Energy Conservation Program: Energy Conservation Standards for Walk-In Coolers and Freezers, 55781-55888 [2013-21530]
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Vol. 78
Wednesday,
No. 176
September 11, 2013
Part II
Department of Energy
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10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for Walk-In
Coolers and Freezers; Proposed Rule
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket No. EERE–2008–BT–STD–0015]
RIN 1904–AB86
Energy Conservation Program: Energy
Conservation Standards for Walk-In
Coolers and Freezers
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking
(NOPR) and public meeting.
AGENCY:
The Energy Policy and
Conservation Act of 1975 (EPCA), as
amended, prescribes energy
conservation standards for various
consumer products and certain
commercial and industrial equipment,
including walk-in coolers and walk-in
freezers. EPCA also requires the U.S.
Department of Energy (DOE) to
determine whether more-stringent,
amended standards would be
technologically feasible and
economically justified, and would save
a significant amount of energy. In this
notice, DOE proposes amended energy
conservation standards for walk-in
coolers and walk-in freezers. The notice
also announces a public meeting to
receive comment on these proposed
standards and associated analyses and
results.
SUMMARY:
DOE will hold a public meeting
on Wednesday, October 9, 2013, from 9
a.m. to 4 p.m., in Washington, DC. The
meeting will also be broadcast as a
webinar. See section VII, ‘‘Public
Participation,’’ for webinar registration
information, participant instructions,
and information about the capabilities
available to webinar participants.
DOE will accept comments, data, and
information regarding this notice of
proposed rulemaking (NOPR) before and
after the public meeting, but no later
than November 12, 2013. See section
VII, ‘‘Public Participation,’’ for details.
ADDRESSES: The public meeting will be
held at the U.S. Department of Energy,
Forrestal Building, Room 8E–089, 1000
Independence Avenue SW.,
Washington, DC 20585. To attend,
please notify Ms. Brenda Edwards at
(202) 586–2945. For more information,
refer to section VII, Public Participation.
Any comments submitted must
identify the NOPR for Energy
Conservation Standards for walk-in
coolers and freezers, and provide docket
number EERE–2008–BT–STD–0015
and/or regulatory information number
(RIN) number 1904–AB86. Comments
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DATES:
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may be submitted using any of the
following methods:
1. Federal eRulemaking Portal:
www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: WICF–2008–STD–0015@
ee.doe.gov. Include the docket number
and/or RIN in the subject line of the
message.
3. Mail: Ms. Brenda Edwards, U.S.
Department of Energy, Building
Technologies Office, Mailstop EE–2J,
1000 Independence Avenue SW.,
Washington, DC, 20585–0121. If
possible, please submit all items on a
CD. It is not necessary to include
printed copies.
4. Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Office, 950
L’Enfant Plaza SW., Suite 600,
Washington, DC 20024. Telephone:
(202) 586–2945. If possible, please
submit all items on a CD, in which case
it is not necessary to include printed
copies.
Written comments regarding the
burden-hour estimates or other aspects
of the collection-of-information
requirements contained in this proposed
rule may be submitted to Office of
Energy Efficiency and Renewable
Energy through the methods listed
above and by email to Chad_S_
Whiteman@omb.eop.gov.
For detailed instructions on
submitting comments and additional
information on the rulemaking process,
see section VII of this document (Public
Participation).
Docket: The docket, which includes
Federal Register notices, public meeting
attendee lists and transcripts,
comments, and other supporting
documents/materials, is available for
review at regulations.gov. All
documents in the docket are listed in
the regulations.gov index. However,
some documents listed in the index,
such as those containing information
that is exempt from public disclosure,
may not be publicly available.
A link to the docket Web page can be
found at: https://www1.eere.energy.gov/
buildings/appliance_standards/
rulemaking.aspx/ruleid/30. This Web
page contains a link to the docket for
this notice on the regulations.gov site.
The regulations.gov Web page contains
instructions on how to access all
documents, including public comments,
in the docket. See section VII for further
information on how to submit
comments through
www.regulations.gov.
For further information on how to
submit a comment, review other public
comments and the docket, or participate
in the public meeting, contact Ms.
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Brenda Edwards at (202) 586–2945 or by
email: Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. Charles Llenza, U.S. Department of
Energy, Office of Energy Efficiency
and Renewable Energy, Building
Technologies Program, EE–2J, 1000
Independence Avenue SW.,
Washington, DC 20585–0121.
Telephone: (202) 586–2192. Email:
walk-in_coolers_and_walk-in_
freezers@EE.Doe.Gov.
Mr. Michael Kido, U.S. Department of
Energy, Office of the General Counsel,
GC–71, 1000 Independence Avenue
SW., Washington, DC 20585–0121.
Telephone: (202) 586–8145. Email:
Michael.Kido@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for
Walk-In Coolers and Freezers
III. General Discussion
A. Component Level Standards
B. Test Procedures and Metrics
1. Panels
2. Doors
3. Refrigeration
C. Prescriptive Versus Performance
Standards
D. Certification, Compliance, and
Enforcement
E. Technological Feasibility
1. General
2. Maximum Technologically Feasible
Levels
F. Energy Savings
1. Determination of Savings
2. Significance of Savings
G. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and
Consumers
b. Life-Cycle Costs
c. Energy Savings
d. Lessening of Utility or Performance of
Products
e. Impact of Any Lessening of Competition
f. Need of the Nation to Conserve Energy
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion
A. Market and Technology Assessment
1. Definitions Related to Walk-In Coolers
and Freezers
a. Display Doors
b. Freight Doors
c. Passage Doors
2. Equipment Included in this Rulemaking
a. Panels and Doors
b. Refrigeration System
3. Equipment Classes
a. Panels and Doors
b. Refrigeration Systems
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4. Technology Assessment
B. Screening Analysis
1. Technologies That Do Not Affect Rated
Performance
2. Screened-Out Technologies
a. Panels and Doors
b. Refrigeration
3. Screened-In Technologies
C. Engineering Analysis
1. Representative Equipment
a. Panels and Doors
b. Refrigeration
2. Energy Modeling Methodology
a. Refrigeration
3. Cost Assessment Methodology
a. Teardown Analysis
b. Cost Model
c. Manufacturing Production Cost
d. Manufacturing Markup
e. Shipping Costs
4. Baseline Specifications
a. Panels and Doors
b. Refrigeration
5. Design Options
a. Panels and Doors
b. Refrigeration
6. Cost-Efficiency Results
a. Panels and Doors
b. Refrigeration
c. Numerical Results
D. Markups Analysis
E. Energy Use Analysis
1. Sizing Methodology for the Refrigeration
System
2. Oversize Factors
3. Product Load
4. Other Issues
F. Life-Cycle Cost and Payback Period
Analyses
1. Equipment Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Energy Price Projections
6. Maintenance and Repair Costs
7. Product Lifetime
8. Discount Rates
9. Compliance Date of Standards
10. Base-Case and Standards-Case
Efficiency Distributions
11. Inputs to Payback Period Analysis
12. Rebuttable-Presumption Payback
Period
G. National Impact Analysis—National
Energy Savings and Net Present Value
1. Shipments
a. Share of Shipments and Stock Across
Equipment Classes
b. Lifetimes and Replacement Rates
c. Growth Rates
d. Other Issues
2. Forecasted Efficiency in the Base Case
and Standards Cases
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3. National Energy Savings
4. Net Present Value of Consumer Benefit
5. Benefits from Effects of Standards on
Energy Prices
H. Consumer Subgroup Analysis
I. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model
Analysis
a. Government Regulatory Impact Model
Key Inputs
b. Government Regulatory Impact Model
Scenarios
3. Discussion of Comments
a. Cumulative Regulatory Burden
b. Inventory Levels
c. Manufacturer Subgroup Analysis
4. Manufacturer Interviews
a. Cost of testing
b. Enforcement and Compliance
c. Profitability Impacts
d. Excessive Conversion Cost
e. Disproportionate Impact on Small
Businesses
f. Refrigerant Phase-Out
J. Employment Impact Analysis
K. Utility Impact Analysis
L. Emissions Analysis
M. Monetizing Carbon Dioxide and Other
Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in
Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions
Reductions
V. Analytical Results
A. Trial Standard Levels
1. Trial Standard Level Selection Process
2. Trial Standard Level Equations
B. Economic Justification and Energy
Savings
1. Economic Impacts on Commercial
Customers
a. Life-Cycle Cost and Payback Period
b. Life-Cycle Cost Subgroup Analysis
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Direct Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Small Manufacturer SubGroup
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Amount and Significance of Energy
Savings
b. Net Present Value of Consumer Costs
and Benefits
c. Employment Impacts
4. Impact on Utility or Performance of
Equipment
5. Impact of Any Lessening of Competition
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6. Need of the Nation to Conserve Energy
7. Other Factors
C. Proposed Standard
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866
and 13563
B. Review Under the Regulatory Flexibility
Act
C. Review Under the Paperwork Reduction
Act
D. Review Under the National
Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates
Reform Act of 1995
H. Review Under the Treasury and General
Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General
Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality
Bulletin for Peer Review
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared
General Statements for Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Summary of the Proposed Rule
DOE proposes creating new
performance-based energy conservation
standards for walk-in coolers and walkin freezers (collectively, ‘‘walk-ins’’ or
‘‘WICFs’’). The proposed standards,
which are expressed as an annual walkin energy factor (AWEF) for refrigeration
systems, the maximum allowable Ufactor expressed as a function of the
ratio of edge area to core area for panels,
and the maximum allowable daily
energy use expressed as a function of
the surface area for non-display and
display doors, are shown in Table I.1.
These proposed standards, if adopted,
would apply to all products listed in
Table I.1 and manufactured in, or
imported into, the United States on or
after 3 years after the publication date
of any final rule establishing energy
conservation standards for walk-ins.
Appendix 10D of the TSD lists the
technologies that DOE assumes
manufacturers will use to meet the
proposed standards.
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
A. Benefits and Costs to Consumers
Table I–2 presents DOE’s evaluation
of the economic impacts of the proposed
standards on consumers of walk-in
coolers and freezers, as measured by the
shipment-weighted average life-cycle
cost (LCC) savings 1 and the median
payback period.2 The average LCC
savings are positive for all equipment
classes. At TSL 4, the percentage of
customers who experience net benefits
or no impacts ranges from 55 to 100
percent, and the percentage of
customers experiencing a net cost
ranges from 0 to 45 percent. Chapter 11
55785
presents the LCC subgroup analysis on
groups of customers that may be
disproportionately affected by the
proposed standard. The installed cost
increase over the 9-year analysis period
(2017–2025) for the proposed TSL is
1.98 billion discounted at 7 percent.
TABLE I–2—SHIPMENT-WEIGHTED AVERAGE IMPACTS OF PROPOSED STANDARDS (TSL 4) ON CONSUMERS OF WALK-IN
COOLERS AND WALK-IN FREEZERS
Average LCC
savings (2012$)
Equipment class
Refrigeration System Class:*
DC.M.I ...............................................................................................................................
DC.M.O .............................................................................................................................
DC.L.I ................................................................................................................................
DC.L.O ..............................................................................................................................
MC.M ................................................................................................................................
MC.L .................................................................................................................................
Panel Class:
SP.M** ..............................................................................................................................
SP.L** ...............................................................................................................................
FP.L** ...............................................................................................................................
Non-Display Door Class:
PD.M .................................................................................................................................
PD.L ..................................................................................................................................
FD.M .................................................................................................................................
FD.L ..................................................................................................................................
Display Door Class:
DD.M .................................................................................................................................
DD.L ..................................................................................................................................
Median payback period
(years)
$611
3,195
1,117
2,664
1,724
2,061
4.4
2.2
2.7
2.3
0.5
0.4
8
72
30
4.5
3.6
4.5
0.3
52
1
136
5.5
4.7
5.4
2.9
228
200
2.2
N/A
* For dedicated condensing (DC) refrigeration systems, results include both capacity ranges.
** Results are per 100 square feet.
freezer refrigeration systems, panels,
and doors in the base case (without new
standards) is $851 million in 2012$.
Under the proposed standards, DOE
expects the impact on INPV to range
from no change to a 9 percent decrease.
1 Life-cycle cost (LCC) of commercial refrigeration
equipment is the cost to customers of owning and
operating the equipment over the entire life of the
equipment. Life-cycle cost savings are the
reductions in the life-cycle costs due to amended
energy conservation standards when compared to
the life-cycle costs of the equipment in the absence
of amended energy conservation standards. Further
discussion of the LCC analysis can be found in
Chapter 8 of the TSD.
2 Payback period (PBP) refers to the amount of
time (in years) it takes customers to recover the
increased installed cost of equipment associated
with new or amended standards through savings in
operating costs. Further discussion of the PBP can
be found in Chapter 8 of the TSD.
3 These rates were used to discount future cash
flows in the Manufacturer Impact Analysis. The
discount rates were calculated from SEC filings and
then adjusted based on cost of capital feedback
collected from walk-in door, panel, and
refrigeration manufacturers in MIA interviews. For
a detailed explanation of how DOE arrived at these
discount rates, refer to Chapter 12 of the NOPR
TSD.
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The industry net present value (INPV)
is the sum of the discounted cash flows
to the industry from the base year
through the end of the analysis period
(2013 to 2046). Using real discount rates
of 10.5 percent for panels, 9.4 percent
for doors, and 10.4 percent for
refrigeration 3, DOE estimates that the
industry net present value (INPV) for
manufacturers of walk-in cooler and
B. Impact on Manufacturers
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
Total industry conversion costs
estimated to be $51 million are assumed
to be incurred in the years prior to the
start of compliance with the standards.
Based on DOE’s interviews with the
manufacturers of walk-in coolers and
walk-in freezers, DOE does not expect
significant loss of employment.
C. National Benefits 4
DOE’s analyses indicate that the
proposed standards would save a
significant amount of energy. The
lifetime full-fuel-cycle energy savings
for walk-in coolers and freezers
purchased in the 30-year period that
begins in the year of compliance with
new standards (2017–2046) amount to
5.39 quadrillion British thermal units
(quads). The average annual energy
savings over the life of walk-in coolers
and freezers purchased in 2017 through
2046 is 0.18 quads, which is equivalent
to 14.8 percent of the annual U.S
commercial refrigeration sector energy.5
The cumulative net present value
(NPV) of total consumer costs and
savings of the proposed standards
ranges from $8.6 billion (at a 7-percent
discount rate) to $24.3 billion (at a 3percent discount rate) for walk-in
coolers and freezers. This NPV
expresses the estimated total value to
customers of future operating cost
savings minus the estimated increased
product costs for products purchased in
2017–2046.
In addition, the proposed standards
would have significant environmental
benefits. The energy savings would
result in cumulative emission
reductions of 298 million metric tons
(Mt) 6 of carbon dioxide (CO2), 1,428
thousand tons of methane, 379.5
thousand tons of sulfur dioxide (SO2),
443.8 thousand tons of nitrogen oxides
(NOX), and 0.6 tons of mercury (Hg).7 8
The value of the CO2 reductions is
calculated using a range of values per
metric ton of CO2 (otherwise known as
the Social Cost of Carbon, or SCC)
developed by an interagency process.
The derivation of the SCC values is
discussed in section IV.M. DOE
estimates the net present monetary
value of the CO2 emissions reduction is
between $1.9 billion and $27.5 billion,
depending on the SCC value used, over
a 30-year analysis period. DOE also
estimates the net present monetary
value of the NOX emissions reduction is
$243 million at a 7-percent discount rate
and $553 million at a 3-percent discount
rate over a 30-year analysis period. Over
a 9-year analysis period, DOE estimates
the net present monetary value of the
CO2 emissions reduction is between
$0.33 billion and $4.07 billion,
depending on the SCC value used, while
the net present monetary value of the
NOX emissions reduction is $70.5
million at a 7-percent discount rate and
$99.8 million at a 3-percent discount
rate.9 DOE notes that the estimated total
social benefits of the rule outweigh the
costs whether a 30-year or a 9-year
analysis period is used.
Table I–3 summarizes the national
economic costs and benefits expected to
result from the proposed standards for
walk-in coolers and walk-in freezers.
TABLE I–3—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF WALK-IN COOLER AND WALK-IN FREEZER
ENERGY CONSERVATION STANDARDS
Present value
Billion 2012$
Category
Discount rate
(percent)
Benefits
Operating Cost Savings .......................................................................................................
12.4
31.6
1.9
9.0
14.4
27.5
0.24
0.55
21.6
41.1
7
3
17.8
33.9
Total Benefits† ..............................................................................................................
7
3
3.8
7.2
CO2 Reduction Monetized Value (at $12.9/t case)* ............................................................
CO2 Reduction Monetized Value (at $40.8/t case)* ............................................................
CO2 Reduction Monetized Value (at $62.2/t case)* ............................................................
CO2 Reduction Monetized Value (at $117.0/t case)* ..........................................................
NOX Reduction Monetized Value (at $2,639/Ton)** ...........................................................
7
3
5
3
2.5
3
7
3
7
3
Costs
Incremental Installed Costs .................................................................................................
Net Benefits
Including CO2 and NOX Reduction Monetized Value .........................................................
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* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC
from the integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate an escalation factor.
4 All monetary values in this section are
expressed in 2012 dollars and are discounted to
2013.
5 Total U.S. commercial sector energy (source
energy) used for refrigeration in 2010 was 1.21
quads. Source: U.S. Department of Energy—Office
of Energy Efficiency and Renewable Energy.
Buildings Energy Data Book, Table 3.1.4, 2010
Commercial Energy End-Use Splits, by Fuel Type
(Quadrillion Btu). 2012. (Last accessed April 23,
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2013.) https://buildingsdatabook.eren.doe.gov/
TableView.aspx?table=3.1.4
6 A metric ton is equivalent to 1.1 short tons.
Results for NOX and Hg are presented in short tons.
7 DOE calculates emissions reductions relative to
the Annual Energy Outlook (AEO) 2013 Reference
case, which generally represents current legislation
and environmental regulations for which
implementing regulations were available as of
December 31, 2012.
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8 DOE also estimated CO and CO equivalent
2
2
(CO2eq) emissions that occur through 2030 (CO2eq
includes greenhouse gases such as CH4 and N2O).
The estimated emissions reductions through 2030
are 79 million metric tons CO2, 7,897 thousand tons
CO2eq for CH4, and 338 thousand tons CO2eq for
N2O.
9 DOE has decided to await further guidance
regarding consistent valuation and reporting of Hg
emissions before it monetizes Hg in its rulemakings.
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55787
** The value represents the average of the low and high NOX values used in DOE’s analysis.
† Total Benefits for both the 3 percent and 7 percent cases are derived using the CO2 reduction monetized value series corresponding to average SCC with 3-percent discount rate.
The benefits and costs of today’s
proposed standards, for equipment sold
in 2017–2046, can also be expressed in
terms of annualized values. The
annualized monetary values are the sum
of (1) the annualized national economic
value of the benefits from consumer
operation of equipment that meets the
proposed standards (consisting
primarily of operating cost savings from
using less energy, minus increases in
equipment purchase and installation
costs, and (2) the annualized monetary
value of the benefits of emission
reductions, including CO2 emission
reductions.10
Although combining the values of
operating savings and CO2 emission
reductions provides a useful
perspective, two issues should be
considered. First, the national operating
savings are domestic U.S. consumer
monetary savings that occur as a result
of market transactions while the value
of CO2 reductions is based on a global
value. Second, the assessments of
operating cost savings and CO2 savings
are performed with different methods
that use different time frames for
analysis. The national operating cost
savings is measured for the lifetime of
walk-ins shipped from 2017–2046. The
SCC values, on the other hand, reflect
the present value of some future
climate-related impacts resulting from
the emission of one ton of carbon
dioxide in each year. These impacts
continue well beyond 2100.
Table I–4 shows the estimates of
annualized benefits and costs of the
proposed standards. (All monetary
values below are expressed in 2012$.)
The results under the primary estimate
are as follows. Using a 7-percent
discount rate for benefits and costs other
than CO2 reduction, for which DOE
used a 3-percent discount rate along
with the average SCC series that uses a
3-percent discount rate, the cost of the
standards proposed in today’s rule is
$367 million per year in increased
equipment costs, while the annualized
benefits are $1.225 billion per year in
reduced equipment operating costs,
$499 million in CO2 reductions, and $24
million in reduced NOX emissions. In
this case, the net benefit amounts to
$1.382 billion per year. Using a 3percent discount rate for all benefits and
costs and the average SCC series, the
cost of the standards proposed in
today’s rule is $399 million per year in
increased equipment costs, while the
benefits are $1.606 billion per year in
reduced operating costs, $499 million in
CO2 reductions, and $31 million in
reduced NOX emissions. In this case, the
net benefit amounts to $1.737 billion
per year.
TABLE I–4—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR WALK-IN COOLERS AND WALK-IN
FREEZERS
Primary
estimate*
Discount rate
Low net
benefits
estimate*
(million 2012$/year)
High net
benefits
estimate*
Benefits
Operating Cost Savings ..........................
CO2 Reduction Monetized
$12.9t case)**.
CO2 Reduction Monetized
$40.8/t case)**.
CO2 Reduction Monetized
$62.2/t case)**.
CO2 Reduction Monetized
$117.0/t case)**.
NOX Reduction Monetized
$2,639/Ton)**.
Value (at
7% ..........................
3% ..........................
5% ..........................
1,225
1,606
142
1,188
1,544
142
1,279
1,687
142
Value (at
3% ..........................
499
499
499
Value (at
2.50% .....................
739
739
739
Value (at
3% ..........................
1,534
1,534
1,534
Value (at
7% ..........................
24
24
24
31
1,748
1,249
1,637
2,136
31
1,712
1,212
1,574
2,074
31
1,803
1,303
1,718
2,217
367
399
377
414
357
385
1,382
883
1,238
1,335
835
1,160
1,446
946
1,333
Total Benefits† .................................
3%
7%
7%
3%
3%
..........................
plus CO2 range
..........................
..........................
plus CO2 range
Costs
Total Incremental Installed Costs ...........
7% ..........................
3% ..........................
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Net Benefits
Total† ......................................................
7% plus CO2 range
7% ..........................
3% ..........................
10 DOE used a two-step calculation process to
convert the time-series of costs and benefits into
annualized values. First, DOE calculated a present
value in 2013, the year used for discounting the
NPV of total consumer costs and savings, for the
time-series of costs and benefits using discount
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rates of three and seven percent for all costs and
benefits except for the value of CO2 reductions. For
the latter, DOE used a range of discount rates, as
shown in Table I.3. From the present value, DOE
then calculated the fixed annual payment over a 30year period (2014 through 2043) that yields the
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same present value. The fixed annual payment is
the annualized value. Although DOE calculated
annualized values, this does not imply that the
time-series of cost and benefits from which the
annualized values were determined is a steady
stream of payments.
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TABLE I–4—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR WALK-IN COOLERS AND WALK-IN
FREEZERS—Continued
Primary
estimate*
Discount rate
(million 2012$/year)
3% plus CO2 range
Low net
benefits
estimate*
1,737
High net
benefits
estimate*
1,660
1,832
tkelley on DSK3SPTVN1PROD with PROPOSALS2
* This table presents the annualized costs and benefits associated with walk-in coolers and freezers shipped in 2017¥2046. These results include benefits to consumers which accrue after 2046 from the walk-in coolers and freezers purchased in 2017–2046. Costs incurred by manufacturers, some of which may be incurred in preparation for the rule, are not directly included, but are indirectly included as part of incremental
equipment costs. The Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the AEO2013 Reference case,
Low Estimate, and High Estimate, respectively. In addition, incremental product costs reflect a medium decline rate for projected product price
trends in the Primary Estimate, a low decline rate for projected product price trends using a Low Benefits Estimate, and a high decline rate for
projected product price trends using a High Benefits Estimate.
** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC
from the three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile
SCC estimate across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature
change further out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate
an escalation factor. The value for NOX is the average of the low and high values used in DOE’s analysis.
† Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount
rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled
discount rate, and those values are added to the full range of CO2 values.
DOE has tentatively concluded that
the proposed standards represent the
maximum improvement in energy
efficiency that is technologically
feasible and economically justified. DOE
further notes that manufacturers already
produce commercially available
equipment that achieve these levels for
most, if not all, equipment classes
covered by today’s proposal. Based on
the analyses described above, DOE has
tentatively concluded that the benefits
of the proposed standards to the Nation
(energy savings, positive NPV of
consumer benefits, consumer LCC
savings, and emission reductions)
would outweigh the burdens (loss of
INPV for manufacturers).
DOE also considered more-stringent
and less-stringent efficiency levels as
trial standard levels (TSLs), and is still
considering them in this rulemaking.
However, DOE has tentatively
concluded that the potential burdens of
the more-stringent efficiency levels
would outweigh the projected benefits.
Based on consideration of the public
comments DOE receives in response to
this notice and related information
collected and analyzed during the
course of this rulemaking effort, DOE
may adopt efficiency levels presented in
this notice that are either higher or
lower than the proposed standards, or
some combination of level(s) that
incorporate the proposed standards in
part.
II. Introduction
The following section briefly
discusses the statutory authority
underlying today’s proposal, as well as
some of the relevant historical
background related to walk-ins.
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A. Authority
Title III, Part C of EPCA, Public Law
94–163 (42 U.S.C. 6311–6317, as
codified), added by Public Law 95–619,
Title IV, section 441(a), established the
Energy Conservation Program for
Certain Industrial Equipment, a program
covering certain industrial equipment,
which includes the walk-in coolers and
walk-in freezers that are the focus of this
notice.11 12 (42 U.S.C. 6311(1), (20),
6313(f) and 6314(a)(9)) Walk-ins consist
of two major pieces—the structural
‘‘envelope’’ within which items are
stored and a refrigeration system that
cools the air in the envelope’s interior.
DOE’s energy conservation program
for covered equipment generally
consists of four parts: (1) Testing; (2)
labeling; (3) the establishment of
Federal energy conservation standards;
and (4) certification and enforcement
procedures. For walk-ins, DOE is
responsible for the entirety of this
program. The DOE test procedures for
walk-ins, including those prescribed by
Congress in EISA 2007 and those
established by DOE in the test
procedure final rule, currently appear at
title 10 of the Code of Federal
Regulations (CFR) part 431, section 304.
Any new or amended performance
standards that DOE prescribes for walkins must achieve the maximum
improvement in energy efficiency that is
technologically feasible and
economically justified. (42 U.S.C.
6313(f)(4)(A)) For purposes of this
rulemaking, DOE also plans to adopt
11 All references to EPCA in this document refer
to the statute as amended through the American
Energy Manufacturing Technical Corrections Act
(AEMTCA), Public Law 112–210 (Dec. 18, 2012).
12 For editorial reasons, upon codification in the
U.S. Code, Part C was re-designated Part A–1.
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those standards that are likely to result
in a significant conservation of energy
that satisfies both of these requirements.
See 42 U.S.C. 6295(o)(3)(B).
Technological feasibility is
determined by examining technologies
or designs that could be used to improve
the efficiency of the covered equipment.
DOE considers a design to be
technologically feasible if it is in use by
the relevant industry or if research has
progressed to the development of a
working prototype.
In ascertaining whether a particular
standard is economically justified, DOE
considers, to the greatest extent
practicable, the following factors:
1. The economic impact of the
standard on manufacturers and
consumers of the equipment subject to
the standard;
2. The savings in operating costs
throughout the estimated average life of
the covered equipment in the type (or
class) compared to any increase in the
price, initial charges, or maintenance
expenses for the covered equipment that
are likely to result from the imposition
of the standard;
3. The total projected amount of
energy or, as applicable, water savings
likely to result directly from the
imposition of the standard;
4. Any lessening of the utility or the
performance of the covered equipment
likely to result from the imposition of
the standard;
5. The impact of any lessening of
competition, as determined in writing
by the Attorney General, that is likely to
result from the imposition of the
standard;
6. The need for national energy and
water conservation; and
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7. Other factors the Secretary of
Energy (Secretary) considers relevant.
(42 U.S.C. 6295(o)(2)(B)(i) (I)–(VII))
DOE does not plan to prescribe an
amended or new standard if interested
persons have established by a
preponderance of the evidence that the
standard is likely to result in the
unavailability in the United States of
any covered product type (or class) of
performance characteristics (including
reliability), features, sizes, capacities,
and volumes that are substantially the
same as those generally available in the
United States. Further, under EPCA’s
provisions for consumer products, there
is a rebuttable presumption that a
standard is economically justified if the
Secretary finds that the additional cost
to the consumer of purchasing a product
complying with an energy conservation
standard level will be less than three
times the value of the energy savings
during the first year that the consumer
will receive as a result of the standard,
as calculated under the applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii))
For purposes of its walk-in analysis,
DOE plans to account for these factors.
Additionally, when a type or class of
covered equipment such as walk-ins has
two or more subcategories, in
promulgating standards for such
equipment, DOE often specifies more
than one standard level. DOE generally
will adopt a different standard level
than that which applies generally to
such type or class of products for any
group of covered products that have the
same function or intended use if DOE
determines that products within such
group (A) consume a different kind of
energy than that consumed by other
covered products within such type (or
class) or (B) have a capacity or other
performance-related feature that other
products within such type (or class) do
not have, and which justifies a higher or
lower standard. Generally, in
determining whether a performancerelated feature justifies a different
standard for a group of products, DOE
considers such factors as the utility to
the consumer of the feature and other
factors DOE deems appropriate. In a rule
prescribing such a standard, DOE
typically includes an explanation of the
basis on which such higher or lower
level was established. DOE plans to
follow a similar process in the context
of today’s rulemaking.
DOE notes that since the inception of
the statutory requirements setting
standards for walk-ins, Congress has
since made one additional amendment
to those provisions. That amendment
provides that the wall, ceiling, and door
insulation requirements detailed in 42
U.S.C. 6313(f)(1)(C) do not apply to the
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given component if the component’s
manufacturer has demonstrated to the
Secretary’s satisfaction that ‘‘the
component reduces energy consumption
at least as much’’ if those specified
requirements were to apply to that
manufacturer’s component. American
Energy Manufacturing Technology
Corrections Act, Public Law 112–210,
Section 2 (Dec. 18, 2012) (codified at 42
U.S.C. 6313(f)(6)) (AEMTCA).
Manufacturers seeking to avail
themselves of this provision must
‘‘provide to the Secretary all data and
technical information necessary to fully
evaluate its application.’’ Id. DOE is
proposing to codify this amendment
into its regulations.
Since its codification, one company,
HH Technologies, submitted data on
May 24, 2013, demonstrating that its
RollSeal doors satisfied this new
AEMTCA provision. DOE reviewed
these data and all other submitted
information and concluded that the
RollSeal doors at issue satisfied 42
U.S.C. 6313(f)(6). Accordingly, DOE
issued a determination letter on June 14,
2013, indicating that these doors met
Section 6313(f)(6) and that the
applicable insulation requirements did
not apply to the RollSeal doors HH
Technologies identified. Nothing in this
proposed rule affects the previous
determination regarding HH
Technologies.
Federal energy conservation
requirements generally pre-empt state
laws or regulations concerning energy
conservation testing, labeling, and
standards. (42 U.S.C. 6297(a); 42 U.S.C.
6316(b)) However, EPCA provides that
for walk-ins in particular, any state
standard issued before publication of
the final rule shall not be pre-empted
until the standards established in the
final rule take effect. (42 U.S.C
6316(h)(2)(B))
Where applicable, DOE generally
considers standby and off mode energy
use for certain covered products or
equipment when developing energy
conservation standards. See 42 U.S.C.
6295(gg)(3). Because the vast majority of
walk-in coolers and walk-in freezers
operate continuously to keep their
contents cold at all times, DOE is not
proposing standards for standby and off
mode energy use.
B. Background
1. Current Standards
EPCA defines a walk-in cooler and a
walk-in freezer as an enclosed storage
space refrigerated to temperatures
above, and at or below, respectively,
32 °F that can be walked into. The
statute also defines walk-in coolers and
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55789
freezers as having a total chilled storage
area of less than 3,000 square feet,
excluding products designed and
marketed exclusively for medical,
scientific, or research purposes. (42
U.S.C 6311(20)) EPCA also provides
prescriptive standards for walk-in
coolers and freezers manufactured on or
after January 1, 2009, which are
described below.
First, EPCA sets forth general
prescriptive standards for walk-ins.
Walk-ins must have automatic door
closers that firmly close all walk-in
doors that have been closed to within 1
inch of full closure, for all doors
narrower than 3 feet 9 inches and
shorter than 7 feet; walk-ins must also
have strip doors, spring hinged doors, or
other methods of minimizing infiltration
when doors are open. Walk-ins must
also contain wall, ceiling, and door
insulation of at least R–25 for coolers
and R–32 for freezers, excluding glazed
portions of doors and structural
members, and floor insulation of at least
R–28 for freezers. Walk-in evaporator
fan motors of under 1 horsepower and
less than 460 volts must be
electronically commutated motors
(brushless direct current motors) or
three-phase motors, and walk-in
condenser fan motors of under 1
horsepower must use permanent split
capacitor motors, electronically
commutated motors, or three-phase
motors. Interior light sources must have
an efficacy of 40 lumens per watt or
more, including any ballast losses; lessefficacious lights may only be used in
conjunction with a timer or device that
turns off the lights within 15 minutes of
when the walk-in is unoccupied. See 42
U.S.C. 6313(f)(1).
Second, EPCA sets forth new
requirements related to electronically
commutated motors for use in walk-ins.
See 42 U.S.C. 6313(f)(2)). Specifically,
in those walk-ins that use an evaporator
fan motor with a rating of under 1
horsepower and less than 460 volts, that
motor must be either a three-phase
motor or an electronically commutated
motor unless DOE determined prior to
January 1, 2009 that electronically
commutated motors are available from
only one manufacturer. (42 U.S.C.
6313(f)(2)(A)) DOE determined by
January 1, 2009 that these motors were
available from more than one
manufacturer; thus, according to EPCA,
walk-in evaporator fan motors with a
rating of under 1 horsepower and less
than 460 volts must be either threephase motors or electronically
commutated motors. DOE documented
this determination in the rulemaking
docket as docket ID EERE–2008–BT–
STD–0015–0072. This document can be
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found at https://www.regulations.gov/
#!documentDetail;D=EERE-2008-BTSTD-0015-0072. Additionally, EISA
provided DOE with the authority to
permit the use of other types of motors
as evaporative fan motors—if DOE
determines that, on average, those other
motor types use no more energy in
evaporative fan applications than
electronically commutated motors. (42
U.S.C. 6313(f)(2)(B)) DOE is unaware of
any other motors that would offer
performance levels comparable to the
electronically commutated motors
required by Congress. Accordingly, all
evaporator motors rated at under 1
horsepower and under 460 volts must
be electronically commutated motors or
three-phase motors.
Third, EPCA sets forth additional
requirements for walk-ins with
transparent reach-in doors. Freezer
doors must have triple-pane glass with
either heat-reflective treated glass or gas
fill for doors and windows for freezers.
Cooler doors must have either doublepane glass with treated glass and gas fill
or triple-pane glass with treated glass or
gas fill. (42 U.S.C. 6313(f)(3)(A)–(B)) For
walk-ins with transparent reach-in
doors, EISA also prescribed specific
anti-sweat heater-related requirements:
Walk-ins without anti-sweat heater
controls must have a heater power draw
of no more than 7.1 or 3.0 watts per
square foot of door opening for freezers
and coolers, respectively. Walk-ins with
anti-sweat heater controls must either
have a heater power draw of no more
than 7.1 or 3.0 watts per square foot of
door opening for freezers and coolers,
respectively, or the anti-sweat heater
controls must reduce the energy use of
the heater in a quantity corresponding
to the relative humidity of the air
outside the door or to the condensation
on the inner glass pane. See 42 U.S.C.
6313(f)(3)(C)–(D).
