In addition to working to undo the previous administration’s rollbacks and roadblocks, DOE has also published about 80 notices over the last year related to test procedure or standards rulemakings. The paragraphs below highlight some of this recent activity. DOE's latest schedule indicates that it plans to publish more than 20 notices related to test procedures and another more than 20 notices related to standards by the end of the year.
Residential Boilers
In a March 2021 request for information (RFI) on residential boiler standards, DOE requested comment on various issues including the potential separation of condensing and non-condensing boilers into different product classes. In our comments on the RFI, we urged DOE to maintain the current product classes because both condensing and noncondensing boilers use gas as the primary fuel source and provide the same utility to consumers. In addition, we highlighted the availability of models on the market that are considerably more efficient than both the current DOE standards and the ENERGY STAR specification. Improved standards for residential boilers at condensing levels could result in significant energy savings for consumers.
Commercial Refrigeration Equipment
In our comments on the July 2021 RFI for standards for commercial refrigeration equipment, we noted that for some of the most common equipment categories, there are products on the market that consume more than 70% less energy than models just meeting the current federal standards. We also encouraged DOE to consider establishing standards for new equipment categories such as refrigerated preparation tables and chef bases. Finally, we urged DOE to merge the existing equipment classes for refrigerated display cases with and without doors since open cases waste large amounts of energy compared to display cases with glass doors.
Commercial and Industrial Fans
In August 2021, DOE published a final rule classifying commercial and industrial fans—which are used in applications such as commercial building HVAC systems, commercial kitchen exhaust systems, and agricultural ventilation—as “covered” equipment under the Energy Policy and Conservation Act. DOE initiated a rulemaking for commercial and industrial fans in 2011 but has yet to establish efficiency standards. In a report published in 2020, we found that standards for commercial and industrial fans represent one of the top opportunities for carbon reductions.
Microwave Ovens
DOE published a supplemental notice of proposed rulemaking (SNOPR) for microwave oven test procedures in August 2021 with proposed clarifications for testing the standby mode power of a microwave oven. In our comments on the SNOPR, we urged DOE to require that all microwave ovens that have “connected” functions be tested with those functions in the “as shipped” condition so that the test procedure is representative of actual power consumption. We also urged DOE to establish an active mode test procedure for microwave ovens in order to provide consumers with accurate energy consumption information.
In addition, DOE issued a notice of proposed determination (NOPD) in August 2021 proposing not to amend the current standards for microwave ovens. In our comments in response, we urged DOE to reconsider, because there are products on the market with significantly lower standby power consumption than the levels that DOE analyzed.
Residential Clothes Washers
DOE’s preliminary analysis for residential clothes washers published in September 2021 showed that amended standards could cost-effectively save nearly 3 quadrillion Btus (quads) of energy . However, in our comments on the preliminary technical support document (PTSD), we explained that DOE is likely significantly underestimating drying energy use, which represents the majority of the energy consumption associated with clothes washers. (The clothes washer test procedure includes an estimate of the energy consumed by a clothes dryer to dry the clothes coming out of the washer based on the moisture content of the clothes.) Higher, more realistic drying energy usage estimates would further improve the cost-effectiveness of higher efficiency levels.
We also encouraged DOE to further investigate the correlation between washer capacity and measured efficiency. The current efficiency metrics contain a bias toward larger-capacity washers, which can achieve higher efficiency ratings than smaller-capacity washers. While DOE has proposed to change the water and energy usage metrics to be based on pounds of clothes washed rather than washer capacity—which will mitigate the current bias—the Department’s preliminary analysis suggests that it may still be easier for larger washers to meet higher standards.
Refrigerators and Freezers
In a PTSD published in October 2021, DOE showed that more than 7 quads of cost-effective cumulative energy savings are achievable from amending the current standards for residential refrigerators and freezers. However, in our comments on the PTSD, we identified several ways DOE could improve its analysis, potentially leading to even greater cost-effective energy savings. For example, we explained that for certain product classes, DOE is significantly overestimating the cost to reach higher efficiency levels. In addition, we encouraged DOE to increase the “max-tech” level for several product classes since we identified models currently available on the market that exceed those levels. We also explained that DOE may be underestimating the potential energy savings from improved insulation (vacuum insulated panels) and variable-speed compressors.
Residential Dishwashers
DOE published a notice of proposed rulemaking (NOPR) for dishwasher test procedures in December 2021 with proposed changes to various aspects of the test including loading pattern, connected functions, and standby and off mode testing. In our comments, we generally supported DOE’s proposed changes, in particular related to cleaning performance. Dishwashers are currently tested on the “normal” cycle. In the NOPR, DOE noted that if a consumer is not satisfied with the cleaning performance on the normal cycle, they may select a more energy- and water-intensive cycle setting. Therefore, DOE is proposing to require that tested cycles meet a minimum cleaning index threshold; if that threshold is not met, the dishwasher would be re-rested using the most energy-intensive cycle that meets the cleaning index threshold. We explained in our comments that we believe that the implementation of a cleaning performance threshold will result in tested cycles that are more representative of dishwasher energy and water consumption.
Electric Motors
In a NOPR for electric motor test procedures published in December 2021, DOE proposed to expand the scope of the test procedure to include a broad range of both efficient and inefficient motor types. Electric motors are responsible for nearly half of all global electricity consumption, yet the current test procedure and standards cover only a small subset of electric motor types. In our comments on the NOPR, we strongly supported this scope expansion as DOE’s recent preliminary analysis for electric motor standards shows that very large cost-effective energy savings are possible with new standards for these additional motor types. However, we encouraged DOE to amend the test procedure to capture efficiency at a range of load points to improve representativeness. (The current test procedure measures efficiency only at full load.) We also encouraged DOE to capture the benefits of speed control, which can result in very large real-world energy savings.