Stop Unaffordable Dishwasher Standards (SUDS) Act

[Bomb#20]

Compared to other appliances*, the dishwasher rule is a paragon of comprehensibility.

Does anyone want to seriously argue that this level of economic micromanagement is good for getting billionaires to innovate anything but lobbying strategies?

Table 1 to Paragraph (a)(1)

Product class	Equations for maximum energy use
(kWh/yr)
based on AV
(ft3)	based on av
(L)
1. Refrigerators and refrigerator-freezers with manual defrost	7.99AV + 225.0	0.282av + 225.0.
1A. All-refrigerators—manual defrost	6.79AV + 193.6	0.240av + 193.6.
2. Refrigerator-freezers—partial automatic defrost	7.99AV + 225.0	0.282av + 225.0.
3. Refrigerator-freezers—automatic defrost with top-mounted freezer without an automatic icemaker	8.07AV + 233.7	0.285av + 233.7.
3-BI. Built-in refrigerator-freezer—automatic defrost with top-mounted freezer without an automatic icemaker	9.15AV + 264.9	0.323av + 264.9.
3I. Refrigerator-freezers—automatic defrost with top-mounted freezer with an automatic icemaker without through-the-door ice service	8.07AV + 317.7	0.285av + 317.7.
3I-BI. Built-in refrigerator-freezers—automatic defrost with top-mounted freezer with an automatic icemaker without through-the-door ice service	9.15AV + 348.9	0.323av + 348.9.
3A. All-refrigerators—automatic defrost	7.07AV + 201.6	0.250av + 201.6.
3A-BI. Built-in All-refrigerators—automatic defrost	8.02AV + 228.5	0.283av + 228.5.
4. Refrigerator-freezers—automatic defrost with side-mounted freezer without an automatic icemaker	8.51AV + 297.8	0.301av + 297.8.
4-BI. Built-In Refrigerator-freezers—automatic defrost with side-mounted freezer without an automatic icemaker	10.22AV + 357.4	0.361av + 357.4.
4I. Refrigerator-freezers—automatic defrost with side-mounted freezer with an automatic icemaker without through-the-door ice service	8.51AV + 381.8	0.301av + 381.8.
4I-BI. Built-In Refrigerator-freezers—automatic defrost with side-mounted freezer with an automatic icemaker without through-the-door ice service	10.22AV + 441.4.2	0.361av + 441.4.
5. Refrigerator-freezers—automatic defrost with bottom-mounted freezer without an automatic icemaker	8.85AV + 317.0	0.312av + 317.0.
5-BI. Built-In Refrigerator-freezers—automatic defrost with bottom-mounted freezer without an automatic icemaker	9.40AV + 336.9	0.332av + 336.9.
5I. Refrigerator-freezers—automatic defrost with bottom-mounted freezer with an automatic icemaker without through-the-door ice service	8.85AV + 401.0	0.312av + 401.0.
5I-BI. Built-In Refrigerator-freezers—automatic defrost with bottom-mounted freezer with an automatic icemaker without through-the-door ice service	9.40AV + 420.9	0.332av + 420.9.
5A. Refrigerator-freezer—automatic defrost with bottom-mounted freezer with through-the-door ice service	9.25AV + 475.4	0.327av + 475.4.
5A-BI. Built-in refrigerator-freezer—automatic defrost with bottom-mounted freezer with through-the-door ice service	9.83AV + 499.9	0.347av + 499.9.
6. Refrigerator-freezers—automatic defrost with top-mounted freezer with through-the-door ice service	8.40AV + 385.4	0.297av + 385.4.
7. Refrigerator-freezers—automatic defrost with side-mounted freezer with through-the-door ice service	8.54AV + 432.8	0.302av + 431.1.
7-BI. Built-In Refrigerator-freezers—automatic defrost with side-mounted freezer with through-the-door ice service	10.25AV + 502.6	0.362av + 502.6.
8. Upright freezers with manual defrost	5.57AV + 193.7	0.197av + 193.7.
9. Upright freezers with automatic defrost without an automatic icemaker	8.62AV + 228.3	0.305av + 228.3.
9I. Upright freezers with automatic defrost with an automatic icemaker	8.62AV + 312.3	0.305av + 312.3.
9-BI. Built-In Upright freezers with automatic defrost without an automatic icemaker	9.86AV + 260.9	0.348av + 260.6.
9I-BI. Built-In Upright freezers with automatic defrost with an automatic icemaker	9.86AV + 344.9	0.348av + 344.9.
10. Chest freezers and all other freezers except compact freezers	7.29AV + 107.8	0.257av + 107.8.
10A. Chest freezers with automatic defrost	10.24AV + 148.1	0.362av + 148.1.
11. Compact refrigerators and refrigerator-freezers with manual defrost	9.03AV + 252.3	0.319av + 252.3.
11A.Compact refrigerators and refrigerator-freezers with manual defrost	7.84AV + 219.1	0.277av + 219.1.
12. Compact refrigerator-freezers—partial automatic defrost	5.91AV + 335.8	0.209av + 335.8.
13. Compact refrigerator-freezers—automatic defrost with top-mounted freezer	11.80AV + 339.2	0.417av + 339.2.
13I. Compact refrigerator-freezers—automatic defrost with top-mounted freezer with an automatic icemaker	11.80AV + 423.2	0.417av + 423.2.
13A. Compact all-refrigerator—automatic defrost	9.17AV + 259.3	0.324av + 259.3.
14. Compact refrigerator-freezers—automatic defrost with side-mounted freezer	6.82AV + 456.9	0.241av + 456.9.
14I. Compact refrigerator-freezers—automatic defrost with side-mounted freezer with an automatic icemaker	6.82AV + 540.9	0.241av + 540.9.
15. Compact refrigerator-freezers—automatic defrost with bottom-mounted freezer	11.80AV + 339.2	0.417av + 339.2.
15I. Compact refrigerator-freezers—automatic defrost with bottom-mounted freezer with an automatic icemaker	11.80AV + 423.2	0.417av + 423.2.
16. Compact upright freezers with manual defrost	8.65AV + 225.7	0.306av + 225.7.
17. Compact upright freezers with automatic defrost	10.17AV + 351.9	0.359av + 351.9.
18. Compact chest freezers	9.25AV + 136.8	0.327av + 136.8.
AV = Total adjusted volume, expressed in ft3, as determined in appendices A and B to subpart B of this part.