2. History of Standards Rulemaking for
Walk-In Coolers and Freezers
EPCA directs the Secretary to issue
performance-based standards for walkins that would apply to equipment
manufactured 3 years after the final rule
is published, or 5 years if the Secretary
determines by rule that a 3-year period
is inadequate. (42 U.S.C. 6313(f)(4))
DOE initiated the current rulemaking
by publishing a notice announcing the
availability of its ‘‘Walk-In Coolers and
Walk-In Freezers Energy Conservation
Standard Framework Document’’ and a
meeting to discuss the document. The
notice also solicited comment on the
matters raised in the document. 74 FR
411 (Jan 6, 2009). More information on
the framework document is available at:
https://www1.eere.energy.gov/buildings/
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18:15 Sep 10, 2013
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appliance_standards/rulemaking.aspx/
ruleid/30. The framework document
described the procedural and analytical
approaches that DOE anticipated using
to evaluate energy conservation
standards for walk-ins and identified
various issues to be resolved in
conducting this rulemaking.
DOE held the framework public
meeting on February 4, 2009, in which
it: (1) Presented the contents of the
framework document; (2) described the
analyses it planned to conduct during
the rulemaking; (3) sought comments
from interested parties on these
subjects; and (4) in general, sought to
inform interested parties about, and
facilitate their involvement in, the
rulemaking. Major issues discussed at
the public meeting included: (1) The
scope of coverage for the rulemaking; (2)
development of a test procedure and
appropriate test metrics; (3)
manufacturer and market information,
including distribution channels; (4)
equipment classes, baseline units, and
design options to improve efficiency;
and (5) life-cycle costs to consumers,
including installation, maintenance, and
repair costs, and any consumer
subgroups DOE should consider. At the
meeting and during the comment period
on the framework document, DOE
received many comments that helped it
identify and resolve issues pertaining to
walk-ins relevant to this rulemaking.
DOE then gathered additional
information and performed preliminary
analyses to help develop potential
energy conservation standards for this
equipment. This process culminated in
DOE’s announcement of another public
meeting to discuss and receive
comments on the following matters: (1)
The equipment classes DOE planned to
analyze; (2) the analytical framework,
models, and tools that DOE used to
evaluate standards; (3) the results of the
preliminary analyses performed by
DOE; and (4) potential standard levels
that DOE could consider. 75 FR 17080
(April 5, 2010) (the April 2010 Notice).
DOE also invited written comments on
these subjects and announced the
availability on its Web site of a
preliminary technical support document
(preliminary TSD) it had prepared to
inform interested parties and enable
them to provide comments. Id. (More
information about the preliminary TSD
is available at: https://
www1.eere.energy.gov/buildings/
appliance_standards/rulemaking.aspx/
ruleid/30.)Finally, DOE sought views on
other relevant issues that participants
believed either would impact walk-in
standards or that the proposal should
address. Id. at 17083.
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The preliminary TSD provided an
overview of the activities DOE
undertook to develop standards for
walk-ins and discussed the comments
DOE received in response to the
framework document. The preliminary
TSD also addressed separate standards
for the walk-in envelope and the
refrigeration system, as well as
compliance and enforcement
responsibilities and food safety
regulatory concerns. The document also
described the analytical framework that
DOE used (and continues to use) in
considering standards for walk-in
coolers and freezers, including a
description of the methodology, the
analytical tools, and the relationships
between the various analyses that are
part of this rulemaking. Additionally,
the preliminary TSD presented in detail
each analysis that DOE had performed
for these products up to that point,
including descriptions of inputs,
sources, methodologies, and results.
These analyses were as follows:
• A market and technology
assessment addressed the scope of this
rulemaking, identified the potential
classes for walk-in coolers and freezers,
characterized the markets for these
products, and reviewed techniques and
approaches for improving their
efficiency;
• A screening analysis reviewed
technology options to improve the
efficiency of walk-in coolers and
freezers, and weighed these options
against DOE’s four prescribed screening
criteria;
• An engineering analysis estimated
the manufacturer selling prices (MSPs)
associated with more energy-efficient
walk-in coolers and freezers;
• An energy use analysis estimated
the annual energy use of walk-in coolers
and freezers;
• A markups analysis converted
estimated MSPs derived from the
engineering analysis to consumer prices;
• A life-cycle cost analysis calculated,
for individual consumers, the
discounted savings in operating costs
throughout the estimated average life of
walk-in coolers and freezers, compared
to any increase in installed costs likely
to result directly from the imposition of
a given standard;
• A payback period analysis
estimated the amount of time it takes
individual consumers to recover the
higher purchase price expense of more
energy-efficient products through lower
operating costs;
• A shipments analysis estimated
shipments of walk-in coolers and
freezers over the time period examined
in the analysis, and was used in
performing the national impact analysis;
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• A national impact analysis assessed
the national energy savings and the
national net present value of total
consumer costs and savings that are
expected to result from specific
potential energy conservation standards
for walk-in coolers and freezers; and
• A preliminary manufacturer impact
analysis (MIA) took the initial steps in
evaluating the effects on manufacturers
of new efficiency standards.
The public meeting announced in the
April 2010 Notice took place on May 19,
2010. At this meeting, DOE presented
the methodologies and results of the
analyses set forth in the preliminary
TSD. Interested parties that participated
in the public meeting discussed a
variety of topics, but the comments
centered on the following issues: (1)
Separate standards for the refrigeration
system and the walk-in envelope; (2)
responsibility for compliance; (3)
equipment classes; (4) technology
options; (5) energy modeling; (6)
installation, maintenance, and repair
costs; (7) markups and distributions
chains; (8) walk-in cooler and freezer
shipments; and (9) test procedures. The
comments received since publication of
the April 2010 Notice, including those
received at the May 2010 public
meeting, have contributed to DOE’s
proposed resolution of the issues in this
rulemaking as they pertain to walk-ins.
This NOPR responds to the issues raised
55791
by the commenters. (A parenthetical
reference at the end of a quotation or
paraphrase provides the location of the
item in the public record.)
III. General Discussion
In preparing today’s notice, DOE
considered input from the various
interested parties who commented on
the framework document and
preliminary analysis, information
obtained from manufacturer interviews,
and additional research that DOE
conducted. The interested parties who
provided comments to DOE during the
framework document and preliminary
analysis phases included the following:
TABLE III–1—FRAMEWORK AND PRELIMINARY ANALYSIS COMMENTERS
Abbreviated
designation
Affiliation
AFM Corporation .............................................................................................
Air-Conditioning, Heating, and Refrigeration Institute ....................................
American Chemistry Council ...........................................................................
American Chemistry Council Center for the Polyurethanes Industry .............
American Council for an Energy Efficient Economy, Appliance Standards
Awareness Project, Alliance to Save Energy, Natural Resources Defense
Council, Northwest Energy Efficiency Alliance.
American Panel Corporation ...........................................................................
AmeriKooler, Inc. .............................................................................................
Appliance Standards Awareness Project ........................................................
AFM .....................
AHRI ....................
ACC .....................
CPI .......................
Joint Advocates ...
Manufacturer ........
Trade Association
Material Supplier ..
Material Supplier ..
Energy Efficiency
Advocates.
0012.1
0036.1, 0055.1
0062.1
0052.1
0070.1
American Panel ...
AmeriKooler .........
ASAP ...................
Bally .....................
Carpenter .............
Craig Industries ...
Craig Industries ...
Manufacturer ........
Manufacturer ........
Energy Efficiency
Advocate.
Manufacturer ........
Material Supplier ..
Manufacturer ........
Manufacturer ........
0039.1, 0048.1
0065.1
0024.1
Bally Refrigerated Boxes, Inc. ........................................................................
Carpenter Co. Chemical Systems Division .....................................................
Craig Industries, Inc. and U.S. Cooler Company ...........................................
Craig Industries, Inc. and US Cooler Company .............................................
CrownTonka Walk-Ins .....................................................................................
Earthjustice ......................................................................................................
CrownTonka ........
Earthjustice ..........
Edison Electric Institute ...................................................................................
EEI .......................
Eliason Corporation .........................................................................................
Foam Supplies, Inc. ........................................................................................
Heatcraft Refrigeration Products LLC .............................................................
Heating, Air-conditioning & Refrigeration Distributors International ...............
Hill Phoenix Walk-Ins ......................................................................................
Hired Hand Technologies ...............................................................................
Hussmann and Ingersoll Rand .......................................................................
Kason Industries, Inc. .....................................................................................
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Commenter(s)
Eliason .................
FSI .......................
Heatcraft ..............
HARDI ..................
Hill Phoenix ..........
Hired Hand ..........
Ingersoll Rand .....
Kason ...................
Kysor Panel Systems ......................................................................................
Manitowoc Ice .................................................................................................
Master-Bilt Products, Inc. ................................................................................
NanoPore Insulation, LLC ...............................................................................
Nor-Lake, Incorporated ...................................................................................
Owens Corning Foam Insulation, LLC ............................................................
Southern California Edison and Technology Test Centers ............................
Southern California Edison, San Diego Gas & Electric, Pacific Gas & Electric Company, Sacramento Municipal Utility District.
The Northwest Energy Efficiency Alliance and the Northeast Power Coordinating Council.
Zero-Zone, Inc. ................................................................................................
Kysor ....................
Manitowoc ............
Master-Bilt ............
NanoPore .............
Nor-Lake ..............
Owens Corning ....
SCE .....................
Joint Utilities ........
A. Component Level Standards
In the framework document, DOE
considered setting standards that would
apply to the entire walk-in. See the
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NEEA and NPCC
Zero-Zone ............
framework document at https://
www1.eere.energy.gov/buildings/
appliance_standards/commercial/pdfs/
wicf_framework_doc.pdf. Several
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Manufacturer ........
Energy Efficiency
Advocate.
Energy Efficiency
Advocate.
Manufacturer ........
Material Supplier ..
Manufacturer ........
Trade Association
Manufacturer ........
Manufacturer ........
Manufacturer ........
Component Supplier.
Manufacturer ........
Manufacturer ........
Manufacturer ........
Material Supplier ..
Manufacturer ........
Material Supplier ..
Utility ....................
Utility Group .........
Utility Representative.
Manufacturer ........
Comment number(s) in
docket
0023.1
0068.1
0064.1
0011.1, 0025.1, 0038.1,
0064.1, 0071.1
0026.1, 0057.1
0027.1, 0047.1
0028.1
0013.1, 0022.1
0029.1
0058.1, 0069.1
0031.1
0066.1
0030.1, 0050.1
0053.1
0009.1, 0019.1
0032.1, 0054.1
0056.1
0033.1, 0046.1
0067.1
0049.1
0034.1
0035.1
0061.1
0021.1, 0059.1
0051.1
interested parties expressed concern
about this approach because of the
variety among assembled walk-ins,
which would make compliance with
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such a walk-in standard difficult and
burdensome. Stakeholders also stated
that different components of each walkin would likely be manufactured by
different entities, which would make it
difficult to enforce any standard that
applied to an entire walk-in.
After considering the comments
submitted on the framework document,
DOE modified its approach in the
preliminary analysis. During that phase,
it had tentatively identified two primary
components of a walk-in: the envelope
(the insulated box that separates the
exterior from the interior) and the
refrigeration system (the mechanical
equipment that cools the envelope’s
interior). DOE also indicated that it was
tentatively considering developing
separate standards for refrigeration
systems and envelopes.
Several interested parties agreed with
this general approach. Manitowoc
supported separate standards for the
envelope and refrigeration system,
stating that the envelope is typically
supplied by one manufacturer and the
refrigeration system is typically
supplied by one or more manufacturers.
(Manitowoc, Public Meeting Transcript,
No. 0045 at p. 38 and No. 0056.1 at p.
1) Manitowoc further stated that it
would not be practical to regulate the
energy used by the entire walk-in
assembly because walk-ins are highly
customized. Manitowoc estimated that
fewer than 20 percent of its walk-ins use
a standard envelope and refrigeration
system combination. (Manitowoc, No.
0056.1 at p. 1) Pacific Gas and Electric
Company, Southern California Edison,
Sempra Energy Utility, and the
Sacramento Municipal Utility District
(hereafter referred to as the ‘‘Joint
Utilities’’) also agreed with DOE’s
proposal to separate the refrigeration
system standards from the envelope
standards because the components are
separately produced and often
separately sold. (Joint Utilities, No.
0061.1 at pp. 2–3) American Panel
stated that the envelope and
refrigeration systems must be
considered separately because the
majority of WICFs are custom-made.
(American Panel, No. 0048.1 at p. 4)
Kysor, Master-Bilt, AHRI, and
CrownTonka all supported separate
standards for the envelope and
refrigeration systems. (Kysor, Public
Meeting Transcript, No. 0045 at p. 39;
Master-Bilt, No. 0046.1 at p. 1; AHRI,
No. 0055.1 at p. 2; CrownTonka, No.
0057.1 at p. 1) One interested party did
not agree with this approach. Craig
Industries, also doing business as U.S.
Cooler, commented that DOE should
establish a combination standard for the
envelope and refrigeration system to
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permit manufacturers greater flexibility
when designing walk-ins. Under this
combination approach, a more efficient
envelope could be paired with a less
efficient refrigeration system, or vice
versa, to achieve the same overall
efficiency at a lower cost. (Craig
Industries, No. 0064.1 at p. 1)
Additionally, interested parties
suggested that DOE extend the idea of
separate standards to subcomponents of
envelopes and refrigeration systems.
The Joint Utilities stated that a
component performance approach
would accurately capture efficiency
measurements associated with the
components, and that energy savings
associated with targeted components
would apply to different configurations
of whole walk-ins and possibly even to
repairs and retrofits. (Joint Utilities, No.
0061.1 at p. 4) The Joint Utilities further
added that DOE should consider
component performance standards for
major walk-in components that could be
enforced at the level of the
manufacturer’s catalog and could be
labeled for easy inspection. (Joint
Utilities, No. 0061.1 at p. 12) Hill
Phoenix also recommended that large
construction-based envelopes (i.e., those
constructed in a manner similar to a
building) be regulated at the component
level, asserting that these envelopes may
need many different options and design
flexibility, without which a wholeenvelope calculation would likely limit
the accuracy of any estimate of a walkin’s total energy use. (Hill Phoenix, No.
0066.1 at p. 1) As stated previously,
Manitowoc agreed that it would not be
practical to regulate the energy used by
the entire walk-in assembly because
walk-ins are highly customized.
(Manitowoc, No. 0056.1 at p. 1)
Manitowoc also remarked that
performance metrics could be
developed for sub-classes of the
components of an envelope, and the
component manufacturers should be
responsible for their own components.
(Manitowoc, Public Meeting Transcript,
No. 0045 at p. 46)
Other stakeholders discussed specific
sub-components of the envelope or the
refrigeration system that could be
regulated. Kysor mentioned panels and
doors as envelope components that
should be considered separately and
stated that because these components
are often manufactured by separate
parties, the manufacturer of each
component should be responsible for
the performance of that component.
(Kysor, Public Meeting Transcript, No.
0045 at p. 41) The Northwest Energy
Efficiency Alliance (NEEA) and
Northwest Power Conservation Council
(NPCC) recommended that DOE develop
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efficiency performance standards for
display and solid doors separately so
that an envelope manufacturer could
certify that the envelope meets specified
standards. (NEEA and NPCC, No. 0059.1
at p. 2)
Likewise, with regard to the
refrigeration system, NEAA and NPCC
recommended that DOE regulate the
efficiency of the cooling system
components separately, an example of
which would be setting a performance
requirement for the specific efficiency of
unit coolers based on control
algorithms. (NEAA and NPCC, No.
0059.1 at pp. 2 and 7) The Joint Utilities
also stated that a refrigeration system
requirement should not be based on a
single metric and added that the indoor
unit (i.e., unit cooler) could have a
minimum efficiency requirement
regardless of other components of the
refrigeration system. (Joint Utilities, No.
0061.1 at p. 4 and Public Meeting
Transcript, No. 0045 at p. 64)
Manitowoc, on the other hand,
recommended that manufacturers have
the option of rating the entire
refrigeration system and that
considering the condensing unit
separately would not allow
manufacturers to implement options
that would improve the efficiency of a
matched system. (Manitowoc, Public
Meeting Transcript, No. 0045 at p. 38)
Manitowoc further remarked that testing
the refrigeration system as an integrated,
single component and calculating the
overall annual efficiency has the
greatest potential for optimizing energy
efficiency, but added that DOE should
permit the individual components to be
tested and the performance stated for
the individual parts. (Manitowoc, Public
Meeting Transcript, No. 0045 at p. 59)
After carefully considering the
comments described above, DOE
proposes an approach for the envelope
that would set separate standards for
panels, display doors, and non-display
doors for the reasons set forth below.
Different manufacturers typically
produce panels and doors (both display
and non-display types) for use in walkin applications. In particular, display
doors are commonly manufactured
separately because their unique
construction and materials require
specialized manufacturing methods.
Additionally, the modular nature of a
walk-in envelope means that it is
constructed of relatively standardized
components that can be assembled in a
virtually infinite number of
configurations that may affect the
overall consumption of a given walk-in
unit. By regulating the performance of
those standardized components,
manufacturers will be able to choose
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compliant components that should help
ensure that whatever walk-in
configuration is built satisfies the
minimal level of energy consumption
and efficiency that DOE may prescribe.
Because of the large number of possible
combinations of panels and doors that
could make up an envelope, the burdens
presented by a system-based approach
for the entire walk-in unit would also
likely be significantly greater than the
burdens of the proposed approach
because each walk-in envelope
configuration would need to be
separately certified as compliant.
Alternatively, if DOE were to establish
a set envelope of specified dimensions
for a manufacturer to build and then to
certify as compliant, the efficiency or
energy usage measurement from that
envelope would not only be more costly
to obtain, but it would also not
necessarily reflect the actual energy
usage or efficiency of a given walk-in
that is installed in the field.
DOE also notes that requiring an
overall envelope performance standard
would be likely to present significant
enforcement burdens, as it would likely
require DOE to test several fully
constructed envelopes in order to
ascertain the energy efficiency
performance of a given envelope. DOE
tentatively believes that such an
approach, at this time, would be unduly
burdensome.
DOE is not, however, proposing to set
standards for the constituent
components of refrigeration systems
separately. To ensure that
manufacturers have sufficient flexibility
to improve the energy efficiency
performance of their systems, DOE
proposes to set a performance standard
for the overall refrigeration system and
to regulate that system as a single
component. This approach would help
ensure that the final refrigeration system
assembled by the manufacturer would
meet a given level of efficiency and
would account for the interactive effects
of the numerous components
comprising the overall system. For
example, some refrigeration systems
implement complex control strategies,
the benefits of which could not be
adequately demonstrated if the
condensing unit and unit cooler were
considered separately for purposes of
setting standards.
In summary, DOE proposes to set
specific component standards for the
panels, display doors, and non-display
doors of a walk-in, and a single standard
to assess the overall performance of the
refrigeration system. DOE acknowledges
that, by not establishing a standard for
the energy use of the entire walk-in,
manufacturers cannot meet the standard
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by pairing a more-efficient envelope
with a less-efficient refrigeration system,
and vice versa. Also, DOE would not
account for the energy use of some
components, such as the electricity use
of overhead lighting or heat load due to
the infiltration of warm air into the
walk-in, and would not consider design
options whose efficacy depends on the
interaction between the different
covered components. Including these
factors as part of the current rulemaking
would likely introduce significant
complications with respect to
compliance and enforcement while
yielding a comparatively small benefit
in energy savings. DOE believes,
however, that the proposed approach
would help ensure that the walk-in
components used by manufacturers
satisfy some minimal level of energy
efficiency and reduce the overall
certification and enforcement burden on
manufacturers. DOE may reconsider this
issue in the future, particularly if
accurate computer modeling, such as
through an alternative efficiency
determination method, becomes
possible with respect to predicting the
energy usage and efficiency of fully
constructed walk-in units. DOE
continues to invite comments on the
approach presented in this NOPR.
B. Test Procedures and Metrics
While Congress had initially
prescribed certain performance
standards and test procedures
concerning walk-ins as part of the EISA
2007 amendments, Congress also
instructed DOE to develop specific test
procedures to cover walk-in equipment.
DOE subsequently established a test
procedure for walk-ins. See 76 FR 21580
(April 15, 2011). See also 76 FR 33631
(June 9, 2011) (final technical
corrections). The test procedure lays out
an approach that bases compliance on
the ability of component manufacturers
to produce components that meet the
required standards. This approach is
also consistent with the framework
established by Congress, which set
specific energy efficiency performance
requirements on a component-level
basis. (42 U.S.C. 6313(f)) The approach
is discussed more fully below.
1. Panels
In the final test procedure rule for
walk-ins, DOE defines ‘‘panel’’ as a
construction component, excluding
doors, used to construct the envelope of
the walk-in (i.e., elements that separate
the interior refrigerated environment of
the walk-in from the exterior). 76 FR
33631 (June 9, 2011). The rule explains
that panel manufacturers would test
their panels to obtain a thermal
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55793
transmittance metric—known as Ufactor, measured in Btu/h-ft2-°F—and
identifies three types of panels: display
panels, floor panels, and non-floor
panels. A display panel is defined as a
panel that is entirely or partially
comprised of glass, a transparent
material, or both, and is used for display
purposes. Id. It is considered equivalent
to a window and the U-factor is
determined by NFRC 100–2010–E0A1,
‘‘Procedure for Determining
Fenestration Product U-factors.’’ 76 FR
at 33639. Floor panels are used for walkin floors, whereas non-floor panels are
used for walls and ceilings.
The U-factor for floor and non-floor
panels accounts for any structural
members internal to the panel and the
long-term thermal aging of foam. This
value is determined by a three-step
process. First, both floor and non-floor
panels must be tested using ASTM
C1363–10, ‘‘Standard Test Method for
Thermal Performance of Building
Materials and Envelope Assemblies by
Means of a Hot Box Apparatus.’’ The
panel’s core and edge regions must be
used during testing. Second, the panel’s
core U-factor must be adjusted with a
degradation factor to account for foam
aging. The degradation factor is
determined by EN 13165:2009–02,
‘‘Thermal Insulation Products for
Buildings—Factory Made Rigid
Polyurethane Foam (PUR) Products—
Specification,’’ or EN 13164:2009–02,
‘‘Thermal Insulation Products for
Buildings—Factory Made Products of
Extruded Polystyrene Foam (XPS)—
Specification,’’ as applicable. Third, the
edge and modified core U-factors are
then combined to produce the panel’s
overall U-factor. All industry protocols
were incorporated by reference most
recently in the test procedure final rule
correction. 76 FR 33631.
2. Doors
The walk-in test procedure final rule
addressed two door types: display and
non-display doors. Within the general
context of walk-ins, a door consists of
the door panel, glass, framing materials,
door plug, mullion, and any other
elements that form the door or part of
its connection to the wall. DOE defines
display doors as doors designed for
product movement, display, or both,
rather than the passage of persons; a
non-display door is interpreted to mean
any type of door that is not captured by
the definition of a display door. 76 FR
at 33631.
The test metric for doors is in terms
of energy use, measured in kilowatthours per day (kWh/day). The energy
use accounts for thermal transmittance
through the door and the electricity use
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of any electrical components associated
with the door. The thermal
transmittance is measured by NFRC
100–2010–E0A1, and is converted to
energy consumption via conduction
losses using an assumed efficiency of
the refrigeration system in accordance
with the test procedure. See 76 FR at
33636–33637. The electrical energy
consumption of the door is calculated
by summing each electrical device’s
individual consumption and accounts
for all device controls by applying a
‘‘percent time off’’ value to the
appropriate device’s energy
consumption. For any device that is
located on the internal face of the door
or inside the door, 75 percent of its
power is assumed to contribute to an
additional heat load on the compressor.
Finally, the total energy consumption of
the door is found by combining the
conduction load, electrical load, and
additional compressor load.
3. Refrigeration
The test procedure incorporates an
industry test procedure applied to walkin refrigeration systems: AHRI 1250 (I–
P)-2009, ‘‘2009 Standard for
Performance Rating of Walk-In Coolers
and Freezers’’ (‘‘AHRI 1250–2009’’). 76
FR at 33631. This procedure applies to
unit coolers and condensing units sold
together as a matched system, unit
coolers and condensing units sold
separately, and unit coolers connected
to compressor racks or multiplex
condensing systems. It also describes
methods for measuring the refrigeration
capacity, on-cycle electrical energy
consumption, off-cycle fan energy, and
defrost energy. Standard test conditions,
which are different for indoor and
outdoor locations and for coolers and
freezers, are also specified.
The test procedure includes a
calculation methodology to compute an
annual walk-in energy factor (AWEF),
which is the ratio of heat removed from
the envelope to the total energy input of
the refrigeration system over a year.
AWEF is measured in Btu/W-h and
measures the efficiency of a refrigeration
system. DOE established a metric based
on efficiency, rather than energy use, for
describing refrigeration system
performance, because a refrigeration
system’s energy use would be expected
to increase based on the size of the
walk-in and on the heat load that the
walk-in produces. An efficiency-based
metric would account for this
relationship and would simplify the
comparison of refrigeration systems to
each other. Therefore, DOE proposes to
use an energy conservation standard for
refrigeration systems that would be
presented in terms of AWEF.
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C. Prescriptive Versus Performance
Standards
EPCA established standards for
certain WICF components, while also
directing the Secretary to establish
‘‘performance-based standards,’’ which
are the subject of this rulemaking. (42
U.S.C. 6313(f)(4)(A)) Some interested
parties suggested that DOE establish
prescriptive standards for certain
components in addition to the
performance-based standards that DOE
is proposing. NEEA and NPCC stated
that DOE should establish a prescriptive
(i.e., design) standard for electronically
commutated motors. (NEEA and NPCC,
No. 0059.1 at p. 7) The Joint Utilities
recommended that DOE consider the
precedent set by EPCA, as the EPCA
provisions include both prescriptive
and performance standards, and further
recommended that DOE include
additional prescriptive requirements for
various components of a walk-in as
necessary to maximize energy savings,
and performance standards for the unit
cooler. (Joint Utilities, No. 0061.1 at p.
11) The Joint Utilities also
recommended that DOE base new
standards using those design
requirements already prescribed by Title
20 of California’s Code as the baseline
when developing a performance
standard. (Joint Utilities, No. 0061.1 at
p. 13) SCE also referred to the
prescriptive standards in Title 20, and
suggested that because EPCA already
established prescriptive measures, there
will be limited additional benefit from
performance measures. SCE further
recommended that a standard for
infiltration should be implemented
through ASHRAE 90.1 (SCE, Public
Meeting Transcript, No. 0045 at p. 63)
The Joint Utilities recommended other
specific prescriptive requirements that
DOE should implement, including a
minimum solar reflective index for the
roof of a walk-in located outdoors,
adjustable variable speed fan control for
unit coolers, and floating head pressure
control (a control that allows the
pressure of the refrigerant at the
compressor exit point to reach an
optimal level). (Joint Utilities, No.
0061.1 at pp. 5 and 12; Public Meeting
Transcript, No. 0045 at p. 29) The Joint
Utilities also asked DOE to examine
how controls could be specified in a
performance standard. (Joint Utilities,
No. 0061.1 at p. 13)
DOE notes that EPCA requires the
promulgation of ‘‘performance-based
standards’’ for walk-ins. That phrase
indicates that DOE must set standards
based on energy-related performance.
See 42 U.S.C. 6313(f)(4). Accordingly,
the design requirements suggested by
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commenters would be inconsistent with
this requirement.
D. Certification, Compliance, and
Enforcement
Walk-ins consist primarily of panels,
display and non-display doors, and a
refrigeration system, as described in
section III.A. A number of arrangements
exist for manufacturing walk-ins. One
company may manufacture the panels,
purchase the display and/or non-display
doors and refrigeration system, assemble
the walk-in at the factory, and ship the
walk-in to a consumer. Alternatively,
the same company may ship the walkin without a refrigeration system, which
is then purchased separately by the
consumer and installed on the walk-in.
A contractor may purchase all the
components from the component
manufacturers and assemble the walk-in
on-site. Other scenarios may also exist.
Given the wide variety of scenarios
under which a walk-in is manufactured,
it is important to identify an entity or
entities responsible for complying with
standards and certifying compliance to
DOE, and against whom a possible
enforcement action could be taken.
During the preliminary analysis
public meeting, many interested parties
expressed concern about compliance
responsibilities and whether those
burdens would fall on the envelope and
refrigeration manufacturers
individually, the installer, or another
party. Additionally, the Joint Advocates
submitted a comment urging DOE to
ensure that the separate system
components would be compliant with
the energy conservation standards, and
stating that each manufacturer should
be held accountable for their products
(e.g., door manufacturers are responsible
for compliance with door standards).
(Joint Advocates, No. 0070.1 at pp. 2–3)
Craig Industries recommended that the
definition of a manufacturer be
expanded to include the installer of the
unit, because the installer has the ability
to ensure that the installed unit meets
the energy conservation standards.
(Craig Industries, No. 0071.1 at p. 1).
Comments on this issue were
summarized in the 2011 Certification,
Compliance, and Enforcement for
Consumer Products and Commercial
and Industrial Equipment (referred to
hereafter as the CCE final rule), and are
not repeated here. 76 FR 12422, 12442–
12446 (March 7, 2011).
DOE notes that within the context of
today’s proposal, the agency is
contemplating an approach that would
place the primary certification and
compliance burden on those entities
that manufacture particular key
components of a walk-in—that is, the
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E. Technological Feasibility
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1. General
In each standards rulemaking, DOE
conducts a screening analysis, which it
bases on information gathered on all
current technology options and
prototype designs that could improve
the efficiency of the products or
equipment that are the subject of the
rulemaking. As the first step in such
analysis, DOE develops a list of design
options for consideration in
consultation with manufacturers, design
engineers, and other interested parties.
DOE then determines which of these
means for improving efficiency are
technologically feasible. DOE considers
technologies incorporated in
commercial products or in working
prototypes to be technologically
feasible. 10 CFR 430, subpart C,
appendix A, section 4(a)(4)(i) Although
DOE considers technologies that are
proprietary, it will not consider
efficiency levels that can only be
reached through the use of proprietary
technologies (i.e., a unique pathway), as
it could allow a single manufacturer to
monopolize the market.
Once DOE has determined that
particular design options are
technologically feasible, it generally
evaluates each of these design options
in light of the following additional
screening criteria: (1) Practicability to
manufacture, install, or service; (2)
adverse impacts on product utility or
availability; and (3) adverse impacts on
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health or safety. 10 CFR part 430,
subpart C, appendix A, section
4(a)(4)(ii)-(iv) Section IV.B of this notice
discusses the results of the screening
analyses for walk-in coolers and
freezers. Specifically, it presents the
designs DOE considered, those it
screened out, and those that are the
basis for the TSLs in this rulemaking.
For further details on the screening
analysis for this rulemaking, see chapter
4 of the TSD.
2. Maximum Technologically Feasible
Levels
When DOE proposes to adopt a new
or amended or new energy conservation
standard for a type or class of covered
equipment such as walk-ins, it
determines the maximum improvement
in energy efficiency that is
technologically feasible for such
equipment. Accordingly, DOE
determined the maximum
technologically feasible (max-tech)
improvements in energy efficiency for
walk-ins by applying those design
parameters that passed the screening
analysis to the engineering analysis that
DOE prepared as part of the preliminary
analysis.
In a comment on the max-tech levels
in the preliminary analysis, AHRI
commented that max-tech efficiency
levels would be achieved only by a few
units, and it requested that DOE
demonstrate that max-tech levels can be
achieved by commonly used products.
(AHRI, No. 0055.1 at p. 3)
As indicated previously, whether
efficiency levels exist or can be
achieved in commonly used products
does not determine whether they are
max-tech levels. DOE considers
technologies to be technologically
feasible if they are incorporated in any
commercially available equipment or
working prototypes. A maximum
technologically feasible level results
from the combination of design options
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that result in the highest efficiency level
for an equipment class, with such
design options consisting of
technologies already incorporated in
commercial products or working
prototypes. DOE notes that it reevaluated the efficiency levels,
including the max-tech levels, when it
updated its results for this NOPR. See
chapter 5 of the NOPR TSD for the
results of the analysis.
For panels, non-display doors, display
doors, and refrigeration systems, the
max-tech efficiency levels DOE has
identified represent products with the
most efficient design options available
on the market, or previously offered for
sale, in the given equipment class. No
products at higher efficiencies are
available or have been in the past, and
DOE is not aware of any working
prototype designs that would allow
manufacturers to achieve higher
efficiencies. Table III–2, Table III–3,
Table III–4, and Table III–5 list the maxtech levels for panels, display doors,
non-display doors, and refrigeration
systems, respectively. (See section
IV.A.3 for a description of the
equipment classes.)
For structural cooler and freezer
panels, the max-tech level is
represented by a single value for Ufactor. For all other TSLs (and for all
floor panel levels including the maxtech level), the level is represented by
a polynomial equation expressing the Ufactor in terms of certain panel
dimensions, but the max tech level does
not result in a polynomial equation
because the U-factor does not vary with
the size of the panel. (See section V.A.2
for a list of equations for all TSLs.) At
max-tech, panels are designed without
structural members, making the panel
uniformly comprised of hybrid
insulation. See section IV.C.5 and
chapter 5 of the TSD for the list of
technologies included in max-tech
equipment.
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panels, doors, and refrigeration system.
This approach dovetails with that
outlined in the recent test procedure
final rule. The various requirements that
manufacturers would need to follow are
detailed in the 2011 final rule noted
above regarding manufacturer
certification, compliance, and
enforcement-related responsibilities. 76
FR 12422. For further details, see 76 FR
at 12491.
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TABLE III–3—MAX-TECH LEVELS FOR DISPLAY DOORS
Equations for maximum
energy consumption
(kWh/day) *
Equipment class
Display Door, Medium Temperature ...................................................................................................................................
Display Door, Low Temperature .........................................................................................................................................
0.0080 × Add + 0.29
0.11 × Add + 0.32
* Add represents the surface area of the display door.
TABLE III–4—MAX-TECH LEVELS FOR NON-DISPLAY DOORS
Equations for maximum
energy consumption
(kWh/day) *
Equipment class
Passage Door, Medium Temperature .................................................................................................................................
Passage Door, Low Temperature .......................................................................................................................................
Freight Door, Medium Temperature ...................................................................................................................................
Freight Door, Low Temperature ..........................................................................................................................................
0.00093 × And + 0.0083
0.13 × And + 3.9
0.00092 × And + 0.13
0.094 × And + 5.2
* And represents the surface area of the non-display door.
TABLE III–5—MAX-TECH LEVELS FOR REFRIGERATION SYSTEMS
Equations for minimum
AWEF
(Btu/W-h) *
Equipment class
Dedicated Condensing, Medium Temperature, Indoor System, < 9,000 Btu/h Capacity ..................................................
Dedicated Condensing, Medium Temperature, Indoor System, ≥ 9,000 Btu/h Capacity ..................................................
Dedicated Condensing, Medium Temperature, Outdoor System, < 9,000 Btu/h Capacity ...............................................
Dedicated Condensing, Medium Temperature, Outdoor System, ≥ 9,000 Btu/h Capacity ................................................
Dedicated Condensing, Low Temperature, Indoor System, < 9,000 Btu/h Capacity ........................................................
Dedicated Condensing, Low Temperature, Indoor System, ≥ 9,000 Btu/h Capacity .........................................................
Dedicated Condensing, Low Temperature, Outdoor System, < 9,000 Btu/h Capacity ......................................................
Dedicated Condensing, Low Temperature, Outdoor System, ≥ 9,000 Btu/h Capacity ......................................................
Multiplex Condensing, Medium Temperature .....................................................................................................................
Multiplex Condensing, Low Temperature ...........................................................................................................................
