact disc (“CD”), in which case it is not necessary to include printed copies.

Hand Delivery/Courier:

Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, 950 L'Enfant Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202) 287-1445. If possible, please submit all items on a CD, in which case it is not necessary to include printed copies.

No telefacsimiles (“faxes”) will be accepted. For detailed instructions on submitting comments and additional information on this process, see section VII of this document.

Docket:

The docket for this activity, which includes

Federal Register

notices, 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, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.

The docket web page can be found at

www.regulations.gov/docket/EERE-2020-BT-STD-0013.

The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section VII of this document for information on how to submit comments through

www.regulations.gov.

EPCA requires the Attorney General to provide DOE a written determination of whether the proposed standard is likely to lessen competition. The U.S. Department of Justice Antitrust Division invites input from market participants and other interested persons with views on the likely competitive impact of the proposed standard. Interested persons may contact the Division at

energy.standards@usdoj.gov

on or before the date specified in the

DATES

section. Please indicate in the “Subject” line of your email the title and Docket Number of this proposed rulemaking.

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. Email:

ApplianceStandardsQuestions@ee.doe.gov.

Ms. Melanie Lampton, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (240) 751-5157. Email:

Melanie.Lampton@hq.doe.gov.

For further information on how to submit a comment, review other public comments and the docket, or participate in the public meeting, contact the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:

ApplianceStandardsQuestions@ee.doe.gov.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Synopsis of the Proposed Rule

A. Benefits and Costs to Consumers

B. Impact on Manufacturers

C. National Benefits and Costs

D. Conclusion

II. Introduction

A. Authority

B. Background

1. Current Standards

2. History of Standards Rulemaking for Battery Chargers

3. Deviation From Appendix A

III. General Discussion

A. General Comments

B. Scope of Coverage

C. Test Procedure

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

IV. Methodology and Discussion of Related Comments

A. Market and Technology Assessment

1. Product Classes

2. Technology Options

B. Screening Analysis

1. Screened-Out Technologies

2. Remaining Technologies

C. Engineering Analysis

1. Efficiency Analysis

a. Baseline Energy Use

b. Higher Efficiency Levels

2. Cost Analysis

3. Cost-Efficiency Results

D. Markups Analysis

E. Energy Use Analysis

F. Life-Cycle Cost and Payback Period Analysis

1. Product Cost

2. Annual Energy Consumption

3. Energy Prices

4. Product Lifetime

5. Discount Rates

6. Energy Efficiency Distribution in the No-New-Standards Case

7. Payback Period Analysis

G. Shipments Analysis

H. National Impact Analysis

1. Product Efficiency Trends

2. National Energy Savings

3. Net Present Value Analysis

I. Consumer Subgroup Analysis

J. Manufacturer Impact Analysis

1. Overview

2. Government Regulatory Impact Model and Key Inputs

a. Manufacturer Production Costs

b. Shipments Projections

c. Product and Capital Conversion Costs

d. Markup Scenarios

3. Manufacturer Interviews

K. Emissions Analysis

1. Air Quality Regulations Incorporated in DOE's Analysis

L. Monetizing Emissions Impacts

1. Monetization of Greenhouse Gas Emissions

a. Social Cost of Carbon

b. Social Cost of Methane and Nitrous Oxide

2. Monetization of Other Emissions Impacts

M. Utility Impact Analysis

N. Employment Impact Analysis

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. Direct 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 Economic Impacts

C. Conclusion

1. Benefits and Burdens of TSLs Considered for Battery Chargers Standards

2. Annualized Benefits and Costs of the Proposed Standards

D. Reporting, Certification, and Sampling Plan

VI. Procedural Issues and Regulatory Review

A. Review Under Executive Orders 12866 and 13563

B. Review Under the Regulatory Flexibility Act

1. Description of Reasons Why Action Is Being Considered

2. Objectives of, and Legal Basis for, Rule

3. Description on Estimated Number of Small Entities Regulated

4. Description and Estimate of Compliance Requirements for Small Entities

5. Duplication, Overlap, and Conflict With Other Rules and Regulations

6. Significant Alternatives to the Rule

C. Review Under the Paperwork Reduction Act

D. Review Under the National Environmental Policy Act of 1969

E. Review Under Executive Order 13132

F. Review Under Executive Order 12988

G. Review Under the Unfunded Mandates Reform Act of 1995

H. Review Under the Treasury and General Government Appropriations Act, 1999

I. Review Under Executive Order 12630

J. Review Under the Treasury and General Government Appropriations Act, 2001

K. Review Under Executive Order 13211

L. Information Quality

VII. Public Participation

A. Participation in the Webinar

B. Procedure for Submitting Prepared General Statements for Distribution

C. Conduct of the Webinar

D. Submission of Comments

E. Issues on Which DOE Seeks Comment

VIII. Approval of the Office of the Secretary

I. Synopsis of the Proposed Rule

The Energy Policy and Conservation Act, Public Law 94-163, as amended (“EPCA”),

authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. (42 U.S.C. 6291-6317) Title III, Part B of EPCA established the Energy Conservation Program for Consumer Products Other Than Automobiles. (42 U.S.C. 6291-6309) These products include battery chargers, the subject of this rulemaking.

All references to EPCA in this document refer to the statute as amended through the Energy Act of 2020, Public Law 116-260 (Dec. 27, 2020), which reflect the last statutory amendments that impact Parts A and A-1 of EPCA.

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 a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) EPCA also provides that not later than 6 years after issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a notice of proposed rulemaking including new proposed energy conservation standards (proceeding to a final rule, as appropriate). (42 U.S.C. 6295(m))

In accordance with these and other statutory provisions discussed in this document, DOE proposes new multi-metric energy conservation standards for battery chargers. The proposed standards, which are expressed in max active charge energy and max standby and off modes power values, are shown in Table I.1. These proposed standards, if adopted, would apply to all battery chargers listed in Table I.1 manufactured in, or imported into, the United States starting on the date 2 years after the publication of the final rule for this rulemaking.

Table I.1—Proposed Energy Conservation Standards for Battery Chargers

Product class

Battery energy E

batt

(Wh)

Maximum active mode energy E

(Wh)

Maximum standby mode power P

(W)

Off mode power P

off

(W)

1a Fixed-Location Wireless

≤100

1.718 * Ebatt + 8.5

1.5

1b Open-Placement Wireless

N/A

0.8 (P

only)

2a Low-Energy

≤100

1.222 * Ebatt + 4.980

0.00098 * Ebatt + 0.4

2b Medium-Energy

100-1,000

1.367 * Ebatt + −9.560

2c High-Energy

>1,000

1.323 * Ebatt + 34.361

* Standby mode power is the sum of no-battery mode power and maintenance mode power, unless noted otherwise.

A. Benefits and Costs to Consumers

Table I.2 presents DOE's evaluation of the economic impacts of the proposed standards on consumers of battery chargers, as measured by the average life-cycle cost (“LCC”) savings and the simple payback period (“PBP”).

The average LCC savings are positive or nearly zero for all product classes and the PBP is similar to or less than the average lifetime of battery chargers, which is estimated to range from 3.0 to 10.0 years (see section IV.F of this document).

The average LCC savings refer to consumers that are affected by a standard and are measured relative to the efficiency distribution in the no-new-standards case, which depicts the market in the compliance year in the absence of new or amended standards (see section IV.F.6 of this document). The simple PBP, which is designed to compare specific efficiency levels, is measured relative to the baseline product (see section IV.C of this document).

Table I.2—Impacts of Proposed Energy Conservation Standards on Consumers of Battery Chargers

Battery charger product class

Average LCC savings

(2021$)

Simple payback period

(years)

Fixed-Location Wireless Chargers

−0.03

3.8

Open-Placement Wireless Chargers

0.12

4.1

Low-Energy Wired Chargers

0.13

4.0

Medium-Energy Wired Chargers

1.55

4.4

High-Energy Wired Chargers

14.32

1.5

DOE's analysis of the impacts of the proposed 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 base year through the end of the analysis period (2023-2056). Using a real discount rate of 9.1 percent, DOE estimates that the INPV for manufacturers of battery charger applications in the case without amended standards is $78.9 billion in 2021$. Under the proposed standards, the change in INPV is estimated to range from 4.6 percent to −0.3 percent, which is approximately −$3,659 million to −$214 million. To bring products into compliance with amended standards, it is estimated that the industry would incur total conversion costs of $398.2 million.

DOE's analysis of the impacts of the proposed standards on manufacturers is described in section IV.J of this document. The analytic results of the manufacturer impact analysis (“MIA”) are presented in section V.B.2.

C. National Benefits and Costs

All monetary values in this document are expressed in 2023 dollars.

DOE's analyses indicate that the proposed energy conservation standards for battery chargers would save a significant amount of energy. Relative to the case without amended standards, the lifetime energy savings for battery chargers purchased in the 30-year period that begins in the anticipated year of compliance with the amended standards (2027-2056) amount to 1.2 quadrillion British thermal units (“Btu”), or quads.

This represents a savings of 17.6 percent relative to the energy use of these products in the case without amended standards (referred to as the “no-new-standards case”).

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.1 of this document.

The cumulative net present value (“NPV”) of total consumer benefits of the proposed standards for battery chargers ranges from $3.7 billion (at a 7-percent discount rate) to $7.5 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 2027-2056.

In addition, the proposed standards for battery chargers are projected to yield significant environmental benefits. DOE estimates that the proposed standards would result in cumulative emission reductions (over the same period as for energy savings) of 40 million metric tons (“Mt”)

of carbon dioxide (“CO

”), 272 thousand tons of methane (“CH

”), 0.42 thousand tons of nitrous oxide (“N

O”), 18 thousand tons of sulfur dioxide (“SO

”), 62 thousand tons of nitrogen oxides (“NO

”), and 0.11 tons of mercury (“Hg”).

A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO

are presented in short tons.

DOE calculated emissions reductions relative to the no-new-standards case, which reflects key assumptions in the

Annual Energy Outlook 2022

(“

AEO2022

”).

AEO2022

represents current federal and state legislation and final implementation of regulations as of the time of its preparation. See section IV.K of this document for further discussion of

AEO2022

assumptions that effect air pollutant emissions.

DOE estimates the value of climate benefits from a reduction in greenhouse gases (GHG) using four different estimates of the social cost of CO

(“SC-CO

”), the social cost of methane (“SC-CH

”), and the social cost of nitrous oxide (“SC-N

O”). Together these represent the social cost of GHG (SC-GHG).

DOE used interim SC-GHG values developed by an Interagency Working Group on the Social Cost of Greenhouse Gases (IWG).

The derivation of these values is discussed in section IV.L. of this document. For presentational purposes, the climate benefits associated with the average SC-GHG at a 3-percent discount rate are estimated to be $2.1 billion. DOE does not have a single central SC-GHG point estimate and it emphasizes the importance and value of considering the

benefits calculated using all four sets of SC-GHG estimates.

On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in

Louisiana

Biden,

No. 21-cv-1074-JDC-KK (W.D. La.). As a result of the Fifth Circuit's order, the preliminary injunction is no longer in effect, pending resolution of the federal government's appeal of that injunction or a further court order. Among other things, the preliminary injunction enjoined the defendants in that case from “adopting, employing, treating as binding, or relying upon” the interim estimates of the social cost of greenhouse gases—which were issued by the Interagency Working Group on the Social Cost of Greenhouse Gases on February 26, 2021—to monetize the benefits of reducing greenhouse gas emissions. As reflected in this proposed rule, DOE has reverted to its approach prior to the injunction and presents monetized benefits where appropriate and permissible under law.

See Interagency Working Group on Social Cost of Greenhouse Gases, Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide. Interim Estimates Under Executive Order 13990, Washington, DC, February 2021 (“February 2021 SC-GHG TSD”).

www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf

DOE estimated the monetary health benefits of SO

and NO

emissions reductions using benefit per ton estimates from the scientific literature, as discussed in section IV.L. of this document. DOE estimated the present value of the health benefits would be $1.8 billion using a 7-percent discount rate, and $3.8 billion using a 3-percent discount rate.