av = Total adjusted volume, expressed in Liters.

Don't get overwhelmed. It's merely a piece-wise function. Anyone familiar with math can see you just scroll down to your refrigerator type to find the relevant formula.

Well, that's assuming scrolling down to your refrigerator type will tell you whether you're selling

11. Compact refrigerators and refrigerator-freezers with manual defrost 9.03AV + 252.3​

or

11A.Compact refrigerators and refrigerator-freezers with manual defrost 7.84AV + 219.1​

Billionaires always engage in lobbying. They will engage in lobbying until they win which means a monopoly of everything.

And a lot of the numbers in that table were probably set where they are due to lobbying by some company that was trying to interfere with some competitor's product. Complex regulations are good for monopolies; uniform taxes are good for competition.

It's a shame that their vote means way more than the average vote of a person because right-wingers decided money is speech, but that's how it is for now.

That didn't happen. Citizens United v FEC ruled money isn't speech. If money were speech then the disclosure law wouldn't have been upheld.

In the meantime, Big Dishwasher and their shills are trying to convince everyone that deregulation will save their pocketbooks which won't be the case at all, once the greedy people decide to make the biggest bestest broadest bustiest fridges ever and only make those to maximize profits.

The world be damned. Climate change? Who cares about that when you can make a quick buck!

The notion that DOE regulators are better at bean-counting than corporate bean-counters is without empirical support. If the regulatory regime focused on incentives to achieve its overall goal instead of on compliance with micromanagers who care more about pleasing their overlords than about cost-benefit analysis, then fighting climate change would be a good way to maximize profits and make a quick buck.

 

[barbos]

The notion that DOE regulators are better at bean-counting than corporate bean-counters is without empirical support.

corporate bean-counters are good but only interested in money. If environment and climate stays in the way of that goal then to hell with them.

 

[Bomb#20]

The notion that DOE regulators are better at bean-counting than corporate bean-counters is without empirical support.

corporate bean-counters are good but only interested in money. If environment and climate stays in the way of that goal then to hell with them.

Of course. That's why the way to get them to pay attention to climate is to incentivize it. Put a tax on greenhouse gas emissions and let the corporate bean-counters do what they do best: figure out how to minimize the tax.

 

[barbos]

The notion that DOE regulators are better at bean-counting than corporate bean-counters is without empirical support.

corporate bean-counters are good but only interested in money. If environment and climate stays in the way of that goal then to hell with them.

Of course. That's why the way to get them to pay attention to climate is to incentivize it. Put a tax on greenhouse gas emissions and let the corporate bean-counters do what they do best: figure out how to minimize the tax.

You mean make electricity expensive? Well, it could work but how do you make China to comply? They are not going to tax their electricity and their stuff would become even cheaper.
Also expensive electricity will make lives of poor people miserable, they will start save money by turning off A/C and die from the heat.

 

[Bomb#20]

corporate bean-counters are good but only interested in money. If environment and climate stays in the way of that goal then to hell with them.