2.63 ×
6.90
9.23 ×
12.21
1.93 ×
3.67
4.53 ×
6.25
10.82
5.91
10¥4 × Q + 4.53
10¥4 × Q + 3.90
10¥4 × Q + 1.93
10¥4 × Q + 2.17
* Q represents the system gross capacity as calculated in AHRI 1250.
F. Energy Savings
1. Determination of Savings
tkelley on DSK3SPTVN1PROD with PROPOSALS2
For each TSL, DOE projected energy
savings from the products that are the
subject of this rulemaking purchased in
the 30-year period that begins in the
year of compliance with new standards
(2017–2046). The savings are measured
over the entire lifetime of products
purchased in the 30-year period.13 DOE
quantified the energy savings
attributable to each TSL as the
difference in energy consumption
between each standards case and the
base case. The base case represents a
projection of energy consumption in the
absence of amended mandatory
efficiency standards and considers
market forces and policies that affect
demand for more efficient products.
13 In the past DOE presented energy savings
results for only the 30-year period that begins in the
year of compliance. In the calculation of economic
impacts, however, DOE considered operating cost
savings measured over the entire lifetime of
products purchased in the 30-year period. DOE has
chosen to modify its presentation of national energy
savings to be consistent with the approach used for
its national economic analysis.
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DOE used its national impact analysis
(NIA) spreadsheet model to estimate
energy savings from amended standards
for the products that are the subject of
this rulemaking. The NIA spreadsheet
model (described in section IV.G of this
notice and chapter 10 of the TSD)
calculates energy savings in site energy,
which is the energy directly consumed
by products at the locations where they
are used. For electricity, DOE reports
national energy savings in terms of the
savings in the energy that is used to
generate and transmit the site
electricity. To calculate this quantity,
DOE derives annual conversion factors
from the model used to prepare the
Energy Information Administration’s
(EIA) Annual Energy Outlook (AEO).
DOE has begun to also estimate fullfuel-cycle (FFC) energy savings. 76 FR
51282 (Aug. 18, 2011), as amended at 77
FR 49701 (August 17, 2012). The FFC
metric includes the energy consumed in
extracting, processing, and transporting
primary fuels (i.e., coal, natural gas,
petroleum fuels), and thus presents a
more complete picture of the impacts of
energy efficiency standards. DOE’s
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approach is based on calculation of an
FFC multiplier for each of the energy
types used by covered products. For
more information on FFC energy
savings, see sections IV.G.3 and IV.L
and appendix 10G of the TSD.
2. Significance of Savings
DOE may not adopt a standard that
would not result in significant
additional energy savings. While the
term ‘‘significant’’ is not defined in the
Act, the U.S. Circuit Court of Appeals
for the District of Columbia in Natural
Resources Defense Council v.
Herrington, 768 F.2d 1355, 1373 (DC
Cir. 1985), indicated that Congress
intended significant energy savings to
be savings that were not ‘‘genuinely
trivial.’’ The estimated energy savings in
the analysis period for the trial standard
levels considered in this rulemaking
range from 4.28 to 6.37 quadrillion Btu
(quads), an amount DOE considers
significant.
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b. Life-Cycle Costs
1. Specific Criteria
As discussed in section II.A, EPCA
provides seven factors to be evaluated in
determining whether a potential energy
conservation standard is economically
justified. The following sections
generally discuss how DOE addresses
each of those seven factors in this
rulemaking. For further details and the
results of DOE’s analyses pertaining to
economic justification, see sections IV
and V of today’s notice.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
G. Economic Justification
The LCC is the sum of the purchase
price of equipment (including the cost
of its installation) and the operating
expense (including energy and
maintenance and repair expenditures)
discounted over the lifetime of the
equipment. The LCC savings for the
considered efficiency levels are
calculated relative to a base case that
reflects likely trends in the absence of
new standards. The LCC analysis
requires a variety of inputs, such as
equipment prices, equipment energy
consumption, energy prices,
maintenance and repair costs,
equipment lifetime, and consumer
discount rates. DOE assumes in its
analysis that consumers purchase the
equipment in the year in which
compliance with the new standard is
required.
To account for uncertainty and
variability in specific inputs, such as
equipment lifetime and discount rate,
DOE uses a distribution of values with
probabilities attached to each value. A
distinct advantage of this approach is
that DOE can identify the percentage of
consumers estimated to receive LCC
savings or experience an LCC increase.
In addition to identifying ranges of
impacts, DOE evaluates the LCC impacts
of potential standards on identifiable
subgroups of consumers that may be
disproportionately affected by a new
national standard. For the results of
DOE’s analyses related to the life-cycle
costs of equipment, see section V.B.1.a
of this notice and chapter 8 of the TSD.
a. Economic Impact on Manufacturers
and Consumers
In determining the impacts of an
amended standard on manufacturers,
DOE first uses an annual cash-flow
approach to determine the quantitative
impacts. This step includes both a shortterm assessment—based on the cost and
capital requirements during the period
between when a regulation is issued and
when entities must comply with the
regulation—and a long-term assessment
over a 30-year period. The industrywide impacts analyzed include industry
net present value (INPV), which values
the industry on the basis of expected
future cash flows; cash flows by year;
changes in revenue and income; and
other measures of impact, as
appropriate. Second, DOE analyzes and
reports the impacts on different types of
manufacturers, including impacts on
small manufacturers. Third, DOE
considers the impact of standards on
domestic manufacturer employment and
manufacturing capacity, as well as the
potential for standards to result in plant
closures and loss of capital investment.
Finally, DOE takes into account
cumulative impacts of various DOE
regulations and other regulatory
requirements on manufacturers.
For individual consumers, measures
of economic impact include the changes
in LCC and the PBP associated with new
or amended standards. The LCC, which
is also separately specified as one of the
seven factors to be considered in
determining the economic justification
for a new or amended standard, is
discussed in the following section. For
consumers in the aggregate, DOE also
calculates the net present value from a
national perspective of the economic
impacts on consumers over the forecast
period used in a particular rulemaking.
For the results of DOE’s analyses related
to the economic impact on consumers,
see section V.B.1 of this notice and
chapters 8 and 11 of the TSD. For the
results of DOE’s analyses related to the
economic impact on manufacturers, see
section V.B.2 of this notice and chapter
12 of the TSD.
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c. Energy Savings
While significant conservation of
energy is a separate statutory
requirement for imposing an energy
conservation standard, EPCA requires
DOE, in determining the economic
justification of a standard, to consider
the total projected energy savings that
are expected to result directly from the
standard. DOE uses the NIA spreadsheet
results in its consideration of total
projected savings. For the results of
DOE’s analyses related to the potential
energy savings, see section V.B.3.a of
this notice and chapter 10 of the TSD.
d. Lessening of Utility or Performance of
Products
In establishing classes of equipment,
and in evaluating design options and
the impact of potential standard levels,
DOE seeks to develop standards that
would not lessen the utility or
performance of the equipment under
consideration. None of the TSLs
presented in today’s NOPR would
reduce the utility or performance of the
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equipment considered in the
rulemaking. During the screening
analysis, DOE eliminated from
consideration any technology that
would adversely impact consumer
utility. For the results of DOE’s analyses
related to the potential impact of new
standards on equipment utility and
performance, see section IV.B of this
notice and chapter 4 of the TSD.
e. Impact of Any Lessening of
Competition
EPCA directs DOE to consider the
impact of any lessening of competition,
as determined in writing by the
Attorney General, that is likely to result
from the imposition of a standard. It
also directs the Attorney General to
determine the impact, if any, of any
lessening of competition likely to result
from a proposed standard and to
transmit such determination to the
Secretary within 60 days of the
publication of a proposed rule, together
with an analysis of the nature and
extent of the impact. DOE will transmit
a copy of today’s proposed rule to the
Attorney General with a request that the
Department of Justice (DOJ) provide its
determination on this issue. DOE will
address the Attorney General’s
determination in the final rule.
f. Need of the Nation To Conserve
Energy
The energy savings from the proposed
standards are likely to provide
improvements to the security and
reliability of the nation’s energy system.
Reductions in the demand for electricity
also may result in reduced costs for
maintaining the reliability of the
nation’s electricity system. DOE
conducts a utility impact analysis to
estimate how standards may affect the
nation’s needed power generation
capacity. The utility impact analysis is
contained in chapter 14 of the TSD.
The proposed standards also are
likely to result in environmental
benefits in the form of reduced
emissions of air pollutants and
greenhouse gases associated with energy
production. DOE reports the emissions
impacts from today’s standards, and
from each TSL it considered, in section
V.B.6 of this notice and chapter 15 of
the TSD. DOE also reports estimates of
the economic value of emissions
reductions resulting from the
considered TSLs.
g. Other Factors
EPCA allows the Secretary, in
determining whether a standard is
economically justified, to consider any
other factors that the Secretary deems to
be relevant. For the results of DOE’s
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analyses related to other factors, see
section V.B.7 of this notice.
2. Rebuttable Presumption
As set forth in 42 U.S.C.
6295(o)(2)(B)(iii), EPCA provides for a
rebuttable presumption that an energy
conservation standard is economically
justified if the additional cost to the
consumer of equipment that meets the
standard level is less than three times
the value of the first-year energy (and,
as applicable, water) savings resulting
from the standard, as calculated under
the applicable DOE test procedure.
DOE’s LCC and PBP analyses generate
values which can be used to calculate
the payback period for consumers of
products or equipment that meet the
proposed standards. These analyses
include, but are not limited to, the
three-year payback period contemplated
under the rebuttable presumption test.
However, DOE routinely conducts a full
economic analysis that considers the
full range of impacts to the consumer,
manufacturer, nation, and environment,
as required under 42 U.S.C.
6295(o)(2)(B)(i). The results of this
analysis serve as the basis for DOE to
evaluate the economic justification for a
potential standard level (thereby
supporting or rebutting the results of
any preliminary determination of
economic justification). The rebuttable
presumption payback calculation is
discussed in section IV.F.12 of this
NOPR and chapter 8 of the TSD.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
IV. Methodology and Discussion
A. Market and Technology Assessment
When beginning an energy
conservation standards rulemaking,
DOE develops information that provides
an overall picture of the market for the
products concerned, including the
purpose of the products, the industry
structure, and market characteristics.
This activity includes both quantitative
and qualitative assessments based
primarily on publicly-available
information (e.g., manufacturer
specification sheets and industry
publications) and data submitted by
manufacturers, trade associations, and
other stakeholders. The subjects
addressed in the market and technology
assessment for this rulemaking include:
(1) Quantities and types of products
sold and offered for sale; (2) retail
market trends; (3) products covered by
the rulemaking; (4) equipment classes;
(5) manufacturers; (6) regulatory
requirements and non-regulatory
programs (such as rebate programs and
tax credits); and (7) technologies that
could improve the energy efficiency of
the products under examination. DOE
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researched manufacturers of panels,
display doors, non-display doors, and
refrigeration equipment. DOE also
identified and characterized small
business manufacturers of these
components. See chapter 3 of the TSD
for further discussion of the market and
technology assessment.
In the preliminary TSD, DOE
presented market performance data.
Typically, DOE’s analysis of market data
uses catalog and performance data to
determine the number of products on
the market at varying efficiency levels.
However, WICF systems and equipment
have not previously been rated for
efficiency by manufacturers, nor has an
efficiency metric been established for
this equipment. Based on the available
data, DOE presented a sample of
equipment at various sizes in the
preliminary TSD and estimated the
energy consumption of the equipment
using the preliminary engineering
spreadsheet. For refrigeration
equipment in particular, DOE found
that, as expected, the relationship
between capacity and energy
consumption was roughly linear.
In a comment on the market
performance data DOE presented,
Manitowoc expressed concern that
DOE’s use of linear trends to establish
the relationship between energy
consumption and net capacity will lead
to an overestimation of the potential
benefits of refrigeration system
standards. (Manitowoc, No. 0056.1 at p.
2)
DOE presented the market
performance data to illustrate its
understanding of the market. In
response to Manitowoc’s concern, DOE
notes that the benefits of the rule are not
derived from the estimates of market
performance data but are determined
from the LCC analysis and NIA. DOE
seeks market performance data to help
inform DOE’s analysis.
1. Definitions Related to Walk-In
Coolers and Freezers
DOE proposes to amend the definition
of display door and to adopt definitions
for passage and freight door in order to
clarify the boundaries separating these
equipment classes. The display door
definition was modified to permit
transparent doors used for the passage
of people to be categorized as display
doors rather than as non-display passage
doors. DOE is proposing to define
transparent passage doors as a type of
display door because transparent
passage doors are generally constructed
in the same manner and with the same
materials as transparent reach-in doors.
DOE proposes to include definitions for
non-display passage and freight doors in
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order to clarify the distinction between
the two types of doors. Non-display
passage doors are typically smaller than
freight doors and are designed for
passage of people and small machines,
whereas non-display freight doors are
larger than passage doors and designed
for the passage of large machines like
forklifts.
a. Display Doors
As described in section III.B of this
notice, DOE established a definition for
display door in the test procedure. 76
FR 33631 (June 9, 2011). DOE is now
proposing to amend this definition to
include all doors that are comprised of
75 percent or more glass or other
transparent material. This amendment is
intended to classify passage doors that
are mostly comprised of glass as display
doors because the utility and
construction of glass passage doors more
closely resembles that of a display door.
DOE proposes to define a display door
as one that ‘‘(1) is designed for product
display; or (2) has 75 percent or more
of its surface area comprised of glass or
another transparent material.’’ DOE
requests comment on this proposed
definition.
b. Freight Doors
DOE is proposing to separate nondisplay doors into two equipment
classes, passage doors and freight doors.
DOE proposes to define freight doors in
order to clarify the distinction between
these two equipment classes and
remove any ambiguity about which
energy standards apply to a given door.
The two types of doors are constructed
differently—for example, freight doors
tend to have more structural support
because they are bulkier—and warrant
different standards for each type. DOE is
proposing a definition of freight doors
that would account for the fact that
these doors are typically larger than
passage doors and are used to allow
large machines, like forklifts, into walkins. Specifically, DOE proposes to
define a freight door to mean ‘‘a door
that is not a display door and is equal
to or larger than 4 feet wide and 8 feet
tall.’’ DOE based these proposed
dimensions on the standard size of a
walk-in panel, which is 4 feet wide by
8 feet tall. In DOE’s estimation doors
used for the passage of people small
machines would be less than the
standard size of a walk-in panel and
therefore all other doors would be
freight doors. DOE requests comment on
its proposed definition.
c. Passage Doors
DOE proposes a definition of passage
doors to differentiate passage doors from
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freight doors and display doors. Passage
doors are mostly intended for the
passage of people and small machines
like hand carts and not for product
display. DOE proposes to define this
term to mean ‘‘a door that is not a
freight or display door.’’ DOE requests
comment on this proposed definition.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
2. Equipment Included in This
Rulemaking
a. Panels and Doors
As mentioned in section III.B.1, DOE
identified three types of panels used in
the walk-in industry: Display panels,
floor panels, and non-floor panels.
Based on its research, DOE determined
that display panels, typically found in
beer caves (walk-ins used for the display
and storage of beer or other alcoholic
beverages often found in a supermarket)
make up a small percentage of all panels
currently present in the market.
Therefore, because of the extremely
limited energy savings potential
currently projected to result from
amending the requirements that these
panels must meet, DOE is not proposing
standards for walk-in display panels in
this NOPR. Display panels, however,
must still follow all applicable design
standards already prescribed by EPCA,
as discussed in section II.B.1 of this
notice.
DOE is also not proposing to require
the installation of walk-in cooler floor
panels. DOE did not consider including
walk-in cooler floor panels in its
analysis because of their complex
nature. Through manufacturer
interviews and market research, DOE
determined that, unlike walk-in
freezers, the majority of walk-in coolers
are made with concrete floors and do
not use insulated floor panels. The
entity that installs the cooler floor is
considered the floor’s manufacturer and
is responsible for testing and complying
with a walk-in cooler floor standard. If
DOE were to require that all walk-in
coolers to be equipped with floor
panels, the onus of complying with this
requirement would likely fall on entities
that do not specialize in constructing
walk-in coolers, and the accompanying
burden in using these components and
certifying compliance with the
appropriate standards would likely be
costly and difficult for that entity to
fulfill. Therefore, at this time, it is
DOE’s view that requiring the use of
floor panels—along with the
accompanying compliance costs—
would present an undue burden to those
entities that would be responsible for
meeting these requirements. For these
reasons, DOE is not proposing to require
walk-in coolers to have floor panels, nor
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is DOE proposing energy efficiency
standards for cooler floor panels. (DOE
is, however, proposing energy efficiency
standards for walk-in freezer floor
panels and notes that EPCA requires
floor insulation of at least R–28 for
walk-in freezers. (42 U.S.C.
6313(f)(1)(D)).)
DOE also identified two types of
doors in the walk-in market, display
doors and non-display doors, which are
discussed in section III.B.2 of this
NOPR. All types of doors will be subject
to the performance standards proposed
in this rulemaking.
b. Refrigeration System
DOE defines the refrigeration system
of a walk-in as the mechanism
(including all controls and other
components integral to the system’s
operations) used to create the
refrigerated environment in the interior
of the walk-in cooler and freezer,
consisting of either (1) a packaged
system where the unit cooler and
condensing unit are integrated into a
single piece of equipment, (2) a split
system with separate unit cooler and
condensing unit sections, or (3) a unit
cooler that is connected to a multiplex
condensing system. 76 FR at 33631.
DOE based its preliminary results
used in today’s proposal on an analysis
of storage coolers and freezers. DOE did
not analyze blast freezer walk-ins,
which are designed to quickly freeze
food and then store it at a specified
holding temperature. American Panel
commented that blast freezer
performance differs from storage freezer
performance due to the large product
loads experienced with this specialized
equipment. (American Panel, No. 0048.1
at p. 4) Heatcraft added that blast freezer
refrigeration systems’ energy
consumption would be higher than that
of storage freezers and that they require
wider fin spacing because of a higher
rate of frost accumulation. (Heatcraft,
No. 0058.1 at p. 1)
DOE agrees with American Panel and
Heatcraft that blast freezer refrigeration
systems have different energy
characteristics from storage freezers, but
questions whether they would
necessarily have a lower rated
efficiency. DOE is not proposing to
include blast freezers in this rulemaking
analysis because they make up a small
percentage of walk-ins currently present
in the market. DOE requests comment
on whether blast freezer refrigeration
systems would have difficulty
complying with DOE’s refrigeration
efficiency standards and, if so, to direct
DOE to (and supply it with) any test
procedure data supporting this
conclusion. DOE proposes to apply the
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same standards to blast freezer
refrigeration systems as to storage
freezer refrigeration systems, unless
DOE finds that blast freezer refrigeration
systems would have difficulty
complying with DOE’s standards.
Otherwise, DOE will consider excluding
blast freezers from coverage under this
rulemaking, although they would still
have to comply with the already
statutorily-prescribed standards in
EPCA.
Regarding the particular refrigerant to
be used in the analysis, DOE analyzed
refrigeration equipment using R404A, a
hydrofluorocarbon (HFC) refrigerant
blend, in the preliminary analysis.
Heatcraft supported DOE’s approach to
use only HFC refrigerants in the
analysis, but also suggested that DOE
consider lower global warming potential
(GWP) refrigerants—such as R134a,
R407A, or R407C—in the analyses as
well because of shifts in the marketplace
towards these products, even though
these refrigerants may have lower
efficiencies. (Heatcraft, No. 0069.1 at p.
3)
DOE used R404A in its analysis for
this NOPR because it is widely used
currently in the walk-in industry. DOE
appreciates Heatcraft’s suggestion to
analyze alternative refrigerants,
especially those with a lower GWPs
given the interest by many
manufacturers to use these alternatives,
and requests comment on the extent of
the use or likely phase-in of lower GWP
refrigerants and asks manufacturers to
submit data related to the ability of the
equipment (either existing or
redesigned) using these refrigerants to
meet the proposed standard, as well as
the cost of such equipment.
3. Equipment Classes
a. Panels and Doors
In the preliminary analysis, DOE
proposed to divide the envelope into
two separate equipment classes: display
and non-display walk-ins (that is, walkins with and without glass). Display
walk-ins are walk-ins that have doors
for display purposes, are typically made
with glass, and are inherently less
efficient than walk-ins without glass
because glass is not as insulative as the
insulation material used in non-display
walk-ins (typically polyurethane or
polystyrene).
Interested parties commented on the
need to separate display and nondisplay walk-ins into two different
equipment classes. Nor-Lake and AHRI
agreed with the equipment classes
proposed by DOE, and AHRI
commented that the equipment classes
represent the most common walk-in
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configurations. (Nor-Lake, No. 0049.1 at
p. 1; AHRI, No. 0055.1 at p. 2)
Manitowoc stated that classification of
envelopes into storage and display types
is appropriate as it may allow for
different performance levels for certain
components. (Manitowoc, No. 0056.1 at
p. 2) However, CrownTonka contended
that it was unnecessary to have two
equipment classes for display and nondisplay walk-ins and that separate
classes for coolers and freezers are
adequate. (CrownTonka, No. 0057.1 at
p. 1) ASAP and SCE opined that one
equipment class is sufficient and that
the difference between non-display and
display doors could be accounted for
through a weighted average of the
opaque and glass surface areas. (ASAP,
Public Meeting Transcript, No. 0045 at
p. 70; SCE, Public Meeting Transcript,
No. 0045 at p. 79) However, NEAA,
NPCC and Manitowoc countered that
there should not be a single metric for
both display and non-display doors
because it would not account for the
unique utility offered by display walkins (i.e., permitting the display of stored
items). (NEAA and NPCC, Public
Meeting Transcript, No. 0045 at p. 76;
Manitowoc, Public Meeting Transcript,
No. 0045 at p. 78) NEAA and NPCC
stated that, if DOE were to separate
display and non-display walk-ins into
two different classes, DOE should
carefully define the boundary between
the two classes. (NEAA and NPCC,
Public Meeting Transcript, No. 0045 at
p. 77) NEAA and NPCC also suggested
that, as an alternative to having one
equipment class for display and nondisplay walk-ins with a single
performance metric, DOE should move
to component level-based classes with
separate performance metrics. (NEAA
and NPCC, Public Meeting Transcript,
No. 0045 at p. 76)
Interested parties also submitted
comments about the names of the
equipment classes. NEAA and NPCC
stated that if DOE has two separate
equipment classes for display and nondisplay walk-ins, DOE should carefully
define the boundary between the two
classes. (NEAA and NPCC, Public
Meeting Transcript, No. 0045 at p. 77)
Kysor stated that the class names DOE
suggested were confusing and offered an
alternative—‘‘coolers with glass doors’’
instead of ‘‘display coolers’’—to help
clarify the difference between the two
separate equipment classes. (Kysor,
Public Meeting Transcript, No. 0045 at
p. 78)
In light of the component level
standards described in section III.A,
DOE proposes to create separate
equipment classes for panels, display
doors, and non-display doors. These
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different items comprise the main
components of a walk-in envelope. DOE
proposes separate classes for panels,
display doors, and non-display doors
because each component type has a
different utility to the consumer and
possesses different energy use
characteristics.
In the preliminary analysis, DOE also
considered the possibility of creating
separate classes for walk-in coolers and
walk-in freezers because EPCA
specifically divides walk-in equipment
into coolers (above 32 °F) and freezers
(at or below 32 °F), (42 U.S.C. 6311(20)),
and prescribes unique design
requirements for each. (42 U.S.C.
6313(f)(1)(C)–(D)(3)) DOE has continued
to apply this approach in its analysis.
Panels
DOE has placed panels into two
equipment classes: Freezer floor panels
and non-floor panels (also called
structural panels). DOE understands
that freezer floor panels and structural
panels serve two different utilities.
Freezer floor panels, which are panels
used to construct the floor of a walk-in,
must often support the load of small
machines like hand carts and pallet
jacks on their horizontal faces. Nonfloor panels or structural panels, which
include panels used to construct the
ceiling or wall of a walk-in, provide
structure for the walk-in. Because of
their different utilities, the two classes
of panels are constructed differently
from each other and use different
amounts of framing material, which
affects the panels’ energy consumption.
Structural panels are further divided
into two more classes based on
temperature—i.e., cooler versus freezer
panels. Cooler structural panels are
rated with their internal faces exposed
to a temperature of 35 °F, as called for
in the test procedure final rule. Freezer
structural panels are used in walk-in
freezers and rated with its internal face
exposed to a temperature of ¥10 °F, as
required by the test procedure final rule.
76 FR at 21606; 10 CFR 431.303. EPCA
also requires walk-in freezer panels to
have a higher R-value than walk-in
cooler panels. These differences result
in different amounts of insulating foam
between these panel types and affect the
panel’s U-value.
Doors
DOE has distinguished between two
different door types used in walk-in
coolers and freezers: Display doors and
non-display doors. DOE proposed
separate classes for display doors and
non-display doors to retain consistency
with the dual approach laid out by
EPCA for these walk-in components. (42
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U.S.C. 6313(f)(1)(C) and (3)) Nondisplay doors and display doors also
serve separate purposes in a walk-in.
Display doors contain mainly glass in
order to display products or objects
located inside the walk-in. Non-display
doors function as passage and freight
doors and are mainly used to allow
people and products to be moved into
and out of the walk-in. Because of their
different utilities, display and nondisplay doors are made up of different
material. Display doors are made of
glass or other transparent material,
while non-display doors are made of
highly insulative materials like
polyurethane. The different materials
found in display and non-display doors
significantly affect their energy
consumption.
DOE divided display doors into two
equipment classes based on temperature
differences: cooler and freezer display
doors. Cooler display doors and freezer
display doors are exposed to different
internal temperature conditions, which
affect the total energy consumption of
the doors. In the test procedure final
rule, DOE established an internal rating
temperature of 35 °F for walk-in cooler
display doors and ¥10 °F for walk-in
freezer display doors. 76 FR at 21606; 10
CFR Part 431, Subpart R, Appendix A,
Section 5.3.
DOE also separated non-display doors
into two equipment classes, passage and
freight doors. Passage doors are
typically smaller doors and mostly used
as a means of access for people and
small machines, like hand carts. Freight
doors typically are larger doors used to
allow access for larger machines, like
forklifts, into walk-ins. The different
shape and size of passage and freight
doors affects the energy consumption of
the doors. Both passage and freight
doors are also separated into cooler and
freezer classes because, as explained for
display doors, cooler and freezer doors
are rated at different temperature
conditions. A different rating
temperature impacts the door’s energy
consumption.
In the preliminary analysis, DOE did
not consider outdoor envelopes as a
separate equipment class. Walk-ins
located outdoors have very similar
features to walk-ins located indoors, and
DOE could not identify any additional
design options that improved the energy
consumption only of outdoor walk-ins.
The Joint Utilities, NEEA and NPCC,
CrownTonka, Nor-Lake, and Hill
Phoenix stated that DOE should
differentiate equipment classes by their
external environment. (Joint Utilities,
No. 0061.1 at p. 5; NEEA and NPCC, No.
0059.1 at p. 6; CrownTonka, Public
Meeting Transcript, No. 0045 at p. 81;
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Nor-Lake, No. 0049.1 at p. 2; Hill
Phoenix, No. 0066.1 at p. 2) The Joint
Utilities requested that DOE evaluate
cost-effective insulation levels for
outdoor walk-ins, and stated that there
would be a loss in energy savings if DOE
did not consider region-specific
insulation levels. (Joint Utilities, Public
Meeting Transcript, No. 0045 at pp. 80
and 82) Nor-Lake contested DOE’s claim
that walk-ins designed as outdoor units
include no additional features that
impact energy consumption, stating that
the ambient temperature and product
load will change the energy
consumption for both the indoor and
outdoor units. (Nor-Lake, No. 0049.1 at
p.2) Hill Phoenix recommended a
separate equipment class for outdoor
walk-ins because outdoor walk-ins must
have thicker panels to withstand
environmental conditions. (Hill
Phoenix, No. 0066.1 at p. 2) American
Panel observed that a walk-in located
outdoors has an added benefit in that no
building space was constructed to house
the walk-in, which is a significant
energy savings not considered in the
preliminary analysis. (American Panel,
No. 0048.1 at p. 3)
Some commenters described how
DOE could include equipment classes
that capture the external conditions.
SCE suggested that DOE set a series of
different conditions by the location of
the wall such as an outdoor, indoor, or
demising wall (i.e., a dividing wall to
separate spaces) between a cooler and a
freezer space. (SCE, Public Meeting
Transcript, No. 0045 at pp. 80 and 82–
83) NEEA and NPCC recommended
changing the equipment classes to
indoor cooler, indoor freezer, outdoor
cooler, and outdoor freezer. (NEEA and
NPCC, No. 0059.1 at p. 6)
Other interested parties agreed with
DOE’s assertion that it was unnecessary
to consider outdoor walk-ins as a
separate equipment class. Kysor
explained that the envelope would be
designed for whatever ambient
conditions it may be subjected to, and
that adding additional performance
requirements would be unnecessary.
(Kysor, Public Meeting Transcript, No.
0045 at p. 80) Manitowoc stated that
there should not be any classification
based on external environments as there
are times when the envelope is exposed
to both internal and external conditions.
(Manitowoc, Public Meeting Transcript,
No. 0045 at p. 82)
DOE is not proposing to include any
panel or door equipment class that
accounts for the different external
environmental conditions that a walk-in
could experience in real world
applications. DOE does not find outdoor
and indoor walk-in envelope
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components to have distinct utilities.
Components for outdoor walk-ins and
indoor walk-ins are generally
constructed with the same design and
materials and serve the same purpose.
In response to Nor-Lake’s comment
about DOE’s assumption about
additional features, DOE clarifies that
while the difference in outdoor
temperatures affects the real world
energy consumption of the walk-in
envelope, DOE was referring to design
features, such as different types of
insulation, which differ from the design
options found on indoor walk-ins and
improve the energy efficiency of the
outdoor walk-in. As to Hill Phoenix’s
comment that a panel facing external
conditions requires more insulation,
DOE notes that panels with thicker
insulation already surpass the baseline
panel specifications, which would make
it easier for these types of panels to meet
the standards in today’s proposal.
Hill Phoenix also recommended that
DOE divide envelopes into factory
assembled step-in style walk-ins and
larger construction-based walk-ins. (Hill
Phoenix, No. 0066.1 at p. 1) Because it
is not proposing standards for walk-in
envelopes, but rather for the panels and
doors that are components of the
envelopes, DOE has not adopted Hill
Phoenix’s recommendation in today’s
proposal. DOE has, however, separated
into different equipment classes the
components typically found in factoryassembled walk-ins, such as passage
doors and floor panels, and those
components found in large
construction-based walk-ins, such as
freight doors. DOE believes this
approach will achieve the objective of
the Hill Phoenix recommendation,
namely that the proposed standards
reflect the different energy use
characteristics of factory-assembled and
construction-based walk-ins.
Table IV–1 lists the equipment classes
DOE proposes to create in this NOPR. In
the table below, medium temperature
refers to cooler equipment and low
temperature refers to freezer equipment.
The column entitled ‘‘Class’’ lists the
codes that will be used to abbreviate
each equipment class, and will be used
throughout the NOPR.
TABLE IV–1—EQUIPMENT CLASSES
FOR PANELS AND DOORS
Product
Temperature
Class
Structural
Panel.
Medium ........
SP.M
Floor Panel ...
Display Door
Low ..............
Low ..............
Medium ........
Low ..............
SP.L
FP.L
DD.M
DD.L
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TABLE IV–1—EQUIPMENT CLASSES
FOR PANELS AND DOORS—Continued
Product
Temperature
Passage Door
Medium ........
Low ..............
Medium ........
Low ..............
Freight Door
Class
PD.M
PD.L
FD.M
FD.L
b. Refrigeration Systems
In the preliminary analysis, DOE
considered dividing walk-in
refrigeration systems into six equipment
classes based on key physical
characteristics that affect equipment
efficiency: (1) The type of condensing
unit (i.e., whether the system has a
dedicated condensing unit or is
connected to a multiplex system), (2)
the operating temperature, and (3) the
location of the walk-in (i.e., indoors or
outdoors). In this NOPR, DOE also
proposes to differentiate refrigeration
system classes based on capacity. DOE
discusses the four proposed class
differentiations below.
Type of Condensing Unit
Due to the significant impact of the
condensing unit on the overall energy
consumption of the walk-in (as much as
90 percent), the preliminary analysis
differentiated between two different
condensing unit types: dedicated
condensing systems and multiplex
condensing systems. In a dedicated
condensing system, only one
condensing unit (consisting of one or
more compressors and condensers)
serves a single walk-in. A multiplex
condensing system consists of a rack of
compressors usually located in a
mechanical room, a large condenser or
condensers usually located on the roof,
and several unit coolers or evaporators
belonging to various types of
refrigeration equipment, including
walk-ins. The only part of a multiplex
condensing system that would be
covered under the proposed standard
would be a unit cooler in a walk-in—a
‘‘unit cooler connected to a multiplex
condensing system.’’ The compressor
and condenser of a multiplex system
would not be covered under the walkin standard because they serve
equipment other than walk-ins.
Furthermore, DOE would be unable to
attribute the portion of energy use
related to only the walk-in, at the point
of manufacture of the compressor and
condenser of the multiplex system.
DOE received several comments about
the classification of condensing types.
AHRI, Nor-Lake and Manitowoc agreed
with DOE’s equipment classes proposed
in the preliminary analysis, while the
Joint Utilities suggested redesignating
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the multiplex and dedicated equipment
classes as remote and self-contained,
respectively. (AHRI, Public Meeting
Transcript, No. 0045 at p. 74, Nor-Lake,
No. 0049.1 at p. 1, Manitowoc, No. 0056
at p. 2, Manitowoc, Public Meeting
Transcript, No. 0045 at p. 73, Joint
Utilities, Public Meeting Transcript, No.
0045 at p. 71) The Joint Utilities
suggested regulating condensing units
in a manner similar to that used by DOE
for commercial refrigeration equipment,
which, in their view, would result in
coverage of most of the condensing
units serving the walk-in industry. (Joint
Utilities, No. 0061.1 at p. 11, 12) The
Joint Advocates suggested that DOE
conduct a separate rulemaking for
condensing units. (Joint Advocates, No.
0070.1 at p. 3) They added that DOE
should reduce the number of
refrigeration types to self-contained and
unit coolers only, while the Joint
Utilities recommended against
including remote condensing units as
part of this rulemaking. (Joint
Advocates, No. 0070.1 at p. 3, Joint
Utilities, No. 0045 at p. 22)
DOE believes the refrigeration systems
covered by the two classes of
equipment, dedicated condensing and
multiplex condensing, accurately
represent the range of refrigeration
equipment used in walk-in coolers and
freezers. Although the proposed classes
differ from the classes designated in the
commercial refrigeration equipment
rulemaking, there are key differences
between commercial refrigeration
equipment refrigeration systems and
walk-in refrigeration systems. The Joint
Advocates and Joint Utilities refer to
two types of refrigeration systems
commonly used with commercial
refrigeration equipment: ‘‘selfcontained’’ (meaning the entire
refrigeration system is built into the
case) and ‘‘remote condensing’’
(meaning the unit cooler is built into the
case, but the whole case is connected to
a central system of compressors and
condensers, called a ‘‘rack’’ or
‘‘multiplex condensing system’’,
connected to most or all of the
refrigeration units in a building).
‘‘Remote condensing’’, however, can
also refer to a configuration in which
the unit cooler is connected to a
dedicated (i.e., only serving that one
unit) compressor and condenser that are
located somewhere away from the unit
cooler. This configuration is rare for
commercial refrigeration equipment, but
comprises a large proportion of walk-in
refrigeration system applications.
To avoid confusion over the different
configurations for walk-ins and
commercial refrigeration equipment that
can be classified as ‘‘remote
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condensing’’, DOE is not proposing to
classify walk-in refrigeration systems as
‘‘remote condensing’’ and ‘‘selfcontained’’. Also, DOE does not agree
that the compressor and condenser parts
should not be covered under the walkin coolers and freezers rulemaking.
