ASAP is tracking and responding to DOE action on a wide range of products and issues. Below are a sampling of what we've been responding to:
Improved consumer water heater standards based upon heat pump technology offer the largest potential savings of any pending DOE rulemaking. Water heaters also can figure prominently in plans for scaling up renewables in electricity generation, since grid-flexible water heaters can be charged up with hot water when power is cheap and clean. In comments responding to the initiation of the standards and test procedure dockets, we urged DOE to fully account for the range of heat pump technologies for both electric and gas-fired products, and to allow for data collection that will help predict heat pump performance in different climates. One challenge is that water heater standards have proven to be especially leaky since buyers’ need for hot water can be met by any number of product options. By reducing the number of product classes, DOE can prevent standards circumvention, making sure that future standards, test procedures and related efforts help drive the market toward super-efficient, grid-flexible products.
Improved and expanded standards for electric motors are also among the largest savings opportunities for future DOE standards. The European Union has already adopted standards at “IE 4” levels, which reduce motor losses by about 15% compared to current US standards. Expanding motor standards to cover a broader range of technologies, types, and horsepower ratings could add even larger energy savings. An improved motor test procedure would incorporate multiple load points representative of typical motor applications and capture the benefits of speed control, which can significantly boost energy savings. We made these and other recommendations in comments responding to DOE’s initiation of the motors standards and test procedures dockets.
Refrigerators and Freezers
DOE has initiated a process to consider amended standards for refrigerators and freezers. As we described in our comments on the request for information (RFI), there are a range of technologies that could provide significant additional savings including variable-speed compressors, vacuum insulated panels (VIPs), and alternative refrigerants. As of 2018, 46% and 37% of refrigerators and freezers, respectively, met the ENERGY STAR levels, which represent energy savings of 10% relative to the minimum standards. We also encouraged DOE in comments on a test procedures proposal to consider adopting an IEC test procedure (IEC 62552:2015). The IEC test procedure provides more representative test conditions than the current DOE test procedure, and may also better capture the energy-saving benefits of new technologies such as variable-speed compressors.
In an RFI on clothes washer test procedures, DOE identified a range of issues that suggest that the current test procedure for clothes washers is not representative of actual usage. Most importantly, the test procedure is likely significantly underestimating drying energy for many clothes washers by not providing a representative measurement of remaining moisture content (RMC). DOE also found that more washers are offering cycle modifiers such as “deep fill” and “extra rinse,” but the energy and water use of these features is not being captured in the test procedure. In our comments on the RFI, we also encouraged DOE to consider alternative efficiency metrics as a potential approach to eliminating the current bias towards large-capacity washers.
Commercial Unitary Air Conditioners and Commercial Furnaces
The standards for rooftop air conditioners and heat pumps published in 2016 will save more energy than any other standard ever issued by DOE. Yet large additional savings are still achievable. In our comments on an RFI initiating the standards revision process, we showed that there are a wide range of models with efficiency levels that exceed the “max-tech” levels from the last rulemaking, and we described how the use of alternative refrigerants can likely provide an additional efficiency boost. We also explained the importance of evaluating potential amended standards based on an improved test procedure that better captures fan energy use. The RFI also addressed commercial warm air furnaces, which are typically part of a rooftop unit. Condensing technology can reduce the energy use of commercial furnaces by about 10%, and improved insulation may provide additional savings.
Short-cycle product classes: A solution looking for a problem
Despite objections from ASAP, our allies and appliance manufacturers, DOE appears poised to finalize a new product class for dishwashers with shorter “normal” cycle times. The new product classes are unnecessary since nearly 90% of current dishwasher models already offer a short cycle option, typically labeled “express” or “quick.” Testing results posted to the docket this spring showed that short cycles can have excellent cleaning performance, provided they are not too short. (DOE provided no notification that the data had been posted, a lapse in transparency that we’ve asked the agency to fix.) But these products are available today, so DOE’s motivation to create a new product class remains a puzzle. The action may be politically motivated (President Trump has complained about dishwashers), or perhaps it is an attempt to undercut the law’s anti-backsliding provision. That provision holds that no new standard can be weaker than the existing standard for a product. In the proposed dishwasher short-cycle class rule, DOE asserted that existing standards would not apply to the new class.
Unfortunately, DOE is now considering similar needless short-cycle classes for clothes washers and dryers.
In addition to comments that ASAP filed on the products above, we also filed a number of comments on additional issues:
Joining with the Northeast Energy Efficiency Alliance, we recommended that DOE update the standards for external power supplies and reevaluate how it regulates interoperable wireless power supplies.
We recommended that DOE evaluate potential amended standards for Single Package Vertical Unit air conditioners, since greater energy savings than those evaluated for the 2015 final rule are likely possible. In addition, an amended test procedure would allow DOE to consider a range of technologies and better represent performance during an average use cycle.
We urged DOE to conduct a full analysis to update standards for General Service Fluorescent Lamps and Incandescent Reflector Lamps, and include in its investigation an evaluation of standards for certain ER-, BR-, and R-type lamps. Furthermore, we noted that DOE has the authority to expand the GSFL rulemaking scope to include very low efficiency linear fluorescent lamps.
We strongly opposed the proposal to change DOE’s decision-making process for selecting energy conservation standards because the change would make reviewing standards more difficult, and it would likely result in lost energy savings.