DOE is currently only monetizing (for SO

and NO

) PM

2.5

precursor health benefits and (for NO

) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM

2.5

emissions.

DOE estimates the economic value of these emissions reductions resulting from the considered TSLs for the purpose of complying with the requirements of Executive Order 12866.

Table I.3 summarizes the economic benefits and costs expected to result from the proposed standards for battery chargers. There are other important unquantified effects, including certain unquantified climate benefits, unquantified public health benefits from the reduction of toxic air pollutants and other emissions, unquantified energy security benefits, and distributional effects, among others.

Table I.3—Summary of Economic Benefits and Costs of Proposed Energy Conservation Standards for Battery Chargers

[TSL 2]

Billion $2021

3% discount rate

Consumer Operating Cost Savings

9.0

Climate Benefits *

2.1

Health Benefits **

3.8

Total Benefits †

15.0

Consumer Incremental Product Costs

1.4

Net Benefits

13.5

7% discount rate

Consumer Operating Cost Savings

4.6

Climate Benefits * (3% discount rate)

2.1

Health Benefits **

1.8

Total Benefits †

8.6

Consumer Incremental Product Costs

0.9

Net Benefits

7.7

Note:

This table presents the costs and benefits associated with product name shipped in 2027-2056. These results include benefits to consumers which accrue after 2056 from the products shipped in 2027-2056.

* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO

), methane (SC-CH

), and nitrous oxide (SC-N

O) (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate) (see section IV.L of this NOPR). Together these represent the global SC-GHG. For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown, but DOE does not have a single central SC-GHG point estimate. On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in

Louisiana

Biden,

** Health benefits are calculated using benefit-per-ton values for NO

and SO

. DOE is currently only monetizing (for SO

and NO

) PM

2.5

precursor health benefits and (for NO

) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM

2.5

emissions. See section IV.L of this document for more details.

† Total and net benefits include those consumer, climate, and health benefits that can be quantified and monetized. For presentation purposes, total and net benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-percent discount rate, but DOE does not have a single central SC-GHG point estimate. DOE emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG estimates.

The benefits and costs of the proposed standards can also be expressed in terms of annualized values. The monetary values for the total annualized net benefits are (1) the reduced consumer operating costs, minus (2) the increase in product purchase prices and installation costs, plus (3) the value of climate and health benefits of emission reductions, all annualized.

To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 2023, 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.,

2030), and then discounted the present value from each year to 2023. Using the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in the compliance year, that yields the same present value.

The national operating savings are domestic private U.S. consumer monetary savings that occur as a result of purchasing the covered products and are measured for the lifetime of battery chargers shipped in 2027-2056. The benefits associated with reduced emissions achieved as a result of the proposed standards are also calculated based on the lifetime of battery chargers shipped in 2027-2056. Total benefits for both the 3-percent and 7-percent cases are presented using the average GHG social costs with 3-percent discount rate. Estimates of SC-GHG values are presented for all four discount rates in section IV.L of this document.

Using a 7-percent discount rate for consumer benefits and costs and health benefits from reduced NO

and SO

emissions, and the 3-percent discount rate case for climate benefits from

reduced GHG emissions, the estimated cost of the standards proposed in this rule is $89 million per year in increased equipment costs, while the estimated annual benefits are $457 million in reduced equipment operating costs, $120 million in climate benefits, and $178 million in health benefits. In this case. The net benefit would amount to $665 million per year.

Using a 3-percent discount rate for all benefits and costs, the estimated cost of the proposed standards is $81 million per year in increased equipment costs, while the estimated annual benefits are $500 million in reduced operating costs, $120 million in climate benefits, and $215 million in health benefits. In this case, the net benefit would amount to $754 million per year.

Table I.4 presents the total estimated monetized benefits and costs associated with the proposed standard, expressed in terms of annualized values. The results under the primary estimate are as follows.

Using a 7-percent discount rate for consumer benefits and costs and health benefits from reduced NO

and SO

emissions, and the 3-percent discount rate case for climate benefits from reduced GHG emissions, the estimated cost of the standards proposed in this rule is $89 million per year in increased equipment costs, while the estimated annual benefits are $457 million in reduced equipment operating costs, $120 million in climate benefits, and $178 million in health benefits. In this case. The net benefit would amount to $665 million per year.

Table I.4—Annualized Benefits and Costs of Proposed Energy Conservation Standards for Battery Chargers

[TSL 2]

Million 2021$/year

Primary

estimate

Low-net-

benefits

estimate

High-net-

benefits

estimate

3% discount rate

Consumer Operating Cost Savings

500

487

516

Climate Benefits *

120

Health Benefits **

215

Total Benefits †

834

821

850

Consumer Incremental Product Costs

Net Benefits

754

731

779

7% discount rate

Consumer Operating Cost Savings

457

447

469

Climate Benefits * (3% discount rate)

120

Health Benefits **

178

Total Benefits †

754

744

766

Consumer Incremental Product Costs

Net Benefits

665

646

687

Note:

This table presents the costs and benefits associated with battery chargers shipped in 2027-2056. These results include benefits to consumers which accrue after 2056 from the products shipped in 2027-2056. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices from the AEO2022 Reference case, Low Economic Growth case, and High Economic Growth case, respectively. In addition, incremental equipment costs reflect a medium decline rate in the Primary Estimate, a low decline rate in the Low Net Benefits Estimate, and a high decline rate in the High Net Benefits Estimate. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.

* Climate benefits are calculated using four different estimates of the global SC-GHG (see section IV.L of this NOPR). For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown, but the Department does not have a single central SC-GHG point estimate, and it emphasizes the importance and value of considering the benefits calculated using all four sets of SC-GHG estimates. On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in

Louisiana

Biden,

** Health benefits are calculated using benefit-per-ton values for NO

and SO

. DOE is currently only monetizing (for SO

and NO

) PM

2.5

precursor health benefits and (for NO

) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM

2.5

emissions. See section IV.L of this document for more details.

† Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-percent discount rate, but the Department does not have a single central SC-GHG point estimate.

DOE's analysis of the national impacts of the proposed standards is described in sections IV.H, IV.K, and IV.L of this document.

D. Conclusion

DOE has tentatively concluded that the proposed standards represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in the significant conservation of energy. Specifically, with regards to technological feasibility products achieving these standard levels are already commercially available for

all product classes covered by this proposal. As for economic justification, DOE's analysis shows that the benefits of the proposed standard exceed, to a great extent, the burdens of the proposed standards.

Using a 7-percent discount rate for consumer benefits and costs and NO

and SO

reduction benefits, and a 3-percent discount rate case for GHG social costs, the estimated cost of the proposed standards for battery chargers is $89 million per year in increased battery charger costs, while the estimated annual benefits are $457 million in reduced battery charger operating costs, $120 million in climate benefits and $178 million in health benefits. The net benefit amounts to $665 million per year.

The significance of energy savings is evaluated by DOE on a case-by-case basis considering the specific circumstances surrounding a specific rulemaking. The standards are projected to result in estimated national energy savings of 1.2 quad FFC. DOE has initially determined the energy savings that would result from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B). A more detailed discussion of the basis for these tentative conclusions is contained in the remainder of this document and the accompanying TSD.

DOE also considered more-stringent energy efficiency levels as potential standards, and is still considering them in this rulemaking. However, DOE has tentatively concluded that the potential burdens of the more-stringent energy efficiency levels would outweigh the projected benefits.

Based on consideration of the public comments DOE receives in response to this document and related information collected and analyzed during the course of this rulemaking effort, DOE may adopt energy efficiency levels presented in this document that are either higher or lower than the proposed standards, or some combination of level(s) that incorporate the proposed standards in part.

II. Introduction

The following section briefly discusses the statutory authority underlying this proposed rule, as well as some of the relevant historical background related to the establishment of standards for battery chargers.

A. Authority

EPCA authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. Title III, Part B of EPCA established the Energy Conservation Program for Consumer Products Other Than Automobiles. These products include battery chargers, the subject of this document. (42 U.S.C. 6291(32); 42 U.S.C. 6292(a)(20)) EPCA directed DOE to issue a final rule that prescribes energy conservation standards for battery chargers or classes of battery charges or to determine that no energy conservation standard is technically feasible or economically justified. 42 U.S.C. 6295(u)(1)(E)(i)(II) EPCA further provides that, not later than 6 years after the issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a NOPR including new proposed energy conservation standards (proceeding to a final rule, as appropriate). (42 U.S.C. 6295(m)(1))

The energy conservation program under EPCA consists essentially of four parts: (1) testing, (2) labeling, (3) the establishment of Federal energy conservation standards, and (4) certification and enforcement procedures. Relevant provisions of EPCA specifically include definitions (42 U.S.C. 6291), test procedures (42 U.S.C. 6293), labeling provisions (42 U.S.C. 6294), energy conservation standards (42 U.S.C. 6295), and the authority to require information and reports from manufacturers (42 U.S.C. 6296).

Federal energy efficiency requirements for covered products established under EPCA generally supersede State laws and 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 EPCA. (See 42 U.S.C. 6297(d))

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 42 U.S.C. 6295(r)) Manufacturers of covered products must use the prescribed DOE test procedure as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA and when making representations to the public regarding the energy use or efficiency of those products. (42 U.S.C. 6293(c) and 42 U.S.C. 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 and appendix Y1.

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 the Secretary of Energy determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and 42 U.S.C. 6295(o)(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 imposition of the standard;

(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the imposition of the standard;

(4) Any lessening of the utility or the performance of the covered products likely to result from the imposition of 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 imposition of 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 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 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 product that has the same function or intended use, if DOE determines that products within such group: (A) consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-related feature justifies a different standard for a group of products, DOE must consider such factors as the utility to the consumer of the 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))

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 for battery chargers address standby mode and off mode energy use. In this rulemaking, DOE intends to incorporate such energy use into any amended energy conservation standards that it may adopt.

B. Background

1. Current Standards

In a final rule published on June 13, 2016 (“June 2016 Final Rule”), DOE prescribed the current energy conservation standards for battery chargers manufactured on and after June 13, 2018. 81 FR 38266. These standards are set forth in DOE's regulations at 10 CFR 430.32(z) and are summarized in Table II.1.

Table II.1—Current Federal Energy Conservation Standards for Battery Chargers

Product class

Battery charger classification

Maximum unit of energy consumption (UEC) *

(kWh/year)

Low-energy inductive battery chargers to be used in wet environment with associated battery energy of less than or equal to 5 watt-hours (Wh)

3.04.

Low-energy, low-voltage battery chargers with associated battery energy of less than 100Wh, and battery voltage of less than 4 volts (V)

0.1440 * E

batt

+ 2.95.

Low-energy, medium-voltage battery chargers with associated battery energy of less than 100Wh, and battery voltage of 4V to 10V

For E

batt

< 10Wh, 1.42;

For E

batt

≥ 10Wh,

0.0255 * E

batt

+ 1.16.

Low-energy, high-voltage battery chargers with associated battery energy of less than 100Wh, and battery voltage of more than 10V

0.11 * E

batt

+ 3.18.

Medium-energy, low-voltage battery chargers with associated battery energy of 100Wh to 3,000Wh, and battery voltage of less than 20V

0.0257 * E

batt

+ 0.815.

Medium-energy, high-voltage battery chargers with associated battery energy of 100Wh to 3,000Wh, and battery voltage of higher than or equal to 20V

0.0778 * E

batt

+ 2.4.

High-energy battery chargers with associated battery energy of more than 3,000Wh

0.0502 * E

batt

+ 4.53.