Instead, DOE is proposing to include
dedicated condensing units in the rule,
even if remotely located, because these
units could be viewed as part of the
walk-in as long as they are connected
only to that particular walk-in and not
to other refrigeration equipment. For
systems where the walk-in is connected
to a multiplex condensing system that
runs multiple pieces of equipment, the
compressor and condenser would not be
covered because they are not
exclusively part of the walk-in.
In consideration of the above, DOE
proposes to create two classes of
refrigeration systems: dedicated
condensing and multiplex condensing.
DOE believes that dedicated remote
condensing units represent a substantial
opportunity for energy savings in a
regulation for walk-in components
because the configuration of a dedicated
remote condensing unit is widespread
in several market segments, such as
restaurants. Manufacturers can optimize
the dedicated remote condensing unit
with the unit cooler to take advantage of
certain conditions, such as low ambient
outdoor temperatures.
DOE does not propose to create
separate classes for dedicated packaged
systems (where the unit cooler and
condensing unit are integrated into a
single piece of equipment) and
dedicated split systems (with separate
unit cooler and condensing unit
sections). Packaged systems are
potentially more efficient than split
systems because they do not experience
as much energy loss in the refrigerant
lines. However, because packaged
systems comprise a small share of the
refrigeration market, DOE currently
believes that little additional energy
savings could be achieved by
considering them as a separate class.
Accordingly, DOE is not proposing to
consider the creation of a separate
packaged systems class.
DOE also notes that its proposed
standards for dedicated condensing
systems are based on an analysis of split
systems. DOE requests comment on its
proposal not to consider dedicated
packaged systems and dedicated split
systems as separate classes and whether
this proposal would unfairly
disadvantage any manufacturers.
Operating Temperature
The second physical characteristic
that DOE proposes as a basis for
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dividing refrigeration systems into
equipment classes is the operating
temperature. EPCA divides walk-in
equipment into coolers (above 32 °F)
and freezers (at or below 32 °F) (42
U.S.C. 6311(20)) Using this distinction,
DOE is proposing to categorize
refrigeration systems as low or medium
temperature systems based on the
temperature profiles of their unit
coolers. The medium (M) and low (L)
temperature units are differentiated by
their operating temperatures, which are
greater than 32 °F (for coolers) and less
than or equal to 32 °F (for freezers). In
response to DOE’s discussion of these
classes in the preliminary analysis,
Ingersoll Rand suggested that any walkin with defrost be rated as a freezer
regardless of the operating temperature.
(Ingersoll Rand, No. 0053.1 at p. 1) DOE
has not adopted these suggestions
because doing so would conflict with
the statutory distinction created by
Congress that relies on operating
temperature to distinguish between
walk-in coolers and freezers. See 42
U.S.C. 6311(2) (treating walk-ins as
separate equipment based on whether
they are coolers or freezers).
Furthermore, applying the rating
conditions for low temperature
refrigeration systems is unlikely to
enable a tester to accurately measure the
efficiency of a medium temperature
refrigeration system. Requiring a
refrigeration system with defrost to be
rated at the low temperature rating
conditions even if it is designed to
operate closer to the medium
temperature rating conditions could
lead to inaccurate equipment ratings for
such equipment. In certain cases,
applying temperature ratings in this
manner may not permit this type of
equipment to be rated at low
temperature rating conditions if it is not
designed to operate at those
conditions.14
Location of the Walk-In
The third physical characteristic DOE
considered is the location of the
condensing unit (i.e., indoor or
outdoor), which also affects the energy
consumption of dedicated condensing
systems. Indoor refrigeration systems
generally operate at fixed ambient
temperatures, while outdoor
refrigeration systems experience varying
temperatures through the year. This
change in temperature affects the
performance of the refrigeration system
by requiring it to operate more during
14 For example, most medium temperature unit
coolers are designed to operate between 15 °F and
45 °F, and would not be able to operate at the low
temperature rating condition of ¥10 °F.
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warmer conditions and less during
colder ones. Accordingly, the test
procedure has one ambient rating
condition for indoor systems and three
ambient rating temperatures for outdoor
systems.
In the preliminary analysis, DOE
considered creating separate classes for
refrigeration systems with indoor (I) and
outdoor (O) condensing units because of
their different energy consumption
characteristics. Outdoor condensing
units can also implement a wide variety
of design options to run more efficiently
at low ambient temperatures. (In
contrast, DOE did not consider indoor
and outdoor envelope components as
belonging to separate classes partly
because of the absence of available
options for improving efficiency based
on the ambient temperature. See section
IV.A.3.a for details.) Following the
preliminary analysis, DOE did not
receive any comments regarding the
indoor and outdoor condensing unit
classes, and therefore proposes the same
differentiation in this NOPR.
Refrigeration Equipment Size
In the preliminary analysis, DOE did
not consider different equipment classes
based on refrigeration equipment size.
Heatcraft suggested adding subcategories to the proposed equipment
classes, stating that the size of
refrigeration systems varies with
envelope size. (Heatcraft, No. 0069.1 at
p. 1) Manitowoc commented that small
sized equipment would struggle to meet
minimum standards if DOE based the
metric on a larger size, largely due to the
efficiency difference of each system
size. (Manitowoc, Public Meeting
Transcript, No. 0044 at p. 118)
DOE is not proposing to base
refrigeration system classes on envelope
size because it is taking a componentlevel approach that sets standards for
the refrigeration system independent of
the envelope. In reaching this tentative
decision, DOE examined the ability of
various sized equipment to meet a
proposed standard. For the NOPR
analysis, DOE analyzed a wider range of
equipment sizes than it did for the
preliminary analysis, as described later
in section IV.C.1.b. As a result of this
expanded analysis, DOE observed that
small sized equipment may have
difficulty meeting an efficiency standard
that is based on an analysis of large
equipment, as Manitowoc noted. DOE
found that this result was primarily due
to a lack of availability of the more
efficient compressor types (e.g., scroll
compressors) at lower capacities.
Additionally, certain design options,
mainly controls, generally have a fixed
cost, but their benefit decreases with
lower capacities, so they are less cost-
55803
effective for lower-capacity equipment.
Therefore, DOE proposes one equipment
class for high-capacity equipment and
another for low-capacity equipment
within the dedicated condensing
category (because the compressor is
covered only for DC systems). DOE has
tentatively chosen 9,000 Btu/h as the
capacity threshold for small- and largecapacity equipment based on the
efficiency characteristics of available
compressors, among other factors. See
chapter 3 for details. DOE requests
comment on the capacity threshold
between the two capacity classes for
dedicated condensing systems.
Proposed Classes
Using the proposed combinations of
condensing unit types, operating
temperatures, location, and size, ten
equipment classes are possible for walkin cooler or freezer refrigeration
systems. DOE believes that these ten
classes accurately represent the
refrigeration units used in the walk-in
market today.
Table IV–2 lists the equipment classes
for refrigeration equipment that DOE is
proposing in this NOPR. The column
entitled ‘‘Class’’ lists the codes that will
be used to abbreviate each equipment
class, and will be used throughout the
NOPR.
TABLE IV–2—EQUIPMENT CLASSES FOR REFRIGERATION EQUIPMENT
Refrigeration capacity
(Btu/h)
Condensing type
Operating temperature
Condenser location
Dedicated ....................................
Medium .......................................
Indoor .........................................
Outdoor ......................................
Low .............................................
Indoor .........................................
Outdoor ......................................
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Multiplex ......................................
Medium .......................................
Low .............................................
4. Technology Assessment
In a technology assessment, DOE
identifies technologies and designs that
could be used to improve the energy
efficiency or performance of covered
equipment. For the preliminary
analysis, DOE conducted a technology
assessment to identify all technologies
and designs that could be used to
improve the energy efficiency of walkins or walk-in components. DOE
described these technologies in chapter
3 of the preliminary TSD.
DOE received several comments in
response to its preliminary list of
technology options. NEEA and NPCC
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.....................................................
.....................................................
recommended that DOE include
modulating condenser fan controls in its
analysis because there are significant
potential energy savings from this
technology. (NEEA and NPCC, No.
0059.1 at p. 8) Emerson agreed and
noted that higher-efficiency
compressors often require modulating
fan controls to realize the full benefit of
the higher-efficiency compressors.
(Emerson, Public Meeting Transcript,
No. 0045 at p. 90) The Joint Utilities
pointed out that DOE did not include
variable speed controls for condenser
fans. (Joint Utilities, No. 0061.1 at p.10)
In addition, NEEA and NPCC
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Class
< 9,000
≥ 9,000
< 9,000
≥ 9,000
< 9,000
≥ 9,000
< 9,000
≥ 9,000
..............................
..............................
DC.M.I, < 9,000
DC.M.I, ≥ 9,000
DC.M.O, < 9,000
DC.M.O, ≥ 9,000
DC.L.I, < 9,000
DC.L.I, ≥ 9,000
DC.L.O, < 9,000
DC.L.O, ≥ 9,000
MC.M
MC.L
recommended that DOE include liquid
suction heat exchangers in its analysis
because there are significant potential
energy savings from this technology.
(NEEA and NPCC, No. 0059.1 at p. 8)
In response to the recommendation
that DOE consider condenser fan
controls, DOE has added condenser fan
controls as a design option because it
determined through further analysis that
they could be an effective means of
saving energy. As to NEEA and NPCC’s
recommendation that DOE include
liquid suction heat exchangers, DOE
also considered liquid suction heat
exchangers in the technology
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assessment because this technology
could potentially be used to save
energy. However, DOE screened this
option from further consideration
because further examination indicated
that it would be unlikely to yield
significant energy savings under the
rating conditions used in setting
standards for walk-in equipment. See
chapters 3, 4, and 5 of the TSD for more
details on the technologies considered
in the analysis.
B. Screening Analysis
DOE uses four screening criteria to
determine which design options are
suitable for further consideration in a
standards rulemaking. Namely, design
options will be removed from
consideration if they (1) are not
technologically feasible; (2) are not
practicable to manufacture, install, or
service; (3) have adverse impacts on
product utility or product availability;
or (4) have adverse impacts on health or
safety. 10 CFR 430, subpart C, appendix
A, sections (4)(a)(4) and (5)(b).)
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1. Technologies That Do Not Affect
Rated Performance
In the preliminary analysis TSD, DOE
proposed to screen out the following
technologies because they do not
improve energy efficiency: nonpenetrative internal racks and shelving,
air and water infiltration sensors,
humidity sensors, and heat flux sensors.
For the reasons stated in the test
procedure final rule, DOE’s test
procedure establishes metrics to test the
energy consumption or energy use of
walk-in components and does not
include heat load caused by infiltration.
See 76 FR at 21594–21595. As a result,
DOE included additional infiltrationrelated technologies in the following list
of technologies that do not improve
rated performance:
• Internal racks and shelving that are
non-penetrative;
• Air and water infiltration sensors;
• Extruded polystyrene insulation;
• Humidity sensors;
• Heat flux sensors;
• Door gasketing improvements and
panel interface systems;
• Automatic door opening and
closing systems;
• Air curtains;
• Strip curtains;
• Vestibule entryways; and
• Insulation with improved moisture
resistance.
In the preliminary analysis, DOE
listed hot gas defrost as a technology
that does not improve rated
performance of refrigeration equipment.
In response, the Joint Utilities stated
that DOE should include hot gas defrost.
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(Joint Utilities, Public Meeting
Transcript, No. 0045 at p. 25; Joint
Utilities, No. 0061.1 at pp. 3, 7, and 10).
DOE has included hot gas defrost as a
design option for multiplex condensing
systems, but not for dedicated
condensing systems due to its lack of
effectiveness in improving efficiency.
Specifically, for multiplex condensing
systems, the hot gas defrost system
utilizes hot gas generated by the
compressor rack. Because at least one of
the compressors in the rack is likely to
be running (because the rack also has to
operate with other refrigeration units)
no new energy is consumed to generate
the hot gas. In contrast, for dedicated
systems, the condensing unit typically
turns off during an electric defrost cycle.
Running the compressor to generate hot
gas at a time when it would normally be
off results in energy use that outweighs
the energy saved by using hot gas
defrost instead of electric defrost. See
chapters 3 and 5 of the TSD for details.
Also as part of the preliminary
analysis, DOE analyzed the envelope
and the refrigeration system separately
and did not consider design options that
depend on the interaction between the
envelope and the refrigeration system.
SCE suggested that DOE consider
control options that depend on the
interaction between envelope
components and the refrigeration
system, such as a control that turns off
the evaporator fan when the door is
opened. SCE suggested that DOE
evaluate such technologies by
establishing a typical, nominal savings
value for use in energy consumption
equations. (SCE, Public Meeting
Transcript, No. 0045 at p. 25) Similarly,
NEEA and NPCC stated that such
technological controls have not been
included in the design options. (NEEA
and NPCC, No. 0059.1 at p. 7)
A nominal savings value, as suggested
by SCE, would be highly dependent on
many assumptions about the application
of the walk-in and the pairing of the
refrigeration system with the walk-in.
As a result, DOE does not believe that
it would be reasonable to apply this
shared value to all refrigeration system
or door manufacturers because of the
wide variety of equipment produced by
these entities for walk-in applications.
Moreover, DOE’s proposed component
level approach eliminates the need to
consider design options whose efficacy
depends on the interaction between
different components.
DOE also did not consider design
options whose benefits would not be
captured by the test procedure, such as
economizer cooling. Economizer cooling
consists of directly venting outside air
into the interior of the walk-in when the
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outside air is as cold as or colder than
the interior of the walk-in. This
technique relieves the load on the
refrigeration system when a pull-down
load (i.e., a load due to items brought
into the walk-in at a higher temperature
than the operating temperature and
must then be cooled to the operating
temperature) is necessary. However, the
test procedure does not include a
method for accounting for economizer
cooling, as it does not specify
conditions for air that would be vented
into the walk-in, nor does it provide a
method for measuring the energy use of
the economizer. Therefore, any benefits
from including an economizer on a
WICF would not be captured by the test
procedure.
2. Screened-Out Technologies
a. Panels and Doors
In the preliminary analysis, DOE
screened out the following technologies
for envelopes: revolving doors, energy
storage systems, fiber optic natural light,
non-electric anti-sweat systems, and
automatic insulation deployment
systems. DOE did not receive comments
regarding any of the screened-out
technologies, and will continue to
exclude them from this rulemaking.
DOE has also screened out additional
technologies as part of its proposal to
regulate the components of the envelope
separately (i.e., display doors, nondisplay doors, and panels.) See chapter
4 of the TSD for more details on the
screened-out technologies.
b. Refrigeration
In the preliminary analysis, DOE
screened out the following technologies
for refrigeration systems: Higherefficiency evaporator fan motors,
improved evaporator coil, three-phase
motors, and economizer cooling. In
response to DOE’s request for comment
on the screening analysis, American
Panel, AHRI and CrownTonka agreed
with this approach to screen out these
technologies. (American Panel, Public
Meeting Transcript, No. 0045 at p. 98;
AHRI. Public Meeting Transcript, No.
0045 at p. 99; CrownTonka, No. 0057.1
at p. 1) Emerson, however, disagreed
with DOE’s decision to screen out
economizer cooling because there are
potential energy savings under certain
circumstances. (Emerson, Public
Meeting Transcript, No. 0045 at p. 100)
Also, Heatcraft disagreed with the
exclusion of phase motor technology
because three-phase motors are the
dominant motor type in the larger walkin envelopes that are a part of this
rulemaking. (Heatcraft No. 0069.1 at p.
2) Manitowoc remarked that there are
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other ways to achieve an effective
economizer cooling cycle and
encouraged DOE to investigate other
options to improve cycle efficiency, but
did not provide any specific
recommendations. (Manitowoc, Public
Meeting Transcript, No. 0045 at p. 92)
DOE continues to screen out threephase motor technology. The use of
three-phase motor technology generally
provides higher energy savings as
compared to single-phase motors.
Three-phase power is commonly used to
power large motors and heavy electrical
loads; however, it is not available for all
businesses, particularly small business
consumers of walk-ins. DOE did not
consider three-phase motor technology
as a design option based on utility to the
consumer, one of the four screening
criteria. In addition, use of three-phase
motor technology may also be
impracticable to install and service
given the lack of three-phase power for
some businesses. DOE did find that, as
Heatcraft noted, very large refrigeration
systems typically use three-phase
power, and notes that manufacturers
may use three-phase motors to improve
the efficiency ratings of their equipment
as the benefit would likely be captured
by the test procedure. However, DOE
continued to screen three-phase motor
technology from its analysis for the
reasons discussed above.
DOE also did not consider economizer
cooling in its analysis. Although there
are potential energy savings under
certain circumstances, as Emerson
mentioned, these energy savings are not
captured by the test procedure, as
discussed in section IV.B.1.
Regarding Manitowoc’s remark about
considering other options to improve
cycle efficiency, DOE did not identify
any options to improve cycle efficiency
beyond what was already considered.
DOE requests specific recommendations
on how to improve cycle efficiency.
3. Screened-In Technologies
Based on DOE’s decision to regulate
walk-ins on a component level, DOE
will consider separate technologies for
each covered walk-in component (i.e.
panels, display doors, non-display
doors, and refrigeration systems). The
remaining technologies that were not
‘‘screened-out’’ are called the ‘‘screenedin’’ technologies and will be used to
create design options for improving the
efficiency of the walk-in components.
The ‘‘screened-in’’ technologies for each
covered component include:
• Panels
Æ Insulation thickness
Æ Insulation material
Æ Framing material
• Display doors
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Æ High-efficiency lighting
Æ Occupancy sensors
Æ Improved glass system insulation
performance
Æ Anti-sweat heater controls
• Non-display doors
Æ Insulation thickness
Æ Insulation material
Æ Framing material
Æ Improved window glass systems
Æ Anti-sweat heat controls
• Refrigeration Systems
Æ Higher efficiency compressors
Æ Improved condenser coil
Æ Higher efficiency condenser fan
motors
Æ Improved condenser fan blades
Æ Condenser fan control
Æ Ambient sub-cooling
Æ Improved evaporator fan blades
Æ Evaporator fan control
Æ Defrost controls
Æ Hot gas defrost
Æ Head pressure control
C. Engineering Analysis
The engineering analysis determines
the manufacturing costs of achieving
increased efficiency or decreased energy
consumption. DOE has identified the
following three methodologies to
generate the manufacturing costs
needed for the engineering analysis: (1)
The design-option approach, which
provides the incremental costs of adding
design options to a baseline model to
improve its efficiency; (2) the efficiencylevel approach, which provides the
relative costs of achieving increases in
energy efficiency levels without regard
to the particular design options used to
achieve such increases; and (3) the costassessment (or reverse engineering)
approach, which provides ‘‘bottom-up’’
manufacturing cost assessments for
achieving various levels of increased
efficiency based on detailed data as to
costs for parts and material, labor,
shipping/packaging, and investment for
models that operate at particular
efficiency levels.
DOE conducted the engineering
analyses for this rulemaking using a
combination of the design-option and
cost-assessment approaches in
analyzing the U-factor standards for
panels, maximum energy use for nondisplay doors and display doors, and
minimum AWEF for refrigeration
systems. More specifically, DOE
identified design options for analysis
and then used the cost-assessment
approach to determine the
manufacturing costs and analytical
modeling to determine the energy
consumption at those levels. Additional
details of the engineering analysis are in
chapter 5 of the NOPR TSD.
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1. Representative Equipment
a. Panels and Doors
In presenting the preliminary
analysis, DOE proposed three
representative sizes for each envelope
equipment class: Small, medium, and
large. American Panel agreed with the
sizes that DOE proposed. (American
Panel, No. 0048.1 at p. 4) CrownTonka
recommended that the equipment
classes for envelopes be divided into
only two sections, small and medium,
because EPCA covers only walk-ins of
less than 3,000 square feet, which
excludes sizes that are typically
considered ‘‘large.’’ (CrownTonka,
Public Meeting Transcript, No. 0045 at
p.111) Heatcraft agreed that the sizes
chosen are small, as all the sizes
considered must be less than 3,000
square feet, and they recommended that
the distribution of envelope sizes
include larger sizes approaching the
3,000 square foot limit, the maximum
size limit defined in the statute.
Heatcraft also stated that the selected
envelope sizes will have an effect on the
engineering analysis because certain
technologies are utilized at different
sizes. (Heatcraft, Public Meeting
Transcript, No. 0045 at p. 111, No.
0058.1 at p. 4) American Panel
suggested that DOE use three sizes and
investigate using an extra large size.
(American Panel, Public Meeting
Transcript, No. 0045 at p. 114)
Manitowoc asserted that DOE did not
include a large enough range of sizes
and should consider smaller sized walkins to correctly represent the energy
consumption of a given unit.
Additionally, Manitowoc noted that as
the walk-in’s size increases, there are
different base levels of performance and
that if DOE sets the minimum efficiency
based on a larger size, manufacturers
will not be able to make small-sized
equipment meeting the standards.
(Manitowoc, Public Meeting Transcript,
No. 0045 at pp. 116 and 118) Hill
Phoenix recommended that the
envelope sizes be determined by surface
area or volume. (Hill Phoenix, No.
0066.1 at p. 2) NEEA and NPCC
suggested that DOE establish a standard
based on the square feet of panels
shipped each year and use the square
footage to determine the energy
consumption of a complete functioning
envelope. (NEEA and NPCC, No. 0059.1
at p. 8)
DOE notes that its proposal rests on
a component-based approach and does
not include infiltration losses. As a
result, the size of the walk-in envelope
does not affect the energy consumption
of the components. In regard to
American Panel’s and Heatcraft’s
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comments about large sized walk-ins,
DOE analyzed a large panel size that it
considered to represent the large panels
found in the industry. DOE anticipated
the possibility raised by Manitowoc that
small panels might not be able to meet
a standard based on the large panel size
previously under consideration and is
now considering the adoption of an
approach that considers small, medium,
and large sizes. As Hill Phoenix
suggested, DOE determined the size of
the panel based on the panel’s surface
area. Also, similar to NEEA and NPCC’s
suggestion, DOE is proposing a standard
for walk-in panels based on the panel’s
surface area.
Panels
As explained previously, the
engineering analysis for walk-in panels
uses three different panel sizes to
represent the variations within each
class. DOE determined the sizes based
on market research and the impact on
the test metric U-factor. Table IV–3
shows each equipment class and the
representative sizes associated with that
class. DOE requests comment on the
representative sizes used in the
proposed analysis.
TABLE IV–3—SIZES ANALYZED: PANELS
Equipment class
Representative
height
(feet)
Size code
SP.M ......................................................................
SML
MED
LRG
SML
MED
LRG
SML
MED
LRG
SP.L .......................................................................
FP.L .......................................................................
Doors
Similar to the panel analysis, the
engineering analyses for walk-in display
.......................................................................
.......................................................................
.......................................................................
.......................................................................
.......................................................................
.......................................................................
.......................................................................
.......................................................................
.......................................................................
and non-display doors both use three
different sizes to represent the
differences in doors within each size
class DOE examined. The door sizes
Representative
width
(feet)
8
8
9
8
8
9
8
8
9
1.5
4
5.5
1.5
4
5.5
2
4
6
were determined using market research.
Details are provided in Table IV–4 for
non-display doors and Table IV–5 for
display doors.
TABLE IV–4—SIZES ANALYZED: NON-DISPLAY DOORS
Equipment class
Representative
height
(feet)
Size code
PD.M .....................................................................
PD.L ......................................................................
FD.M .....................................................................
FD.L ......................................................................
SML
MED
LRG
SML
MED
LRG
SML
MED
LRG
SML
MED
LRG
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
Representative
width
(feet)
6.5
7
7.5
6.5
7
7.5
8
9
12
8
9
12
2.5
3
4
2.5
3
4
5
7
7
5
7
7
TABLE IV–5—SIZES ANALYZED: DISPLAY DOORS
Equipment class
DD.M .....................................................................
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DD.L ......................................................................
b. Refrigeration
In the engineering analysis for walkin refrigeration systems, DOE used a
range of capacities as analysis points for
each equipment class. The name of each
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Representative
height
(feet)
Size code
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SML
MED
LRG
SML
MED
LRG
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
......................................................................
equipment class along with the naming
convention was discussed in section
IV.A.3.b. In addition to the multiple
analysis points, scroll, hermetic, and
semi-hermetic compressors were also
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Representative
width
(feet)
5.25
6.25
7
5.25
6.25
7
investigated because different
compressor types have different
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2.5
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efficiencies and costs.15 Due to the wide
range of capacities considered for each
condenser type, and the availability of
compressors at certain capacities,
compressors closely matching the
condenser capacities were examined in
terms of their performance at varying
operating temperatures.
Table IV–6 identifies, for each class of
refrigeration system, the sizes of the
55807
equipment DOE analyzed in the
engineering analysis. Chapter 5 of the
NOPR TSD includes additional details
on the representative equipment classes
used in the analysis.
TABLE IV–6—SIZES ANALYZED: REFRIGERATION SYSTEM
Sizes analyzed
(Btu/h)
Equipment class
DC.M.I, < 9,000 .................................................................................................................
DC.M.I, ≥ 9,000 .................................................................................................................
DC.M.O, < 9,000 ................................................................................................................
DC.M.O, ≥ 9,000 ................................................................................................................
DC.L.I, < 9,000 ..................................................................................................................
DC.L.I, ≥ 9,000 ..................................................................................................................
DC.L.O, < 9,000 .................................................................................................................
DC.L.O, ≥ 9,000 .................................................................................................................
MC.M .................................................................................................................................
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MC.L ..................................................................................................................................
6,000
18,000
54,000
96,000
6,000
18,000
54,000
96,000
6,000
9,000
54,000
6,000
9,000
54,000
72,000
4,000
9,000
24,000
4,000
9,000
18,000
40,000
Compressors analyzed
Hermetic, Semi-hermetic.
Hermetic, Semi-hermetic,
Semi-Hermetic, Scroll.
Semi-Hermetic, Scroll.
Hermetic, Semi-hermetic.
Hermetic, Semi-hermetic,
Semi-Hermetic, Scroll.
Semi-Hermetic, Scroll.
Hermetic, Semi-hermetic,
Hermetic, Semi-hermetic,
Semi-Hermetic, Scroll.
Hermetic, Semi-hermetic,
Hermetic, Semi-hermetic,
Semi-Hermetic, Scroll.
Semi-Hermetic.
Scroll.
Scroll.
Scroll.
Scroll.
Scroll.
Scroll.
2. Energy Modeling Methodology
In the preliminary analysis, DOE
proposed using an energy consumption
model to estimate separately the energy
consumption rating of entire envelopes
and entire refrigeration systems at
various performance levels using a
design-option approach. DOE developed
the model as a Microsoft Excel
spreadsheet. The spreadsheet calculated
the cumulative effect on the energy
consumption of adding options above
the baseline.
DOE continues to use a spreadsheetbased model, but is now modeling
panels, display doors, non-display
doors, and refrigeration systems
separately because these components
are tested separately. As mentioned
above, the purpose of the engineering
analysis is to determine the
manufacturing costs of achieving
increased efficiency or decreased energy
consumption. DOE assumes that
manufacturers will only incur costs to
achieve efficiency gains or energy
reductions that are accounted for in
their certified equipment rating.
Therefore, the energy models estimate
the performance rating that the
manufacturer would obtain by testing
their equipment using the DOE test
procedure because manufacturers are
required to rate the components using
the test procedure. The models estimate
the energy ratings of baseline equipment
and levels of performance above the
baseline associated with specific design
options that are added cumulatively to
the baseline equipment. The model does
not account for interactions between
refrigeration systems and envelope
components, nor does it address how a
design option for one component may
affect the energy consumption of other
components, because such effects are
not accounted for in the test procedure.
Component performance results are
found in appendix 5A of the TSD. DOE
requests comment on the performance
data found in appendix 5A of the TSD
and requests data about the performance
of panels, display doors, or non-display
doors and their design options.
The refrigeration energy model
calculates the annual energy
consumption and the AWEF of walk-in
refrigeration systems at various
performance levels using a design
option approach. AWEF is the ratio of
the total heat removed, in Btus, from a
walk-in envelope during a one-year
period of use (not including the heat
generated by operation of the
refrigeration system) to the total energy
input of refrigeration systems, in watthours, during the same period. DOE
proposes to base its standards for the
refrigeration system using the AWEF
metric and seeks comment on this
approach.
This model was used to analyze
specific examples of equipment in each
refrigeration system equipment class.
For a given class, the analysis consists
of calculating the annual energy
consumption and the AWEF for the
baseline and several levels of
performance above the baseline. See
chapter 5 of the TSD for further details
about the analytical models used in the
engineering analysis.
For the preliminary analysis, DOE
partially relied on refrigeration catalog
information to obtain equipment
specifications for its energy model.
Manitowoc and the Joint Utilities
believed that catalog information was
not the best source from an analytical
standpoint. Manitowoc observed that
catalog information is provided mainly
for sizing equipment and not for
representing equipment performance,
while the Joint Utilities pointed out that
15 Scroll compressors are compressors that
operate using two interlocking, rotating scrolls that
compress the refrigerant. Hermetic and semi-
hermetic compressors are piston-based compressors
and the key difference between the two is that
hermetic compressors are sealed and hence more
difficult to repair, resulting in higher replacement
costs, while semi-hermetic compressors can be
repaired relatively easily.
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a. Refrigeration
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the rating methodology that produced
the data in the catalogs could be
different from the rating methodology
for walk-ins, which could make the data
inappropriate for analyzing walk-ins.
(Manitowoc, Public Meeting Transcript,
No. 0045 at p. 31; Joint Utilities, No.
0061.1 at p. 3)
In recognition of these comments,
DOE conducted further research into
refrigeration system performance and
has improved the analysis for the NOPR
in several ways. First, the energy model
now calculates system performance
based on a whole-system approach
using thermodynamic principles. The
model determines the refrigerant
properties (pressure, temperature, etc.)
at each point in the system and these
properties, rather than catalog
specifications, are used to calculate
refrigeration capacity. Second, for any
catalog information based on specific
rating conditions, DOE ensured the
rating conditions were consistent with
those for walk-in refrigeration systems,
or adjusted the specifications
accordingly. Third, while it continued
to rely on catalog data directly for some
equipment specifications (e.g., typical
number of fans and fan horsepower for
units of the sizes analyzed), DOE also
surveyed catalogs from various
manufacturers to determine the most
representative specifications for a
particular type and size of equipment.
See chapter 5 for more details on the
refrigeration system energy model and
other enhancements made to its
analysis.
The energy consumption calculations
in the engineering analysis are based on
calculations in AHRI 1250–2009, the
industry test procedure incorporated by
reference in the walk-in test procedure.
76 FR at 33631. These calculations
involve the refrigeration system running
at a high load for one-third of the time
and a low load for two-thirds of the
time. American Panel noted that the
load profile for restaurants would
generally be reversed (i.e., the
refrigeration system is sized for running
at a high load two-thirds of the time and
a low load one-third of the time) and
requested DOE to adjust the load
assumptions based on the walk-in
application. (American Panel, No.
0048.1 at p. 8)
DOE’s assumption in the engineering
analysis about the refrigeration load
profile was made for purposes of
comparing the performance of different
types of refrigeration equipment that
have varying features. Furthermore, the
analysis attempts to assess the impacts
of technologies manufacturers might use
to improve the efficiencies of their
equipment, including impacts on the
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efficiency ratings of the equipment. DOE
will base any standards it adopts on the
use of some or all of these technologies,
and the DOE test procedure would serve
as the basis for rating equipment and
determining compliance. Therefore, the
test procedure calculations are used in
the analysis to determine the efficiency
ratings of equipment utilizing the
various technologies on which DOE
might base the standards.
However, DOE does not treat the load
profile assumptions used in the
engineering analysis as equivalent to the
actual duty cycle of every class or
application of refrigeration systems.
Rather, where warranted, DOE evaluates
other duty cycle assumptions in its
energy use analysis, which examines the
actual energy consumption of the
refrigeration system under a variety of
operating conditions and applications.
In the energy use analysis, DOE has
adjusted its assumptions for actual duty
cycles based in part on American
Panel’s recommendation. See section
IV.E.1 and chapter 7 of the TSD for
details.
In the preliminary analysis, DOE
analyzed the result of adding design
options cumulatively to the baseline.
DOE observed that some design options
(e.g., larger condenser coil) increased
the efficiency of the refrigeration system
while also increasing its capacity. To
distinguish between these effects, DOE
created a ‘‘normalized energy
consumption’’ metric in the preliminary
analysis which represented the energy
consumption per unit capacity. DOE
expected that the normalized energy
consumption metric would generally be
analogous to an efficiency metric. For
example, for two units of the same
capacity, the unit with lower
normalized energy consumption would
be more efficient because it would use
less energy for the same heat removal
capability.
In a comment on the preliminary
analysis, American Panel stated that it
was not beneficial for the capacity of a
unit to increase because the refrigeration
system must balance the heat load to
control temperature and humidity.
(American Panel, Public Meeting
Transcript, No. 0045 at p. 175) After
interviewing manufacturers and
examining refrigeration catalogs, DOE
observed that manufacturers typically
offer refrigeration systems in specific,
discrete capacities while providing
consumers with options for improving
system efficiency. DOE reasoned that
manufacturers would likely design their
systems for a certain set of capacities
regardless of the efficiency options
available and, consequently,
implementing efficiency options on a
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system would be unlikely to change the
capacity of the system because the
manufacturer would prefer to market
the system at the established capacity.
Therefore, DOE agrees with American
Panel’s assessment and has
implemented its suggestion into the
NOPR analysis.
DOE notes that it analyzed six classes
of refrigeration systems at various
capacity points, as explained in section
IV.C.1.b. When a design option is added
to the baseline, it does not change the
capacity of the unit; instead, other
aspects of the system are adjusted to
maintain the capacity at the specified
point. See chapter 5 of the TSD for
details.
In the preliminary analysis, DOE
considered the effects of adding design
options to the baseline. Some interested
parties commented on the interactive
effects of design options. Thermocore
stated that there are substantial
differences in performances based on
the integrated system as opposed to
considering options separately.
(Thermocore, Public Meeting
Transcript, No. 0045 at p. 86) Emerson
stated that DOE must account for how
the technologies are combined because
the effects will vary depending on what
is already included in the system.
(Emerson, Public Meeting Transcript,
No. 0045 at p. 93) AHRI agreed that
efficiency gains due to combinations of
certain design options are not
necessarily additive and noted that
assessing the aggregate benefit from
combined design options requires
rigorous analysis and simulation of the
total system. (AHRI, No. 0055.1 at p. 2)
DOE recognizes that the interactive
effects of design options must be
considered because the efficacy of
certain design options differs depending
on whether they are analyzed separately
or in conjunction with other design
options. DOE has taken a system-based
approach to the refrigeration system
energy model that calculates the effect
on the entire system of adding design
options. Each efficiency level above the
baseline consists of a design option
added cumulatively and the interactive
effects of each new design option on all
previously added design options are
considered. In formulating the costefficiency curves, DOE attempted to
capture the most cost-effective design
option at each efficiency level, given all
previously added design options at that
level. Manufacturers may use any
combination of design options to meet
the future energy conservation standard.
See chapter 5 of the TSD for further
discussion on the interactive effects of
design options.
