Issue 18
Dec 10, 2015
In This Issue of Unplugged
Paper finds mismatch between expectations and observations

An October 2015 discussion paper by Taylor et al. examines the impact of minimum efficiency performance standards on the price, quality, and design of products subject to standards and explores the relationship between regulation and innovation. The paper, Confronting Regulatory Cost and Quality Expectations: An Exploration of Technical Change in Minimum Efficiency Performance Standards, was published in October 2015, in conjunction with Lawrence Berkeley National Laboratory.

The authors conducted a retrospective review of five common household 'white' appliances (so-called because early models were all white) which had been subject to a series of national regulations between 1990 and 2012 - refrigerator/freezers, clothes washers, dryers, dishwashers, and air conditioners.

The big takeaways from the report are that federal agency analysis overestimated the cost of standards for all five of the appliances and underestimated the energy savings for four products (except for dryers for which they did not have energy-use data). Third-party data (Consumer Reports) showed that product reliability improved.  In addition, they studied quality parameters for clothes washers and found that the quality of the non-regulated aspects improved alongside energy efficiency.

Key Findings: 
-DOE analyses consistently overestimated product prices.
-After standards went into effect, energy efficiency of  products exceeded the standards. 
-Product quality improved in conjunction with standards. 
-Product reliability improved; rate of significant repairs over  five years declined.

The authors conclude that federal agencies are not aggressive enough when considering technologies that are new to the market, especially given the six-plus year period between the start of a rulemaking and the compliance date. Some technologies are ruled out at the beginning of the process, potentially missing technological inroads that are made over the course of the rulemaking. The authors note a "present-day bias" and "overly pessimistic expectations about commercial viability," and ask how these can be avoided in future rulemakings.

In their concluding remarks (below), the authors question whether behavior plays a role in the mismatch between expectations and observations:  

"It may well be that regulators and other stakeholders to the rulemaking process are more risk averse in their perceptions of the future of technological change than is warranted by available evidence. There are a number of environmental factors that shade the rulemaking process (e.g., political pressures, legal constraints, limited analytical resources, etc.) and could be contributing to a general pessimistic bias."

For the sake of good efficiency outcomes, let's hope that we also hear from non risk-averse optimistic voices in future appliance standards rulemakings.

For the full report, click here.

Margaret Taylor, C. Anna Spurlock , and Hung-Chia Yang; Confronting Regulatory Cost and Quality Expectations: An Exploration of Technical Change in Minimum Efficiency Performance Standards. October 2015.
Regional AC enforcement plan proposed
regional map
On November 19, 2015, DOE published a proposed rule for the enforcement of regional air conditioner and heat pump standards based on working group recommendations. The working group -- sponsored by DOE and comprised of stakeholders representing industry, contractors, utilities, efficiency organizations and consumer groups -- met 14 times over a three-month period to hammer out enforcement details for the first-ever DOE regional standards. The regional standards divide the country into three regions: north, south, and southwest. The criteria are based on the number of heating degree days and the climate (hot-dry vs. humid).

DOE proposes to adopt the working group recommendations which would place the responsibility for selling and installing compliant products on distributors and contractors, and require manufacturers to label condensing units to indicate where they can be installed, e.g., "Install prohibited in southwest." Contractors and dealers who routinely sell or install products which do not meet the regional standards would be considered routine violators. Manufacturers would be liable for selling products to routine violators. 

Additional recommendations from the working group would require DOE to:
Clarify definitions (contractor, dealer, installation);
Educate stakeholders about regional AC standards;
Facilitate reporting of violations and provide remediation;
Conduct proactive investigations regarding noncompliance (if funding is available);
Require that manufacturers, dealers and installers retain records on AC sales and installations for varying periods up to five years; and 
Ask the Federal Trade Commission to initiate a rulemaking for simplified labeling.