* Maximum UEC is expressed as a function of representative battery energy (E

batt

2. History of Standards Rulemaking for Battery Chargers

On September 16, 2020, DOE published notice that it was initiating an early assessment review to determine whether any new or amended standards would satisfy the relevant requirements of EPCA for a new or amended energy conservation standard for battery chargers and a request for information (“RFI”). 85 FR 57787 (“September 2020 Early Assessment Review RFI”). Specifically, through the published notice and request for information, DOE sought data and information that could enable the agency to determine whether DOE should propose a “no new standard” determination because a more stringent standard: (1) would not result in a significant savings of energy; (2) is not technologically feasible; (3) is not economically justified; or (4) any combination of foregoing.

Id.

Subsequently, DOE published a preliminary analysis on March 3, 2022 (“March 2022 Preliminary Analysis”) to respond to comments pertaining to the September 2020 Early Assessment Review RFI, and presented preliminary engineering analyses based on a multi-metric approach that independently measures active mode, standby mode, and off mode energy use metrics. 87 FR 11990. DOE conducted in-depth technical analyses in the following

areas: (1) engineering; (2) markups to determine product price; (3) energy use; (4) LCC” and “PBP”; and (5) national impacts. The preliminary TSD that presents the methodology and results of each of these analyses is available at

https://www.regulations.gov/docket/EERE-2020-BT-STD-0013

DOE received comments in response to the March 2022 Preliminary Analysis from the interested parties listed in Table II.2.

Table II.2—March 2022 Preliminary Analysis Written Comments

Commenter(s)

Abbreviation

Comment number in the docket

Commenter type

UL Solutions

Efficiency Organization.

Northwest Energy Efficiency Alliance

NEEA

Efficiency Organization.

Association of Home Appliance Manufacturers; Consumer Technology Association; Information Technology Industry Council; National Electrical Manufacturers Association; Outdoor Power Equipment Institute; Power Tool Institute

Joint Trade Associations

Trade Association.

Pacific Gas and Electric Company; San Diego Gas & Electric Company; Southern California Edison

CA IOUs

Utility Association.

Appliance Standards Awareness Project; American Council for an Energy-Efficiency Economy; Consumer Federation of America; New York State Energy Research and Development Authority

Joint Efficiency Advocates

Efficiency Organization.

Delta-Q Technologies

Delta-Q

Manufacturer.

A parenthetical reference at the end of a comment quotation or paraphrase provides the location of the item in the public record.

To the extent that interested parties have provided written comments that are substantively consistent with any oral comments provided during the April 2022 public meeting, DOE cites the written comments throughout this document. Any oral comments provided during the webinar that are not substantively addressed by written comments are summarized and cited separately throughout this document.

The parenthetical reference provides a reference for information located in the docket of DOE's rulemaking to develop energy conservation standards for battery chargers. (Docket No. EERE-2020-BT-STD-0013, which is maintained at

www.regulations.gov

). The references are arranged as follows: (commenter name, comment docket ID number, page of that document).

3. Deviation From Appendix A

In accordance with section 3(a) of 10 CFR part 430, subpart C, appendix A (“appendix A”), DOE notes that it is deviating from the provision in appendix A regarding the NOPR stages for an energy conservation standards rulemaking. Section 6(f)(2) of appendix A specifies that the length of the public comment period for a NOPR will not be less than 75 calendar days. For this NOPR, DOE has opted to instead provide a 60-day comment period. DOE requested comment in the March 2022 Preliminary Analysis on the technical and economic analyses and provided stakeholders with a 60-day comment period. 87 FR 11990. DOE has relied on many of the same analytical assumptions and approaches as used in the preliminary assessment and has determined that a 60-day comment period in conjunction with the prior comment periods provides sufficient time for interested parties to review the proposed rule and develop comments.

III. General Discussion

DOE developed this proposal after considering oral 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. General Comments

This section summarizes general comments received from interested parties regarding rulemaking timing and process.

In response to the March 2022 Preliminary Analysis, Joint Trade Associations commented that DOE's process for this rulemaking undermines the value of early stakeholder engagement because: (1) DOE developed the preliminary analysis based on a proposed test procedure rather than a finalized one; and (2) DOE has provided a shortened comment period on the preliminary analysis that overlaps with the comment period for the external power supply (“EPS”) preliminary analysis as well as a preliminary analysis on amended standards for electric motors, both of which impact many of the same manufacturers as the ones for battery chargers. (Joint Trade Associations, No. 17 at pp. 2-3) The Joint Trade Associations further commented that the proposed test procedure has drawn serious concerns from several commenters, and it would be flawed without addressing opposing comments. The Joint Trade Associations also suggested that amended standards would not be justified regardless of whether the standards were analyzed using either the current test procedure or the recently finalized new test procedure in appendix Y1 and that, as a result, DOE should issue a notice of proposed determination not to amend battery charger standards. (Joint Trade Associations, No. 17 at p. 4)

DOE reiterates that the preliminary analysis was intended to provide stakeholders with an opportunity to comment on the various methodologies DOE intended to use in the NOPR. DOE again notes that the preliminary analysis results should not be relied upon to assess whether amended standards for battery chargers are justified. In addition, by conducting the March 2022 Preliminary Analysis with the proposed test procedure, DOE gave stakeholders an early preview of what the new multi-metric standards may potentially look like, allowing stakeholders enough time to review and comment on potential issues with DOE's approach and results. DOE notes that there were concerns and potential test burdens associated with the original proposed test procedure; however, these issues have been addressed in the test procedure final rule published in September 2022 (“September 2022 Test Procedure Final Rule”). 87 FR 55090. As such, unless otherwise noted, test results used in support of this NOPR were measured using the multi-metric test procedure as finalized in the September 2022 Test Procedure Final Rule. DOE further notes that because the finalized test procedure adopts the multi-metric approach, the current integrated UEC standards would

no longer be applicable to test results under the new test procedure. As such, even if DOE were to hold the multi-metric standards at the same level as the current UEC standards, DOE would still need to amend the current standards to translate them to the multi-metric one. DOE understands that the Joint Trade Associations are concerned that amended standards might not be justified, based on results from the preliminary analysis. However, DOE has expanded its analysis further in the NOPR stage and has more robust results that indicate amended standards can result in significant conservation of energy. These results are further discussed in section V of this NOPR document.

With regards to a shortened comment period, DOE believes the 60-day comment period was sufficient for reviewing the methodologies and results presented. However, DOE did not receive any comment period extension requests from any stakeholder during the preliminary analysis comment period.

NEEA stated its general support for several aspects of the preliminary TSD, including the general framework and approach to battery charger efficiency metrics and standards levels, active candidate standard levels (CSLs) that are continuous across product class boundaries, the approach to translate current compliance certification data (CCD) to active mode by subtracting 5 hours of battery maintenance power from the total charge and maintenance energy measurement, and the technology neutral definition of wireless charging. (NEEA, No. 16 at p. 5) DOE appreciates NEEA's general support on these aspects of DOE's battery charger rulemaking.

B. Scope of Coverage

This NOPR covers those consumer products that meet the definition of “battery chargers,” which are devices that charge batteries for consumer products, including battery chargers embedded in other consumer products. 10 CFR 430.2. (

See also

42 U.S.C. 6291(32)) A battery charger may be wholly embedded in another consumer product, partially embedded in another consumer product, or wholly separate from another consumer product. Under appendix Y, only consumer wired chargers and wet environment wireless inductive chargers designed for battery energies of no more than 5 watt-hours are covered battery charger product classes.

In the September 2022 Test Procedure Final Rule, DOE adopted the proposal to expand the battery charger test procedure scope to cover all both fixed-location wireless chargers and open-placement wireless chargers. 87 FR 55090, 55095-55098. DOE also adopted the proposal to establish new multi-metric test procedure for battery chargers. 87 FR 55090, 55100-55108.

DOE notes that in transitioning to the multi-metric approach where each mode of operation is independently regulated, usage profiles are no longer required. Currently established product classes help identify the particular set of usage profiles that must be applied to the UEC equation for a given battery charger model's UEC to be calculated. Without the need for usage profiles, however, the need to maintain currently established product classes is also greatly diminished. In light of this situation, along with the additional wireless battery charger test procedure coverage, DOE is proposing to remove the existing product classes and establish new ones as follows:

Table IV.2—Proposed Battery Charger Product Class Description

Product class No.

Product class description

Rated battery energy

(Ebatt)

Fixed-Location Wireless Battery Chargers

≤100Wh.

Open-Placement Wireless Battery Chargers

All Battery Energies.

Low-energy Wired Battery Charger

0-100Wh.

Medium-energy Wired Battery Charger

100-1000Wh.

High-energy Wired Battery Charger

>1000Wh.

As shown in Table IV.2, wired battery chargers are further divided into three sub-product classes representing chargers with associated battery energies that are either low-energy (0-100Wh), medium-energy (100-1000Wh), or high-energy (>1000Wh) such that equations representing potential standards for each of these sub-classes can be independently adjusted to accommodate the unique characteristics of chargers at each of these ranges and to achieve a desired pass rate. Similarly, wireless chargers are divided into fixed-location wireless charger and open-placement wireless charger because of the expanded test procedure scope.

The Joint Efficiency Advocates stated support for DOE's evaluation of both fixed-location and open-placement wireless chargers in the NOPR stage analysis because of the significant energy savings that could be achieved. The Joint Efficiency Advocates reiterated that wireless chargers are significantly less efficient than wired chargers, as stated from their response to the standards RFI published on September 16, 2020.

(Joint Efficiency Advocates, No. 19 at p. 2)

The Joint Efficiency Advocates' response to the September 2020 RFI can be found at

https://www.regulations.gov/comment/EERE-2020-BT-STD-0013-0005.

The CA IOUs and NEEA both supported DOE's development of standards for wireless chargers. (CA IOUs, No. 18 at pp.2-3; NEEA No. 16 at pp. 3-4) NEEA further commented that considering active mode and standby mode CSLs are appropriate for fixed-location wireless chargers and no battery mode only standards for open-placement wireless chargers are also appropriate at this time. (

Id.

) Both the CA IOUs and NEEA also encouraged DOE to further analyze the standards for wireless chargers with the CA IOUs urging DOE to work with the industry to cover the active mode operation of open-placement wireless chargers as well.

DOE notes that DOE's battery charger standards are developed with the test procedure in mind. Although DOE adopted both active and standby modes test procedure for fixed-location wireless chargers, because of the intrinsic testing repeatability and representativeness issues, DOE did not prescribe an active mode test procedure for open-placement wireless chargers in the September 2022 Test Procedure Final Rule. As a result, DOE is also not considering active mode energy conservation standards for open-placement wireless chargers in this rulemaking.

An engineer from UL commented that a cross-class standard for multi-port and/or multi-voltage battery chargers should be developed because one of the battery charger products that they are testing cannot be classified with the current battery charger product classes, and the compliance certification management system (CCMS) reporting template also does not address such issue. (UL, No. 11 at pp. 1-2)

DOE notes that for multi-port and/or multi-voltage battery chargers, DOE's battery selection criteria in Table 3.2.1 from appendix Y and appendix Y1 clearly notes that all ports and battery or configuration of batteries with the highest individual voltage should be used for testing, and if multiple batteries meet the criteria, then the battery or configuration of batteries with the highest total nameplate charge capacity at the highest individual voltage should be used for testing. As such, the battery charger product class for such multi-port/multi-voltage battery would be based on the highest individual battery voltage, and the highest total battery charge capacity.

The CA IOUs stated that DOE should reconsider its decision not to include DC fast chargers (DCFCs) used to charge light-duty EVs and PHEVs in DOE's battery charger standards. The CA IOUs stated that the original decision to not regulate these products under battery charger rulemaking scope was because DOE stated that it lacks the authority to regulate automobiles as consumer products. However, the CA IOUs considered that DCFCs fall within the definition of covered products in that “a battery charger must charge batteries for consumer products,” and that such DCFCs are consumer products used to charge other consumer products. The CA IOUs further commented that when EPCA passed in 1975, it could not have foreseen how excluding automobiles from consumer products could bar DOE from regulating DCFCs. Therefore, the CA IOUs recommended DOE to reconsider if DCFCs should fall within the scope of DOE's standards. (CA IOUs, No. 18 at pp. 3-5)

DOE reiterates that DOE's authority to regulate battery chargers is limited to battery chargers that charge batteries for consumer products. (42 U.S.C. 6291(32)) As defined by EPCA, “consumer products” explicitly excludes automobiles as that term is defined in 49 U.S.C. 32901(a)(3). (42 U.S.C 6291(1)) DOE has limited information on whether DCFCs are used to charge any consumer products other than automobiles. As such, DOE is not proposing standards for DCFCs at this time. However, considering the current trend towards electrification in many industries, DOE is interested in whether DCFCs are used to charge other consumer products, including electric vehicles other than automobiles, such as electric motorcycles.