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Some commenters disagreed with
DOE’s refrigeration energy modeling
approach. SCE recommended using
DOE 2.2R (an expanded version of the
building simulation program DOE 2.2)
to directly model certain design options,
such as modulating the fan speed for the
on-cycle fan power for a unit cooler
connected to a multiplex system. (SCE,
Public Meeting Transcript, No. 0045 at
p. 138) NEEA and NPCC also stated that
the spreadsheet-based model does not
adequately evaluate all of the design
options and their combinations, and
that DOE should consider using DOE
2.2R for modeling instead. (NEEA and
NPCC, No. 0059.1 at p. 9)
DOE 2.2R is designed to simulate the
operation of building refrigeration
systems, such as those found in
supermarkets, refrigerated warehouses,
and industrial facilities. Although DOE
2.2R is a powerful simulation tool that
can aid in refrigeration system design,
DOE believes it is inappropriate for the
energy modeling that DOE is conducting
as part of this rulemaking. This
rulemaking is taking a component-level
approach and determining the
performance of each component (the
panels, the doors, and the refrigeration
system) separately, whereas DOE 2.2R
models the interactions of components
that comprise an entire building. Also,
the component performance as modeled
in the engineering analysis must be
based on the operating conditions and
calculations contained in the test
procedure, which DOE believes is not
consistent with the simulation
methodology in DOE 2.2R. To address
the concerns of SCE, NEEA and NPCC
that a spreadsheet model would be
inadequate for certain options or
combinations of options, DOE has
modified the spreadsheet model to more
accurately account for combinations of
design options and interactive effects of
design options within a component. To
address the Joint Utilities’ concerns
with fan speed modulation, DOE
included calculations for fan speed
modulation that are consistent with the
test procedure.
Although DOE is not conducting the
analysis using DOE 2.2R, DOE
encourages interested parties to submit
their own simulation results from DOE
2.2R modeling and compare them to
DOE’s engineering results.
3. Cost Assessment Methodology
a. Teardown Analysis
To calculate the manufacturing costs
of the different components of walk-in
coolers and freezers, DOE disassembled
baseline equipment. This process of
disassembling systems to obtain
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information on their baseline
components is referred to as a ‘‘physical
teardown.’’ During the physical
teardown, DOE characterized each
component that makes up the
disassembled equipment according to
its weight, dimensions, material,
quantity, and the manufacturing
processes used to fabricate and assemble
it. The information was used to compile
a bill of materials (BOM) that
incorporates all materials, components,
and fasteners classified as either raw
materials or purchased parts and
assemblies.
DOE also used a supplementary
method, called a ‘‘virtual teardown,’’
which examines published
manufacturer catalogs and
supplementary component data to
estimate the major physical differences
between equipment that was physically
disassembled and similar equipment
that was not. For virtual teardowns,
DOE gathered product data such as
dimensions, weight, and design features
from publicly-available information,
such as manufacturer catalogs.
The teardown analyses allowed DOE
to identify the technologies that
manufacturers typically incorporate into
their equipment. The end result of each
teardown is a structured BOM, which
DOE developed for each of the physical
and virtual teardowns. DOE then used
the BOM from the teardown analyses as
one of the inputs to the cost model to
calculate the manufacturer production
cost (MPC) for the product that was torn
down. The MPCs derived from the
physical and virtual teardowns were
then used to develop an industry
average MPC for each equipment class
analyzed. See chapter 5 of the NOPR
TSD for more details on the teardown
analysis.
For display doors and non-display
freight doors, limited information was
publicly available, particularly as to the
assembly process and shipping. To
compensate for this situation, DOE
conducted physical teardowns for two
representative units, one within each of
these equipment classes. DOE
supplemented the cost data it derived
from these teardowns with information
from manufacturer interviews. The cost
models for panels and for non-display
structural doors were created by using
public catalog and brochure information
posted on manufacturer Web sites and
information gathered during
manufacturer interviews.
For the refrigeration system, DOE
conducted physical teardowns of unit
cooler and condensing unit samples to
construct a BOM. The selected systems
were considered representative of
baseline, medium-capacity systems, and
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used to determine the base components
and accurately estimate the materials,
processes, and labor required to
manufacture each individual
component. From these teardowns, DOE
gleaned important information and data
not typically found in catalogs and
brochures, such as heat exchanger and
fan motor details, assembly parts and
processes, and shipment packaging.
Along with the physical teardowns,
DOE performed several virtual
teardowns of refrigeration units for the
NOPR analysis. The complete set of
teardowns helped DOE obtain the
baseline average MPC for all equipment
classes proposed.
b. Cost Model
The cost model is one of the
analytical tools DOE used in
constructing cost-efficiency curves. DOE
derived the cost model from the
teardown BOMs and the raw material
and purchased parts databases. Cost
model results are based on material
prices, conversion processes used by
manufacturers, labor rates, and
overhead factors such as depreciation
and utilities. For purchased parts, the
cost model considers the purchasing
volumes and adjusts prices accordingly.
Original equipment manufacturers
(OEMs), i.e., the manufacturers of WICF
components, convert raw materials into
parts for assembly, and also purchase
parts that arrive as finished goods,
ready-to-assemble. DOE bases most raw
material prices on past manufacturer
quotes that have been inflated to present
day prices using Bureau of Labor
Statistics (BLS) and American Metal
Market (AMM) inflators. DOE inflates
the costs of purchased parts similarly
and also considers the purchasing
volume—the higher the volume, the
lower the price. Prices of all purchased
parts and non-metal raw materials are
based on the most current prices
available, while raw metals are priced
on the basis of a 5-year average to
smooth out spikes. Chapter 5 of the
NOPR TSD describes DOE’s cost model
and definitions, assumptions, data
sources, and estimates.
For panels, non-display doors, and
display doors DOE used a
‘‘parameterized’’ computational cost
model, which allows a user to
manipulate the components parameters
such as height and length by inputting
different numerical values for these
features to produce new cost estimates.
This parameterized model, coupled
with the design specifications chosen
for each representative unit modeled in
the engineering analysis, was used to
develop fundamental MPC costs. The
fundamental MPC costs were then
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incorporated into the engineering
analysis model where they were
combined with additional costs
associated with each design option.
Costs for each design option were
calculated based on discussions with
panel, non-display, and display door
manufacturers and pricing from
commercially available sources.
As previously mentioned in section
IV.B.3, DOE is considering high
efficiency lighting, specifically lightemitting diode (LED) lighting, as a
design option to improve the efficiency
of display doors. Forecasts of the LED
lighting industry, including those
performed by DOE, suggest that LED
lighting is an emerging technology that
will continue to experience significant
price decreases in coming years. For this
reason, in an effort to capture the
anticipated cost reduction in LED
fixtures in the analyses for this
rulemaking, DOE incorporated price
projections from its Solid State Lighting
program into its MPC values. The price
projections for LED lighting were
developed using projections created for
the DOE’s Solid State Lighting
Program’s 2012 report, Energy Savings
Potential of Solid-State Lighting in
General Illumination Applications 2010
to 2030 (‘‘the energy savings report’’). In
the appendix of this report, price
projections from 2010 to 2030 were
provided in ($/klm) for LED lamps and
LED luminaires. DOE analyzed the
models used in the Solid State Lighting
program work and determined that the
LED luminaire projection would serve
as a proxy for a cost projection to apply
to LEDs on walk-in display doors.
The price projections presented in the
Solid State Lighting program’s energy
savings report are based on the DOE’s
2011 Solid State Lighting R&D MultiYear Program Plan (MYPP).16 The
MYPP is developed based on input from
manufacturers, researchers, and other
industry experts. This input is collected
by the DOE at annual roundtable
meetings and conferences. The
projections are based on expectations
dependent on the continued investment
into solid state lighting by the DOE.
DOE incorporated the price projection
trends from the energy savings report
into its engineering analysis by using
the data to develop a curve of
decreasing LED prices normalized to a
base year. That base year corresponded
16 The DOE Solid-State Lighting Research and
Development Multi-Year Program Plan is a
document that outlines DOE’s research goals and
planned methodologies with respect to the
advancement of solid-state lighting technologies in
the United States. The complete document is
available at: https://apps1.eere.energy.gov/buildings/
publications/pdfs/ssl/ssl_mypp2011_web.pdf.
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to the year when LED price data were
collected for the NOPR analyses of this
rulemaking from catalogs, manufacturer
interviews, and other sources. DOE
started with LED cost data specific to
walk-in manufacturers and then applied
the anticipated trend from the energy
savings report to forecast the projected
cost of LED fixtures at the time of
required compliance with the proposed
rule (2017). These 2017 cost figures
were incorporated into the engineering
analysis to calculate the MPC of display
doors with LEDs as a design option. The
LCC analysis (section IV.F) was carried
out with the engineering numbers that
account for the 2017 cost of LED
luminaires. The reduction in costs of
LED luminaires from 2018 to 2030 were
taken into account in the NIA (section
IV.G). The cost reductions were
calculated for each year from 2018 and
2030 and subtracted from the equipment
costs in the NIA.
During the preliminary analysis, DOE
developed a cost model for the proposed
representative sizes of walk-in
envelopes. Panel manufacturers
generally make panels with a
combination of raw materials and
purchased parts, and DOE estimated
manufacturing process parameters, the
required initial material quantity, scrap,
and other factors to determine the value
of each component. DOE then
aggregated all parameters related to
manufacture and assembly to determine
facility requirements at various
manufacturing scales and the final unit
cost.
To more accurately model walk-in
costs, DOE used common factory
parameters, which affect the cost of each
unit produced (e.g., labor and
fabrication rates). American Panel
commented on some of the factors
assumed in the cost model and the
resulting values. In particular, in its
view, approximately 1 million square
feet of panels are manufactured per year
per manufacturer, and most door
manufacturers produce 1,800 doors per
year. Accordingly, these numbers
suggest a total walk-in production
volume of well under DOE’s initial
estimate of 30,000 per year per
manufacturer. American Panel believed
that overestimating the amount of
panels manufactured per year would
cause the small manufacturers to be at
a disadvantage. (American Panel, Public
Meeting Transcript, No. 0045 at
p. 14–15; American Panel, No. 0048.1 at
pp. 5–6)
Assuming an average walk-in surface
area of 500 ft2 (roughly corresponding to
an 8-foot by 10-foot walk-in), American
Panel’s estimate equates to
approximately 2,000 walk-ins per year,
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per manufacturer—much lower than
DOE’s estimate. DOE understands that
its estimate may be more reasonable for
a large manufacturer than a small one
and agrees with American Panel that
impacts on small manufacturers may be
underestimated in an analysis that
assumes a high production capacity.
Thus, DOE has considered particular
impacts on small manufacturers in the
MIA by adjusting for their reduced
production capacity as compared to
larger manufacturers. See sections
IV.I.3.c and V.B.2.d (Manufacturer
Impact Analysis) and VI.B (Regulatory
Flexibility Analysis, which specifically
address the impact of the rule on small
business manufacturers).
Additionally, American Panel, citing
its own experience, stated that other
DOE cost estimates needed adjusting.
Some examples include the following:
• The cost of the tongue and groove
design found on panels should be
increased by a factor of 10.8.
• The cost of the advanced door
sweep should increase by a factor of 7.8.
• The DOE cost per square foot of
panel was too high and actual costs
were closer to $0.25 per square foot.
• The actual MSP for walk-in cooler
envelopes was 70–112 percent lower
than the DOE estimate.
• The actual MSP for walk-in freezer
envelopes was 24–42 percent lower than
the DOE estimate. (American Panel,
Public Meeting Transcript, No. 0045 at
pp. 14–15; American Panel, No. 0048.1
at pp. 5–6).
DOE appreciates the efforts made by
American Panel in preparing detailed
comments and providing useful
information about factory parameters,
material costs, and the resulting
manufacturing selling price for walk-in
envelopes. Some of the differences can
be explained based on the parameters
used in the cost model, such as the
material costs. DOE particularly
appreciates American Panel’s comments
related to the costs of certain designs
and has taken these costs into
consideration in its analysis by
aggregating them with other data DOE
has received through research and
confidential manufacturer interviews.
For instance, American Panel’s cost per
square foot of panel was particularly
useful in helping DOE estimate the costs
of certain materials that make up the
panel.
DOE was not, however, able to use
some of the cost data—for example,
costs related to infiltration-reducing
measures were not used because DOE is
no longer considering infiltration in the
analysis. Also, DOE has not calculated
costs related to the assembly of the
entire envelope—for instance, the MSP
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of the envelope—as part of the
engineering analysis because of the
component-based approach DOE is
proposing to use. Consequently, DOE is
now using the cost model to determine
the manufacturer production costs and
manufacturer selling prices of the
individual components covered by the
standards.
DOE estimated installation costs for
the refrigeration systems and the
envelope components separately as part
of the life-cycle cost analysis. DOE has
proposed new manufacturer cost
estimates in chapter 5 of the TSD and
seeks comment on the new parameters
proposed for each component.
c. Manufacturing Production Cost
Once it finalized the cost estimates for
all the components in each teardown
unit, DOE totaled the cost of the
materials, labor, and direct overhead
used to manufacture the unit to
calculate the manufacturer production
cost of such equipment. The total cost
of the equipment was broken down into
two main costs: (1) The full
manufacturer production cost, referred
to as MPC; and (2) the non-production
cost, which includes selling, general,
and administration (SG&A) costs; the
cost of research and development; and
interest from borrowing for operations
or capital expenditures. DOE estimated
the MPC at each design level considered
for each equipment class, from the
baseline through max-tech. After
incorporating all of the data into the
cost model, DOE calculated the
percentages attributable to each element
of total production cost (i.e., materials,
labor, depreciation, and overhead).
These percentages were used to validate
the data by comparing them to
manufacturers’ actual financial data
published in annual reports, along with
feedback obtained from manufacturers
during interviews. DOE uses these
production cost percentages in the MIA
(see section IV.I).
In the preliminary analysis, DOE
developed both an envelope cost and a
refrigeration system cost for each
equipment class and size using a
manufacturing cost model. See chapter
5 of the preliminary TSD. American
Panel suggested that manufacturer cost
should be estimated using a sample
from 40 manufacturers and
representative volumes. (American
Panel, Public Meeting Transcript, No.
0045 at p. 312) In response to American
Panel’s comment, DOE believes it is
infeasible to sample so many
manufacturers because data on
manufacturing cost and representative
volumes are not publicly available for
most manufacturers of walk-ins and
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walk-in components, particularly small,
private companies. Additionally, not all
manufacturers were willing to share cost
information with DOE. DOE did hold
confidential interviews with
manufacturers, some of whom chose not
to share this information. DOE notes
that cost information it did obtain was
helpful in enabling the agency to
develop and refine its estimates of
manufacturer cost. The interview
process is explained in chapter 12 of the
TSD.
d. Manufacturing Markup
DOE uses MSPs to conduct its
downstream economic analyses. DOE
calculated the MSPs by multiplying the
manufacturer production cost by a
markup and adding the equipment’s
shipping cost. The production price of
the equipment is marked up to ensure
that manufacturers can make a profit on
the sale of the equipment. DOE gathered
information from manufacturer
interviews to determine the markup
used by different equipment
manufacturers. Using this information,
DOE calculated an average markup for
each component of a walk-in. DOE
requests comments on the proposed
markups listed in Table IV–7.
TABLE IV–7—MANUFACTURER
MARKUPS
Walk-in component
Panels .......................................
Display Doors ...........................
Non-Display Doors ...................
Refrigeration Equipment ...........
Markup
(percent)
32
50
62
35
e. Shipping Costs
In the preliminary analysis TSD, DOE
calculated manufacturer shipping costs
assuming that manufacturers include
outbound freight as part of their
equipment selling price. In response to
DOE’s request for comment on shipping
assumptions, American Panel and
NEEA and NPCC remarked that DOE’s
costs were significantly higher than
actual industry shipping rates.
(American Panel, Public Meeting
Transcript, No. 0045 at pp. 15, 142;
NEEA and NPCC, No. 0059 at p. 9)
Additionally, American Panel stated
that freight costs are typically paid in
full by the customer and not absorbed
by the manufacturer who is selling the
equipment. (American Panel, No. 0048.1
at p. 5) Both American Panel and
CrownTonka said that sometimes the
freight cost would be included as part
of the selling price and sometimes it
would be entirely separate; i.e., paid by
the buyer directly to the freight
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company. (American Panel, Public
Meeting Transcript, No. 0045 at p. 143;
CrownTonka, Public Meeting
Transcript, No. 0045 at p. 144) NEEA
and NPCC stated that freight costs are
normally included in the packaged price
to consumers. (NEEA and NPCC, No.
0059.1 at p. 9)
DOE re-evaluated the shipping rates
in preparing this NOPR. These rates
were developed by conducting
additional research on shipping rates
and by interviewing manufacturers of
the covered equipment. For example,
DOE found through its research that
most panel, display door, and nondisplay door manufacturers use less
than truck load freight to ship their
respective components and revised its
estimated shipping rates accordingly.
DOE also found that most
manufacturers, when ordering
component equipment for installation in
their particular manufactured product,
do not pay separately for shipping costs;
rather, it is included in the selling price
of the equipment. However, when
manufacturers include the shipping
costs in the equipment selling price,
they typically do not mark up the
shipping costs for profit, but instead
include the full cost of shipping as part
of the price quote. DOE has revised its
methodology accordingly. Please refer to
chapter 5 of the TSD for details.
4. Baseline Specifications
a. Panels and Doors
In the preliminary analysis, DOE set
the baseline level of performance to
correspond to the most common least
efficient component that is compliant
with the standards set forth in EPCA.
(42 U.S.C. 6313(f)(1)(3)) DOE
determined specifications for each
equipment class by surveying currently
available units and models. This
approach was used for the NOPR
analyses to determine the baseline units
for panels, display doors, and nondisplay doors. More detail about the
specifications for each baseline model
can be found in chapter 5 of the TSD.
Because the walk-in market is
comprised of panels insulated with
polyurethane and extruded polystyrene,
DOE proposed in the preliminary
analysis that the R-value for the baseline
insulation used in the walk-in envelope
would be the average of the typical long
term thermal resistance (LTTR) R-values
of polyurethane and extruded
polystyrene. CPI opposed the use of an
average R-value for extruded
polystyrene and polyurethane because it
would affect the accuracy of the
normalized energy consumption
calculation for the envelope. (CPI, No.
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0052.1, at p.1) DOE agrees with CPI’s
concern and is using in the revised
analysis foam-in-place polyurethane as
the baseline insulation for panels and
non-display doors. Polyurethane is more
commonly used as panel or non-display
door insulation, has a better long term
thermal resistance, and is less expensive
than extruded polystyrene. DOE notes
that extruded polystyrene may
outperform polyurethane in other
respects, like moisture absorption,
which are not captured in the energy
consumption model because they are
not included in the test procedure.
DOE’s analysis also uses wood
framing members as the baseline
framing material in panels. The analysis
assumes the typical wood frame
completely borders the insulation and is
1.5 inches wide. DOE requests comment
on its baseline specifications for walkin panels, specifically the assumptions
about framing material and framing
dimensions.
The baseline display doors modeled
in DOE’s analysis are based on the
minimum specifications set by EPCA.
(42 U.S.C. 6313(f)(3)) DOE modeled
baseline display cooler doors comprised
of two panes of glass with argon gas fill
and hard coat low emittance or low-e
coating. The baseline cooler display
door requires 2.9 Watts per square foot
of anti-sweat heater wire and does not
have a heater wire controller. The
baseline display freezer doors modeled
in DOE’s analysis consist of three panes
of glass, argon gas, and soft coat low-e
coating. Baseline freezer doors use 15.23
watts per square foot of anti-sweat
heater wire power and require an antisweat heater wire controller. DOE also
estimates that each baseline door
includes one fluorescent light with
electronic ballasts, with a door shorter
than 6.5 feet having a 5-foot fluorescent
bulb and a door equal to or taller than
6.5 feet having a 6-foot fluorescent bulb.
DOE requests comment on the baseline
assumptions for display cooler and
freezer doors. In particular, DOE
requests data illustrating the energy
consumption of anti-sweat heaters
found on cooler and freezer display
doors.
DOE’s analysis assumes that the
baseline non-display doors are
constructed in a similar manner to
baseline panels. Therefore, DOE’s
analysis uses baseline non-display doors
that consist of wood framing materials
1.5 inches wide that completely border
the foamed-in-place polyurethane
insulation. DOE also includes a small
window in a non-display door that
conforms to the standards set by EPCA.
DOE estimates that all passage doors
have a 2.25 square foot window
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regardless of the passage door’s size.
DOE analyzed two different size
windows for non-display freight doors.
The small freight doors have a 2.25
square foot window and both the
medium and large freight doors have a
4-square foot window. DOE requests
comment on the baseline specifications
for non-display doors, and specifically
on the size of the windows included in
the baseline doors.
DOE also received comments about
the amount of energy savings attributed
to infiltration reduction devices (IRDs)
on baseline walk-in doors. NEEA and
NPCC commented that even though
EISA requires an infiltration reduction
device on the baseline door, DOE
should also include additional IRDs as
a design option. NEEA and NPCC
continued to suggest that DOE should
re-evaluate the amount of energy
savings associated with IRDs. (NEEA
and NPCC, Public Meeting Transcript,
No. 0045 at p. 170) The Joint Utilities
also believed that DOE overestimated
the impacts of IRDs in the baseline
doors and explained that overestimating
the baseline savings from an IRD affects
the amount of savings achieved by the
design options DOE evaluated. (Joint
Utilities, No. 0061.1 at p. 5) DOE agrees
with NEEA and NPCC and the Joint
Utilities that a baseline door must have
an IRD because this is required by
EPCA. (42 U.S.C. 6313(f)(1)(A)(B))
However, the walk-in test procedure
does not measure energy consumption
from door-opening infiltration so there
is no rated energy saving from IRDs and
DOE is not estimating the amount of
energy saved from IRDs on baseline
doors.
b. Refrigeration
As with panels and doors, DOE set the
baseline level of refrigeration system
performance to correspond to
components that were the least efficient
but compliant with the standards set
forth in EPCA. See 42 U.S.C. 6313(f)(1)–
(3). DOE determined specifications for
each equipment class by surveying
currently available models. See chapter
5 of the TSD for more details about the
specifications for each baseline model.
In the preliminary analysis, DOE
analyzed several representative baseline
units for refrigeration systems and
requested comment on the
characterization of the baseline units. In
response to DOE’s request for comment
on the representative units analyzed,
several stakeholders expressed concern
that the range of refrigeration systems
DOE evaluated was too limited.
Heatcraft and the Joint Utilities
encouraged DOE to include larger
capacity equipment and different
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compressor types. (Heatcraft, No. 0058.1
at pp. 3–4; Heatcraft, No. 0069.1 at p. 2;
Joint Utilities, No. 0061.1 at p. 3)
American Panel echoed this concern
and stated that DOE should explore the
full range of condensing units and that
WICF envelopes should be paired with
different sized refrigeration systems
based on use. (American Panel, No.
0048.1 at pp. 8–9) DOE has considered
these comments and has expanded its
analysis to include a larger range of
refrigeration system capacities. DOE has
also included different compressor
types in the refrigeration system
analysis; see section IV.C.5.b and
chapter 5 of the TSD for details. DOE
has not considered pairing WICF
envelopes and refrigeration systems in
the engineering analysis, however,
because DOE is applying a componentbased approach.
The preliminary analysis also
presented estimated baseline
specifications and costs for the
representative units it analyzed.
American Panel remarked that the
baseline costs in the engineering
analysis were too low and were not
comparable to their data. Additionally,
it stated that the refrigeration load will
increase if the product is not at the same
temperature as the walk-in cooler or
freezer. (American Panel, No. 0048.1 at
p. 7) Interested parties also commented
on certain baseline unit subcomponents
that were not included in the
engineering analysis. American Panel
noted that baseline units could include
a downstream solenoid valve that would
prevent refrigerant from migrating to the
evaporator and Heatcraft encouraged
DOE to make sure that the amount of
refrigerant, piping, and insulation scale
properly with size. (American Panel,
No. 0048.1 at p. 7; Heatcraft, No. 0069.1
at p. 3)
In response to American Panel’s
comments on refrigeration system costs,
DOE adjusted its cost model as
described in section IV.C.3 and believes
its costs are now more representative of
typical equipment. Regarding
refrigeration load, DOE does not
consider the effect of different product
loads in the engineering analysis
because the engineering analysis is
based on the rating conditions; DOE
considers product loads in the energy
use analysis as explained in section
IV.E.3. In response to American Panel’s
and Heatcraft’s comments about
subcomponents of refrigeration
equipment, the revised analysis now
includes all necessary subcomponents
from the manufacturer—i.e., those
subcomponents needed for the unit to
operate. The analysis includes a
calculation of refrigerant charge that is
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scaled with the size of the unit, as
Heatcraft suggested. DOE has tentatively
decided not to include piping and
insulation between the unit cooler and
condensing unit, as it believes these
components would not be supplied by
the manufacturer or included in the
equipment’s MSP, but by the contractor
upon installation of the equipment. DOE
requests comment on this assumption.
In the preliminary analysis, DOE
made certain assumptions regarding
saturated evaporator temperature (SET)
and saturated condensing temperature
(SCT) that it used in the analysis for
freezers and coolers and indoor and
outdoor units. In general, DOE based
these temperatures on an assumed
temperature difference (TD) between the
coil temperature and the ambient
temperature where the ambient
temperature for indoor and outdoor
units was specified by the rating
conditions in AHRI 1250–2009, the test
procedure for refrigeration systems. 76
FR at 33631. The Joint Utilities and
Heatcraft both submitted comments
about the temperature set points in the
baseline equipment; the Joint Utilities
suggested a condensing temperature
control point of 90 °F for both freezers
and coolers, while Heatcraft
recommended different temperatures for
several equipment classes. (Joint
Utilities, No. 0061.1 at p. 10; Heatcraft,
No. 0069.1 at p. 2)
In determining appropriate
temperature set points, DOE considered
information from various sources when
formulating its assumptions, including
comments, research, and discussions
with manufacturers and other parties.
DOE notes that the ambient temperature
for the test procedure is 90 and 95 °F
for indoor and outdoor condensing
units, respectively. Given that the
system must maintain a reasonable TD
between the SCT and the ambient
temperature, the SCT during the test
procedure would be higher than the 90–
95 °F assumption recommended by the
Joint Utilities. Even though the set point
during actual use may be lower,
equipment is rated—and evaluated for
meeting the standard—at the test
procedure rating points. For these
reasons, DOE believes its SCT
assumptions are reasonable for baseline
equipment operating at the rating
conditions required for the test
procedure. DOE requests comment on
this assumption, particularly whether
the TDs for baseline and higher
efficiency equipment are appropriate.
See chapter 5 of the TSD for details.
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5. Design Options
a. Panels and Doors
For the preliminary analysis, DOE
included the following design options
for the walk-in envelope:
• Improved wall, ceiling, and floor
insulation
• Improved door gaskets and panel
interface systems
• Electronic lighting ballasts and
high-efficiency lighting
• Occupancy sensors and automatic
door opening and closing systems
• Air curtains and strip curtains
• Vestibule entryways
• Display and window glass system
insulation enhancements
• Anti-sweat heater controls and no
anti sweat heat systems
In the preliminary analysis, DOE
presented tables detailing each design
option, including the cost of
implementing each option and a
description of the design option’s
properties. The discussion below sets
forth comments received on these
design options for panels and doors, as
well as DOE’s proposed approach in
today’s NOPR.
Panels
Stakeholders commented on steady
state IRDs that DOE initially considered
including as design options for the
walk-in envelope. Craig Industries
commented that DOE should consider
different caulking materials as a design
option because it is inexpensive and
would reduce infiltration by sealing the
joints of walk-ins, but noted that this
design option would conflict with the
current National Sanitation Foundation
(NSF) standards. (Craig Industries, No.
0064.1 at p. 3) American Panel stated
that changing the gasketing or joint
profile of an insulated panel would
require a new test burden of $20,000,
and that the improved gasketing is not
necessarily going to be functional. It
also noted that improved panel
interfaces may not mate with existing
walk-in panels, which would prevent
manufacturers from supplying
replacement panels. Lastly, in its view,
the complex gasketing and panel
interface systems could cause walk-ins
to become more difficult to build.
(American Panel, No. 0048.1 at p. 6;
American Panel, Public Meeting
Transcript, No. 0045 at p. 121) Hill
Phoenix commented that enhancing the
gasketing between panels will not have
a significant impact on the walk-in’s
energy consumption. In its view, the
main heat load caused by infiltration is
from door openings as opposed to
steady state infiltration. (Hill Phoenix,
No. 0066.1 at p. 3)
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For the reasons stated in the test
procedure final rule, the test procedure
promulgated by DOE no longer requires
manufacturers to measure a walk-in’s
steady-state infiltration. Therefore,
design options for reducing steady state
infiltration, including caulking and
improved gasketing, would not impact
the rated energy consumption of any of
the walk-in components addressed in
this rulemaking. 76 FR 21580, 21595
(April 15, 2011). Furthermore, DOE
would screen out any design options
(including caulking) that would be
likely to have significant adverse
impacts on the utility of the equipment
or had an adverse impact on health or
safety, according to the screening
criteria described in section IV.B.
In the preliminary analysis, DOE
considered design options that
increased the baseline insulation
thickness and improved insulation
material. The preliminary analysis used
a baseline insulation thickness of 4
inches and analyzed design options
with increased insulation thicknesses of
5 inches, 6 inches, and 7 inches. The
baseline panel insulation R-value was
an average of extruded polystyrene and
foamed-in-place polyurethane. The
improved insulation materials in the
preliminary analysis were vacuum
insulated panel (VIP) insulation and
hybrid insulation, a combination of the
baseline material and vacuum insulated
panels.
Many stakeholders commented on the
proposed insulation improvements.
American Panel did not agree with the
initial costs DOE initially presented for
the increased thicknesses of insulation.
In its view, costs were higher due to the
increased difficulty of manufacturing
thicker panels. To accurately reflect this
inefficiency, American Panel suggested
DOE increase the cost of labor per panel
because it takes more time to foam the
fixture. (American Panel, No. 0048.1 at
p. 5) American Panel also remarked that
most manufacturers possess tooling that
is adjustable only from 4–6 inches.
(American Panel, Public Meeting
Transcript, No. 0045 at p. 121) Hill
Phoenix stated that panel thicknesses
above 5.5 inches will have a costly
impact on the manufacturer and end
user because manufacturers need to
purchase more equipment to deal with
the increased weight and the end-user
will need more floor space to house or
site the walk-in. (Hill Phoenix, No.
0066.1 at p. 3) American Panel
criticized the preliminary analysis for
omitting insulating floor panels or an
insulation slab with vertical breaks as
design options. American Panel
explained that although the payback
period would be longer if these options
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are included, DOE should still consider
the long term energy savings that these
options may yield. (American Panel, No.
0048.1 at p. 5)
DOE agrees with American Panel that
most manufacturers do not currently
have the tooling to produce panels with
more than 6 inches of insulation. In
addition, DOE finds that constructing
and handling panels thicker than 6
inches would be unduly burdensome to
the manufacturer because panels thicker
than 6 inches would be very difficult to
handle, store, ship, and produce at
typical industry production volumes.
Because panels thicker than 6 inches
would not be practicable to
manufacture, DOE screened them out
from its analysis. DOE’s NOPR analysis
limits the maximum insulation
thickness to 6 inches of foam and DOE
does not expect its proposed standard to
require panels thicker than 5 inches (see
chapter 5 and appendix 10D of the
TSD); however, the agency requests
comment on this assumption in the
analysis. DOE notes Hill Phoenix’s
comment about the increased labor cost
associated with increasing the panel
thickness and proposes to account for
the increased cost of handling large
panels in its cost-efficiency analysis.
DOE also agrees with American Panel’s
comment that requiring insulated floor
panels for walk-in coolers would
produce long term energy savings.
However, DOE is not proposing to set a
standard for walk-in cooler floors as
explained in section IV.A.2.a of this
notice.
Two stakeholders made comments
specifically about VIPs. NanoPore stated
that silica-carbon based core materials
have a better lifetime performance than
fiberglass core materials when using
vacuum insulated panels, and noted
that VIPs have reached a point of large
scale commercialization. (NanoPore, No.
0067.1 at pp. 1 and 6) However, Hill
Phoenix commented that VIPs are
impractical because of the high cost to
the manufacturer, and that vacuum
insulated panels would require
additional labor and tooling. (Hill
Phoenix, No. 0066.1 at p. 3)
DOE included hybrid insulation (half
foam-in-place polyurethane and half
VIP) as a design option to improve the
efficiency of walk-in panels and nondisplay doors. It did not, however,
include VIP insulation as a design
option because DOE cannot definitively
conclude that VIPs have the structural
capability of supporting typical walk-in
loads, particularly since VIPs can easily
be punctured, which would cause a loss
in thermal insulation (see chapter 5 of
the TSD for details). DOE notes that
while NanoPore stressed the benefits of
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silica-carbon based VIP, DOE did not
specify the type of VIP used in the
engineering analysis in order to
maximize manufacturer flexibility in
meeting the proposed standard. DOE
agrees with Hill Phoenix that VIPs are
more expensive and may require
additional tooling, but DOE does not
find this increased cost would prevent
manufacturers from implementing VIPs.
DOE also notes that the high costs of
VIPs are captured in the engineering
analysis for panels and non-display
doors.
In its engineering analysis for walk-in
panels, DOE included design options
which increase the baseline insulation
thickness, change the baseline
insulation material from foam-in-place
polyurethane to a hybrid of
polyurethane and VIP, change the
baseline framing material from wood to
high density polyurethane, and
eliminate a structural panel’s framing
material. DOE assumed in its analysis
that freezer floor panels retain some
type of framing material to maintain
structural integrity because the foam
itself may be unable to support heavy,
perpendicular loads—e.g. personnel,
machinery, and products—to the panel’s
face. DOE also assumed that high
density polyurethane framing materials
used in a panel have the same
dimensions as the wood framing
materials used in a wood-framed panel.
DOE seeks comment on these panel
design options, particularly with respect
to the specifications for high density
polyurethane framing materials.
Doors
Stakeholders also commented on
design options that would reduce the
infiltration from door openings: namely,
automatic door opening and closing
systems, which automatically open and
close the door by sensing when a person
is about to pass or has passed through;
air curtains and strip curtains, both of
which provide a secondary barrier to air
infiltration when the door is open; and
vestibule entryways, which consist of a
series of two doors separated by a space
through which one would pass to enter
the walk-in. Hired Hand noted that the
engineering analysis omitted automatic
roll-up doors or bi-folding envelope
doors, and that these doors cannot be
adequately subsumed under ‘‘automatic
door opening and closing’’ (which DOE
did include) because this option does
not capture the full benefit of these
doors. (Hired Hand, No. 0050.1 at pp. 1–
2) American Panel was skeptical that
automatic door opening and closing
sensors existed in the industry and did
not agree with DOE’s proposed cost of
the technology. (American Panel, No.
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0048.1 at p. 6) American Panel also
stated that a vestibule is not a practical
design option because the cost of the
floor space and the layout of standard
stores would be prohibitive to the end
user. It noted that the cost of a vestibule
is higher than DOE estimated, and
predicted that the cost for materials and
equipment would be well over $2,500.
(American Panel, No. 0048.1 at pp. 3
and 6)
For the reasons stated in its recent
final rule, the test procedure does not
include a method for measuring the
door opening infiltration associated
with walk-ins. See 76 FR at 21595.
Therefore, the energy consumption
caused by door opening infiltration is
not accounted for in the panel, display
door, or non-display door engineering
analyses, and design options related to
door opening infiltration would not
affect the energy consumption of the
walk-in components.
Some stakeholders specifically
commented about the strip curtains
design option. NEEA and NPCC stated
that strip curtains are already required
by EPCA, and should not be considered
a design option, but that infiltration
load could still be reduced by additional
IRDs. (NEEA and NPCC, Public Meeting
Transcript, No. 0045 at p. 170; NEEA
and NPCC, No. 0059.1 at p. 8) NEEA,
NPCC and Master-Bilt disagreed with
DOE’s assumption that strip curtains
can reduce the total energy
consumption of a walk-in by half. NEEA
and NPCC suggested strip curtains
would more likely reduce the energy
consumption by one third, according to
a Pacific Northwest study, and MasterBilt commented that strip curtains
reduce the compressor load by less than
5 percent according to their own field
tests. (NEEA and NPCC, Public Meeting
Transcript, No. 0045 at p. 152; NEEA
and NPCC, No. 0059.1 at p. 8; MasterBilt, Public Meeting Transcript, No.