DOE seeks stakeholder comments on the recommendations and revisions which are outlined in the proposed rule found on the DOE webpage
DOE  fines 17 companies for non-certification

Fines sign In 2015, DOE continued their stepped-up enforcement efforts and issued a string of civil penalties to companies that failed to certify that their products meet DOE energy conservation standards. Seventeen companies were fined between $6,000 and $20,000. Topping the list of non-certified products were several types of lighting (exit signs, CFLs, general service fluorescent lamps, and metal halide lamps), refrigerator/freezers, and commercial refrigeration equipment. Companies must pay the specified fine and certify the products within 60 days of signing a compromise agreement with DOE. 

The documentation provides precise details of the violations. For example, the agreement between DOE and P.Q.L., Inc, notes that, for at least 127 days, P.Q.L. distributed 26 different CFL models for sale in the US. For more information on the enforcement actions, click here.
No 'Roomba' for inefficient vacuums in CA
Roomba vacuum
iRobot's Roomba vacuum.

The California Energy Commission reached an agreement with iRobot over vacuum cleaner battery chargers that do not meet the CEC's energy efficiency standards. iRobot agreed to pay $1 million to CEC and to stop selling non-compliant vacuums in California as of December 1, 2015. Consumers of these products may have wasted more than $1 million in energy costs. In a move that will promote even more energy savings, iRobot agreed to use the more efficient battery chargers in five robotic product lines (Roomba, Braava, Scooba, Create, and Looj) throughout North America. 

Robotic vacuum cleaners are one of many products -- including power drills, cell phones, and electric toothbrushes -- that use battery chargers. CEC estimates that the standards for battery chargers once fully implemented will save California ratepayers more than $300 million a year. 

The settlement noted that the $1 million paid to CEC will go toward enforcement efforts.
See the CEC press release  
Ultra-high Def TVs not all ultra efficient

Read the blog post by Noah HorowitzShifting to Ultra High-Def TVs Could Add $1 Billion to Viewers' Annual Energy Bills Unless Efficiency Improves
A+ for standards and labeling programs worldwide

A recent global assessment of national appliance energy efficiency standards and labeling (EESL) programs point to major impacts around the world. The assessment, prepared by Energy Efficient End-Use Equipment (4E) forum of the International Energy Agency (IEA), highlights the following key points: 
  • More than 80 countries now have EESL programs covering more than 50 products.
  • EESL programs are among the most broadly adopted and longest running energy efficiency policies.
  • Energy efficiency of major appliances in these countries have increased at more than three times the underlying rate of technology improvement.
  • One-off improvements of more than 30% have been observed when new EESL programs have been first introduced to a market where few energy efficiency programs had existed previously.
  • The most mature national EESL programs covering a broad range of products are estimated to save between 10% and 25% of national or relevant sectoral energy consumption.
  • In all of the EESL programs reviewed, the national benefits outweighed the additional costs by a ratio of at least 3 to 1, i.e. EESL programs deliver energy and CO2 reductions while also reducing total costs. 
Read more about the role EESL programs play worldwide here: "Achievements of Appliance Energy Efficiency Standards and Labeling Programs" (scroll down to September 2015). 
New sign Standards around the globe
Each month, we'll highlight stories from one or two countries that are developing or adopting efficiency standards. You'll find that the terminology will vary from place to place but the savings add up in any language. In this issue, we'll look at EcoDesign standards for boilers and water heaters in the European Union (EU) and incandescent lighting standards in Japan.  

FROM:, September 16, 2015
According to official EU data compiled by the European Environmental Bureau (EEB), new energy standards for home boilers going into effect this month are expected to take offline the equivalent of 47 Fukushima-type nuclear power stations in Europe by 2020. Boilers are the most common type of heating technology in the EU.

The stricter Ecodesign standards for home boilers - and corresponding labeling requirements went into effect September 26, after years of negotiation between the European Commission and industry representatives. The new standards are at an efficiency levels achieved by condensing technology.

FROM: Japan Times, November 27, 2015 
The government plans to tighten its energy-efficiency standards for lamps to effectively
eliminate production and imports of fluorescents and incandescents. The move is aimed at promoting the replacement of such lamps with light-emitting diode ones, in an effort to reduce carbon dioxide emissions.

