RE: Docket Number EERE–2019–BT–STD–0043/RIN 1904–AE61: Notice of Proposed Rulemaking for Energy Conservation Standards for Dehumidifiers

For portable dehumidifiers, we encourage DOE to evaluate and consider adopting levels equivalent to the proposed standards plus the addition of the highest-efficiency single-speed compressors. [...] Additionally, for at least the smaller portable dehumidifier product classes (PCs 1 and 2), DOE’s analysis should consider the highest-efficiency compressors available on the market rather than limiting improved compressor efficiency to that observed in the teardown sample. [...] In the preliminary analysis, the max-tech efficiency levels for all product classes corresponded to products with the highest-efficiency single-speed compressors on the market that are designed for operation with R-32. [...] In comments on the preliminary analysis, one manufacturer expressed concern about the availability of high-efficiency compressors for low-volume product categories (e.g., whole-home units),3 and in response, for the NOPR, DOE limited the improved compressor efficiency for each product class to the highest-efficiency compressor that was observed in the teardown sample for that class.4 This resulted. [...] We understand that the jump in efficiency from PC 2 to PC 3 may be due to the efficiency increases associated with air-to-air heat exchangers, which may not be incorporated in portable units up to 50 pints/day because they can adversely impact consumer utility.8 However, Figure 2, which shows the efficiencies of available models in PCs 1 and 2 , suggests that a jump in efficiency between PC 1 and.