0045 at p. 159; Master-Bilt, No. 0046.1
at p. 1) American Panel noted that strip
curtain manufacturers indicated that the
device achieves a 25 percent reduction
in air infiltration, much lower than
DOE’s assumption of 90 percent
effectiveness. (American Panel, Public
Meeting Transcript, No. 0045 at p. 154;
American Panel, No. 0048.1 at p. 6)
Lastly, AHRI also commented that DOE
overestimated the benefit of strip
curtains, and that DOE should verify
their assumptions with field data; AHRI
did not provide any alternative data on
the benefit of strip curtains. (AHRI, No.
0055.1 at p. 2) As explained in section
IV.B.1 of this document, however,
infiltration devices are no longer
included in the engineering analysis.
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Stakeholders also commented on the
door lighting design options presented
in the preliminary analysis; specifically,
occupancy sensors that cause the lights
to operate only when people are
present; electronic lighting ballasts,
which are more efficient than typical
magnetic ballasts; and high-efficiency
light-emitting diode (LED) lighting, a
type of lighting that uses
semiconducting materials to produce
light and uses less energy per lumen
than incandescent or fluorescent
lighting. American Panel stated that
LED lighting is not a viable design
option because the LED fixture and bulb
payback period is 2.5 years. (American
Panel, No. 0048.1 at p. 6) The Joint
Utilities suggested that DOE should add
LED lighting with motion controls as a
design option for display cases. (Joint
Utilities, Public Meeting Transcript, No.
0045 at p. 26; Joint Utilities, Public
Meeting Transcript, No. 0045 at p. 89;
Joint Utilities, No. 0061.1 at p. 3)
In response to American Panel’s
concern about the cost of LED lighting,
DOE accounts for the cost of the bulb
and fixture when estimating the total
cost of LED lighting. However, DOE has
not automatically eliminated LED
lighting from consideration based on
payback period but includes it in the
range of design options it is considering.
For more details on the payback period
analysis, see section IV.F. In response to
the suggestion from Joint Utilities, a
combined design option with LED
lighting and motion control sensors is
not warranted because DOE already
includes a lighting sensor and LED
lighting as separate design options in
the walk-in display door engineering
analysis. A separate design option for
lighting sensors allows the sensor to be
applied to fluorescent as well as LED
lighting.
Some stakeholders commented on the
anti-sweat heater wire design option.
CrownTonka commented that anti-sweat
heater wire should be applied to nondisplay freezer doors and any windows
in non-display doors. (CrownTonka,
Public Meeting Transcript, No. 0045 at
p. 89) Craig Industries supported the
inclusion of self-regulating heater wire
and noted that this wire is readily
available and more efficient than other
types of heater wires. (Craig Industries,
No. 0064.1 at p. 1) DOE agrees with
CrownTonka and proposes to include
anti-sweat heater wire around the outer
edge of non-display freezer doors as
well as on the windows located on nondisplay doors as design options. In
response to Craig Industries’ suggestion,
the energy savings from self-regulating
anti-sweat heater wire alone cannot be
captured in the proposed engineering
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analysis for display and non-display
doors because the energy savings are not
captured by the test procedure. The test
procedure credits the manufacturer with
energy savings if a preinstalled timer,
control system or other auto-shut-off
system is used in conjunction with antisweat heater wire. The credit is called
a percent time off (PTO) credit, which
reduces the calculated power associated
with the device. 76 FR 33631, 33635,
33637 (June 9, 2011).
The display door design options used
in the analysis include improved glass
packs—where ‘‘glass pack’’ refers to the
combination of glass panes, gas fill, and
low-emission coatings making up the
transparent part of the door; anti-sweat
heater controls for cooler doors; LED
lighting; and lighting sensors that
control when the lights turn on and off.
DOE did not analyze anti-sweat heater
controls for freezer display doors
because baseline freezer doors are
already required to have a controller to
regulate the power consumed by the
anti-sweat heater wire. EISA requires all
freezer doors to have an anti-sweat
heater control if the anti-sweat heater
wire consumes more than 7.1 watts per
square foot of door opening, and DOE
estimated that baseline display doors
consume 15.2 watts per square foot of
door opening. Therefore, baseline
display doors already have an antisweat heater wire control system in
order to comply with EISA.
As explained previously, the walk-in
cooler and freezer test procedure credits
the manufacturer for having a control.
The type or amount of controls does not
change the credit nor increase the
energy savings realized by the DOE test
procedure. For these reasons, DOE did
not include control systems as a design
option. Additionally, DOE did not
consider eliminating anti-sweat heater
wire as a separate design option. The
improvements made to the glass pack
cause a reduction in the power draw of
the anti-sweat heater wire. In the case of
display cooler doors, the performance of
the glass pack is improved enough so
that anti-sweat heater wire is no longer
required on the door. DOE also did not
consider higher efficiency ballasts in its
analysis because it found that electronic
ballasts already incorporated into
baseline units and DOE is not aware of
more efficient ballasts. DOE requests
comment on its analyzed design options
and specifically seeks any heat transfer
data for the improved glass packs
detailed in chapter 5 of the TSD.
The design options that DOE analyzed
in the engineering analysis for nondisplay doors include increasing the
insulation thickness, changing the
insulation material from baseline to a
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hybrid of polyurethane and VIP,
changing the baseline framing material
from wood to high density
polyurethane, improving the window’s
glass pack, and adding an anti-sweat
heater wire controller to the door. These
options are more fully described in
chapter 5 of the TSD. DOE requests
comment on the non-display door
design options it analyzed, particularly
with respect to the cost of the window
improvements detailed in chapter 5 of
the TSD.
American Panel suggested that DOE
consider low cost methods for extending
the envelope and door lifetimes.
(American Panel, No. 0048.1 at p. 9)
DOE has not considered options in this
analysis that do not improve the rated
performance of the equipment, as
described in section IV.B.1. The purpose
of the engineering analysis is to analyze
the manufacturing cost and the
performance of the covered equipment
as rated by the test procedure.
Examining methods to extend the life of
walk-in equipment, including the
impact of such methods on standards
adopted by DOE, would complicate and
create a significant impediment to
completion of this rulemaking, without
any clear prospect that it would affect
the standards DOE ultimately adopts.
For this reason, DOE has decided not to
pursue this issue.
After considering all the comments it
received on the design options, DOE is
including the following design options
in the NOPR analysis for panels, display
doors, and non-display doors:
Panels
• Increased insulation thickness up to
6 inches
• Improved insulation material
• Improved framing material
Display Doors
• High-efficiency lighting
• Occupancy sensors
• Display and window glass system
insulation performance
• Anti-sweat heater controls
Non-Display Doors
• Increased insulation thickness up to
6 inches
• Improved insulation material
• Improved panel framing material
• Display and window glass system
insulation performance
• Anti-sweat heater controls
• No anti-sweat systems
b. Refrigeration
In the preliminary analysis, DOE
included the following design options
for the walk-in refrigeration system:
• High-efficiency compressors
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• Improved condenser coil
• High-efficiency condenser fan
motors
• Improved condenser fan blades
• Improved evaporator coil
• Improved evaporator fan blades
• Evaporator fan controls
• Floating head pressure
• Defrost controls
The preliminary analysis contained
tables detailing each design option,
including the cost of implementing each
option and a description of the design
option’s properties. The discussion
below sets forth comments received on
these design options for refrigeration
systems, as well as DOE’s proposed
approach in today’s NOPR.
One option DOE considered was highefficiency compressors. For example,
DOE suggested using scroll compressors
to represent the performance associated
with higher efficiency compressors in
walk-in applications. In response,
Master-Bilt and Heatcraft commented
that scroll compressors are not
necessarily more efficient than other
compressor types and are limited by
their application and the prevalent
conditions in which the compressor
operates. (Master-Bilt, Public Meeting
Transcript, No. 0045 at p. 1; Heatcraft,
No. 0058.1 at p. 2) Heatcraft also stated
that with increasing horsepower, fewer
compressor types are available.
(Heatcraft, No. 0069.1 at p. 1) The Joint
Utilities added that for larger walk-in
units, semi-hermetic compressors are
more efficient than scroll types—except
at low temperatures where, in their
view, scroll compressors are more often
utilized—but they did not provide
information supporting the same. In
addition, the Joint Utilities stated that
hermetic compressors hold an added
cost advantage over semi-hermetic
compressors. (Joint Utilities, No. 0061.1
at pp. 6 and 10) With regard to the types
of compressors used in the food service
market, American Panel suggested that
hermetic compressors were dominant
and stated that semi-hermetic
compressors’ high initial cost made
them less prevalent generally.
(American Panel, No. 0048.1 at p. 9)
DOE conducted additional research
on available compressors and found that
the prevalence of some compressor
types varied at certain sizes. DOE also
ensured that its analysis accounted for
the effect that different applications and
conditions may have on the relative
efficiency of compressor types. In
particular, the NOPR analysis includes
an evaluation of a wide range of
refrigeration capacities, and DOE has
separately evaluated the different
compressor types available at each
capacity point. DOE believes that this
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modified analysis adequately captures
the performance of each compressor
type at each size and set of operating
conditions.
To obtain data on compressor
performance, DOE’s preliminary
analysis relied on manufacturer Web
sites and related product specification
sheets and did not consider the effect of
the return gas conditions. The
compressor data were based on return
gas conditions under which the
individual compressors were rated. The
Joint Utilities stated that the return gas
conditions were inconsistent with the
typical operating conditions of walk-ins.
(Joint Utilities, Public Meeting
Transcript, No. 0045 at p. 27 and No.
0061.1 at p. 11) In consideration of the
Joint Utilities’ comment, DOE
investigated the effect of the return gas
conditions on compressor performance
and has updated the compressor
characteristics using return gas
conditions that are consistent with the
rating conditions in AHRI 1250–2009,
which are different from the rating
conditions for individual compressors.
The conditions are contained within
AHRI 1250–2009 itself, which DOE has
incorporated into its test procedure. 76
FR at 33631.
After considering the stakeholder
comments and conducting further
research, DOE expanded its initial
compressor range beyond scroll
compressors and hermetic compressors
to now include semi-hermetic
compressors in the list of compressor
options in order to capture most of the
market share. This was done specifically
due to the varying compressor
efficiencies at different operating
temperatures, and the lack of
availability of certain compressor types
at all capacity ranges. For example, it is
difficult to obtain hermetic compressors
at capacities exceeding 30,000 Btu/h, so
manufacturers may be more likely to use
semi-hermetic compressors at these
capacities as a lower-cost alternative to
scroll compressors.
The preliminary TSD discusses the
evaporator and condensing coil baseline
and improved efficiency as coil size
increases. In that analysis, DOE selected
increased coil size as a design option
because increasing the coil size
corresponds to a drop in temperature
difference, which would increase
compressor capacity and result in lower
normalized energy consumption.
DOE received several comments about
heat exchanger coil size and the
associated savings. The Joint Utilities,
Manitowoc and Heatcraft commented
that the analysis did not consider an
increase in fan power with an increase
in coil size. (Joint Utilities, Public
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Meeting Transcript, No. 0045 at p. 27
and No. 0061.1 at p. 6; Manitowoc, No.
0056.1 at p. 2; Heatcraft, No. 0058.1 at
pp. 2 and 3) American Panel stated that
increasing condenser coil size would
also require an increase in evaporator
coil size, while Manitowoc suggested
that the coil heat transfer equation
should use log-mean temperature.
(American Panel, No. 0048.1 at p. 6;
Manitowoc, No. 0056.1 at p. 2)
After carefully considering these
comments, DOE modified its analysis by
increasing fan power proportionally to
coil size. DOE found through its
analysis, however, that as coil size
increases, the decrease in compressor
power far exceeds the increase in fan
power, which ultimately decreases the
net energy consumption. As a result,
DOE retained increased coil size as a
design option in its analysis. DOE agrees
with Manitowoc’s comment that using
log mean temperature difference is a
more accurate way to calculate heat
transfer because this method accounts
for changes in air temperature and
refrigerant temperature across the
refrigerant coil rather than assuming
that these temperatures are constant.
DOE’s analysis had used a simplified
form of the heat transfer equations in
the preliminary analysis, but now
includes a log mean temperature
difference in its analysis for the NOPR.
In response to American Panel’s
comment about requiring an increase in
evaporator coil with condenser coil,
DOE has taken a complete system
modeling approach in analyzing the
refrigeration system’s performance to
capture any effects on the evaporator
conditions from condenser coil changes.
At this point, DOE believes that
increasing the coil size of the condenser
does not necessarily require an increase
in coil size for the evaporator because
the manufacturer would balance other
aspects of the system to maintain the
same capacity. DOE requests comment
on this assumption, particularly from
manufacturers who currently utilize
larger condenser coils.
Condenser Fan Motors
In chapter 5 of the preliminary TSD,
DOE discussed more efficient condenser
fan motors as a viable design option.
EPCA requires that walk-in condenser
fan motors of less than 1 horsepower
must use permanent split capacitor
motors, electronically commutated
motors, or three-phase motors. (42
U.S.C. 6313(f)(1)(F)) Permanent split
capacitor (PSC) motors are less
expensive and less efficient than
electronically-commutated (EC) motors
and are currently used by the majority
of manufacturers. DOE also assumed the
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same motor efficiencies for PSC and EC
motors that were assumed in the ANSI/
ARI Standard 1200–2006—that is, 29
percent and 66 percent respectively.
(The analysis screened out three-phase
motors as a design option based on
utility to the consumer, as explained in
section IV.B.2.b, although
manufacturers may still use this
technology to improve the overall
efficiency of the equipment they
manufacture.)
DOE received comments about the
assumed efficiency of fan motors.
Manitowoc commented that DOE’s
assumed efficiency for PSC motors was
too low and should be about 50 percent,
while Heatcraft stated that PSC motor
efficiency would likely be between 45
and 55 percent, three-phase motor
efficiency would be approximately 80
percent, and EC motor efficiency would
range from 60 to 90 percent.
(Manitowoc, No. 0056.1 at p. 2;
Heatcraft, No. 0058.1 at p. 2 and No.
0069.1 at p. 2) The Joint Utilities
suggested that the methodology of
determining input power from
efficiency ratings for small motors was
inaccurate. (Joint Utilities, No. 0061.1 at
p. 8) Heatcraft provided a list of parts
to be added to the engineering analysis.
(Heatcraft, No. 0069.1 at p. 1)
DOE has considered the suggestions
of Manitowoc and Heatcraft regarding
motor efficiency and has changed its
assumptions for PSC motors to 50
percent and EC motors to 75 percent
after researching currently available
motors. Additionally, regarding
comments received from Heatcraft about
three-phase motors, DOE did not
include three-phase motors as a design
option or as part of the design of smaller
baseline equipment due to adverse
utility to the consumer and
impracticability to manufacture, install
and service, because many consumers
do not have three-phase power sources;
however, DOE assumed that larger
baseline equipment would use threephase motors. See section IV.B.2.b for
more details. DOE also included in its
analysis the fan motor parts Heatcraft
identified after evaluating teardown
data and conducting further analysis of
those parts. In response to the Joint
Utilities’ comment that DOE should not
determine input power from efficiency
ratings, DOE has used this method as its
best estimate for motor power
consumption. DOE has not identified a
more accurate methodology for
determining input power and requests
feedback on this issue.
Chapter 5 of the preliminary TSD
presented several fan blade options for
the evaporator and condenser fan blade
design option. Responding to these
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options, Heatcraft suggested the
inclusion of swept fan blades as they are
more aerodynamic and reduce
vibrations and noise that result in
inefficiencies. In addition, it also
suggested that motor efficiency is
independent from fan blade efficiency
because more efficient fan blades do not
result in high efficiencies for motors and
vice versa. Rather, the efficiency of each
component is due to its own intrinsic
characteristics. After considering
Heatcraft’s comment, DOE is continuing
to treat the motor and fan blade options
separately.
The preliminary analysis examined
evaporator fan controls as a design
option. The impacts of fan controls were
analyzed consistent with the test
procedure requirement that ‘‘controls
shall be adjusted so that the greater of
a 25 percent duty cycle or the
manufacturer default is used for
measuring off-cycle fan energy. For
variable-speed controls, the greater of 25
percent fan speed or the manufacturer’s
default fan speed shall be used for
measuring off-cycle fan energy.’’
Because of this requirement, DOE set a
75 percent reduction in off-cycle fan
energy as the energy savings achieved
for the fan control technology option.
DOE did not differentiate between
modulated fan controls and variable
speed fan controls in the preliminary
analysis. DOE received comments both
on its characterization of the fan control
design option and on the energy results
for that design option. NEEA and NPCC
expressed concern that DOE’s analysis
caused the evaporator fan control option
to appear less cost-effective compared to
other design options, possibly
indicating that DOE underestimated its
potential energy savings. (NEEA and
NPCC, No. 0059.1 at p. 7) The Joint
Utilities cited studies indicating that fan
speed control is one of the most, if not
the most, cost-effective design option for
many refrigeration systems. (Joint
Utilities, Public Meeting Transcript, No.
0045 at p. 28; No. 0061.1 at pp. 2 and
6) The Joint Utilities also criticized
DOE’s initial approach of not
distinguishing between fan cycling and
fan speed control. They indicated that
the approach taken by DOE overly
simplified the analysis, which then
yielded considerably smaller projected
savings for multiplex systems. Because
of the complexity of the size ranges and
system variations of these units, a more
detailed analysis than the single design
option used in the preliminary analysis
is, in their view, required to sufficiently
evaluate the potential energy savings
from using a fan control system. They
recommended that an analysis of fan
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speed controls include the benefit of
operating at reduced fan speeds for the
majority of the time the system operates.
(Joint Utilities, No. 0061.1 at pp. 6 and
9) NEEA and NPCC agreed with DOE’s
approach insofar as fan controls that
adjust envelope interior temperature
conditions should be applied to every
walk-in. (NEEA and NPCC, No. 0059.1
at p. 7)
Some interested parties also
cautioned DOE about the unintended
consequences of implementing different
types of fan controls. The Joint Utilities
stated that a fan duty-cycling control
strategy would be unacceptable in many
applications because of the increased
likelihood of uneven temperatures and
the related concern for perishable
products. (Joint Utilities, No. 0061.1 at
p. 9) Zero Zone stated that variable
speed evaporator fan motors could
prevent the walk-in from maintaining
the desired product temperature. (Zero
Zone, No. 0051.1 at p. 1) American
Panel stated that if fan controls cause
the compressor to run for longer
periods, energy consumption will
increase because the compressor draws
more power than the fans. American
Panel also recommended that DOE
ensure that whatever standards it may
propose, that air defrost evaporators still
be able to defrost ice build-up on
refrigeration coils during off-cycle
periods using lower fan speeds.
(American Panel, No. 0048.1 at p. 7)
One interested party commented on
DOE’s assumed cost of the fan control
option. The Joint Utilities stated that the
assumed cost of $300 for fan control
would likely be lower, particularly for
small walk-ins, because the EC motors
have inherent variable speed capability
and the microcontrollers used to control
these motors can provide the required
voltage signal to control the EC motors.
(Joint Utilities, No. 0061.1 at p. 9)
To address these concerns, DOE has
made several changes to its fan control
analysis. DOE is now considering both
modulated (fan cycling) and variable
speed controls as potential design
options. Modulated fan controls cycle
the fans at 50 percent runtime at 100
percent speed when the compressor is
off, while variable speed controls set the
fan speed to 50 percent of maximum
speed at 100 percent runtime when the
compressor is off. DOE’s analysis
applies the commonly used fan power
laws, which describe the relationship
between power and speed during a fan’s
operation. A reduction in fan speed
causes a reduction in fan power to the
third power. For example, reducing
speed to 50 percent of full speed
reduces the power to 12.5 percent of full
power. Thus, variable speed controls
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would be expected to save more energy
than modulated fan controls for the
particular control strategies analyzed.
DOE applied both modulated fan
controls and variable speed fan controls
as a design option for all classes
analyzed. DOE did not, however,
consider controls that respond to
specific box conditions because, as
stated in the test procedure final rule,
the impact of these controls would not
be captured using the component-level
approach, which analyzes refrigeration
systems separately from envelope
components. DOE notes that, as a result
of the enhancements made to its
analytical approach, the NOPR analysis
indicates that modulated and variable
speed fan controls would likely be
among the primary options to improve
walk-in refrigeration system efficiency.
DOE appreciates the concerns about
fan controls raised by American Panel,
the Joint Utilities, and Zero Zone. DOE’s
research does not indicate that air
defrost would be adversely affected by
fan controls. Therefore, air defrost
would likely still be adequate with
reduced fan speed. To address
commenters’ concerns about the
potential effects of fan controls on food
safety, DOE estimates that the outcome
of using such controls would be
equivalent to an overall 50 percent
decrease in runtime (for a cycle control)
or a 50 percent decrease in speed (for a
variable-speed control) and has
tentatively concluded that the impact of
the controls it analyzed will be limited
and not affect the maintenance of safe
food temperatures. See chapter 5 for
details. DOE requests comment from
interested parties as to whether food
temperatures would be adequately
maintained in the specific control cases
it has analyzed and, if not, what an
appropriate control strategy would be.
DOE seeks any data that interested
parties can provide to show the
relationship between fan controls and
food temperatures. DOE also seeks
information as to whether additional
components are necessary to ensure
food temperature, such as extra
thermostats located in certain areas of
the walk-in. To address American
Panel’s comment about compressor
runtime, DOE does not expect
compressor runtime to increase from the
inclusion of fan control implementation
because the fans run at full speed while
the compressor is running and fan speed
or cycling controls are activated only
when the compressor is off. DOE also
does not expect controls to increase the
amount of time the compressor is off
because the compressor cycles on based
on the walk-in’s interior temperature,
which DOE believes will not be
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significantly affected by the fan control
strategy modeled in the analysis.
Defrost Controls
In the preliminary analysis, DOE
evaluated several defrost control options
available in the market. DOE considered
using time-initiated, time-terminated
defrost as the baseline. The design
option involved a generic defrost
control that would result in half as
many defrosts per day. Heatcraft and
American Panel doubted whether
existing defrost controls could achieve
the 50 percent reduction in defrosts
assumed in the preliminary analysis.
(American Panel, No. 0048.1 at p. 7;
Heatcraft, No. 0058.1 at p. 4) In
addition, Heatcraft, American Panel and
the Joint Utilities suggested DOE replace
time termination with temperature
termination in the base case. (Heatcraft,
No. 0058.1 at p. 4; American Panel, No.
0048.1 at p. 7; Joint Utilities, Public
Meeting Transcript, No. 0045 at p. 26)
Heatcraft and the Joint Utilities also
noted that defrost time should be
dependent on system size to account for
the greater surface area of larger units
and suggested that the baseline defrost
control strategy be a time-initiated,
temperature-terminated scheme, which
is the industry standard. (Heatcraft, No.
0058.1 at pp. 3–4; Joint Utilities, No.
0061.1 at p. 3)
In response to comments received
about defrost control, DOE’s analysis
now applies a temperature-terminated
defrost approach for all defrost control
schemes (baseline or higher). The
defrost cycle ends once the coil
temperature reaches 45 °F. For the
defrost design option, DOE is
continuing to apply a generic defrost
control that would reduce the number of
defrosts per day. The magnitude of the
reduction is set at 40 percent, which is
less than the 50 percent level originally
assumed in the preliminary analysis.
DOE chose this reduced level because it
would result in significant energy
savings while still maintaining adequate
defrost capability. Further details about
the defrost control parameters are found
in chapter 5 of the TSD.
Floating Head Pressure
In the preliminary analysis, DOE also
considered floating head pressure as a
design option. With floating head
pressure, the compressor pressure and
the saturated condensing temperature
(SCT) float down to the minimum level
at which the compressor can operate.
DOE assumed that floating head
pressure would allow the SCT to float
down to 70 °F. DOE also assumed that
the SCT would decrease at the same rate
as the ambient temperature such that
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the system would maintain the same
temperature difference (TD) between the
SCT and the ambient air. This change
resulted in a predicted reduction in
energy consumption because
compressors generally run more
efficiently at a lower SCT. The capacity
of the system was related to the SCT and
the TD.
Some interested parties commented
on DOE’s assumptions relating to
floating head pressure. Heatcraft
disagreed with DOE’s assumption that
the TD would be constant as SCT
decreases and stated that the TD
increases as SCT decreases. To illustrate
its point, Heatcraft calculated the TD of
a system at an SCT of 115 °F and again
at an SCT of 70 °F and found that the
ratio of the condenser TD between these
two SCT conditions would be
approximately 1.19, not 1.0 (where a
ratio of 1.0 would correspond to no
change in TD as SCT decreases). This
value was calculated using the total heat
of rejection (THR) of the condenser.
(Heatcraft, No. 0058.1 at p. 4) The Joint
Utilities had several comments relating
to the implementation of floating head
pressure. They recommended that DOE
account for the additional fan power
required for floating head pressure, and
stated that varying the speed of
condenser fans as part of a floating head
pressure control has effects on the
system such as more stable operation of
the expansion valve and less likelihood
of compressor damage due to liquid
refrigerant reaching the compressor.
(Joint Utilities, No. 0061.1 at pp. 6 and
10) The Joint Utilities also identified
two different head pressure control
types that have an impact on projected
energy savings: fan control or fan
cycling and a condenser valve to
maintain the minimum condensing
temperature. (Joint Utilities, No. 0061.1
at p. 10) Finally, the Joint Utilities
pointed out that if a lower initial or
baseline SCT value is assumed, the
estimated savings for floating head
pressure will be less. (Joint Utilities, No.
0061.1 at p. 10)
To account for the suggestions made
by commenters, DOE has implemented
changes to its NOPR analysis of floating
head pressure. First, DOE investigated
the control methods identified by the
Joint Utilities. In the current model used
for the NOPR analysis, fan modulation
is implemented in the baseline to
maintain a fixed head pressure. When
floating head pressure is implemented,
a valve and accompanying controls are
added to maintain a minimum
condensing temperature. Regarding the
comments on fan power submitted by
the Joint Utilities, DOE agrees that at
lower ambient temperatures, the
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required fan airflow is higher when
floating head pressure is implemented
because the TD is smaller. DOE’s
current energy model calculates the fan
power necessary to maintain adequate
heat transfer when floating head
pressure is implemented. DOE assumed
that condenser fans would be
modulated in the baseline; variable
speed condenser fans are considered as
a separate design option. DOE’s model
calculates the energy savings of variable
speed condenser fans with or without
floating head pressure implemented.
The energy model does not capture
increased stability in the expansion
valve or the reduced possibility of
compressor damage because the energy
model attempts to capture the
performance as rated by the test
procedure, and for the reasons stated in
the test procedure final rule, the test
procedure established by DOE is
designed to rate only certain aspects of
the equipment—e.g., AWEF and
capacity. 76 FR 21580, 21597–21598
(April 15, 2011).
DOE also assumes that a system tested
by the manufacturer would likely be a
new system, which is unlikely to
experience decreased stability in the
expansion valve; therefore, DOE did not
capture expansion valve stability in the
energy model. The energy model also
does not capture long-term compressor
damage because DOE assumes the test
procedure would be performed at the
point of manufacture of the equipment,
and would therefore not capture such
damage to the compressor. Compressor
replacement is, however, addressed in
the life cycle cost analysis (see section
IV.F.6). Any additional benefits that
accrue due to reduced maintenance are
also not captured in the engineering
analysis.
DOE also acknowledges the Joint
Utilities’ observation that the savings for
the floating head pressure option
depends on the baseline SCT and DOE’s
energy modeling confirms their
assertion that the floating head pressure
option would appear to save less energy
if the baseline SCT were lower.
However, DOE chose certain baseline
SCT values for each class that would be
realistic considering the equipment
rating conditions, as explained in
section IV.C.4.b. To address Heatcraft’s
comment that TD would increase with
decreasing SCT, DOE analyzed the total
heat of rejection of sample systems
using the specified temperatures in the
test procedure and found an average TD
ratio corresponding to each compressor
type analyzed. DOE implemented the
TD ratio in the engineering analysis. See
chapter 5 of the TSD for more details on
the floating head pressure design
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option. DOE requests comment on its
assumptions and implementation of this
option, particularly regarding the cost to
implement various floating head
pressure control schemes and the energy
savings that would be achieved.
Refrigeration Summary
After considering all the comments it
received on the design options, DOE is
including the following design options
in the NOPR analysis:
• Higher efficiency compressors
• Improved condenser coil
• Higher efficiency condenser fan
motors
• Improved condenser and evaporator
fan blades
• Ambient sub-cooling
• Evaporator and condenser fan
control
• Defrost control
• Hot gas defrost
• Head pressure control
Each design option is explained in
detail in chapter 5 of the TSD.
6. Cost-Efficiency Results
a. Panels and Doors
In the preliminary analysis, DOE
plotted total energy consumption in
kilowatt-hours per day versus the
increasing cost of representative walk-in
envelopes. Because DOE is proposing to
set component level standards, each of
the three main products that make up
walk-in envelopes have independent
cost-efficiency curves. For panels, DOE
measured the U-factor, a measure of
thermal conductivity expressed in
British thermal units per hour-square
foot-Fahrenheit (Btu/h-ft2-F); that is, the
heat conducted through the panel per
unit time, per square foot of panel
surface area, per degree Fahrenheit. A
lower U-factor corresponds to less heat
conducted through the panel, indirectly
decreasing the energy use of the walkin because the refrigeration system does
not have to expend additional energy to
remove heat from the walk-in. DOE
plotted the decrease in U-factor versus
the increase in cost of a single panel.
For non-display doors and display
doors, DOE plotted energy consumption
in kWh/day versus the increasing cost of
an individual non-display door. For a
more detailed description of the
engineering analysis results, see
appendix 5A of the TSD.
b. Refrigeration
In the preliminary analysis, DOE
chose refrigeration system sizes that best
represented the market, but did not
attempt to match the refrigeration
systems to any particular envelope in
the engineering analysis. DOE received
several comments on the preliminary
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analysis regarding matching the
refrigeration system to the envelope
size. American Panel suggested that,
because of their interdependence,
refrigeration and walk-in size should be
analyzed together. (American Panel,
Public Meeting Transcript, No. 0045 at
p. 115) NEEA, NPCC, Heatcraft, and
American Panel recommended that the
refrigeration system size match the
envelope size. (NEEA and NPCC, No.
0059.1 at p. 9, Heatcraft, No. 0069.1 at
p. 1, American Panel, No. 0048.1 at p.
4)
DOE is proposing to regulate the
refrigeration system as an individual
component in accordance with its
proposed component-level approach,
and is also analyzing the individual
components of an envelope (panels and
doors), rather than the entire envelope.
For these reasons, DOE did not attempt
to match refrigeration systems with any
particular envelope size. Rather, DOE
chose refrigeration system sizes for the
analysis that capture the range of
systems that might be used in a walkin.
In the preliminary analysis, DOE
plotted the cost-efficiency data points
using normalized energy consumption
for its engineering analysis. AHRI
recommended using AWEF and
commented that the normalized values
favor design options, which, in its view,
do not necessarily reduce energy
consumption. The Joint Utilities
believed that non-normalized values
would be helpful to understand the
analyses. (AHRI, No. 0055.1 at pp. 2–3;
Joint Utilities, Public Meeting
Transcript, No. 0045 at p. 171)
Consistent with the test procedure final
rule and AHRI’s suggestion, DOE is
using AWEF to construct its costefficiency curves. See 76 FR 21597–
21598, 10 CFR 431.302.
In chapter 5, Appendix A of the
preliminary TSD, DOE provided costefficiency curves for all the equipment
classes. Numerous stakeholders
requested that DOE provide more detail
about the methodology behind the cost
efficiency curves because they are
concerned about the accuracy of these
curves. (Emerson, Public Meeting
Transcript, No. 0045 at p. 165; AHRI,
Public Meeting Transcript, No. 0045 at
p. 169 and No. 0055.1 at p. 2,4;
Manitowoc, No. 0056.1 at p. 2 and
Public Meeting Transcript, No. 0045 at
p. 125) Additionally, Manitowoc
suggested that a broader view of the
industry’s costs and sizes is required to
improve the accuracy of the results
(Manitowoc, Public Meeting Transcript,
No. 0045 at p. 162)
DOE appreciates the stakeholder
comments and notes that it has updated
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its initial cost-efficiency curves based
on changes to its analysis. DOE has
provided more detail in this NOPR and
the NOPR TSD about the calculation
methodology used in the engineering
analysis, particularly due to the
publication of the test procedure final
rule. DOE also updated its analysis with
the most recent pricing data related to
the costs of materials and purchased
parts and adjusted the projected energy
savings of certain design options as
detailed in section IV.C.5.b.
data for panels, display doors, nondisplay doors, and refrigeration systems,
respectively. For refrigeration systems,
because of the large number of analysis
points, DOE presents results for only
one type of system, DC.L.O, in this
notice. See appendix 5A of the TSD for
complete cost-efficiency results.
c. Numerical Results
Table IV–8, Table IV–9, Table IV–10,
and Table IV–11 present cost-efficiency
TABLE IV–8—COST-EFFICIENCY RESULTS FOR PANELS
Efficiency level
Class/size
Baseline
SP.M.SML .............
SP.M.MED ............
SP.M.LRG .............
SP.L.SML ..............
SP.L.MED .............
SP.L.LRG ..............
FP.L.SML ..............
FP.L.MED .............
FP.L.LRG ..............
Cost [$]
U-factor
Cost [$]
U-factor
Cost [$]
U-factor
Cost [$]
U-factor
Cost [$]
U-factor
Cost [$]
U-factor
Cost [$]
U-factor
Cost [$]
U-factor
Cost [$]
U-factor
.................
[Btu/h-ft-F]
.................
[Btu/h-ft-F]
.................
[Btu/h-ft-F]
.................
[Btu/h-ft-F]
.................
[Btu/h-ft-F]
.................
[Btu/h-ft-F]
.................
[Btu/h-ft-F]
.................
[Btu/h-ft-F]
.................
[Btu/h-ft-F]
1
$54
0.082
$153
0.061
$240
0.056
$56
0.073
$159
0.053
$249
0.050
$85
0.071
$176
0.059
$301
0.054
2
$58
0.046
$159
0.043
$247
0.042
$61
0.040
$165
0.038
$256
0.037
$93
0.041
$190
0.039
$322
0.039
3
$61
0.040
$165
0.038
$256
0.037
$67
0.032
$179
0.030
$276
0.030
$97
0.036
$195
0.035
$331
0.035
4
$67
0.032
$179
0.030
$276
0.030
$73
0.027
$192
0.025
$296
0.025
$104
0.030
$209
0.029
$353
0.028
5
$73
0.027
$192
0.025
$296
0.025
$86
0.024
$229
0.024
$354
0.024
$111
0.025
$222
0.024
$374
0.024
6
$86
0.024
$229
0.024
$354
0.024
$231
0.011
$615
0.011
$951
0.011
$270
0.018
$566
0.015
$973
0.014
$231
0.011
$615
0.011
$951
0.011
....................
....................
....................
....................
....................
....................
....................
....................
....................
....................
....................
....................
TABLE IV–9—COST-EFFICIENCY RESULTS FOR DISPLAY DOORS
Efficiency level
Class/size
Baseline
DD.M.SML ............
DD.M.MED ............
DD.M.LRG ............
DD.L.SML .............
DD.L.MED .............
DD.L.LRG .............
