The U.S. Department of Energy currently has 37 rulemaking processes for appliance standards and another 36 for test procedure revisions under way. Below are updates on featured processes that have had a public phase within the past few months.
Automatic Commercial Ice Makers
DOE has initiated a process to consider amended standards for automatic commercial ice makers. In our December 2020 comments on the request for information (RFI), we urged DOE to strengthen existing standards for energy and condenser water use given the considerable potential for additional savings. Existing technology options have the potential to significantly reduce energy consumption, and a wide range of models currently on the market exceed the “max-tech” efficiency levels from the 2015 final rule. We also urged DOE to develop a standard for potable water use and to expand the scope to include ice makers with harvest rates less than 50 lb/24 hr. Ice makers of this size are not covered under the current standards yet can consume as much as 1,000 kWh or more per year.
In a request for information (RFI) on battery charger standards, DOE sought comments on a variety of issues that could assist in determining whether to establish more stringent standards. The battery charger market has changed drastically since the last rulemaking in 2016, with recent technological advancements and cost reductions allowing batteries to be used more frequently in consumer products. Currently available battery chargers achieve energy savings between 14% and 59% on average relative to models just meeting the current DOE standards. In addition, due to the rise in battery-powered consumer electronics and household products like power tools, lawn and garden equipment, and cordless vacuums, the demand for rechargeable batteries in consumer products is projected to increase by 4.6% per year. In our November 2020 comments on the RFI, we also encouraged DOE to establish standards for all wireless charging technology, which can consume nearly 50% more energy than traditional charging cables.
Commercial Clothes Washers
DOE has initiated a rulemaking to consider amended standards for commercial clothes washers. In our September 2020 comments on the RFI, we described how there are a range of both top-loading and front-loading models with efficiency levels that significantly exceed both the current standards and the max-tech efficiency levels from the 2014 final rule. For example, for top-loaders, the most-efficient model has an energy efficiency rating that is 63% higher than the minimum standard and 42% higher than the max-tech level from the 2014 final rule. That same model consumes almost 50% less water than a model just meeting the minimum standard and 35% less water than the max-tech level from the 2014 final rule. We also urged DOE to consider a single standard level for all commercial clothes washers. (The existing standards are significantly less stringent for top-loaders compared to front-loaders.)
DOE has initiated a rulemaking to consider amended standards for dishwashers. In our December 2020 comments on the request for information (RFI), we described how there is significant opportunity to strengthen the standards for energy and water use. For example, while the current standards limit energy and water consumption to 307 kWh/year and 5.0 gallons/cycle, there are many models that meet the ENERGY STAR Most Efficient specification, which specifies a maximum energy use of 240 kWh/year and a maximum water consumption of 3.2 gallons/cycle. We also described how DOE test data along with data from Consumer Reports shows that dishwashers that consume significantly less energy and water than the current standards can provide very good performance across a range of attributes including cleaning performance, drying performance, noise, and cycle time.
DOE released a notice of proposed rulemaking (NOPR) on the enforcement process for consumer products and commercial and industrial equipment. As we described in our December 2020 comments on the NOPR, we largely support the proposed edits to the enforcement provisions, which would increase transparency and specificity. However, we opposed DOE’s proposal to remove the requirement that manufacturers give written notification of a determination of noncompliance to all persons to whom they have distributed products. This change would disadvantage manufacturers of compliant products and harm customers since they would no longer be notified directly of noncompliant products.
Room Air Conditioners
In a proposed rule for test procedures for room air conditioners, DOE proposed amendments to capture the energy-saving benefits of units with variable-speed compressors. While the change would involve testing variable-speed units at multiple outdoor temperature conditions, single-speed units would continue to be tested at only 95 degrees Fahrenheit. In our August 2020 comments on the proposed rule, we strongly supported the move to capture variable-speed technology but also urged DOE to consider future amendments to test all room ACs at multiple conditions using a load-based test, which would better reflect the real-world operation of all units. DOE also published preliminary analysis evaluating potential amended standards for room ACs, which showed that large savings are achievable in a cost-effective manner. In our September 2020 comments on the preliminary analysis, we urged DOE to incorporate additional technology options in the analysis, including alternative refrigerants, which could enable even greater savings.