2. Technology Options

For technology assessment, DOE identifies technology options that appear to be a feasible means of 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 salient aspects of the technology assessment, including issues on which DOE seeks public comment. Chapter 3 of the NOPR TSD provides detailed 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. These technology options are also listed in the table as follows:

Table IV.3—Battery Charger Design Options

Technology option

Description

Slow Charger:

Improved Cores

Use transformer cores with low losses.

Termination

Limit power provided to fully-charged batteries.

Elimination/Limitation of Maintenance Current

Limit power provided to fully-charged batteries.

Elimination of No-Battery Current

Limit power provided drawn when no battery is present.

Switched-Mode Power Supply

Use switched-mode power supplies instead of linear power supplies.

Fast Charger:

Low-Power Integrated Circuits

Use integrated circuit controllers with minimal power consumption.

Elimination/Limitation of Maintenance Current

Limit power provided to fully-charged batteries.

Schottky Diodes and Synchronous Rectification

Use rectifiers with low losses.

Elimination of No-Battery Current

Limit power provided drawn when no battery is present.

Phase Control to Limit Input Power

Limit input power in lower-power modes.

Wide-Band Gap Semiconductors

Use semiconductors such as Gallium Nitride and Silicon Carbide to achieve higher charging efficiency.

B. Screening Analysis

DOE uses the following five screening criteria to determine which technology options are suitable for further consideration in an energy conservation standards rulemaking:

(1)

Technological feasibility.

Technologies that are not incorporated in commercial products or in commercially viable, existing prototypes will not be considered further.

(2)

Practicability to manufacture, install, and service.

If it is determined that mass production of a technology in commercial products and reliable installation and servicing of the technology could not be achieved on the scale necessary to serve the relevant market at the time of the projected compliance date of the standard, then that technology will not be considered further.

(3)

Impacts on product utility.

If a technology is determined to have a significant adverse impact on the utility of the product to subgroups of consumers, or 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)

Safety of technologies.

If it is determined that a technology would have significant adverse impacts on health or safety, it will not be considered further.

(5)

Unique-pathway proprietary technologies.

If a technology has proprietary protection and represents a unique pathway to achieving a given efficiency level, it will not be considered further, due to the potential for monopolistic concerns.

10 CFR part 430, subpart C, appendix A, sections 6(b)(3) and 7(b).

In summary, if DOE determines that a technology, or a combination of technologies, fails to meet one or more of the listed five criteria, it will be excluded from further consideration in the engineering analysis. The reasons for eliminating any technology are discussed in the following sections.

The subsequent sections include comments from interested parties pertinent to the screening criteria, DOE's evaluation of each technology option against the screening analysis criteria, and whether DOE determined that a technology option should be excluded (“screened out”) based on the screening criteria.

1. Screened-Out Technologies

Battery charger manufacturers often use various combinations of the DOE identified technology option, and because these options are relatively common with little barrier to implement, DOE did not screen out any technology option. DOE did not receive comments on its screening analysis.

2. Remaining Technologies

DOE tentatively concludes that all of the identified technologies listed in section IV.A.2 met all five screening criteria to be examined further as design options in DOE's NOPR analysis. In summary, DOE did not screen out the following technology options:

Table IV.4—Remaining Battery Charger Design Options

Technology Option

Description

Slow Charger

Improved Cores

Use transformer cores with low losses.

Termination

Limit power provided to fully-charged batteries.

Elimination/Limitation of Maintenance Current

Limit power provided to fully-charged batteries.

Elimination of No-Battery Current

Limit power provided drawn when no battery is present.

Switched-Mode Power Supply

Use switched-mode power supplies instead of linear power supplies.

Fast Charger

Low-Power Integrated Circuits

Use integrated circuit controllers with minimal power consumption.

Elimination/Limitation of Maintenance Current

Limit power provided to fully-charged batteries.

Schottky Diodes and Synchronous Rectification

Use rectifiers with low losses.

Elimination of No-Battery Current

Limit power provided drawn when no battery is present.

Phase Control to Limit Input Power

Limit input power in lower-power modes.

Wide-Band Gap Semiconductors

Use semiconductors such as Gallium Nitride and Silicon Carbide to achieve higher charging efficiency.

DOE has initially determined that these technology options are technologically feasible because they are being used in commercially-available products or working prototypes. DOE also finds that all of the remaining technology options meet the other screening criteria (

i.e.,

practicable to manufacture, install, and service and do not result in adverse impacts on consumer utility, product availability, health, or safety, unique-pathway proprietary technologies). While DOE does not anticipate any material impact on fit, function, and utility of the battery chargers, we request comment on potential impacts from the proposed standard. For additional details on the analysis, see chapter 4 of the NOPR TSD.

C. Engineering Analysis

The purpose of the engineering analysis is to establish the relationship between the efficiency and cost of battery chargers. There are two elements to consider in the engineering analysis: the selection of efficiency levels to analyze (

i.e.,

the “efficiency analysis”) and the determination of product cost at each efficiency level (

i.e.,

the “cost analysis”). In determining the performance of higher-efficiency products, DOE considers technologies and design option combinations not eliminated by the screening analysis.

For each product class, DOE estimates the baseline cost, as well as the incremental cost for the product at efficiency levels above the baseline. The output of the engineering analysis is a set of cost-efficiency “curves” that are used in downstream analyses (

i.e.,

the LCC and PBP analyses and the NIA).

1. Efficiency Analysis

DOE typically uses one of two approaches to develop energy efficiency levels for the engineering analysis: (1) relying on observed efficiency levels in the market (

i.e.,

the efficiency-level approach), or (2) determining the incremental efficiency improvements associated with incorporating specific design options to a baseline model (

i.e.,

the design-option approach). Using the efficiency-level approach, the efficiency levels established for the analysis are determined based on the market distribution of existing products (in other words, based on the range of efficiencies and efficiency level “clusters” that already exist on the market). Using the design option approach, the efficiency levels established for the analysis are determined through detailed engineering calculations and/or computer simulations of the efficiency improvements from implementing specific design options that have been identified in the technology assessment. DOE may also rely on a combination of these two approaches. For example, the efficiency-level approach (based on actual products on the market) may be extended using the design option approach to “gap fill” levels (to bridge large gaps between other identified efficiency levels) and/or to extrapolate to the max-tech level (particularly in cases where the max-tech level exceeds the maximum efficiency level currently available on the market).

To analyze the battery charger efficiency levels under the new multi-metric approach, DOE established efficiency levels for active charge energy and standby power separately. For off mode power consumption, DOE notes that for chargers that offer an off mode, the power draw is usually negligible; therefore, DOE estimated the off mode power to be zero across all efficiency levels and did not analyze the off mode performance for battery chargers in this NOPR.

In developing CSLs, DOE used data available in the CCD as a representation of the wired battery charger market. The CCD currently provides values for metrics based on the DOE test procedure at 10 CFR, part 430, subpart B, appendix Y, which includes UEC, 24-hour charge and maintenance mode energy (“E

”), maintenance mode power (“P

”), standby mode power (“P

”), and off mode power (“P

off

”). However, in order to develop CSLs for wired chargers in consideration of the metrics in the newly adopted appendix Y1, DOE needed to further disaggregate the current E

rated value to estimate the active charge energy (“E

”) component. DOE achieved this by subtracting maintenance mode energy, which equals the time in hours spent in maintenance mode multiplied by P

, from E

. However, the time spent in maintenance mode for each battery charger basic model can vary significantly depending on intended application, and DOE does not have sufficient information to derive these times on a case-by-case basis. As such, for this NOPR, DOE continues to estimate that every charger spends five hours in maintenance mode out of the 24-hour charge and maintenance mode test period, as determined by section 3.3.2 of the current test procedure. As a result, DOE calculated E

as E

minus five hours times P

. DOE used the resultant data to define CSLs. DOE also slightly adjusted the intercept of the resultant CSL equation for each analyzed battery energy group as necessary so that each CSL would be a continuous function across battery energy groups.

For fixed-location wireless battery chargers, DOE also relied on the CCD data to estimate the relationship between the CCD derived E

and CCD reported E

batt

for their active mode CSLs. However, for the standby mode power (the sum of maintenance mode power and no-battery mode power), or P

, because the newly covered fixed-location wireless chargers can have higher maintenance mode power consumption because of different inductive power transmitting standards, DOE developed the standby power CSLs based on its own testing data. The multi-metric CSL results for fixed-location wireless chargers are further discussed in sections IV.C.1.a and IV.C.1.b below.

For open-placement wireless battery chargers, similarly, because these are chargers covered under the expanded scope, DOE relied on its own testing data to develop the no-battery mode only CSLs for these chargers, with further discussion in sections IV.C.1.a and IV.C.1.b below.

The Joint Efficiency Advocates commented that DOE could consider uncoupling active mode and standby mode efficiency levels rather than increasing both active mode and standby mode efficiency together at each CSL so that alternate combinations could be analyzed to explore the potential for additional cost-effective savings. (Joint Efficiency Advocates, No. 19 at p. 2)

DOE notes that the electronics related to these modes of operations are typically highly integrated and in performing teardowns, DOE was unable to accurately establish technology options and cost that would solely improve the energy performance in one mode of operation without affecting another. While not universal, DOE noticed from its teardowns that battery charger designs with improved efficiency in one more of operation will typically also be more efficient in other modes. Lacking accurate cost information associated with improving the performance in each mode of operation separately, DOE chose not to decouple active mode and standby mode efficiency levels for wired and fixed-location wireless battery chargers in this NOPR. In taking this approach, DOE however ensured that teardown units representing successive efficiency levels (“ELs”) achieved both the required active mode as well as standby performance for that EL. This ensures that the teardown cost of representative units accurately capture the cost of attaining both the active mode and standby performance required by each EL. The results of these TSLs are also further discussed in chapter 5 of the TSD.

The CA IOUs also supported DOE in updating the standards for battery chargers and expand the engineering analysis to higher-capacity battery chargers because of advances in technology and the increasing availability of higher-powered lithium-ion battery consumer devices on the market. (CA IOUs, No. 18 at pp. 1-2) The CA IOUs recommended DOE to reevaluate the bins for battery chargers as proposed in the preliminary analysis because the CSLs allow higher active mode energy for battery chargers with higher battery capacities within a product class. The CA IOUs recommended DOE to develop more granular battery capacity bins or redesign the standard algorithms to flatten the curve of allowable maximum active mode energy, making CSLs equally stringent across battery chargers of all battery capacities. (CA IOUs, No. 18 at p. 5)

DOE notes that DOE's active mode charge energy measures the raw energy input into the battery charger; therefore, as battery energy increases within each product class, the corresponding raw active energy would increase as well. As such, “flattening” the active charge energy curve within each product class

would increase relative stringency for those battery chargers designed to charge higher-energy batteries from the same product class.

The Joint Trade Associations stated that several joint commenters opposed DOE's test procedure proposal to rely on separate metrics, and urged retention of the UEC metric in response to the test procedure NOPR published in November 2021. The commenters also opposed DOE's proposed approach for determining active, standby, and battery maintenance mode energy, as well as DOE's proposal to specify that, for chargers not shipped with adapters and where one is not recommended, the test can be done with any EPS that is minimally compliant with DOE's energy conservation standards. (Joint Trade Associations, No. 17 at pp. 3-4)

DOE notes that these comments pertain to the test procedure rulemaking, and DOE has already addressed these stakeholder concerns in the September 2022 Test Procedure Final Rule by adopting the alternate method for measuring the active mode energy consumption of a battery charger, ensuring that the test method for the new multiple metrics remain largely the same as that of DOE's previous test procedure for the UEC metric. 87 FR 55090, 55100-55108. DOE also notes that it adopted the additional requirement to test battery chargers with an EPS because it ensures test procedure representativeness and test result comparability. 87 FR 55090, 55098-55099.