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
1
2
3
4
5
6
$277
2.50
$274
1.74
$340
0.98
$423
0.84
$544
0.68
$710
0.58
$1,375
0.38
$357
2.91
$354
2.15
$420
1.14
$530
0.96
$651
0.80
$870
0.66
$1,751
0.40
$470
3.76
$478
2.78
$544
1.43
$692
1.18
$813
0.99
$1,108
0.81
$2,291
0.46
$509
5.22
$506
4.34
$627
4.14
$793
2.73
$960
2.02
$1,375
1.66
....................
....................
$643
6.47
$640
5.58
$761
5.39
$980
3.49
$1,202
2.56
$1,751
2.08
....................
....................
$831
8.54
$839
7.40
$1,135
4.83
$1,432
3.57
$1,553
3.36
$2,291
2.70
....................
....................
TABLE IV–10—COST-EFFICIENCY RESULTS FOR NON-DISPLAY DOORS
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Efficiency level
Class/size
Baseline
PD.M.SML .............
PD.M.MED ............
PD.M.LRG .............
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Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
18:15 Sep 10, 2013
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1
2
3
4
5
6
7
8
$180
0.30
$184
0.27
$210
0.22
$214
0.22
$222
0.21
$273
0.17
$281
0.16
$487
0.04
$655
0.02
............
............
$210
0.32
$214
0.28
$240
0.24
$245
0.23
$255
0.22
$306
0.18
$316
0.17
$522
0.05
$741
0.03
............
............
$265
$270
$296
$303
$316
$368
$381
$587
$904
............
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TABLE IV–10—COST-EFFICIENCY RESULTS FOR NON-DISPLAY DOORS—Continued
Efficiency level
Class/size
Baseline
PD.L.SML ..............
PD.L.MED .............
PD.L.LRG ..............
FD.M.SML .............
FD.M.MED ............
FD.M.LRG .............
FD.L.SML ..............
FD.L.MED .............
FD.L.LRG ..............
2
3
4
5
6
7
8
0.36
0.31
0.27
0.25
0.24
0.20
0.19
0.06
0.04
............
$235
7.08
$240
6.96
$291
6.52
$342
6.26
$351
6.23
$359
6.20
$425
6.07
$553
6.01
$728
5.98
............
............
$265
7.82
$270
7.69
$322
7.25
$373
6.99
$383
6.95
$393
6.92
$459
6.79
$587
6.72
$814
6.67
............
............
$322
9.03
$328
8.88
$380
8.43
$431
8.18
$445
8.11
$459
8.07
$524
7.94
$653
7.88
$978
7.79
............
............
$356
0.39
$362
0.35
$388
0.30
$398
0.28
$417
0.26
$469
0.22
$489
0.21
$694
0.08
$1,119
0.05
............
............
$574
0.65
$581
0.60
$647
0.46
$662
0.44
$692
0.40
$738
0.36
$768
0.34
$860
0.31
$1,225
0.25
$1,899
0.19
$719
0.73
$727
0.66
$793
0.53
$813
0.49
$853
0.45
$898
0.41
$938
0.38
$1,029
0.35
$1,394
0.29
$2,296
0.21
$416
10.25
$423
10.08
$474
9.63
$526
9.38
$546
9.29
$566
9.23
$632
9.10
$760
9.03
$1,194
8.92
............
............
$679
13.71
$688
13.49
$753
12.58
$845
12.13
$875
11.99
$905
11.90
$997
11.67
$1,225
11.55
$1,911
11.35
............
............
$828
15.62
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
Cost [$] .................
Energy Use [kWh/
day].
1
9
$838
15.36
$904
14.45
$995
14.00
$1,035
13.81
$1,075
13.69
$1,167
13.45
$1,394
13.34
$2,310
13.06
............
............
TABLE IV–11—COST-EFFICIENCY RESULTS FOR REFRIGERATION SYSTEMS
Efficiency level
Class/size
DC.L.OHER 9
kBtu.
DC.L.O SCR
6 kBtu.
DC.L.O SCR
9 kBtu.
DC.L.O SCR
54 kBtu.
DC.L.O SEM
6 kBtu.
DC.L.O SEM
9 kBtu.
DC.L.O SEM
54 kBtu.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
DC.L.O SEM
72 kBtu.
1
2
3
4
5
6
7
8
9
Cost [$] ...............
$1591
$1616
$1641
$1671
$1745
$1749
$1760
$1798
$1848
$1898
AWEF Btu/Wh ....
Cost [$] ...............
2.40
$1720
2.62
$1745
2.81
$1770
2.97
$1800
3.30
$1876
3.31
$1881
3.34
$1919
3.43
$1969
3.56
$1980
AWEF Btu/Wh ....
Cost [$] ...............
2.91
$1838
3.10
$1863
3.27
$1888
3.47
$1918
3.86
$1992
3.87
$1996
3.96
$2034
4.07
$2084
AWEF Btu/Wh ....
Cost [$] ...............
2.86
$1944
3.14
$1969
3.39
$1999
3.70
$2024
4.07
$2100
4.09
$2105
4.24
$2143
AWEF Btu/Wh ....
Cost [$] ...............
3.70
$6938
3.98
$6968
4.35
$7018
4.64
$7068
5.11
$7188
5.13
$7288
AWEF Btu/Wh ....
Cost [$] ...............
4.09
$2095
4.44
$2120
4.92
$2145
5.38
$2175
5.93
$2248
AWEF Btu/Wh ....
Cost [$] ...............
2.47
$2270
2.69
$2295
2.90
$2320
3.15
$2350
AWEF Btu/Wh ....
Cost [$] ...............
2.78
$7776
2.96
$7806
3.12
$7856
AWEF Btu/Wh ....
Cost [$] ...............
3.36
$9772
3.63
$9802
AWEF Btu/Wh ....
DC.L.O HER*
6 kBtu ...........
Baseline
3.41
3.70
10
11
12
$2058
............
............
3.62
$2144
3.65
$2194
............
............
............
............
4.09
$2095
4.38
$2250
4.44
$2300
............
............
............
............
4.44
$2193
4.48
$2204
4.79
$2381
4.89
$2531
............
$2581
............
............
5.28
$7312
5.48
$7362
5.52
$7512
5.86
$7594
6.15
$10312
6.25
$10337
............
$11062
6.27
$2253
6.34
$2291
6.43
$2341
6.58
$2352
6.64
$2402
7.77
$2555
7.78
............
7.91
............
3.48
$2426
3.50
$2430
3.60
$2468
3.74
$2518
3.77
$2666
3.84
$2677
3.93
$2727
............
............
............
............
3.40
$7906
3.77
$8006
3.78
$8129
3.86
$8208
3.96
$8258
4.28
$8340
4.30
$11254
4.36
$11720
............
$11804
............
............
3.99
$9877
4.32
$9952
4.74
$10075
5.24
$10175
5.36
$10225
5.43
$10304
5.47
$10427
6.37
$11091
6.52
$13999
6.54
$14083
............
............
4.11
4.50
4.96
5.36
5.44
5.53
5.58
5.79
6.71
6.72
............
* HER indicates a hermetic compressor, SCR indicates a scroll compressor, and SEM indicates a semi-hermetic compressor.
D. Markups Analysis
This section explains how DOE
developed the distribution channel and
supply chain markups to determine
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installed costs for the end-users of
refrigeration systems and envelope
components.
In the preliminary analysis, DOE
described different distribution
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channels for the two broadly defined
segments of the WICF market: the food
sales (grocery) segment and the food
service segment for the purposes of
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calculating markups. In the food sales
segment, the refrigeration systems are
predominantly unit coolers connected
to multiplex condensing systems. In the
food service and convenience store
market segment, the refrigeration
systems are mostly dedicated
condensing systems. DOE
acknowledged that walk-in units may
also be assembled in the field, with key
components sourced from different
vendors through different channels.
However, in the preliminary analysis,
DOE conducted the markups analysis on
complete walk-in systems and did not
apply separate markups for different
components. Consequently, DOE
assumed in the preliminary analysis
that the refrigeration system and the
envelope followed identical distribution
channels even if they were
manufactured by a different set of
manufacturers.
One interested party recommended
that DOE include an additional
distribution channel. Heatcraft
commented that the refrigeration system
manufacturers often sell directly to the
envelope manufacturers, who integrate
the refrigeration systems with the
envelopes and then sell the assembled
units. (Heatcraft, Public Meeting
Transcript, No. 0045 at p. 187) Heatcraft
identified this market segment as OEMs
and observed that this important
channel of distribution was not
considered by DOE, even though 50
percent of the refrigeration system
business is distributed through the OEM
market segment.
The revised NOPR analysis uses
component-level standards for specific
envelope components and for the
refrigeration systems. Because of this
component-level standards approach,
DOE conducts all the key analysis steps
separately for the refrigeration systems
and the selected envelope components
in the NOPR analysis. As part of this
approach, DOE includes a distinct OEM
distribution channel in the markup
analysis. Based on interviews with
several manufacturers, DOE estimates
that the percentage share of the
aggregate shipments of refrigeration
systems attributable to the OEM
segment of the market is 55 percent for
all dedicated condensing refrigeration
systems, similar to the 50 percent share
indicated by Heatcraft.
Another interested party commented
on the relative shares of the different
market segments DOE identified. In the
preliminary analysis, DOE estimated
that for walk-ins with dedicated
condensing units, 50 percent of
aggregate sales were for the food service
segment and the remaining 50 percent
were for the convenience and small
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grocery stores segment. American Panel
commented that for walk-in equipment
sold with dedicated condensing
equipment, the share of the food service
segment across the two broad market
segments should be 80 percent and the
share of the convenience and small
grocery stores segment should be 20
percent. (American Panel, No. 0048.1 at
p. 8) In the NOPR, DOE revised its
shipment analysis as described in
chapter 9 of the TSD and noted that for
the walk-ins with dedicated condensing
equipment, the relative shares for the
food service segment and the
convenience and small grocery stores
segment are now 78 percent and 22
percent, respectively, compared to 50
percent each for these two segments
estimated in the preliminary analysis.
These new values closely match the
percentage shares indicated by
American Panel.
Several interested parties commented
on the shares of different distribution
channels across the market segments
that DOE previously applied. In the
preliminary analysis, DOE indicated
that the percentage share of the
aggregate shipments of refrigeration
systems through refrigeration
wholesalers was 15 percent for
multiplex equipment and 57.5 percent
for dedicated condensing equipment on
an average basis for all the market
segments. Heatcraft stated that the
percentage share of the aggregate
shipments of refrigeration systems
through the refrigeration wholesalers is
50 percent. (Heatcraft, Public Meeting
Transcript, No. 0045 at p. 284) Based on
information gathered through interviews
with manufacturers of refrigeration
systems, DOE has revised its estimates
for the percentage share of the aggregate
shipments of refrigeration systems
through wholesalers. For the NOPR,
DOE revised these estimates to 42
percent for dedicated condensing
systems and 45 percent for the unit
coolers connected to a multiplex
condensing system.
In the preliminary analysis, DOE
assumed that the share of electronic
commerce (E-commerce) resellers in the
food service market for dedicated
condensing systems is 10 percent.
American Panel commented that this
figure was too high and should be 1
percent or, at most, 2 percent.
(American Panel, Public Meeting
Transcript, No. 0045 at p. 195 and No.
0048.1 at p. 8) Manitowoc pointed out
that E-commerce resellers often
represent food service equipment
distributors selling to territories outside
the specific territory assigned to them
by the manufacturer and that their sales
could be considered distributor sales. In
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its view, if this aspect is considered,
then the share of the E-commerce
business estimated by DOE in the
preliminary analysis is too high.
(Manitowoc, Public Meeting Transcript,
No. 0045 at p. 195) NEEA and NPCC
reinforced the observations made by
American Panel and Manitowoc, and
suggested that DOE adjust the markup
analysis accordingly. (NEEA and NPCC,
No. 0059.1 at p. 9) DOE agrees with
Manitowoc’s observation that the Ecommerce share of total sales is
essentially composed of sales through
the distributor segment and, therefore,
there is no need to identify this channel
of distribution separately. As a result of
this observation, DOE did not identify
this as a separate distribution channel in
the NOPR analysis.
American Panel noted that the
distribution channel shares described by
DOE for walk-ins with dedicated
condensing equipment sold in the food
service market segment are accurate for
the national accounts and distributors
under the current economic situation,
but it expected to see the market share
of the national chains increase to 20
percent with the economy improving in
the next 2 to 3 years. (American Panel,
Public Meeting Transcript, No. 0045 at
p. 144) American Panel also pointed out
that, for walk-ins with dedicated
condensing equipment sold to the food
service segment, the market share for
contractors should be 5 percent instead
of 10 percent. (American Panel, Public
Meeting Transcript, No. 0045 at p. 194)
In the NOPR markup analysis, DOE has
factored American Panel’s estimates and
revised the corresponding market shares
to 10 percent for the national chains and
5 percent for the contractors.
Regarding the values of the markup
multipliers presented in chapter 6 of the
preliminary TSD, several interested
parties commented on the methodology
for arriving at the multiplier. AHRI
stated that, when multiple-stage
markups (manufacturer, distributor,
dealer, and contractor) are estimated
separately and multiplied to estimate
the overall markups, the errors in the
different stages are compounded in the
final result. (AHRI, No. 0055.1 at p. 3)
AHRI suggested that DOE avoid
compounding errors and instead use
retail prices in the analysis. DOE notes
that the current methodology of the
markup analysis is standardized in
DOE’s economic analysis in its energy
conservation rulemaking activities. A
retail price analysis is not feasible,
because a representative sample of
direct end-user prices is difficult to
obtain from distributors and contractors
because pricing data are considered
business-sensitive. Furthermore, these
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parties often use aggregate markups on
the entire contract and separate
markups for labor and/or equipment
installations cannot be established.
Therefore, DOE continues to use a
markup analysis in this NOPR.
Craig Industries commented that the
mechanical contractor may not always
purchase envelope components from the
distributor, but can purchase them
directly from the manufacturers and,
therefore, the baseline markup for the
mechanical contractor should not
include the distributor markup. (Craig
Industries, No. 0064.1 at p. 1) In the
NOPR, DOE is proposing componentlevel standards for the envelope
components and has revised the markup
analysis accordingly. DOE assumes that
the general contractors would purchase
the envelope components directly from
the manufacturer, and hence, did not
include the markup percentages of the
distributors in the estimated overall
markups for sales through the contractor
channel in the NOPR analysis.
Regarding the values of the markup
multipliers presented in chapter 6 of the
preliminary TSD, American Panel
commented that the markup multiplier
values were too high and should
correspond to approximately 10–12
percent of the markup. (American Panel,
Public Meeting Transcript, No. 0045 at
p. 201) American Panel also questioned
DOE’s assumption that the markup
multipliers for unit coolers connected to
multiplex systems would be
substantially lower than the multipliers
for the dedicated condensing
equipment, when both types of
equipment move through the same
channel of distribution. (American
Panel, No. 0048.1 at p. 8) In response to
the first comment, DOE notes that the
markup multipliers obtained in the
revised analysis are consistent with the
markup multipliers derived for other
refrigeration products that often share
the same distribution channels with
walk-in coolers and freezers. Therefore,
DOE considers the markup multipliers
to be representative of the industry.
Regarding the second comment, DOE
notes that the overall markup
multipliers depend not only on the
channels through which the products
are sold, but also on the relative shares
of sales of the distribution channels.
Because unit coolers connected to
multiplex condensing systems are
predominantly used in food sales, and
a larger percentage of such equipment is
sold directly to contractors, the
equipment would be expected to have
lower weighted average markup
multipliers. The NOPR analysis uses
weighted average baseline markup
multipliers for multiplex and non-
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multiplex equipment of 1.43 and 1.51,
respectively.
One interested party commented on
DOE’s data sources. NEEA and NPCC
recommended that, in view of the
several comments DOE received on the
markup analysis and ongoing
restructuring and consolidation of the
food retailing industry, DOE should
obtain manufacturer assistance in recrafting the markup estimates for each
distribution channel. (NEEA and NPCC,
No. 0059.1 at p. 9) In the NOPR
analysis, DOE has revised many of its
estimates of the shares of individual
channels based on comments received
from interested parties. Given their
general reliability, in estimating the
markup multipliers in specific
distribution channels, DOE uses data
from trade associations and economic
census data from the U.S. Census
Bureau. The NOPR analysis relies on the
most recently available data to derive
the markup multipliers.
Table IV–12 shows the overall
weighted average baseline and
incremental markups for sales of
refrigeration systems and envelope
components. Chapter 6 and appendix
6A of the TSD provide complete details
of the methodology and data used in the
estimation of the markup multipliers.
TABLE IV–12—OVERALL MARKUP
MULTIPLIERS FOR ALL EQUIPMENT
CLASSES
Markup
multipliers
Equipment
class
Baseline
DC.M.I * .....
DC.L.I *
DC.M.O * ...
DC.L.O *
MC.M ........
MC.L
SP.M .........
SP.L
DD.M .........
DD.L
PD.M .........
PD.L
FD.M .........
FD.L
Incremental
1.51
1.19
1.51
1.19
1.43
1.25
1.16
1.09
1.41
1.29
1.16
1.09
1.16
1.09
* For DC refrigeration systems, markups
apply to both capacity ranges.
E. Energy Use Analysis
The energy use analysis estimates the
annual energy consumption of
refrigeration systems serving walk-ins
and the energy consumption that can be
directly ascribed to the selected
components of the WICF envelopes.
These estimates are used in the
subsequent LCC and PBP analyses
(chapter 8 of the TSD) and NIA (chapter
10 of the TSD).
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55823
In the preliminary analysis, DOE
estimated the annual energy
consumption for a complete theoretical
walk-in consisting of an envelope and a
matched refrigeration system, each at a
specific efficiency level, using a set of
assumptions for product loading, duty
cycle, and other associated conditions.
In the NOPR, DOE is proposing energy
consumption standards separately for
the refrigeration systems and a selected
set of envelope components: Panels,
non-display doors, and display doors.
Consequently, DOE revised the
methodology for estimating the annual
energy consumption to reflect the new
approach.
A key change from the preliminary
analysis methodology for estimating the
annual energy consumption is that in
the NOPR analysis, DOE is no longer
matching the refrigeration systems to
specific envelope sizes. The estimates
for the annual energy consumption of
each analyzed representative
refrigeration system (see section IV.C.2)
were reached by assuming that (1) the
refrigeration system is sized such that it
follows a specific daily duty cycle for a
given number of hours per day at full
rated capacity, and (2) the refrigeration
systems produce no additional
refrigeration effect for the remaining
period of the 24-hour cycle. These
assumptions are consistent with the
present industry practice for sizing
refrigeration systems. This methodology
assumes that the refrigeration system is
paired with an envelope that generates
a load profile such that the rated hourly
capacity of the paired refrigeration
system, operated for the given number
of run hours per day, produces adequate
refrigeration effect to meet the daily
refrigeration load of the envelope with
a safety margin to meet contingency
situations. Thus, the annual energy
consumption estimates for the
refrigeration system depends on the
methodology adopted for sizing, the
implied assumptions and the extent of
oversizing. The sizing methodology
adopted in this NOPR analysis is further
discussed later in this section.
For the envelopes, the estimates of
product and infiltration loads are no
longer used in estimating energy
consumption in the analysis because
these factors are not intended to be
mitigated by any of the component
standards. DOE calculated only the
transmission loads across the envelope
components under test procedure
conditions and combined that with the
annual energy efficiency ratio (AEER) to
arrive at the annual refrigeration energy
consumption associated with the
specific component. AEER is a ratio of
the net amount of heat removed from
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the envelope in Btu by the refrigeration
system and the annual energy consumed
in watt-hours using bin temperature
data specified in AHRI 1250–2009 to
calculate AWEF. The annual electricity
consumption attributable to any
envelope component is the sum of the
direct electrical energy consumed by
electrically-powered sub-components
(e.g., lights and anti-sweat heaters) and
the refrigeration energy, which is
computed by dividing the transmission
heat load traceable to the envelope
component by the AEER metric, where
the AEER metric represents the
efficiency of the refrigeration system
with which the envelope is paired.
In the preliminary analysis, DOE
estimated aggregate refrigeration loads
of three sizes of complete WICF
envelopes in each of the four envelope
classes (i.e., storage and display coolers
and freezers.) In the NOPR, given the
component-level approach, DOE
estimated the annual energy
consumption per unit of the specific
envelope components by calculating the
transmission load of the component
over 24 hours under the test procedure
conditions, and then calculating the
annual refrigeration energy
consumption attributed to that
component by applying an appropriate
AEER value.
1. Sizing Methodology for the
Refrigeration System
In the preliminary analysis, DOE
calculated the required size of the
refrigeration system for a given envelope
by assuming that the rated capacity of
the refrigeration system would be
adequate to meet the refrigeration load
of a walk-in cooler or freezer during the
high-load condition. The load profile of
WICF equipment that DOE used broadly
followed the load profile assumptions of
the industry test procedure for
refrigeration systems—AHRI 1250–2009,
Standard for Performance Rating of
Walk-In Coolers and Freezers (‘‘AHRI
1250–2009’’). As noted earlier, that
protocol was incorporated into DOE’s
test procedure. 76 FR 33631 (June 9,
2011).
As a result, the DOE test procedure
incorporates an assumption that, during
a 24-hour period, a WICF refrigeration
system experiences a high-load period
of 8 hours corresponding to frequent
door openings, product loading events,
and other design load factors, and a lowload period for the remaining 16 hours,
corresponding to a minimum load
resulting from conduction, internal heat
gains from non-refrigeration equipment,
and steady-state infiltration across the
envelope surfaces. During the high-load
period, the ratio of the envelope load to
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the net refrigeration system capacity is
70 percent for coolers and 80 percent for
freezers. During the low-load period, the
ratio of the envelope load to the net
refrigeration system capacity is 10
percent for coolers and 40 percent for
freezers. The relevant load equations
correspond to a duty cycle for
refrigeration systems, where the system
runs at full design point refrigeration
capacity for 7.2 hours per day for
coolers and 12.8 hours per day for
freezers. Specific equations to vary load
based on the outdoor ambient
temperature are also specified.
DOE received several comments on its
duty cycle assumptions in the
preliminary analysis. American Panel
pointed out that the average envelope
load hourly distributions for low and
high loads used by DOE in the
preliminary analysis represented a light
loading condition and should be
reversed, implying that a typical
refrigeration system would experience
16 hours of high load and 8 hours of low
load per day, rather than DOE’s
assumptions of 8 hours and 16 hours for
high and low load, respectively.
(American Panel, Public Meeting
Transcript, No. 0045 at p. 212) For the
restaurant market segment in particular,
American Panel noted that the high-load
and low-load periods would both
typically be 12 hours each. (American
Panel, No. 0048.1 at p. 8) American
Panel also commented that its own heat
load calculations use 18 hours of
maximum refrigeration system run time
for the freezers and noted that this is the
industry standard. (American Panel, No.
0048.1 at p. 3) Manitowoc and Heatcraft,
however, agreed with DOE’s
assumptions of the hourly load
distributions for the high-load and lowload periods, which are consistent with
AHRI 1250–2009. (Manitowoc, Public
Meeting Transcript, No. 0045 at p. 215;
Heatcraft, Public Meeting Transcript,
No. 0045 at p. 213) NEEA and NPCC
noted that the duty cycle assumptions
for the energy use analysis were credible
and did not recommend any changes to
this part of the analysis. (NEEA and
NPCC, No. 0059.1 at p. 10) AHRI also
commented that the assumptions made
by DOE to calculate the duty cycle are
acceptable for the analysis. (AHRI, No.
0055.1 at p. 3) Manitowoc noted that the
envelope load assumptions are not
supported with measurements from real
life walk-in monitoring but are based on
conservative sizing practices followed
by the industry to ensure that even in
worst-case situations, the walk-in will
maintain the necessary temperature.
(Manitowoc, No. 0056.1 at p. 3)
In light of the comments received
from American Panel on current
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industry sizing practices, and
Manitowoc’s comment that actual duty
cycles differ from the AHRI test
procedure conditions, DOE tentatively
concludes that the duty cycle
assumptions of AHRI 1250–2009 should
not be used for the sizing purposes
because they may not represent the
average conditions for WICF
refrigeration systems for all applications
under all conditions. DOE recognizes
that test conditions are often designed to
effectively compare the performance of
equipment with different features under
the same conditions.
For the energy use analysis, DOE
revisited the duty cycle issue and found
that the current industry practice for
sizing the refrigeration system is based
on providing a 10 percent safety margin
multiplier to the calculated aggregate
refrigeration load over a 24-hour daily
cycle and assuming a nominal run time
of 16 hours for coolers and 18 hours for
freezers for sizing the refrigeration
system. DOE’s key assumption in the
preliminary analysis of equating the
refrigeration capacity to the high-box
load is not practiced in the industry and
DOE has made no attempt to model the
peak load. The nominal run time varies
only in special situations—such as
when freezers use hot gas defrost or
when the temperature of the evaporator
coil is higher than 32 °F. Consequently,
DOE adopted the industry practice
described above for calculating the
energy use and load characterization.
In this NOPR, DOE proposes a
nominal run time of 16 hours per day
for coolers and 18 hours per day for
freezers to calculate the capacity of a
‘‘perfectly’’ sized refrigeration system. A
fixed oversize factor is then applied to
this size to calculate the actual runtime.
With the oversize factor applied, DOE
assumes that the runtime of the
refrigeration system is 13.3 hours per
day for coolers and 15 hours per day for
freezers at full design point capacity.
The reference outside ambient
temperatures for the design point
capacity conform to the AHRI 1250–
2009 conditions incorporated into the
DOE test procedure and are 95 °F and
90 °F for refrigeration systems with
outdoor and indoor condensers,
respectively.
DOE notes that the AHRI assumptions
for high-load and low-load conditions
were supported by some interested
parties and acknowledges that the
distribution of high-load and low-load
hour assumptions could be relevant to
the equipment energy consumption.
DOE has observed, however, that the
high-load situation is not taken into
account by the industry in its standard
sizing methods and would not represent
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current industry practices. Thus, for the
NOPR analysis, DOE has revised its
sizing methodology to be consistent
with its understanding of the current
industry practice. DOE requests
comment on the sizing methodology.
2. Oversize Factors
American Panel commented that
DOE’s preliminary analysis assumptions
regarding duty cycle and sizing
conflicted with the prevalent practice in
the industry, which resulted in
considerable oversizing of the
refrigeration systems when paired with
a given envelope. Oversizing leads to
higher first cost estimates for the
refrigeration equipment and distorts the
LCC and PBP results because the energy
savings are not commensurate with the
first costs. American Panel further
commented that because the
refrigeration systems examined as part
of the preliminary analysis are poorly
matched to the envelopes, no
meaningful conclusion can be drawn
from the accompanying LCC, PBP, and
NIA results. (American Panel, No.
0048.1 at p. 8 and p. 11) Regarding the
annual energy calculations presented in
chapter 7 of the TSD, American Panel
did not believe that DOE properly
matched the refrigeration systems and
envelopes—which yielded an estimated
8 hours or less of runtime per day. In
its view, this preliminary estimate is
incorrect. (American Panel, No. 0048.1
at p. 9) American Panel also submitted
additional documentation
demonstrating its own methodology for
matching the selected refrigeration
system capacity to the estimated heat
load of a walk-in expressed in Btu/h.
(American Panel, No. 0048.1 at p. 9)
DOE investigated further and found that
the load calculation manuals and sizing
software of several refrigeration system
manufacturers supported American
Panel’s recommendation on the
approach to sizing.
As stated previously, DOE observed
that the typical and widespread
industry practice for sizing the
refrigeration system is to calculate the
daily heat load on the basis of a 24-hour
cycle and divide by 16 hours of runtime
for coolers and 18 hours of runtime for
freezers. DOE also found that it is
customary in the industry to allow for
a 10 percent safety margin to the
aggregate 24-hour load resulting in 10
percent oversizing of the refrigeration
system.
In the preliminary analysis, DOE
considered a scaled mismatch factor in
addition to the oversizing related to its
duty cycle assumptions. DOE
recognized that an exact match for the
calculated refrigeration capacity may
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not be available for the refrigeration
systems available in the market because
most refrigeration systems are massproduced in discrete capacities. The
capacity of the best matched
refrigeration system is likely to be the
nearest higher capacity refrigeration
system available. This consideration led
DOE to develop a scaled mismatch
factor that could be as high as 33
percent for the smaller refrigeration
system sizes, and was scaled down for
the larger sized units. In the preliminary
analysis, DOE applied this mismatch
oversizing factor to the required
refrigeration capacity at the high-load
condition to determine the required
capacity of the refrigeration system to be
paired with a given envelope.
DOE received multiple comments
regarding the mismatch factor.
Manitowoc pointed out that the
mismatch factors used by DOE in the
preliminary analysis are high. DOE
assumed that compressors are available
only in capacity increments of 6000
Btu/h but Manitowoc noted that
compressors are available at capacity
increments of 2000 Btu/h and 1500 Btu/
h for medium- and low-temperature
systems, respectively. (Manitowoc, No.
0056.1 at p. 3; Manitowoc, Public
Meeting Transcript, No. 0045 at p. 220
and p. 222) American Panel pointed out
that the maximum mismatch factor
could be 15 percent. (American Panel,
Public Meeting Transcript, No. 0045 at
p. 220) Heatcraft stated that DOE’s
assumption that the sizes of
refrigeration systems available in the
market are at 0.5-ton intervals is not
applicable for larger sized systems. For
sizes from 5–10 horsepower, the
compressors are available in 2.5horsepower intervals, and for sizes from
10–30 horsepower, compressors are
available in 5-horsepower intervals.
(Heatcraft, No. 0069.1 at p. 2)
Based on these comments, DOE
recalculated the mismatch factor
because compressors for the lower
capacity units are available at smaller
size increments than what DOE
assumed in the preliminary analysis.
DOE also agrees with Manitowoc that
for larger sizes, the size increments of
available capacities are higher than size
increments available for the lower
capacities. DOE further noted as part of
the revised analysis that under current
industry practice, if the exact calculated
size of the refrigeration system with a 10
percent safety margin is not available in
the market, the user may choose the
closest matching size even if it has a
lower capacity, allowing the daily
runtimes to be somewhat higher than
their intended values. The designer
would recalculate the revised runtime
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with the available lower capacity and
compare it with the target runtime of 16
hours for coolers and 18 hours for
freezers and, if this value falls within
acceptable limits, then the chosen size
of the refrigeration system is accepted
and there is no mismatch oversizing.
DOE further examined the data of
available capacities in published
catalogs of several manufacturers and
noted that the range of available
capacities depends on compressor type
and manufacturer. Furthermore, because
smaller capacity increments are
available for units in the lower capacity
range and larger capacity increments are
available for units in the higher capacity
range, the mismatch factor is generally
uniform over the range of equipment
sizes. For the NOPR, DOE tentatively
concluded from these data that a scaled
mismatch factor linked to the target
capacity of the unit may not be
applicable, but that the basic need to
account for discrete capacities available
in the market is still valid. To this end,
DOE is now applying a uniform average
mismatch factor of 10 percent over the
entire capacity range of refrigeration
systems.
3. Product Load
The NOPR analysis does not include
an explicitly modeled product load to
determine the annual energy
consumption. Instead, the annual
energy consumption estimates for the
refrigeration systems are based on
industry practice duty cycle
assumptions. This approach does not
require any explicit modeling of the
product load. However, for the
shipment analysis of refrigeration
systems, DOE expressed annual
shipments and stocks in terms of
installed refrigeration capacity (Btu/h).
The shipments of the refrigeration
system were linked to the shipments of
envelopes, which required DOE to
estimate the required refrigeration
capacity for the units shipped. DOE
included several assumptions about
product loads in these calculations.
These assumptions are discussed in the
relevant section on shipment (Section
IV.G of this NOPR).
4. Other Issues
DOE received one comment on the
issue of the interaction of building airconditioning systems with WICF
systems installed within them. Ingersoll
Rand stated that envelope
improvements may not lead to
significant energy savings because the
load on the refrigeration systems of the
WICF unit would be replaced by the
load on the building air-conditioning
system. DOE did not account for the
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difference in overall energy use that
could be directly attributed to the
improvement of envelope components
on the whole building cooling load and,
correspondingly, any space-cooling
energy impacts. At the same time, any
envelope component improvements
may also result in a decrease in the use
of heating energy within the buildings.
This impact on building heating and
cooling loads would only occur for
WICF units located indoors. The relative
cooling-energy-use penalty to heatingenergy-use benefit is a function of the
climate of the region in which the
building is located, the building type
and size, and the placement of the WICF
units within the building. The relative
monetary benefits are also a function of
the relative heating and cooling fuel
costs. The quantification of the relative
benefits impact would have required an
extensive analysis of building climatecontrol performance, which is both
unnecessary and outside the scope
framed by Congress.
For the refrigeration systems, DOE
calculated the annual energy
consumption for all six classes of
refrigeration systems at various capacity
points with all available compressor
options and at all efficiency levels for
which results of engineering analysis
were available. The annual energy
consumption results were used as
inputs to the LCC and PBP analyses.
Based on the results of the LCC analysis,
DOE selected the most cost-efficient
combination of compressors and other
components at a given AWEF level for
a specific capacity point. Fourteen
efficiency options were selected from
the entire range of available AWEF
values for each capacity point analyzed.
To simplify further analysis, however,
DOE chose two points from a set of four
or five capacity points in each of the
four dedicated condensing equipment
classes, and one for each of the two
multiplex condensing equipment
classes. DOE used the shipment data to
derive a shipment weighted AEER value
for each TSL option for the refrigeration
system. For the envelope components,
DOE estimated the associated
refrigeration energy at each of the TSL
options and each level of efficiency of
the components. The units of analysis
were the unit area for the panels and
each whole door for the doors. DOE
added the direct electrical energy
consumed for each of the doors at
different efficiency levels to the
refrigeration energy to arrive at the total
annual energy consumption. The annual
energy consumption results for the
components were used as inputs to the
LCC and PBP analyses for the
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components. Chapter 7 of the TSD
shows the annual average energy
consumption estimates by equipment
class and efficiency level for both the
refrigeration system and the
components.
F. Life-Cycle Cost and Payback Period
Analyses
DOE conducts LCC and PBP analyses
to evaluate the economic impacts of
potential energy conservation standards
for walk-ins on individual consumers—
that is, buyers of the equipment. As
stated previously, DOE adopted a
component-based approach for
developing performance standards for
walk-in coolers and freezers.
Consequently, the LCC and PBP
analyses were conducted separately for
the refrigeration system and the
envelope components: panels, nondisplay doors, and display doors.
The LCC is defined as the total
consumer expense over the life of a
product, consisting of purchase,
installation, and operating costs
(expenses for energy use, maintenance,
and repair). To calculate the operating
costs, DOE discounts future operating
costs to the time of purchase and sums
them over the lifetime of the product.
The PBP is defined as the estimated
number of years it takes consumers to
recover the increased purchase cost
(including installation) of a more
efficient product. The increased
purchase cost is derived from the higher
first cost of complying with the higher
energy conservation standard. DOE
calculates the PBP by dividing the
increase in purchase cost (normally
higher) by the change in the average
annual operating cost (normally lower)
that results from the standard.
NEEA and NPCC suggested that, when
estimating equipment lifetimes, DOE
should consider both the economic and
physical lifetimes of WICF equipment.
(NEEA and NPCC, No. 0559.1 at p. 11)
The physical lifetime refers to the
duration before the equipment fails or is
replaced, whereas the economic lifetime
refers to the duration before the walk-in
cooler and freezer equipment is taken
out of service because the owner is no
longer in business. In its energy
conservation standards rulemakings,
DOE does not typically consider the
change of ownership of a distressed
property due to business failure or
insolvency of the first owner. The
underlying assumption in this approach
is that the higher efficiency equipment
would continue to serve over its
physical lifetime irrespective of
ownership changes. Interested parties
commented, however, that, in the case
of walk-ins, the economic lifetime could
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be significantly lower. Owners at high
risk of business failure or insolvency
would be less likely to buy higher
efficiency equipment because they
likely would not see the long-term life
cycle benefits of energy savings.