According to the industry ministry, the adoption rate for LED lamps in Japan reached 9 percent in fiscal 2012, which ended in March 2013. The government aims to achieve almost 100 percent adoption by fiscal 2030.
State of the States

California sign Plumbing products: After adopting faucet, toilet, and urinal standards in April 2015, the California Energy Commission (CEC) took additional steps to combat the severe drought facing the state. In August 2015, the Commission set new two-tier standards for showerheads. Tier 1 standards, which go into effect July 1, 2016, require a maximum flow rate of 2.0 gallons of water per minute (gpm). Tier 2, due to take effect July 1, 2018, lowers the maximum flow rate to 1.8 gpm. Once the stock is fully turned over, the showerhead 
standards are expected to save about 38 billion gallons of water annually with consumer savings of more than $700 million per year. The CEC also decided to change the compliance dates for lavatory faucet standards to address manufacturer and retailer concerns about availability of the new products. The lavatory faucet standards switched to 1.5 gpm on September 1, 2015 and will bump down to 1.2 gpm on July 1, 2016.

Small diameter lamps Lighting products: In October 2015, the CEC proposed efficiency standards for small diameter directional lamps (left) and efficiency and quality standards for LEDs. The LED quality parameters address color rendering and lifetime, and should help to avoid some of the quality issues which befell CFLs in the early years. CEC is likely to vote on the lighting standards at their meeting in January.  

Computers and displays: The CEC draft report was issued in March 2015, followed by a staff webinar in April 2015. We reported in the last issue that savings could be achieved by decreasing the power in idle mode. Next step is for CEC to propose standards for these products.

Pool pump motors, portable electric spas, and dryers:
We expect that CEC will issue a draft staff report for these products this winter. The initial webinar requesting information on these products took place in January 2014. 

For more info, consult the list of CEC appliance efficiency rulemakings.

For a related article on how California's climate policy impacts the rest of the world, read: "At Paris Climate Talks, Nations looking to California" in USA Today Online.

us map color
Several states are considering standards legislation in 2016. If you would like a copy of the ASAP model bill and a savings analysis for your state, please contact Marianne DiMascio.
DOE update DOE seal

DOE actions below are in addition to actions highlighted in articles and blog posts above.

High intensity discharge (HID) lamps
Final determination: December 2, 2015
In 2010, DOE published a determination concluding that standards for certain HID lamps would be technologically feasible, economically justified, and would result in significant energy savings. 75 FR 37975 (July 1, 2010). Following this determination, DOE held public meetings, received written comments, conducted interviews with manufacturers, and conducted additional research. Based upon this new information, DOE revised its analyses and has now determined that standards for high-pressure sodium lamps are not technologically feasible and standards for mercury vapor and metal halide lamps are not economically justified.    

Ceiling fan light kits

Proposed Rule (NOPR): August 13, 2015
The last standard revision for ceiling fan light kits (CLFK) created a loophole for CFLKs that use candelabra-based lamps, holding these to a lower efficiency standard than other CFLKs. As a result, there was a mass movement of CFLKs to candelabra-based lamps. For the current revision, DOE proposes to eliminate the loophole and collapse three CFLK product classes into one, which should increase energy efficiency. However, DOE has proposed an efficiency standard level that would allow compact fluorescent lamps to continue to be used in CFLKs after the rule takes effect, despite analysis showing that solid state lighting options would be more cost effective. The rule is expected to take effect in 2019.  

Central AC and heat pumps
Test procedure SNOPR: November 9, 2015
DOE released a pre-publication version of this supplemental proposed test method rule in August. Proposed changes would take effect in two stages, with those not affecting measured energy use soon after a final test method is published and those affecting measured energy use concurrent with the next revision to the standards. Near-term changes include those necessary to implement the regional AC standards now in effect, measurement of standby power and updates and clarifications for how individual products are rated, including "dry-ship" units. Longer term changes will better align ratings with field energy use addressing issues such as external static pressure, default fan power and assumed heating load. A final test method should be published early next year. In parallel, a DOE-formed working group is negotiating the next update to the minimum standards. That group is scheduled to complete its work this month.