Delta-Q commented that DOE's efficiency level analysis of product class 2c contains incorrect assumptions, because the test procedure measures the energy consumption of the battery charge system as a whole, which fails to take into account energy losses in the battery itself and these losses vary depending on battery type and battery chemistry. Attempting to reduce the amount of charge delivered, particularly for lead acid batteries, would result in precipitous reductions in battery life. (Delta-Q, No. 20 at p. 1) Delta-Q provided an example that for a golf cart with a flooded lead acid battery of 80% round-trip efficiency, a charger around 90% efficiency, and a total system efficiency that meets the current DOE standard of around 70% total efficiency; however, DOE's proposed CSL for product class 2c would require battery charge system efficiency to be substantially increased. In the extreme case of CSL 3, lead-acid batteries would be effectively banned because they cannot meet the standard, even though lead-acid batteries dominate some parts of the market. Delta-Q further noted that the cost to replace these batteries can be ten to fifteen times the charger cost, with the total system replacement cost increasing in hundreds of dollars. (Delta-Q, No. 20 at p. 2) As such, Delta-Q commented that DOE's proposed CSL efficiencies appear to be flawed because product class 2c contains products with a variety of battery chemistries and system efficiencies, and while most lithium ion batteries would have system efficiencies passing at CSL 2, flooded lead-acid batteries would struggle to pass CSL 1; in effect, 100% of lead-acid battery charge systems would fail. (

Id.

)

DOE notes that the battery charger test procedure was designed to measure the overall system efficiency. As a result, the energy losses in the batteries would also be accounted for as wasted energy or “non-useful energy”. DOE understands that for some manufacturers, they do not have direct control over the type of battery consumers use with their chargers; however, for each battery charger product class and each comparable battery energy range, these chargers would still be regulated along with other similar types of chargers with comparable battery characteristics. DOE's standards have been, and will be, developed based on the representative units from a variety of end use product types and battery energy ranges. As such, DOE's battery charger standards do account for the battery energy losses and do not negatively impact battery charger manufacturers. DOE further notes that CSL 0 for active mode and standby mode were developed to be an approximate translation of the current DOE battery charger UEC standard, with higher CSLs developed based on CCD reported battery charger performance trends and/or DOE's own testing results. Currently presented CSLs are only for standards development process; any standard DOE decides to adopt later in the final rule stage will be verified to be cost effective while having meaningful energy savings without undue burden. To account for Delta-Q's concern, DOE has slightly relaxed high-energy chargers' higher CSL levels in this NOPR, and from DOE's internal testing and modeling, DOE was able to confirm that even CSL 3 was attainable by some lead-acid battery chargers.

Delta-Q commented that the present single, unified metric of UEC would provide more flexibility in reducing overall energy consumption while still delivering on customer features and cost targets, and that separate standards for separate metrics will reduce design flexibility and raise the cost of compliance. (Delta-Q, No. 20 at p. 2) Delta-Q further commented that the proposed baseline standby mode power requirements are already restrictive, resulting in targets that are very challenging to meet, which can limit the maximum charge speed or the minimum battery size. This is particularly challenging for generic and standalone battery chargers such as those manufactured by Delta-Q and used by many OEMs. (Delta-Q, No. 20 at pp. 2-3) Delta-Q commented that standby mode power provides a variety of customer-required functions, such as status display, signal communication, or maintain state of charge, and therefore does not necessarily represent wasted energy. Delta-Q further stated that if efficiency regulations precluded drawing from AC mains in maintenance mode power, battery chargers would require power draw from the DC battery, reducing battery readiness and runtime. (

Id.

)

DOE recognizes that the current UEC metric may provide design flexibility for manufacturers; however, it risks being increasingly unrepresentative without frequent and continuous updates to the usage profiles. If DOE were to constantly update the usage profiles, manufacturers would also need to repeatedly recalculate the representative UEC and recertify their products, which would add undue burden for manufacturers. Although DOE's adopted multi-metric testing approach does not provide the same level of freedom for battery charger design in all modes of operation when compared to the current integrated UEC approach, it would still provide design flexibility in standby mode operation by allowing manufacturers to prioritize either maintenance power or no-battery power, which accounts for the majority of battery charger operation time. DOE reiterates that the CSLs presented in the preliminary analysis were only for DOE to present the general approach for developing the standards, and for stakeholders to get an early chance at contributing to DOE's standards rulemaking process. As such, the CSLs presented in the preliminary analysis are not final results. Any standard adopted by DOE in the final rule must be economically justifiable and technologically feasible, and will be required to demonstrate that they are verified to be cost effective while having meaningful energy savings without undue burden. In response to Delta-Q's comment that the baseline standard levels presented in the preliminary analysis are already restrictive, DOE notes that these were either translated from the current UEC standard, or developed from DOE's own testing data

representing some of the most energy consumptive products in the market; demonstrating that the technology required to achieve the currently prescribed standards at the baseline level are readily available and not restrictive.

a. Baseline Energy Use

For each product class, DOE generally selects a baseline model as a reference point for each class, and measures changes resulting from potential energy conservation standards against the baseline. The baseline model in each product class represents the characteristics of a product typical of that class (

e.g.,

capacity, physical size). Generally, a baseline model is one that just meets current energy conservation standards, or, if no standards are in place, the baseline is typically the most common or least efficient unit on the market.

Consistent with the baseline efficiency levels analyzed from the preliminary analysis, for this NOPR, DOE's baseline multi-metric efficiency levels for wired battery chargers are approximated from the current UEC standards along with reference to the original California Energy Commission's (“CEC”) battery charger multi-metric standard. Because the current UEC standard was adopted based on approximated CEC standards for most of the original product classes except product classes 5 and 6, which were more efficient than CEC's, DOE's current standard can be approximately “translated” back to the CEC's standard, especially on the lower end of the battery energy spectrum (for battery chargers with battery energy less than 100Wh). DOE further assumed that most chargers on the CCD are only single port chargers and applied the CEC active charge energy standard to the current CCD battery energy levels to get the maximum charge and maintenance energy, and then subtracted five hours of maintenance mode power to approximate the active charge energy for every single wired battery charger entry. DOE did not receive any opposing comments to this approach.

DOE further notes that the September 2022 Test Procedure Final Rule adopted the requirement that for all battery chargers that would need an external power supply for operation, they would need to be tested with a minimally compliant EPS. 87 FR 55090, 55098-55099. DOE anticipated that a proposed standard would also be affected by this change. As such, DOE analyzed the CCD reported battery charger basic models and manually removed entries with negligible power draw in no-battery mode so that the remaining entries would likely be tested with an EPS or with input power measured directly at the wall. Although this may unintentionally remove some entries with very efficient no-battery mode design, it would ensure that all the remaining models are indeed tested with an appropriate power supply or have the conversion losses captured. DOE then applied a linear regression to the remaining CCD entries to establish a relationship between battery energy and the approximated CEC standard described in the previous paragraph. DOE repeated the same steps for standby mode power and battery energy to establish the standby mode baseline efficiency level for wired battery chargers. Each CSL would contain both the independent active mode efficiency level, and the independent standby mode efficiency level.

For fixed-location wireless chargers in active mode, DOE also repeated similar steps to establish the active energy CSL based off of CCD data, but assumed that the slopes across CSL 0 to CSL 3 are the same, which equal to the slope of the active charge energy vs. battery energy from the wet-environment wireless charger CCD data. DOE then adjusted the intercept so that all currently reported wet-environment wireless chargers pass the baseline standard level.

For the baseline efficiency level for standby mode power of fixed-location wireless chargers, DOE relied on the worst average 30% standby mode power of the fixed-location wireless chargers that passed DOE's internal testing. Similarly for open-placement wireless chargers' baseline no-battery mode power level, DOE also relied on the worst no-battery mode power of the wireless chargers that passed DOE's internal testing.

Table IV.5 below shows the baseline efficiency level for all wired and wireless battery chargers.

Table IV.5—Baseline Efficiency Level or CSL 0 for Battery Chargers

CSL 0: Approximated current standards

Product class

Battery energy

batt

)

Active mode energy

)

Standby mode power

= P

+ P

)

Off mode power

off

)

≤100Wh

1.718 * Ebatt + 17.3

1.7

N/A

1.4 (P

only)

≤100Wh

1.656 * Ebatt + 10.5

0.0021 * Ebatt + 1

100-1000

1.564 * Ebatt + 19.661

>1000

1.549 * Ebatt + 34.361

b. Higher Efficiency Levels

As part of DOE's analysis, the maximum available efficiency level is the highest efficiency unit currently available on the market. DOE also defines a “max-tech” efficiency level to represent the maximum possible efficiency for a given product.

Again, DOE applied linear regression models to different portions of the CCD to characterize three different performance levels of the reported wired battery charger basic models. For active mode energy of high-energy battery chargers in product class 2c, DOE held the intercept constant but adjusted the slope to allow slightly relaxed higher CSLs when compared to the preliminary analysis and to retain the continuous CSL for each level.

For active mode energy of fixed-location wireless chargers, DOE held the slopes the same across efficiency levels but adjusted the intercepts to achieve similar pass rates when compared to the wired battery charger pass rates at each corresponding CSLs. DOE further finetuned the intercepts by aligning them with DOE's internal testing results.

Similar to how DOE developed the baseline standard levels for standby mode power of fixed-location wireless chargers and no-battery mode power for open-placement wireless chargers, DOE relied on its own testing data to develop the higher efficiency levels as well. For P

of fixed-location wireless chargers, CSL 2 represents the approximated average value of DOE's tested samples,

whereas CSL 3 represents the most efficient 25-30% of the samples. CSL 1 P

of fixed-location wireless chargers was set to approximately be the average of CSL 0 and CSL 2 levels. For open-placement wireless charger no-battery mode CSLs, DOE approximated CSL 2 to be the average no-battery mode power of all the units tested by DOE. DOE then set CSL 1 to be the average of the bottom third of tested units and CSL 3 to represent open-placement wireless chargers that do not consume any power in no-battery mode from their wireless charging components, but with all power draw coming from the power supply just meeting DOE's multi-voltage EPS maximum no-load power of 0.3W, as prescribed in 10 CFR 430.32(w)(1)(ii).

DOE analyzed these three higher battery charger efficiency levels, identified design options, and obtained incremental cost data at each of these levels. Table IV.6 below shows the efficiency levels analyzed for this NOPR analysis.