Of course. That's why the way to get them to pay attention to climate is to incentivize it. Put a tax on greenhouse gas emissions and let the corporate bean-counters do what they do best: figure out how to minimize the tax.

You mean make electricity expensive? Well, it could work but how do you make China to comply? They are not going to tax their electricity and their stuff would become even cheaper.

Not what I had in mind -- see upthread where ld and I talked about the problems with that approach. I meant have the government measure the power consumption of appliances and tax the manufacturer or importer in proportion. So if China doesn't comply we simply collect the tax at the border.

(Taxing electricity wouldn't necessarily solve the problem anyway, since consumers tend to think short term and discount operating costs years away. (Which is completely rational if they expect their wages to go up with age and experience.))

Also expensive electricity will make lives of poor people miserable, they will start save money by turning off A/C and die from the heat.

Not if the manufacturers minimized their tax bill by making their A/C super-efficient. And if they minimized their tax bill by diverting all the engineering effort they could have used to design super-efficient dishwashers into making their A/C super-efficient, because the bang per buck is far higher with A/Cs, and there wasn't any idiot regulator saying its A/C already complied with an idiot standard and ordering it to put all that effort into a dishwasher whose energy footprint was comparatively negligible, three cheers for them.

 

[barbos]

Not what I had in mind -- see upthread where ld and I talked about the problems with that approach. I meant have the government measure the power consumption of appliances and tax the manufacturer or importer in proportion. So if China doesn't comply we simply collect the tax at the border.

I thought you were against government involvement with this bean counting and setting standards.

Not if the manufacturers minimized their tax bill by making their A/C super-efficient.

This has little to do with manufacturer od A/C. This is building construction issue.
You would have to demolish poor people houses and build new one with better insulation and more complex ventilation and A/C.

 

[Bomb#20]

Not what I had in mind -- see upthread where ld and I talked about the problems with that approach. I meant have the government measure the power consumption of appliances and tax the manufacturer or importer in proportion. So if China doesn't comply we simply collect the tax at the border.

I thought you were against government involvement with this bean counting and setting standards.

Yes, I am. There's no government bean-counting or standard when the government simply measures power consumption and multiplies it by a tax rate. There's no "193.6 kwh/year plus 6.79 kwh/year/cubic foot" standard for whether its legal to sell a refrigerator. There's no "automatic defrost is worth an extra 31.4 kwh/year" bean-counting going on. Nobody in the administrative state needs to make any discretionary decision about the industry. The IRS could do a better job fighting climate change than the DOE.

Not if the manufacturers minimized their tax bill by making their A/C super-efficient.

This has little to do with manufacturer od A/C. This is building construction issue.
You would have to demolish poor people houses and build new one with better insulation and more complex ventilation and A/C.

If that's what you mean, that applies equally whether the A/C is more expensive because of a tax or more expensive because of what it costs the manufacturer to comply with a bunch of detailed regulations.

 

[barbos]

A/C makers has little to do with how much electricity it consumes. So your approach won't work with them at all.

 

[Jimmy Higgins]

The notion that DOE regulators are better at bean-counting than corporate bean-counters is without empirical support.

corporate bean-counters are good but only interested in money. If environment and climate stays in the way of that goal then to hell with them.

Of course. That's why the way to get them to pay attention to climate is to incentivize it. Put a tax on greenhouse gas emissions and let the corporate bean-counters do what they do best: figure out how to minimize the tax.

While taxing carbon emissions would be helpful to equalizing the playing field, are you suggesting that you think it is remotely feasible for the Democrats to pass a carbon tax without a supermajority in the Senate? And then SCOTUS not overturning it because there is nothing in the Constitution allowing taxation on emissions?

 

[scombrid]

Yes, regulatory capture is a thing and results in big companies using regulations to fuck with potential competitors by creating artificial barriers to entry. But, vehicle emissions per mile and per gallon burned are far advanced today compared to when I was a kid because of regulations. There is a place for the administrative agencies to set standards and let the market figure out how to attain them. Stopping or blunting regulatory capture is needed but allowing a free for all in the market just results in the commons getting shit upon.

 

[scombrid]

A/C makers has little to do with how much electricity it consumes. So your approach won't work with them at all.

We replaced our old 4-ton. We dropped our house temperature from 26C to 25C after the swap. Our summer power bill went down $100 per month. That is a huge reduction in KWh per month. The unit we bought is 21 SEER. The regulation calls for a minimum of 14 SEER. So whatever extra we paid to maximize efficiency was on us and the manufacturer is building units more efficient than regulation. Perhaps a tax that makes electricity more expensive would spur the market to respond by more people buying the top end units like we bought?