Commercial Pre-rinse Spray Valves  Pre-rinse spray valve
Notice of Data Availability (NODA): November 20, 2015
This standard covers nozzles most typically used at restaurant dishwashing stations to clear food from cookware and dishware before washing. DOE published a NOPR for the test procedure which added a definition for "spray force" as an important attribute of the product. The NOPR also included a method for measuring spray force. DOE also published a NOPR for the standard which would expand the number of CPSV product classes from one to three (based on spray force) and set maximum water flow-rates in gallons per minute.  Manufacturers could meet the new efficiency levels by redesigning the spray orifices used in their products, and possibly also by switching materials. The challenge for standard-setting for these products is to reduce the amount of water they use, while retaining good performance.  

Battery Chargers
Test procedure NOPR: August 6, 2015
This standard covers battery chargers used with everything from electric shavers to electric forklifts (but not electric automobiles). DOE's original NOPR for this standard issued in 2012 was significantly weaker than California standards for major product categories, threatening to undo energy efficiency progress achieved by the California Energy Commission and other states since the federal standard will pre-empt state standards.  In response to stakeholder comments, DOE revised the proposal and issued the SNOPR, which is largely consistent with the current CA standard.  However, DOE's analysis shows that stronger standards are cost-justified for one very important and still-growing category: cell phone chargers.  Adopting stronger levels for these chargers would significantly increase savings from the new DOE standards. DOE also could increase savings by adopting previously proposed standards for battery chargers used in uninterruptible power supplies. Manufacturers can meet the new standards by using advanced circuitry.

Linear fluorescent lamp ballasts
Framework Document: June 23, 2015
Rapidly evolving ballast and lamp technologies have allowed fluorescent lighting to expand into market niches formerly dominated by HID and other lighting technologies, such as commercial/industrial high-bay applications. However, fluorescent technology has just about peaked in terms of energy efficiency and solid state lighting (SSL) is now coming on strong. Fluorescent lighting is currently used in hundreds of millions of applications across most market sectors and continues to be relatively inexpensive. Unfortunately, loopholes in the current ballast and lamp standards allow inefficient fluorescent lighting systems to persist in the marketplace. The challenge during the upcoming ballast standard revision process is to create a regulatory structure that eliminates loopholes and allows a smooth and rapid transition to SSL. A final rule on a revised ballast standard is projected for late 2019.

Packaged Terminal Air Conditioners and Heat Pumps
Final Rule: June 30, 2015
DOE published a final rule updating the standards for packaged terminal air conditioners and heat pumps (PTACs and PTHPs). PTACs and PTHPs are commonly used to provide heating and cooling for motel rooms. In the final rule, DOE adopted the standards in ASHRAE 90.1-2013 as minimum national standards. The standards remain unchanged for heat pumps, while for PTACs the EER (energy efficiency ratio) requirement was bumped up such that PTACs and PTHPs will have the same cooling efficiency requirement as of January 1, 2017.
ASHRAE Products
Final RuleJuly 17, 2015
DOE published a final rule updating the standards for three of the "ASHRAE Products": commercial three-phase air conditioners and heat pumps (<65,000 Btu/h), water-source heat pumps, and commercial oil-fired water heaters. As with PTACs, DOE adopted the standards in ASHRAE 90.1-2013 as minimum national standards for all three products. The new standards for water-source heat pumps and oil-fired water heaters took effect in October, and the new standards for three-phase ACs and HPs will take effect January 1, 2017. 