Table IV.6—Higher Efficiency Levels for Battery Chargers

Product class

Battery energy

batt

)

Active mode energy

Standby mode power

= P

+ P

)

Off mode power

off

CSL 1: Intermediate (~70% Pass Rate)

≤100Wh

1.718 * Ebatt + 8.5

1.5

N/A

0.8 (P

only)

≤100Wh

1.390 * Ebatt + 7.5

0.00154 * Ebatt + 0.65

100-1000

1.418 * Ebatt + 4.692

>1000

1.388 * Ebatt + 34.361

CSL 2: Above Intermediate (~40% Pass Rate)

≤100Wh

1.718 * Ebatt + 5.54

1.25

N/A

0.5 (P

only)

≤100Wh

1.222 * Ebatt + 4.980

0.00098 * Ebatt + 0.4

100-1000

1.367 * Ebatt + −9.560

>1000

1.323 * Ebatt + 34.361

CSL 3: Max-Tech (~10% Pass Rate)

≤100Wh

1.718 * Ebatt + 2

0.65

N/A

0.3 (P

only)

≤100Wh

1.053 * Ebatt + 4.980

0.0005 * Ebatt + 0.25

100-1000

1.316 * Ebatt + −21.292

>1000

1.260 * Ebatt + 34.361

For wired battery chargers, the three analyzed higher efficiency levels (

i.e.,

ELs) correspond to the top 70%, 40%, and 10% of battery chargers in the market in terms of their active mode energy and standby mode power consumption. For ease of reference, DOE refers to the efficiency level that represents the top 70% of the market as “Intermediate”, the top 40% of the market as “Above Intermediate” and those that represent the top 10% of the market as “Max-Tech,” which typically also represents the lowest active mode energy and standby mode power consumption commercially attainable using current technology. Fixed-location wireless chargers share similar market distribution as wired chargers for these higher CSLs from DOE's estimates. However, for open-placement wireless chargers, DOE's internal testing data shows higher pass rates for higher efficiency levels, especially at Max-Tech. DOE notes that although DOE tried to test a wide variety of the wireless chargers covered under the expanded scope, there are still hundreds of wireless charger models in the market that have various no-battery mode efficiency. As such, the actual market efficiency distribution for open-placement wireless chargers in higher CSLs can be different than DOE's current estimates; additionally, because the CSL differences of the no-battery mode power draw is relatively small, the overall energy use analysis based on these market distribution estimates should still yield meaningful and reliable results.

DOE requests feedback on DOE's approach of establishing these higher efficiency CSLs and welcomes stakeholders to submit any data on the actual market distribution of these higher efficiency CSLs.

2. Cost Analysis

The cost analysis portion of the engineering analysis is conducted using one or a combination of cost approaches. The selection of cost approach depends on a suite of factors, including the availability and reliability of public information, characteristics of the regulated product, the availability and timeliness of purchasing the battery charger on the market. The cost approaches are summarized as follows:

•

Physical teardowns:

Under this approach, DOE physically dismantles a commercially available product, component-by-component, to develop a detailed bill of materials for the product.

•

Catalog teardowns:

In lieu of physically deconstructing a product, DOE identifies each component using parts diagrams (available from manufacturer websites or appliance repair websites, for example) to develop the bill of materials for the product.

•

Price surveys:

If neither a physical nor catalog teardown is feasible (for example, for tightly integrated products such as fluorescent lamps, which are infeasible to disassemble and for which parts diagrams are unavailable) or cost-prohibitive and otherwise impractical (

e.g.,

large commercial boilers), DOE conducts price surveys using publicly available pricing data published on major online retailer websites and/or by soliciting prices from distributors and other commercial channels.

In the present case, DOE conducted the analysis using all three methods (physical teardowns, catalog teardowns, and price surveys) of analysis to determine manufacturing cost as it

relates to the efficiency of a battery charger. Units for teardown were selected from the CCD based on reported energy values. Several units were selected as representative units for each CSL. In addition to units from the CCD, DOE purchased various open-placement and fixed-location wireless chargers to study their design, cost, and performance. DOE received additional cost data from manufacturer interviews and stakeholder feedback, which was incorporated in the cost model generation.

After testing, physical teardowns of CCD units were performed using internal tools. Price survey data was collected in manufacturer interviews and in some stakeholder feedback for units at each CSL.

To generate the cost model, cost data from teardowns were combined with price survey data to generate cost/efficiency relationships at each battery energy group of interest. Equations for cost as a function of relative active mode energy and standby mode power were then created using an exponential fit to the data at each battery energy level. The resulting manufacturer production costs (MPCs) were then generated for each efficiency level using the fit equations.

The Joint Efficiency Advocates expressed concerned that only four units representing CSL 0 and CSL 3 at two battery energy levels were used in the preliminary engineering analysis to estimate costs for all other wired charger CSLs and battery energy combinations. The Joint Efficiency Advocates commented that better accuracy would be obtained through additional testing and teardowns for all product classes, or through a design option approach for estimating costs for all wired chargers, or a combination of both. (Joint Efficiency Advocates, No. 19 at p. 2)

The CA IOUs further suggested DOE conduct additional teardowns of larger battery chargers in product classes 2a, 2b, and 2c for common product types (

e.g.,

notebooks, cordless vacuums, power tools, landscaping equipment, ride-on electric vehicles, electric scooters, and golf carts) because larger battery chargers for such devices may have different efficiency profiles than smaller ones due to higher quality components or the incorporation of high-efficiency technologies, such as wide-band-gap semiconductors. The CA IOUs stated their expectation that larger battery chargers may not show a linear trend between active energy and battery energy. (CA IOUs, No. 18 at p. 2)

Similarly, NEEA commented that DOE's methodology of conducting teardowns of four chargers in product class 2a representing only the lowest (baseline) and highest (CSL 3) of the four CSLs resulted in insufficient reliable data for class 2a CSL 1 and 2. NEEA's own research suggested that design options to enable CSL 1 and CSL 2 efficiencies are likely quite different than those used to achieve the highest efficiency level (CSL 3), creating inaccuracies in DOE's current estimates of the incremental cost for these middle levels. NEEA further commented that the reliance on four charger teardowns with battery energies less than 20 Wh (product class 2a) to 35 different battery charger applications with battery energies up to two orders of magnitude higher (2000 Wh) has yielded insufficient data to develop incremental cost information for product classes 2b and 2c because these higher power battery chargers likely use different semiconductor chipsets and/or can be impacted by production volume-related cost effects from other similar power electronics applications. (NEEA, No. 16 at pp. 1-2) NEEA commented that incremental battery charger costs presented for product class 2b ($2.59 to $8.73) are high relative to DOE EPS cost analysis, indicating that battery charger incremental costs are likely to be overestimated for these middle CSLs (CSLs 1 and 2). (NEEA, No. 16 at p. 2) NEEA stated that DOE should make three changes to more accurately measure the energy consumption of battery chargers: (1) add an alternative approach such as design option approach to teardown data already collected for class 2a CSL 1 and CSL 2; (2) conduct teardowns and/or utilize design option approaches to determine costs for product classes 2b and 2c; and (3) consider costs that maintain charge rate (slow or fast), given that slower chargers can be less costly due to a lower power output level. NEEA commented that if an expanded engineering analysis reveals that current CSL levels are not cost-effective in wired charges, NEEA recommends that DOE consider alternative combinations and standby and active mode that are more likely to be cost-effective, and adding an additional CSL level between CSL 0 and CSL 1. (NEEA, No. 16 at pp. 2-3)

DOE acknowledges that better representativeness can be achieved through additional testing and teardowns. Therefore, for the NOPR analysis, DOE has expanded the representative unit size significantly to cover more battery energy ranges and different end product types. DOE has also conducted various manufacturer interviews to get more direct design and cost information from stakeholders to calibrate DOE's internal teardown results, which improves the accuracy and representativeness of DOE's battery charger cost-efficiency relationship. Details of how DOE updated its cost analysis can be found in chapter 5 of the NOPR TSD.

To account for manufacturers' non-production costs and profit margin, DOE applies a multiplier (the manufacturer markup) to the MPC. The resulting manufacturer selling price (“MSP”) is the price at which the manufacturer distributes a unit into commerce. DOE, throughout this NOPR analysis, is using the average manufacturer markup presented in the June 2016 final rule. This markup was determined based on information collected during the manufacturer interviews preceding that rulemaking. More detail on the manufacturer markup is given in section IV.D of this document.

3. Cost-Efficiency Results

The results of the engineering analysis are presented as cost-efficiency data for each product class by efficiency levels. The cost-efficiency curves are described by the efficiency levels DOE analyzed and the increase in MPC required to improve a baseline-efficiency product to each of the considered efficiency levels. DOE recognizes that costs of battery chargers vary according to the energy of the battery it is intended to charge. DOE analyzed costs at various battery energies from different battery energy groups for each CSL as shown below. These representative battery energies were selected based on areas of significant market density, as indicated by entries in the CCD. They also span a wide range of battery energy groups for which the CSL equations were defined. For battery energy groups for which DOE lacks direct teardown costs, DOE extrapolated these costs from representative units that DOE has physically torn down and calibrated DOE's extrapolation with price information DOE acquired from manufacturer interviews.

Tables and plots with MPC results, as well as extrapolation methods used both within and across each product class, are presented below as well as in greater detail in chapter 5 of the NOPR TSD.

DOE requests stakeholder feedbacks on these analyzed incremental costs as well as any topic covered in chapter 5 of the NOPR TSD. DOE also welcomes stakeholders to submit their own cost-efficiency results, should there be any.

Product class

Product class name

Battery energy

(Wh)

Incremental MPC ($)

Base

CSL 1

CSL 2

CSL 3

Fixed-Location Wireless Charger

0.00

0.67

1.51

3.52

Open-Placement Wireless Charger

N/A

0.00

0.53

1.49

2.14

Low-Energy Wired Battery Charger (≤100Wh)

0.00

0.23

0.40

0.63

0.77

0.75

1.59

0.00

0.55

1.00

1.85

0.00

0.93

1.60

2.67

Medium-Energy Wired Battery Charger (100-1000Wh)

200

420

0.00

1.58

3.35

2.45

5.20

3.24

6.86

High-Energy Wired Battery Charger (>1000Wh)

2000

0.00

3.35

5.20

6.86

D. Markups Analysis

The markups analysis develops appropriate markups (

e.g.,

retailer markups, distributor markups, contractor markups) in the distribution chain and sales taxes to convert the MSP estimates derived in the engineering analysis to consumer prices, which are then used in the LCC and PBP analysis and in the manufacturer impact analysis. At each step in the distribution channel, companies mark up the price of the product to cover business costs and profit margin.

For battery chargers, the main parties in the distribution chain are battery charger manufacturers, end-use product original equipment manufacturers, consumer product retailers, and consumers. DOE developed baseline and incremental markups for each actor in the distribution chain. Baseline markups are applied to the price of products with baseline efficiency, while incremental markups are applied to the difference in price between baseline and higher-efficiency models (the incremental cost increase). The incremental markup is typically less than the baseline markup and is designed to maintain similar per-unit operating profit before and after new or amended standards.

Because the projected price of standards-compliant products is typically higher than the price of baseline products, using the same markup for the incremental cost and the baseline cost would result in higher per-unit operating profit. While such an outcome is possible, DOE maintains that in markets that are reasonably competitive it is unlikely that standards would lead to a sustainable increase in profitability in the long run.

In the March 2022 Preliminary Analysis, DOE used the same baseline and incremental markups that were used in the June 2016 Final Rule.

DOE did not receive any comments regarding the markups or distribution channels in the March 2022 Preliminary Analysis, therefore DOE used the same markups in this NOPR.

See Chapter 6 of the 2016 Final Rule Technical Support Document for Battery Chargers. (Available at:

www.regulations.gov/document/EERE-2008-BT-STD-0005-0257

) (last accessed Sept. 12, 2022). See also Chapter 6 of the 2022 Preliminary Analysis Technical Support Document for Battery Chargers. (Available at:

www.regulations.gov/document/EERE-2020-BT-STD-0013-0009

) (last accessed Sept. 12, 2022).

Chapter 6 of the NOPR TSD provides details on DOE's development of markups for battery chargers.

DOE requests comment on the estimated increased manufacturer markups and incremental MSPs that result from the analyzed energy conservation standards from the NOPR engineering analysis.

E. Energy Use Analysis

The purpose of the energy use analysis is to determine the annual energy consumption of battery chargers at different efficiencies in representative U.S. single-family homes, multi-family residences, and commercial buildings, and to assess the energy savings potential of increased battery charger efficiency. The energy use analysis estimates the range of energy use of battery chargers in the field (

i.e.,

as they are actually used by consumers). The energy use analysis provides the basis for other analyses DOE performs, particularly assessments of the energy savings and the savings in consumer operating costs that could result from adoption of amended or new standards.

In the March 2022 Preliminary Analysis, DOE used usage profiles that were developed in the June 2016 Final Rule, along with efficiency data at different load conditions, to calculate the UECs for battery chargers for a variety of applications.