 

[Playball40]

Is any of this really a concern? I feel like congress could be tackling real issues and now how efficient or inefficient a household dishwasher is.

 

[barbos]

Our summer power bill went down $100 per month.

I suppose old unit was very old and with crappy asynchronous motor. Other than changing motor to more efficient ones, there is very little one can do to improve A/C.

 

[Politesse]

Is any of this really a concern? I feel like congress could be tackling real issues and now how efficient or inefficient a household dishwasher is.

Regulating interstate commerce is the job of congress.

 

[Jimmy Higgins]

People look at the regulations and get upset about how fine tuned it is, but that is just reality. Life is complicated and when you regulate things while keeping an open market, that means several layers of regulation. The US Government could mandate the design of A/C units and that'd greatly simplify the regulating. That doesn't seem like a good idea, so we are stuck with the alternative.

Our summer power bill went down $100 per month.

I suppose old unit was very old and with crappy asynchronous motor. Other than changing motor to more efficient ones, there is very little one can do to improve A/C.

Proper sizing of the system is the best way to cut the cost of use.

 

[Bomb#20]

A/C makers has little to do with how much electricity it consumes. So your approach won't work with them at all.

If that's the case then a regulation requiring a SEER of at least 13 (or 14 if you're in one of 16 designated states) won't work either.

 

[Bomb#20]

corporate bean-counters are good but only interested in money. If environment and climate stays in the way of that goal then to hell with them.

Of course. That's why the way to get them to pay attention to climate is to incentivize it. Put a tax on greenhouse gas emissions and let the corporate bean-counters do what they do best: figure out how to minimize the tax.

While taxing carbon emissions would be helpful to equalizing the playing field, are you suggesting that you think it is remotely feasible for the Democrats to pass a carbon tax without a supermajority in the Senate?

In the current toxic environment in Congress, maybe not, but back in the more bipartisan days, sure. Remember I'm talking about a carbon tax on appliances, not a broad-based tax on all carbon. The Democrats could have made a deal with the Republicans: a tax in exchange for deregulation.

And then SCOTUS not overturning it because there is nothing in the Constitution allowing taxation on emissions?

I don't see a constitutional case against it since it's not a "direct" tax. It's an excise, legally no different from gas and cigarette taxes. Of course, you never know with the current SCOTUS that thinks it's a House of Lords.

 

[Jimmy Higgins]

corporate bean-counters are good but only interested in money. If environment and climate stays in the way of that goal then to hell with them.

Of course. That's why the way to get them to pay attention to climate is to incentivize it. Put a tax on greenhouse gas emissions and let the corporate bean-counters do what they do best: figure out how to minimize the tax.

While taxing carbon emissions would be helpful to equalizing the playing field, are you suggesting that you think it is remotely feasible for the Democrats to pass a carbon tax without a supermajority in the Senate?

In the current toxic environment in Congress, maybe not, but back in the more bipartisan days, sure.

We talking the days when Reagan took the solar panels off the White House? Or when the GOP made it more difficult for President Clinton to go after Bin Laden (as per 9/11 Commission Report)?

Remember I'm talking about a carbon tax on appliances, not a broad-based tax on all carbon.

It needs to be all carbon. Transportation is a notable component. Furthermore, carbon isn't nearly as much the issue with dishwasher and washing machines, especially in the SW, as the consumption of water is.

The Democrats could have made a deal with the Republicans: a tax in exchange for deregulation.

One of the benefits of regulation is it evens the playing field for manufacturers. But that isn't relevant because the GOP has that whole tax pledge thing in the first place!

And then SCOTUS not overturning it because there is nothing in the Constitution allowing taxation on emissions?

I don't see a constitutional case against it since it's not a "direct" tax.

You clearly aren't paying attention to any of the recent decisions in the last couple years. This SCOTUS will rule as their corporate masters want. Because they were selected because they agree with it.

It's an excise, legally no different from gas and cigarette taxes.

Suppose that could be on the chopping block too, but this SCOTUS is getting used to making decisions that aren't particularly consistent or actual decisions.

 

[T.G.G. Moogly]

A big energy consumer is the dryer. Given my electric bills lately and the hot weather, I've been thinking a lot lately of hanging my clothes out to dry in the sun like my grammy did (the first dryer she ever bought was in 1973), but I haven't figured out a great spot yet for a clothesline. Sometimes the olden days had it right.

I haven't used our electric dryer in 30 years. Get one of those umbrella clothes lines. They take up very little space and don't advertise your clothes across the neighborhood. Plus they rotate so you can stand in one place.

 

[scombrid]

Is any of this really a concern? I feel like congress could be tackling real issues and now how efficient or inefficient a household dishwasher is.

Congress created DOE, EPA, USDA, to handle such matters.