DOE published a final rule amending the test procedures for dehumidifiers. Most importantly, the new test procedure will measure dehumidifier capacity and efficiency at an ambient temperature of 65 F rather than the current condition of 80 F. Most dehumidifiers are used in basements, where temperatures are typically much lower than 80 F. The new test procedure will therefore better reflect actual dehumidifier performance in the field. The new test procedure also provides a method to measure the efficiency of whole-home dehumidifiers, which are typically installed as part of a home's HVAC system.
vending machine Beverage Vending Machines
DOE published a final rule amending the test procedures for beverage vending machines. The most significant change from the current test procedure is that that the updated version incorporates methods to capture the energy savings from low-power modes. Low-power modes in vending machines include controls that switch off or dim lights or that allow the temperature of the beverages to rise a few degrees during times when a building is closed, for example.

New AC standards will reduce cooling costs for modular classrooms and offices

Blog post by Joanna Mauer
modular classroom New energy efficiency standards for certain types of specialized air conditioners will reduce cooling costs for many schools as well as other buildings. The new standards issued by the US Department of Energy (DOE) last week will cut cooling energy use by about 18% relative to the current standards.

The final rule sets new minimum efficiency levels for single-package vertical air conditioners and heat pumps, which are commonly used to cool modular classrooms and offices and telecommunications shelters housing electronic equipment. These air conditioners are installed on external building walls.

The final rule adopts the efficiency levels that...

Fun Facts


What percentage of households have the following appliances?  


refrigerator 2012 Appliance                                           Market Penetration

Refrigerator/freezer                       99%
Clothes washer                               93%
Clothes dryer                                  81%
Dishwasher                                     61%
Room air conditioner                      25%
Refrigerator/freezer (2 or more)     19%

Source: Taylor et al.; "Confronting Regulatory Cost and Quality Expectations: An Exploration of Technical Change in Minimum Efficiency Performance Standards." Based on US EIA data 2013.
For more info: 

Marianne DiMascio, Appliance Standards Awareness Project

[email protected]


The ASAP Blog
Read our recent blog posts:

Single-package vertical air conditioners: 

Beverage vending machines: 

ASAP Op-ed in The Hill
Ronald Reagan
Benefits trump costs

The Office of Management and Budget brings cost-benefit analysis to life in the Draft Report to Congress on the Costs and Benefits of Federal Regulation. Benefit cost The report notes that benefits of federal regulations in 2014 range from about $10 billion to $23 billion, and costs from $3-$4.4 billion in 2010 dollars. The benefits outweigh the costs by a WIDE margin.

Peruse the report here and see related op-ed by Stuart Shapiro in The Hill.
New Year's push for DOE?
ice bucket
With 4 DOE final rules expected soon, we may end up celebrating New Year's Eve with a bucket of ice and a barrel of energy savings. New or updated standards for the following products are coming soon:

-Residential boilers
-Commercial furnaces
-Commercial AC
-Commercial and industrial pumps
-Battery chargers

Check our website  to stay up-to-date on the latest developments. Here's to a New Year of savings...and many more!
What's an ECC?

DOE announced a breakthrough in water heater technology. Xergy Inc., with support from DOE, is fine-tuning an electrochemical compressor (ECC) for water heaters which would save 25% energy compared to heat pump technology.
Heating season doesn't have to burn a hole in your budget
Boiler room
Lauren Urbanek of NRDC looks at furnaces, a heating system that accounts for about 40% of household energy use in cold weather. Get the scoop on proposed furnace standards and pass along these 9 helpful tips for saving energy.
10 billion points of light
Points of light
On December 7th, the Clean Energy Ministerial launched a new campaign to deploy10 billion high-efficiency, high-quality light bulbs worldwide.
Click here for more info on the challenge.
Fun Facts 
How well do you know household appliances? Which appliance is found in nearly every US household? Which is found in 6 out of 10 homes? 

Try matching the appliances below with the corresponding percentage per US household.

-Room air conditioner
-Refrigerator/freezer (2 or more)
-Clothes washer
-Clothes dryer
a. 19.2%
b. 25.2%
c. 60.5%
d. 81.1%
e. 93%
f. 99%

See answers below.