Usage profiles are estimates of the average time a device spends in each mode of operation. In the February 2023 NOPR for external power supplies, DOE updated some of the usage profiles for certain applications based on stakeholder comments. 88 FR 7284. For this analysis, DOE aligned the battery charger usage profiles for these applications with the EPS usage profiles for consistency.

See appendix 7A of the 2016 Final Rule Technical Support Document for Battery Chargers. (Available at:

www.regulations.gov/document/EERE-2008-BT-STD-0005-0257

) (last accessed Sept. 12, 2022). See also appendix 7A of the 2022 Preliminary Analysis Technical Support Document for Battery Chargers. (Available at:

www.regulations.gov/document/EERE-2020-BT-STD-0013-0009

) (last accessed Sept. 12, 2022).

Chapter 7 of the NOPR TSD provides details on DOE's energy use analysis for battery chargers.

F. Life-Cycle Cost and Payback Period Analysis

DOE conducted LCC and PBP analyses to evaluate the economic impacts on individual consumers of potential energy conservation standards for battery chargers. The effect of new or amended energy conservation standards on individual consumers usually involves a reduction in operating cost and an increase in purchase cost. DOE used the following two metrics to measure consumer impacts:

☐ The LCC is the total consumer expense of an appliance or product over the life of that product, consisting of total installed cost (manufacturer selling price, distribution chain markups, sales tax, and installation costs) plus operating costs (expenses for energy use, maintenance, and repair). To compute the operating costs, DOE discounts future operating costs to the time of purchase and sums them over the lifetime of the product.

☐ The PBP is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost (including installation) of a more-efficient product through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost at higher efficiency levels by the change in annual operating cost for the year that amended or new standards are assumed to take effect.

For any given efficiency level, DOE measures the change in LCC relative to the LCC in the no-new-standards case, which reflects the estimated efficiency distribution of battery chargers in the absence of new or amended energy conservation standards. In contrast, the PBP for a given efficiency level is

measured relative to the baseline product.

For each considered efficiency level in each product class, DOE calculated the LCC and PBP for a nationally representative set of housing units and commercial buildings. DOE developed household samples from the 2015 Residential Energy Consumption Survey

(RECS 2015) and the 2018 Commercial Building Energy Consumption Survey

(CBECS 2018). For each sample household, DOE determined the energy consumption for the battery chargers and the appropriate energy price. By developing a representative sample of households, the analysis captured the variability in energy consumption and energy prices associated with the use of battery chargers.

www.eia.gov/consumption/residential/data/2015/

(last accessed Sept. 12, 2022). EIA is currently working on RECS 2020, and the entire RECS 2020 microdata are expected to be fully released in early 2023. Until that time, RECS 2015 remains the most recent full data release. For future analyses, DOE plans to consider using the complete RECS 2020 microdata when available.

www.eia.gov/consumption/commercial/

(last accessed Sept. 12, 2022).

Inputs to the calculation of total installed cost include the cost of the product—which includes MPCs, manufacturer markups, retailer and distributor markups, and sales taxes—and installation costs. Inputs to the calculation of operating expenses include annual energy consumption, energy prices and price projections, repair and maintenance costs, product lifetimes, and discount rates. DOE created distributions of values for product lifetime, discount rates, and sales taxes, with probabilities attached to each value, to account for their uncertainty and variability.

The computer model DOE uses to calculate the LCC relies on a Monte Carlo simulation to incorporate uncertainty and variability into the analysis. The Monte Carlo simulations randomly sample input values from the probability distributions and battery chargers' user samples. For this rulemaking, the Monte Carlo approach is implemented in MS Excel. The model calculated the LCC for products at each efficiency level for 10,000 housing units and commercial buildings per simulation run. The analytical results include a distribution of 10,000 data points showing the range of LCC savings for a given efficiency level relative to the no-new-standards case efficiency distribution. In performing an iteration of the Monte Carlo simulation for a given consumer, product efficiency is chosen based on its probability. If the chosen product efficiency is greater than or equal to the efficiency of the standard level under consideration, the LCC calculation reveals that a consumer is not impacted by the standard level. By accounting for consumers who already purchase more-efficient products, DOE avoids overstating the potential benefits from increasing product efficiency.

DOE calculated the LCC and PBP for all consumers of battery chargers as if each were to purchase a new product in the expected year of required compliance with new or amended standards. New and amended standards would apply to battery chargers manufactured 2 years after the date on which any new or amended standard is published. (42 U.S.C. 6295(u)) At this time, DOE estimates publication of a final rule in late 2024, therefore, for purposes of this analysis, DOE used 2027 as the first year of compliance with any amended standards for EPSs.

Table IV.7 summarizes the approach and data DOE used to derive inputs to the LCC and PBP calculations. The subsections that follow provide further discussion. Details of the spreadsheet model, and of all the inputs to the LCC and PBP analyses, are contained in chapter 8 of the NOPR TSD and its appendices.

Table IV.7—Summary of Inputs and Methods for the LCC and PBP Analysis *

Inputs

Source/method

Product Cost

Derived by multiplying MPCs by battery charger manufacturer and appliance manufacturer markups and sales tax, as appropriate. Used historical Product Price Index (PPI) data for semiconductors to derive a price scaling index to project product costs.

Installation Costs

No installation costs.

Annual Energy Use

The total annual energy use calculated using product efficiency and operating hours.

Variability: Based on the 2015 RECS and 2018 CBECS.

Energy Prices

Electricity: EIA data—2021.

Variability: Census Division.

Energy Price Trends

Based on

AEO2022

price projections.

Repair and Maintenance Costs

No repair or maintenance costs were considered.

Product Lifetime

Average: 3 to 10 years.

Discount Rates

Approach involves identifying all possible debt or asset classes that might be used to purchase the considered appliances, or might be affected indirectly. Primary data source was the Federal Reserve Board's Survey of Consumer Finances.

Compliance Date

2027.

* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the NOPR TSD.

1. Product Cost

To calculate consumer product costs, DOE multiplied the MPCs developed in the engineering analysis by the markups described previously (along with sales taxes). DOE used different markups for baseline products and higher-efficiency products because DOE applies an incremental markup to the increase in MSP associated with higher-efficiency products.

In the March 2022 Preliminary Analysis, DOE did not use any price trend.

In response, the CA IOUs commented that based on American Council for an Energy-Efficient Economy information and price comparisons, DOE has historically overestimated its forecasts of the incremental cost for products subject to standards due to energy conservation policies that may accelerate the decline of appliance costs due to increased production and innovation. (CA IOUs, No. 18 at pp. 5-6) The CA IOUs further commented that battery chargers are increasingly employing gallium nitride (GaN) semiconductors as a primary cost component, and GaN semiconductor costs are expected to decrease substantially; in addition, GaN topologies require fewer components and heat dissipation needs, causing system-level costs to decrease. For these reasons, DOE should include price learning in its analysis of battery chargers and develop criteria for applying price learning in all cases involving products with rapidly expanding sales volumes or based on components or materials that are likely

to experience declining costs. (CA IOUs, No. 18 at pp. 6-7)

See Chapters 8 and 10 of the 2022 Preliminary Analysis Technical Support Document for Battery Chargers. (Available at:

www.regulations.gov/document/EERE-2020-BT-STD-0013-0009

) (last accessed Sept. 12, 2022).

The Joint Efficiency Advocates stated that with price learning not addressed in the preliminary analysis, costs to achieve higher efficiency levels over the analysis period could be overestimated; learning rates associated with semiconductors are especially important because improved semiconductors are a key technology option for reaching higher efficiency levels. (Joint Efficiency Advocates, No. 19 at p. 2)

NEEA also commented that DOE should incorporate manufacturer price learning and leverage general semiconductor price data into its analysis of life-cycle cost and payback period for battery chargers. (NEEA, No. 16 at p. 3)

DOE agrees with the commenters that costs for electronic components are likely to change during the analysis period. In this NOPR, DOE has incorporated a price trend based on the PPI for semiconductors,

with an estimated annual deflated price decline of approximately 6 percent per year from 1967 through 2021. DOE applied this price trend to the proportion of battery charger costs attributable to semiconductors, which is estimated at 90 percent of incremental costs.

Producer Price Index: Semiconductors and Related Manufacturing. Series ID: PCU334413334413. (Available at:

beta.bls.gov/dataViewer/view/timeseries/PCU334413334413

) (last accessed Sept. 12, 2022).

2. Annual Energy Consumption

For each sampled household or commercial business, DOE determined the energy consumption for a battery charger at different efficiency levels using the approach described previously in section IV.E of this document.

3. Energy Prices

Because marginal electricity price more accurately captures the incremental savings associated with a change in energy use from higher efficiency, it provides a better representation of incremental change in consumer costs than average electricity prices. Therefore, DOE applied average electricity prices for the energy use of the product purchased in the no-new-standards case, and marginal electricity prices for the incremental change in energy use associated with the other efficiency levels considered.

For the NOPR, DOE derived average monthly residential and commercial marginal electricity prices for the various regions using 2021 data from EIA.

U.S. Department of Energy-Energy Information Administration, Form EIA-861M (formerly EIA-826) Database Monthly Electric Utility Sales and Revenue Data (1990-2020). (Available at:

www.eia.gov/electricity/data/eia861m/

) (last accessed Sept. 12, 2022).

To estimate energy prices in future years, DOE multiplied the 2021 energy prices by the projection of annual average price changes for each of the nine census divisions from the Reference case in

AEO2022,

which has an end year of 2050.

To estimate price trends after 2050, DOE used the average annual rate of change in prices from 2023 through 2050.

EIA.

Annual Energy Outlook 2022 with Projections to 2050.

Washington, DC. (Available at

www.eia.gov/forecasts/aeo/

) (last accessed Sept. 12, 2022).

See chapter 8 of the NOPR TSD for details.

4. Product Lifetime

In the March 2022 Preliminary Analysis, DOE based the battery charger lifetime on the lifetime of the application for which it is associated.

In the February 2023 NOPR for external power supplies, DOE increased the lifetime for several applications based on stakeholder comments. 88 FR 7284. For this analysis, DOE aligned the application lifetimes (and thus battery charger lifetimes) for these applications with the EPS lifetime estimates for consistency.

See Chapter 8 of the 2022 Preliminary Analysis Technical Support Document for Battery Chargers. (Available at:

www.regulations.gov/document/EERE-2020-BT-STD-0013-0009

) (last accessed Sept. 12, 2022).

5. Discount Rates

In the calculation of LCC, DOE applies discount rates appropriate to households and commercial buildings to estimate the present value of future operating cost savings. DOE estimated a distribution of discount rates for battery chargers based on the opportunity cost of consumer funds.

For residential households, DOE applies weighted average discount rates calculated from consumer debt and asset data, rather than marginal or implicit discount rates.

The LCC analysis estimates net present value over the lifetime of the product, so the appropriate discount rate will reflect the general opportunity cost of household funds, taking this time scale into account. Given the long time horizon modeled in the LCC analysis, the application of a marginal interest rate associated with an initial source of funds is inaccurate. Regardless of the method of purchase, consumers are expected to continue to rebalance their debt and asset holdings over the LCC analysis period, based on the restrictions consumers face in their debt payment requirements and the relative size of the interest rates available on debts and assets. DOE estimates the aggregate impact of this rebalancing using the historical distribution of debts and assets.

The implicit discount rate is inferred from a consumer purchase decision between two otherwise identical goods with different first cost and operating cost. It is the interest rate that equates the increment of first cost to the difference in net present value of lifetime operating cost, incorporating the influence of several factors: transaction costs; risk premiums and response to uncertainty; time preferences; interest rates at which a consumer is able to borrow or lend. The implicit discount rate is not appropriate for the LCC analysis because it reflects a range of factors that influence consumer purchase decisions, rather than the opportunity cost of the funds that are used in purchases.

To establish residential discount rates for the LCC analysis, DOE identified all relevant household debt or asset classes in order to approximate a consumer's opportunity cost of funds related to appliance energy cost savings. It estimated the average percentage shares of the various types of debt and equity by household income group using data from the Federal Reserve Board's Survey of Consumer Finances

(“SCF”) for 1995, 1998, 2001, 2004, 2007, 2010, and 2013. Using the SCF and other sources, DOE developed a distribution of rates for each type of debt and asset by income group to represent the rates that may apply in the year in which amended standards would take effect. DOE assigned each sample household a specific discount rate drawn from one of the distributions. The average rate across all types of household debt and equity and income groups, weighted by the shares of each type, is 4.1% percent.

Board of Governors of the Federal Reserve System.

Survey of Consumer Finances.

1995, 1998, 2001, 2004, 2007, 2010, and 2013. (Available at:

www.federalreserve.gov/econres/scfindex.htm

) (last accessed Sept. 12, 2022).

For commercial buildings, DOE derived the discount rates for the LCC analysis by estimating the cost of capital for companies or public entities that purchase EPSs. For private firms, the weighted average cost of capital (“WACC”) is commonly used to estimate the present value of cash flows to be derived from a typical company project or investment. Most companies use both debt and equity capital to fund investments, so their cost of capital is the weighted average of the cost to the firm of equity and debt financing, as estimated from financial data for publicly traded firms across all commercial sectors. The average commercial cost of capital is 6.7%.

See chapter 8 of the NOPR TSD for further details on the development of consumer discount rates.

6. Energy Efficiency Distribution in the No-New-Standards Case

To accurately estimate the share of consumers that would be affected by a potential energy conservation standard at a particular efficiency level, DOE's LCC analysis considered the projected distribution (market shares) of product efficiencies under the no-new-standards case (

i.e.,

the case without amended or new energy conservation standards).

In the March 2022 Preliminary Analysis, DOE used the CCD

to estimate the energy efficiency distribution of battery chargers for 2027.

DOE updated these distributions based on the latest data in CCD. For wireless chargers, DOE estimated the efficiency distributions based on the models tested and used for the engineering analysis. The estimated market shares for the no-new-standards case for battery chargers are shown in Table IV.8. See chapter 8 of the NOPR TSD for further information on the derivation of the efficiency distributions.

https://www.regulations.doe.gov/ccms.

See Chapter 8 of the 2022 Preliminary Analysis Technical Support Document for Battery Chargers. (Available at:

www.regulations.gov/document/EERE-2020-BT-STD-0013-0009

) (last accessed Sept. 12, 2022).

Table IV.8—Estimated Market Shares of Battery Chargers in the No-New-Standards Case

Representative unit

(battery energy)

Baseline

(%)

Intermediate

(%)

Above

intermediate

(%)

Max-Tech

(%)

10Wh

9.8

48.9

19.4

21.9

10-50Wh (RPU 12.7Wh)

26.1

53.0

18.1

2.8

10-50Wh (RPU 25Wh)

26.1

53.0

18.1

2.8

50-100Wh (RPU 75Wh)

20.6

51.5

27.8

0.1

100-400Wh (RPU 200Wh)

19.7

27.5

37.6

15.2

400-1000Wh (RPU 420Wh)

19.7

27.5

37.6

15.2

>1000Wh (RPU 2000Wh)

38.5

36.1

13.6

11.8

Fixed-Location wireless charger

8.3

25.0

58.3

8.3

Open-Placement wireless charger

6.7

20.0

53.3

7. Payback Period Analysis

The payback period is the amount of time (expressed in years) it takes the consumer to recover the additional installed cost of more-efficient products, compared to baseline products, through energy cost savings. Payback periods that exceed the life of the product mean that the increased total installed cost is not recovered in reduced operating expenses.

The inputs to the PBP calculation for each efficiency level are the change in total installed cost of the product and the change in the first-year annual operating expenditures relative to the baseline. DOE refers to this as a “simple PBP” because it does not consider changes over time in operating cost savings. The PBP calculation uses the same inputs as the LCC analysis when deriving first-year operating costs.

As noted previously, EPCA establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the first year's energy savings resulting from the standard, as calculated under the applicable test procedure. (42 U.S.C. 6295(o)(2)(B)(iii)) For each considered efficiency level, DOE determined the value of the first year's energy savings by calculating the energy savings in accordance with the applicable DOE test procedure, and multiplying those savings by the average energy price projection for the year in which compliance with the amended standards would be required.

The Joint Trade Associations and Delta-Q commented that amended standards for battery chargers are not economically justified because the payback periods are far longer than the average useful life of the product; therefore, most consumers will experience a net cost through amended standards. The Joint Trade Associations further recommended that DOE focus on other rulemakings for potential significant energy savings. (Joint Trade Associations, No. 17 at p. 1; Delta-Q, No. 20 at p. 1)

DOE notes that the preliminary analysis did not propose any specific standard level. For this NOPR, DOE's evaluation of the economic justification of potential standard levels, including the consideration of payback periods, is provided in section V.C.

G. Shipments Analysis

DOE uses projections of annual product shipments to calculate the national impacts of potential amended or new energy conservation standards on energy use, NPV, and future manufacturer cash flows.

The shipments model takes an accounting approach, tracking market shares of each product class and the vintage of units in the stock. Stock accounting uses product shipments as inputs to estimate the age distribution of in-service product stocks for all years. The age distribution of in-service product stocks is a key input to calculations of both the national energy savings (“NES”) and NPV, because operating costs for any year depend on the age distribution of the stock.

DOE uses data on manufacturer shipments as a proxy for national sales, as aggregate data on sales are lacking. In general, one would expect a close correspondence between shipments and sales.

In the March 2022 Preliminary Analysis, DOE developed shipments estimates based on actual shipments from 2019 and a population growth rate based on U.S. Census population projections through 2050.

DOE did not receive any comments on the shipments analysis and therefore used this same approach in the NOPR.

See Chapter 9 of the 2022 Preliminary Analysis Technical Support Document for Battery Chargers. (Available at:

www.regulations.gov/document/EERE-2020-BT-STD-0013-0009

) (last accessed Sept. 12, 2022).

See Chapter 9 of the NOPR TSD for more detail on the shipments analysis.

DOE requests comment on its methodology for estimating shipments. DOE also requests comment on its approach to estimate the market share for EPSs of all product classes.

H. National Impact Analysis

The NIA assesses the NES and the NPV from a national perspective of total consumer costs and savings that would be expected to result from new or amended standards at specific efficiency levels.

(“Consumer” in this context

refers to consumers of the product being regulated.) DOE calculates the NES and NPV for the potential standard levels considered based on projections of annual product shipments, along with the annual energy consumption and total installed cost data from the energy use and LCC analyses. For the present analysis, DOE projected the energy savings, operating cost savings, product costs, and NPV of consumer benefits over the lifetime of battery chargers sold from 2027 through 2056.

The NIA accounts for impacts in the 50 states and U.S. territories.

DOE evaluates the impacts of new or amended standards by comparing a case without such standards with standards-case projections. The no-new-standards case characterizes energy use and consumer costs for each product class in the absence of new or amended energy conservation standards. For this projection, DOE considers historical trends in efficiency and various forces that are likely to affect the mix of efficiencies over time. DOE compares the no-new-standards case with projections characterizing the market for each product class if DOE adopted new or amended standards at specific energy efficiency levels (

i.e.,

the TSLs or standards cases) for that class. For the standards cases, DOE considers how a given standard would likely affect the market shares of products with efficiencies greater than the standard.

DOE uses a spreadsheet model to calculate the energy savings and the national consumer costs and savings from each TSL. Interested parties can review DOE's analyses by changing various input quantities within the spreadsheet. The NIA spreadsheet model uses typical values (as opposed to probability distributions) as inputs.

Table IV.9 summarizes the inputs and methods DOE used for the NIA analysis for the NOPR. Discussion of these inputs and methods follows the table. See chapter 10 of the NOPR TSD for further details.

Table IV.9—Summary of Inputs and Methods for the National Impact Analysis

Inputs

Method

Shipments

Annual shipments from shipments model.

Compliance Date of Standard

2027.

Efficiency Trends

No-new-standards case: Varies by application.

Annual Energy Consumption per Unit

Annual weighted-average values are a function of energy use at each TSL.

Total Installed Cost per Unit

Annual weighted-average values are a function of cost at each TSL.

Incorporates projection of future product prices based on historical data.

Annual Energy Cost per Unit

Annual weighted-average values as a function of the annual energy consumption per unit and energy prices.

Repair and Maintenance Cost per Unit

Annual values do not change with efficiency level.

Energy Price Trends

AEO2022

projections (to 2050) and extrapolation thereafter based on the growth rate from 2023-2050.

Energy Site-to-Primary and FFC Conversion

A time-series conversion factor based on

AEO2022.

Discount Rate

3 percent and 7 percent.

Present Year

2022.

1. Product Efficiency Trends

A key component of the NIA is the trend in energy efficiency projected for the no-new-standards case and each of the standards cases. Section IV.F.6 of this document describes how DOE developed an energy efficiency distribution for the no-new-standards case (which yields a shipment-weighted average efficiency) for each of the considered product classes for the first full year of anticipated compliance with an amended or new standard. To project the trend in efficiency absent amended standards for battery chargers over the entire shipments projection period, DOE assumed a constant efficiency trend. The approach is further described in chapter 10 of the NOPR TSD.

For the standards cases, DOE used a “roll-up” scenario to establish the shipment-weighted efficiency for the year that standards are assumed to become effective (2027). In this scenario, the market shares of products in the no-new-standards case that do not meet the standard under consideration would “roll up” to meet the new standard level, and the market share of products above the standard would remain unchanged.

To develop standards case efficiency trends after 2027, DOE used a constant efficiency trend, keeping the distribution equal to the compliance year.

2. National Energy Savings

The national energy savings analysis involves a comparison of national energy consumption of the considered products between each potential standards case (“TSL”) and the case with no new or amended energy conservation standards. DOE calculated the national energy consumption by multiplying the number of units (stock) of each product (by vintage or age) by the unit energy consumption (also by vintage). DOE calculated annual NES based on the difference in national energy consumption for the no-new standards case and for each higher efficiency standard case. DOE estimated energy consumption and savings based on site energy and converted the electricity consumption and savings to primary energy (

i.e.,

the energy consumed by power plants to generate site electricity) using annual conversion factors derived from

AEO2022.

Cumulative energy savings are the sum of the NES for each year over the timeframe of the analysis.

Use of higher-efficiency products is occasionally associated with a direct rebound effect, which refers to an increase in utilization of the product due to the increase in efficiency. DOE did not consider a rebound effect in this analysis, because the price differences by EL and energy use are so small that any rebound effect would be close to zero.

In 2011, in response to the recommendations of a committee on “Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy Efficiency Standards” appointed by the National Academy of Sciences, DOE announced its intention to use FFC measures of energy use and greenhouse gas and other emissions in the national impact analyses and emissions analyses included in future energy conservation standards rulemakings. 76 FR 51281 (Aug. 18, 2011). After evaluating the approaches discussed in the August 18, 2011 notice, DOE published a statement

of amended policy in which DOE explained its determination that EIA's National Energy Modeling System (“NEMS”) is the most appropriate tool for its FFC analysis and its intention to use NEMS for that purpose. 77 FR 49701 (Aug. 17, 2012). NEMS is a public domain, multi-sector, partial equilibrium model of the U.S. energy sector

that EIA uses to prepare its

Annual Energy Outlook.

The FFC factors incorporate losses in production and delivery in the case of natural gas (including fugitive emissions) and additional energy used to produce and deliver the various fuels used by power plants. The approach used for deriving FFC measures of energy use and emissions is described in appendix 10B of the NOPR TSD.

For more information on NEMS, refer to

The National Energy Modeling System: An Overview 2009,

DOE/EIA-0581(2009), October 2009. Available at

www.eia.gov/forecasts/aeo/index.cfm

(last accessed December 2, 2022).

3. Net Present Value Analysis

The inputs for determining the NPV of the total costs and benefits experienced by consumers are (1) total annual installed cost, (2) total annual

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