In response to these comments, DOE
attempted to include alternative Weibull
probability distributions in the NOPR
analysis to capture the effects of a
reduced economic lifetime of WICF
equipment for small restaurants, but due
to the increased complexity resulting
from the component-level approach and
lack of data on reduced lifetimes on
account of change of ownership of walkin equipment, DOE did not incorporate
a shorter restaurant sector economic
lifetime in the NOPR life cycle cost
model. In many, if not most, cases when
there is a change in ownership,
equipment is not disassembled, but is
sold ‘‘as is.’’
For any given efficiency level, DOE
measures the PBP and the change in
LCC relative to the base-case equipment
efficiency levels. The base-case estimate
reflects the market without new or
amended energy conservation
standards. For walk-ins, the base-case
estimate assumes that newly
manufactured walk-in equipment
complies with the existing EPCA
requirements and either equals or
exceeds the efficiency levels achievable
by EPCA-compliant equipment. Inputs
to the economic analyses include the
total installed operating, maintenance,
and repair costs.
Inputs to the calculation of total
installed cost include the cost of the
product—which consists of
manufacturer costs, manufacturer
markups, distribution channel markups,
and sales taxes—and installation costs.
Inputs to the calculation of operating
expenses include annual energy
consumption, energy prices and price
projections, repair and maintenance
costs, product lifetimes, discount rates,
and the year that compliance with
standards is required. DOE created
probability distributions for product
lifetime inputs to account for their
uncertainty and variability.
DOE developed refrigeration and
envelope component spreadsheet
models used for calculating the LCC and
PBP. Chapter 8 of the TSD and its
appendices provide details on the
refrigeration and envelope
subcomponent spreadsheet models and
on all the inputs to the LCC and PBP
analyses.
Table IV–13 summarizes DOE’s
approach and data used to derive inputs
to the LCC and PBP calculations for
both the preliminary TSD and the
changes made for today’s NOPR. The
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subsections that follow discuss the
initial inputs and methods and the
changes DOE made for the NOPR.
For refrigeration systems, DOE
analyzed all possible compressor
technology options available for a given
capacity of the refrigeration system.
From the results of the individual
compressor technology LCC analysis,
DOE developed LCC savings plots in
which the LCC savings over the LCC
cost at the lowest total installed price
option was plotted against the
refrigeration system efficiency metric
(AWEF). The LCC savings plots for the
individual compressor technologies
were superimposed into a single plot. A
full range of optimal technology options
were obtained by choosing the
compressor technology available from
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the suite of available technologies that
can reach a given efficiency level with
the highest calculated LCC savings. The
series of technology choices over the
entire range of AWEF values from
baseline to the highest achievable
efficiency level obtained in this manner
comprise the optimal path in
developing higher efficiency equipment.
TABLE IV–13—SUMMARY OF INPUTS AND METHODS IN THE LCC AND PBP ANALYSIS *
Inputs
Preliminary analysis
Changes for the NOPR
Installed Costs
Equipment Cost ...........
Installation Costs ..........
Derived by multiplying manufacturer cost by
manufacturer and retailer markups and
sales tax, as appropriate.
Based on RS Means Mechanical Cost Data
2009. Assumed no change with efficiency
level.
Included factor for estimating price trends due to manufacturer experience.
Based on RS Means Mechanical Cost Data 2012. Assumed no
change with efficiency level.
Operating Costs
Annual Energy Use ......
Energy Prices ...............
Energy Price Trends ....
Repair and Maintenance Costs.
DOE calculated the average annual energy
use for each WICF envelope class matched
with outdoor condenser systems using a
load profile described in AHRI 1250–2009
(8 hours of high load and 16 hours of low
load per day).
EIA (Energy Information Administration). Form
EIA–861 for 2006.
Forecasted using AEO2009 price forecasts ....
Annualized repair and maintenance costs of
the combined system were derived from RS
Means 2009 walk-in cooler and freezer
maintenance data. Doors and refrigeration
systems were replaced during the lifetime.
Daily load profile of the refrigeration system revised to 13.3 hours
runtime per day for coolers and 15 hours for freezers, at full rated
capacity and at outside air temperatures corresponding to the reference rating temperatures.
Source for Commercial and Industrial Retail Prices of Electricity:
Form EIA–826 Database Monthly Electric Utility Sales and Revenue Data (EIA–826 Sales and Revenue Spreadsheets).
www.eia.doe.gov/cneaf/electricity/page/eia826.html. Accessed September 30, 2012.
Forecasts updated using AEO2013.
Revised to RS Means 2012 walk-in cooler and freezer maintenance
data and maintenance data; maintenance and repair costs for the
refrigeration system and the envelope components were individually estimated.
Present Value of Operating Cost Savings
Equipment Lifetime ......
Discount Rates .............
Compliance Date .........
Based on manufacturer interviews. Variability:
characterized using Weibull probability distributions.
Based on the 2009 commercial refrigeration
equipment final rule (72 FR 1092); vary
across commercial building types.
2015 ..................................................................
Revised to reflect stakeholder comments.
Based on Damodaran Online, October 2012.
2017.
* References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the TSD.
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1. Equipment Cost
To calculate consumer equipment
costs, DOE multiplied the MSPs from
the engineering analysis by the supplychain markups described above (along
with sales taxes). DOE used different
markups for baseline products and
higher efficiency products because, as
discussed previously, DOE applies an
incremental markup to the MSP
increase associated with higherefficiency products.
On February 22, 2011, DOE published
a notice of data availability (NODA, 76
FR 9696) stating that DOE may consider
improving its regulatory analysis by
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addressing equipment price trends.
Consistent with the NODA, DOE
examined historical producer price
indices (PPI) for refrigeration equipment
in general and found both positive and
negative short-term real price trends.
Over the historical long term DOE found
slightly negative time real price trends.
Therefore, DOE assumes in its price
forecasts for this NOPR that the real
prices of refrigeration equipment
decrease slightly over time. DOE
performed a sensitivity analysis of the
NPV results for refrigeration equipment
to the observed range of uncertainty in
this long term price trend. DOE
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projected the price of the panels and
doors using constant real 2012$ prices
(See chapter 8 and chapter 10 of the
TSD). DOE is aware that there have been
significant changes in both the
regulatory environment and equipment
technologies during this period that
create analytical challenges for
estimating longer-term product price
trends from the product-specific PPI
data. DOE performed price trend
sensitivity calculations to examine the
dependence of the analysis results on
different analytical assumptions. A
more detailed discussion of price trend
modeling and calculations is provided
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in Appendix 8D of the TSD. DOE invites
comment on methods to improve its
equipment price forecasting, as well as
any data supporting alternate methods.
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2. Installation Cost
Installation cost includes labor,
overhead, and any miscellaneous
materials and parts needed to install the
equipment. For the preliminary
analysis, DOE derived baseline
installation costs for walk-in coolers and
freezers from data in RS Means
Mechanical Cost Data 2009.
DOE estimated installation costs
separately for panels, non-display doors,
and display doors. Installation costs for
panels were calculated per square foot
of area while installation costs for nondisplay doors were calculated per door.
Display door installation costs were
omitted and assumed to be included in
the panel installation costs for display
walk-ins. DOE assumed that display
doors are either installed by the
assembler or manufacturer of the walkin unit, and the installation costs for the
display doors are included in the
‘‘mark-up’’ amounts for the OEM
channel.
For the NOPR analysis, DOE included
refrigeration system component
installation costs based on RS Means
Mechanical Cost Data 2012.
Refrigeration system installation costs
included separate installation costs for
the condensing unit and unit cooler.
American Panel commented that these
units are installed simultaneously by
the same installation crew and quoted
as a combined price. (American Panel,
Public Meeting Transcript, No. 0045 at
p. 246 and No. 0048.1 at p. 9) RS Means
2012 provides these installation costs
separately, although the installation
activities may be performed by the same
crew. DOE proposes to be consistent
with the approach of the cost data
source because this approach permits
one to estimate the installation costs of
many combinations of unit coolers and
condensing units.
In the preliminary analysis, DOE did
not distinguish between installation
costs for indoor and outdoor systems.
Manitowoc stated that indoor and
outdoor systems would likely incur
different installation costs. (Manitowoc,
Public Meeting Transcript, No. 0045 at
p. 245) Installation cost differences
between indoor and outdoor condensing
units were not reported in the RS Means
data because the costs shown are based
only on unit capacity. DOE assumed
that the installation costs reported in the
RS Means data are based on a weighted
average of outdoor and indoor units—
accordingly, DOE used identical
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installation costs for indoor and outdoor
condensing units.
3. Annual Energy Consumption
To estimate the annual energy
consumption, DOE assumed that the
installed refrigeration capacity is 20
percent larger than the refrigeration load
calculated in the sizing methodology.
The prevailing industry practice is to
recommend that the rated capacity for
refrigeration equipment selection
includes a 10 percent ‘‘safety factor’’.
DOE chose to use a somewhat higher
oversizing factor to account for the
differences between the sizes calculated,
using load estimation software
programs, and the discrete sizes
available in the market (that is, the
mismatch factor). To determine annual
energy consumption, DOE calculated,
using the industry practice described
above, that a refrigeration system with
the selected oversizing factor would be
required to run 13.3 hours per day for
coolers and 15 hours per day for freezers
at full rated capacity at the reference
outside air temperatures to meet the
aggregate refrigeration load of the paired
walk-in envelope. These time periods
were determined from DOE’s sizing
methodology, as discussed in section
IV.E.1. DOE used reference temperatures
of 90 °F and 95 °F for indoor and
outdoor condensing refrigeration
systems, respectively, which is
consistent with the standard rating
conditions incorporated by DOE from
AHRI 1250–2009.
through 2040.17 AHRI supported DOE’s
approach for estimating current and
future energy prices. (AHRI, No. 0055.1
at p. 3) DOE did not change its general
approach, but today’s NOPR analysis
updates the initial energy price forecasts
using AEO2013, which has an end year
of 2035.18 To estimate the price trends
after 2035, DOE used the average annual
rate of change in prices from 2026 to
2035.
4. Energy Prices
DOE calculated average commercial
electricity prices using Form EIA–826
Database Monthly Electric Utility Sales
and Revenue Data (EIA–826 Sales and
Revenue Spreadsheets)
(www.eia.doe.gov/cneaf/electricity/
page/eia826.html; accessed September
30, 2012). DOE calculated an average
national commercial price by (1)
estimating an average commercial price
for each utility by dividing the
commercial revenues by commercial
sales; and (2) weighting each utility by
the number of commercial consumers it
served in that state, across the nation.
For the preliminary TSD, DOE used the
electricity price data from 2009. DOE
updated the NOPR analysis using 2012
data.
6. Maintenance and Repair Costs
DOE calculated both maintenance and
repair costs for the analysis.
Maintenance costs are associated with
maintaining the equipment operation,
whereas repair costs are associated with
repairing or replacing components that
have failed in the refrigeration system
and the envelope (i.e. panels and doors).
In the preliminary analysis, DOE
considered only general maintenance
costs (e.g., checking and maintaining
refrigerant charge levels, checking
settings, and cleaning heat exchanger
coils) and lighting maintenance
activities. The NOPR analysis applies
the same lighting maintenance
assumptions for display doors with
lights as DOE previously applied during
the preliminary analysis phases. The
remaining data on general maintenance
for an entire walk-in were apportioned
between the refrigeration system and the
envelope doors. Based on the
descriptions of maintenance activities in
the RS Means 2012 Facilities
Maintenance and Repair Cost Data
(available on CD–ROM) and
manufacturer interviews, DOE assumed
that the general maintenance associated
with the panels is minimal and did not
include any maintenance costs for
panels in its analysis. RS Means 2012
data provided general maintenance
costs for display and storage walk-ins.
In response to this approach,
American Panel suggested that DOE
contact the Commercial Food
Equipment Service Association (CFESA)
to obtain additional maintenance and
repair information. (American Panel,
No. 0048.1 at p. 8) At American Panel’s
recommendation, DOE contacted
CFESA, who explained that they did not
have the information requested.
Of the total annual maintenance costs
for a walk-in unit, which ranges from
$170–$262, DOE assumed $150 would
5. Energy Price Projections
To estimate energy prices in future
years for the preliminary TSD, DOE
multiplied the average state energy
prices described above by the forecast of
annual average commercial energy price
indices developed in the Reference Case
from AEO2013, which forecasted prices
17 The spreadsheet tool that DOE used to conduct
the LCC and PBP analyses allows user0s to select
price forecasts from either AEO’s High Economic
Growth or Low Economic Growth Cases. Users can
thereby estimate the sensitivity of the LCC and PBP
results to different energy price forecasts.
18 U.S. Energy Information Administration.
Annual Energy Outlook 2013. May 2013. U.S.
Energy Information Administration: Washington,
DC.
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be spent on the refrigeration system and
the rest would be spent on the display
and passage doors of the envelope. DOE
made this assumption as part of its
preliminary analyses based on
comments and research that pointed to
this value as the likely amount that
would need to be expended to cover
refrigeration system-related costs.
Maintenance costs were assumed to be
the same across small, medium, and
large door sizes in the case of both nondisplay doors and display doors. (DOE
derived the envelope-related costs as the
difference between the total
maintenance costs for a walk-in and the
assumed maintenance costs for the
refrigeration system.) As stated
previously, annual maintenance costs
for the envelope wall and floor panels
were assumed to be negligible and were
not considered.
Interested parties commented on
maintenance costs associated with
refrigerant leakage and refrigerant
charge. Emerson stated that DOE’s
estimated maintenance costs should
account for higher refrigerant costs due
to higher leakage rates and other issues
in systems with higher refrigerant
charge. (Emerson, Public Meeting
Transcript, No. 0045 at p. 238) However,
Emerson also commented that higher
refrigerant costs could lead to the use of
refrigerant leakage-reduction devices
that offset the increased repair costs due
to higher refrigerant charge and loss.
(Emerson, Public Meeting Transcript,
No. 0045 at p. 239) DOE did not receive
any data for refrigeration maintenance
costs, but based on the comments from
Emerson, DOE assumes as part of the
NOPR analysis that the $150
maintenance cost for a refrigeration
system would include expenses related
to refrigerant charge maintenance costs.
DOE seeks data from interested parties
on refrigerant charge maintenance costs
applicable to walk-ins.
Other interested parties commented
on potential climate change legislation.
AHRI suggested that DOE study the
impact of climate change legislation on
the future availability and price of HFC
refrigerants. (AHRI, No. 0055.1 at p. 3)
Emerson also said that any future capand-trade bill would increase refrigerant
costs significantly. (Emerson, Public
Meeting Transcript, No. 0045 at p. 238)
NEEA and NPCC suggested that
refrigerant leakage and climate change
responses should be evaluated in a
manner that seeks to reduce refrigerant
leakage rather than focusing solely on
managing refrigerant replacement costs,
particularly since maintenance costs are
rising. (NEEA and NPCC, No. 0059.1 at
p. 10) DOE acknowledges the concerns
of interested parties regarding the effect
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of climate change legislation on
refrigerant leakage and refrigerant costs.
DOE does not speculate on pending
legislation, which is outside the scope
of this rulemaking.
DOE also updated its methodology for
determining repair costs for the NOPR
in response to earlier comments. In the
preliminary analysis, DOE assumed that
both the unit cooler and the condensing
unit of the refrigeration system are
replaced when the refrigeration system
fails. Master-Bilt commented that
repairing a failed refrigeration system
typically would require replacement of
the compressors, not the entire system,
and that approximately five percent of
refrigeration systems would require a
compressor replacement during a 10year span. (Master-Bilt, Public Meeting
Transcript, No. 0045 at p. 287)
American Panel agreed and noted that,
when a refrigeration system fails the
entire refrigeration system is not
typically replaced; rather, only
compressors or fan motors are replaced.
(American Panel, Public Meeting
Transcript, No. 0045 at p. 11) After
carefully considering these comments,
DOE assumed for the NOPR analysis
that 5 percent of systems require
compressor replacement and 10 and 15
percent of systems require fan motor
replacement for evaporators and
condensers, respectively, over the
lifetime of the system. Aftermarket
prices for fan motors and compressors
were obtained from data collected
during the engineering analysis and
multiplied by a trade channel markup.
DOE estimated installation costs using
the RS Means Mechanical Cost Data
2012 and calculated the total repair cost
per occasion of replacement. DOE then
calculated the annualized repair costs
by multiplying the discounted total
replacement cost per occasion by the
replacement lifetime percentage.
Under this approach, the NOPR
analysis factored repair costs for lighting
repairs pertaining to the lighting of the
display doors. Data from the RS Means
Electrical Cost Data 2012 were used to
obtain the labor installation cost for
lighting replacements. For refrigeration
systems, DOE observed that estimated
repair costs often increased with
increasing efficiency levels, particularly
for higher-efficiency compressors and
fan motors.
In the preliminary analysis, DOE
assumed that annualized maintenance
and repair costs were constant across all
efficiency levels. Manitowoc and
Master-Bilt stated that maintenance and
repair cost increases across efficiency
levels should not be negligible because
more efficient equipment is more
complex and may have design options
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55829
that lead to the incorporation of
additional or more expensive parts,
which would cost more to maintain and
replace. (Manitowoc, Public Meeting
Transcript, No. 0045 at p. 241; MasterBilt, No. 0046.1 at p. 1) Heatcraft agreed
that maintenance and repair costs may
increase with higher efficiency levels,
stating that more efficient equipment
would incur higher maintenance and
repair costs because higher efficiency
evaporator and condenser coils are
larger and heavier, making them more
difficult and costly to maintain.
(Heatcraft, No. 0069.1 at p. 1) AHRI
stated that larger evaporator and
condenser coils require more refrigerant
and concluded that the maintenance
and cost repair differences across
efficiency levels are evident. (AHRI, No.
0055.1 at p. 3 and 4) NEEA and NPCC
stated, however, that there are no data
available to support the contention that
the complexity of electronics systems
used in the controls of higher efficiency
equipment leads to higher maintenance
costs. (NEEA and NPCC, No. 0059.1 at
p. 10)
In the NOPR analysis, DOE
considered these comments and
examined whether each design option
would have higher maintenance and
repair costs associated with it. As stated
earlier, DOE agreed with comments
made by Master-Bilt and American
Panel on repair costs and found that
certain design options that entail
substitution of either evaporator and
condenser fan motors or higher
efficiency compressors would likely
incur higher maintenance and repair
costs because of the higher cost of these
components. The NOPR analysis
accounts for these observations. In
summary, DOE believes that repair costs
will increase with efficiency level
whereas all non-lighting maintenance
costs will not increase with efficiency
level.
7. Product Lifetime
In the preliminary analysis, DOE
estimated an average product lifetime of
15 years for envelopes and 7 years for
refrigeration systems. The NOPR
analysis alters this approach by
estimating lifetimes for the individual
components analyzed, instead of the
entire envelope. DOE estimated an
average lifetime of 15 years for panels
and 14 years for display and nondisplay doors. DOE also revised the
average refrigeration system lifetime to
12 years. Weibull distributions were
derived around average lifetime
estimates to obtain specific failure rates
at each year of equipment life. See
chapter 8 of the NOPR TSD for further
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details on the method and sources DOE
used to develop product lifetimes.
8. Discount Rates
In calculating LCC, DOE applies
discount rates to estimate the present
value of future operating costs. DOE did
not have sufficient information in
preparing its preliminary analysis to
derive discount rates for walk-ins.
Instead, DOE used discount rates from
the 2009 commercial refrigeration
equipment final rule as a surrogate to
approximate the rates that would apply
to walk-ins. 72 FR at 1123 (January 9,
2009). For the NOPR, DOE derived the
discount rates for the walk-in cooler and
freezer equipment analysis by
estimating the cost of capital for a large
number of companies similar to those
that could purchase walk-in cooler and
freezer equipment and then sampling
them to characterize the effect of a
distribution of potential customer
discount rates. The cost of capital is
commonly used to estimate the present
value of cash flows to be derived from
a typical company project or
investment. Most companies use both
debt and equity capital to fund
investments, so their cost of capital is
the weighted average of the cost to the
company of equity and debt financing.
Average discount rates (real) in these
updated analyses by service building
type are as follows:
• Grocery: 3.7 percent
• Food service: 3.9 percent
• Convenience Store: 5.0 percent
• Restaurant: 6.2 percent
• Other Food Service: 3.8 percent
DOE estimated the cost of equity
financing by using the Capital Asset
Pricing Model (CAPM).19 The CAPM,
among the most widely used models to
estimate the cost of equity financing,
assumes that the cost of equity is
proportional to the amount of
systematic risk associated with a
company. The cost of equity financing
tends to be high when a company faces
a large degree of systematic risk, and it
tends to be low when the company faces
a small degree of systematic risk.
See chapter 8 of the TSD for further
details on the development of
commercial discount rates.
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9. Compliance Date of Standards
EPCA prescribes that DOE establish
performance-based standards for walkins by 2012. (42 U.S.C. 6313(f)(4)(A))
The standards apply to equipment
manufactured beginning on the date 3
years after the final rule is published
19 Harris, R.S. Applying the Capital Asset Pricing
Model. UVA–F–1456. Available at SSRN: https://
ssrn.com/abstract=909893.
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unless DOE determines, by rule, that a
3-year period is inadequate, in which
case DOE may extend the compliance
date for that standard by an additional
2 years. (42 U.S.C. 6314(f)(4)(B)) In the
absence of any information indicating
that 3 years is inadequate, DOE
proposes a compliance date for the
standards of 2017. Therefore, DOE
calculated the LCC and PBP for walk-in
coolers and freezers under the
assumption that compliant equipment
would be purchased in the year when
compliance with the new standard is
required—2017. DOE seeks comments
and information on the adequacy of the
3-year compliance date.
10. Base-Case and Standards-Case
Efficiency Distributions
To accurately estimate the share of
consumers who would likely be
impacted by a standard at a particular
efficiency level, DOE’s LCC analysis
considers the projected distribution of
product efficiencies that consumers
purchase under the base case (i.e., the
case without new energy efficiency
standards). DOE refers to this
distribution of product efficiencies as a
base-case efficiency distribution. DOE
examined the range of standard and
optional equipment features offered by
manufacturers. For refrigeration
systems, DOE estimated that 75 percent
of the equipment sold under the base
case would be at DOE’s assumed
baseline level—that is, the equipment
would comply with the existing
standards in EPCA, but have no
additional features that improve
efficiency. The remaining 25 percent of
equipment would have features that
would increase its efficiency. While
manufacturers could have many
options, DOE assumed that the average
efficiency level of this equipment would
correspond to the efficiency level
achieved by the baseline equipment
with the first design option in the
sequence of design options in the
engineering analysis ordered by their
relative cost-effectiveness. DOE
estimated that for panels and nondisplay doors, 100 percent of the
equipment sold under the base case
would consist of equipment at DOE’s
assumed baseline level—that is,
minimally compliant with EPCA. For
cooler display doors, DOE assumed that
25 percent of the current shipments are
minimally compliant with EISA and the
remaining 75 percent are higherefficiency (45 percent are assumed to
have LED lighting, corresponding to the
first efficiency level above the baseline
in the engineering analysis, and 30
percent are assumed to have LED
lighting plus anti-sweat heater wire
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controls, corresponding to the second
efficiency level above the baseline). For
freezer display doors, DOE assumed that
80 percent of the shipments would be
minimally compliant with EPCA and
the remaining 20 percent have LED
lighting, corresponding to the first
efficiency level above the baseline. (See
Section IV.C and chapter 5 of the TSD
for a discussion of the efficiency levels
and design options in the engineering
analysis). The current analysis assumes
that all consumers purchase only the
minimally compliant equipment from
2017 on, when the walk-in cooler and
freezer standard is in effect. DOE
requests comment on the distribution of
product efficiencies in the absence of
standards, particularly with respect to
the magnitude of market penetration of
any specific higher-efficiency
technologies. For further information on
DOE’s estimate of base-case efficiency
distributions, see chapter 8 of the TSD.
11. Inputs to Payback Period Analysis
The payback period is the number of
years that it takes the consumer to
recover the additional installed cost of
more efficient products, compared to
baseline products, through energy cost
savings. The simple payback period
does not account for changes in
operating expense over time or the time
value of money. Payback periods that
exceed the life of the product mean that
the increased total installed cost is not
recovered in reduced operating
expenses (based on the first year’s
estimated operating cost).
The inputs to the PBP calculation are
the total installed costs to the consumer
of the equipment for each efficiency
level and the average annual operating
expenditures for each efficiency level in
the first year. The PBP calculation uses
the same inputs as the LCC analysis,
except that discount rates are not used.
Interested parties raised several
concerns regarding the LCC and PBP
analyses. American Panel commented
that the LCC and PBP presented in the
preliminary analysis may be inaccurate
because the refrigeration systems were
not properly matched to the walk-in
envelope, and the refrigeration system
would be oversized for food safety and
have a shorter run time. American Panel
recommended that DOE select the
refrigeration system capacity based on
the heat load of the envelope size to
achieve realistic LCC and PBP results.
(American Panel, No. 0048.1 at p. 8) To
account for this possibility, the current
analysis now assumes that the
refrigeration system is oversized by 20
percent over the aggregate refrigeration
load of the walk-in unit.
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American Panel submitted several
comments relating to PBP issues for
specific market segments. During the
public meeting, American Panel
commented that small business owners,
such as non-chain restaurants or
independent food service operators,
generally attempt to avoid higher first
costs due to the uncertainty of business
success, while food service franchisees
can afford to consider a longer term
view of future savings. (American Panel,
Public Meeting Transcript, No. 0045 at
p. 252) American Panel cited data from
the National Restaurant Association
indicating that approximately 70
percent of all restaurants and 90 percent
of small restaurants that open in the
same building as a previously failed
business fail in the first year due to
insufficient up-front capital. American
Panel predicted from these data that
increased equipment costs resulting
from new energy standards would have
a serious negative impact on the small
business restaurant owner, especially
during the first year of restaurant
operation, and that these entities would
be able to sustain equipment efficiency
improvements with a payback period of
only 1 year or less. (American Panel,
No. 0048.1 at p. 10) Owners and
operators of franchised restaurant
chains could afford to consider a longer
payback period (e.g., 2 years or more).
(American Panel, Public Meeting
Transcript, No. 0045 at p. 254)
DOE will continue to use the standard
LCC and PBP methods to convey the
economic impacts of energy efficiency
standards on walk-ins. DOE recognizes
the particular PBP considerations of
various market segments, however,
including small businesses and
independent restaurants. In preparing
this NOPR, DOE examined the
‘‘business lifetime’’ (also referred to as
the ‘‘economic lifetime’’), which is an
issue prevalent in the restaurant market
sector. According to submitted
comments, the economic lifetime of
WICF equipment used in certain
businesses may significantly differ from
the operational lifetime. This issue
could potentially impact the LCC and
NIA analyses and is further discussed in
section IV.G.1.b of this document. The
walk-in lifetime details are also
discussed in chapter 8 of the TSD.
12. Rebuttable-Presumption Payback
Period
As noted above, EPCA, as amended,
establishes a rebuttable presumption
that a standard is economically justified
if the Secretary finds that the additional
cost to the consumer of purchasing a
product that complies with an energy
conservation standard level will be less
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than three times the value of the
consumer’s first-year energy (and, as
applicable, water) savings derived as a
result of the standard, as calculated
under the test procedure in place for
that standard. (42 U.S.C.
6295(o)(2)(B)(iii)) For each considered
efficiency level, DOE determined the
value of the first year’s energy savings
by calculating the quantity of those
savings in accordance with the
applicable DOE test procedure, and
multiplying that amount by the average
energy price forecast for the year in
which compliance with the new
standard would be required.
American Panel commented that the
3-year PBP established in EPCA should
be decreased to 1 or 1.5 years at the
most. (American Panel, No. 0048.1 at p.
11) DOE acknowledges the economic
impacts on small businesses resulting
from implementing energy efficiency
standards but has maintained the 3-year
PBP guideline as an initial step for
determining economic justification,
consistent with 42 U.S.C. 6295(o).
However, DOE routinely conducts a full
economic analysis that considers the
full range of impacts to the consumer,
manufacturer, nation, and environment
and will consider other applicable
criteria in determining whether a
proposed standard is economically
justified, including impacts on small
businesses. For the results of DOE’s
detailed analysis of economic impacts
on commercial customers and
manufacturers, see sections V.B.1 and
V.B.2.
For the NOPR analysis, DOE
calculated a rebuttable presumption
payback period at each TSL for WICF
equipment. Rather than using
distributions for input values, DOE used
discrete values and, as required by
EPCA, based the calculation on the
assumptions in the DOE WICF test
procedure. As a result, DOE calculated
a single rebuttable presumption payback
value, rather than a distribution of
payback periods. Table IV–14 and Table
IV–15 show the rebuttable presumption
payback periods at TSL 4 for
refrigeration systems and envelope
components, respectively.
55831
TABLE IV–14—WICF REFRIGERATION
SYSTEMS REBUTTABLE PAYBACK PERIOD AT TSL 4—Continued
Equipment class
Compressor
type
analyzed
Rebuttable
payback
period
DC.L.I, < 9,000 .....
DC.L.I, ≥ 9,000 .....
DC.L.O, < 9,000 ...
DC.L.O, ≥ 9,000 ...
MC.M ....................
MC.L .....................
SCR ...........
SCR ...........
SCR ...........
SCR ...........
....................
....................
2.1
2.3
1.7
3.1
0.8
0.7
TABLE IV–15 WICF ENVELOPE COMPONENTS REBUTTABLE PAYBACK PERIOD AT TSL 4
Equipment
class
Equipment
size
SP.M .............
Small .............
Medium .........
Large .............
Small .............
Medium .........
Large .............
Small .............
Medium .........
Large .............
Small .............
Medium .........
Large .............
Small .............
Medium .........
Large .............
Small .............
Medium .........
Large .............
Small .............
Medium .........
Large .............
Small .............
Medium .........
Large .............
Small .............
Medium .........
Large .............
SP.L ..............
FP.L ...............
DD.M .............
DD.L ..............
PD.M .............
PD.L ..............
FD.M .............
FD.L ..............
Rebuttable
payback
period
5.3
5.2
5.1
3.1
3.8
4.1
3.8
4.6
5.1
2.5
2.2
1.9
N/A
N/A
0.4
6.2
6.1
6.0
4.7
4.7
4.6
6.0
6.0
5.9
3.5
2.4
2.4
While DOE examined the rebuttablepresumption criterion, it considered
whether the standard levels considered
are economically justified through a
more detailed analysis of the economic
impacts of these levels consistent with
the approach laid out in 42 U.S.C.
6295(o)(2)(B)(i). The results of this
analysis serve as the basis for DOE to
TABLE IV–14—WICF REFRIGERATION evaluate the economic justification for a
SYSTEMS REBUTTABLE PAYBACK PE- potential standard level (thereby
supporting or rebutting the results of
RIOD AT TSL 4
any preliminary determination of
Rebutta- economic justification).
Equipment class
DC.M.I, < 9,000 ....
DC.M.I, ≥ 9,000 ....
DC.M.O, < 9,000 ..
DC.M.O, ≥ 9,000 ..
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Compressor
type
analyzed
SEM
SCR
SEM
SCR
Fmt 4701
...........
...........
...........
...........
Sfmt 4702
ble
payback
period
4.7
1.8
3.9
3.1
G. National Impact Analysis—National
Energy Savings and Net Present Value
The NIA assesses the national energy
savings (NES) and the net present value
(NPV) of total consumer costs and
savings that would be expected to result
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from the new energy conservation
standards. (‘‘Consumer’’ in this context
refers to customers of the product being
regulated.) The NES and NPV are
analyzed at specific efficiency levels
separately for the refrigeration systems
and components of the envelope
(panels, non-display doors, and display
doors). DOE calculates the NES and
NPV based on projections of annual
equipment shipments, along with the
annual energy consumption and total
installed cost data from the energy use
and LCC analyses. For the NOPR
analysis, DOE forecasted the energy
savings, operating cost savings, product
costs, and NPV of consumer benefits for
products sold from 2017 through 2073—
the year in which the last standards—
compliant equipment shipped during
the 30-year analysis period beginning in
2017 operates.
DOE evaluates the impacts of the new
standards by comparing base-case
projections with standards-case
projections. The base-case projections
characterize energy use and consumer
costs for each equipment class in the
absence of any new energy conservation
standards. DOE compares these
projections with projections
characterizing the market for each
equipment class if DOE adopted the
new standard at specific energy
efficiency levels (that is, the TSLs or
standards cases) for that equipment
class. For the base case forecast, DOE
considered a mix of two levels of
efficiency for the refrigeration systems
and a single efficiency level for the
components, except for cooler display
doors as noted in Table IV–16. For the
standards cases, DOE considered a ‘‘rollup’’ scenario in which DOE assumes
that product efficiencies that do not
meet the standard level under
consideration would roll-up to meet the
new standard level, and those already
above the proposed standard level
would remain unaffected.
DOE uses a Microsoft Excel
spreadsheet model to calculate the
energy savings and the national
consumer costs and savings from each
TSL. The NOPR TSD and other
documentation that DOE provides
during the rulemaking helps explain the
models and how to use them and also
allow interested parties to review DOE’s
analyses. The NIA spreadsheet model
uses average values as inputs (as
opposed to probability distributions of
key input parameters from a set of
possible values).
For the current analysis, the NIA used
projections of energy prices and
commercial building starts from the
AEO2013 Reference case. In addition,
DOE analyzed scenarios that used
inputs from the AEO2013 Low
Economic Growth and High Economic
Growth cases. These cases have higher
and lower energy price trends compared
to the Reference case, as well as higher
and lower commercial building starts,
which result in higher and lower walkin shipments to new commercial
buildings. NIA results based on these
cases are presented in appendix 10E of
the NOPR TSD.
Table IV–16 summarizes the inputs
and key assumptions DOE used for both
the preliminary analysis and NOPR with
respect to the NIA analysis. Discussion
of these inputs and changes follows the
table. See chapter 10 of the NOPR TSD
for further details.
TABLE IV–16—SUMMARY OF INPUTS AND KEY ASSUMPTIONS FOR THE NATIONAL IMPACT ANALYSIS
Preliminary analysis
Changes for the NOPR analysis
Shipments ...........................................................
Annual shipments from the shipments model
for complete walk-in units.
Compliance Date of Standard ............................
Base-Case Forecasted Efficiencies ...................
2015 .................................................................
No efficiency distributions assumed for the
base case and the current baseline level
was assumed to represent the market for
the forecasted shipments of complete walkin systems.
Standards-Case Forecasted Efficiencies ...........
No efficiency distributions assumed for the
standards case. A single efficiency level
was assumed to represent the market for
the forecasted shipments of complete walkin systems.
Annual Energy Consumption per Unit ................
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Inputs
DOE calculated the average annual energy
use for each WICF envelope class matched
with outdoor condenser systems using a
load profile described in AHRI 1250–2009
(8 hours of high load and 16 hours of low
load per day).
Manufacturer’s selling price is estimated from
Engineering Analysis. Installation costs are
based on RS Means Mechanical Cost Data
2009. Assumed no change with efficiency
level.
Annual shipments from the shipments model
calculated separately for refrigeration systems and components.
2017.
Refrigeration systems: For EISA * shipments,
75 percent of shipments are assumed to be
at the baseline and 25 percent of shipments
are assumed to be equivalent to the first efficiency level in the engineering analysis.
Panels and non-display doors: For EISA
shipments, 100 percent of shipments are
assumed to be at the baseline.
Display doors: For EISA shipments, 25 percent of cooler display doors are assumed to
be at the baseline and 75 percent are higher-efficiency (45 percent with LED lighting
and 30 percent with LED lighting and lighting controls); and 80 percent of freezer
doors are assumed to be at the baseline
and 20 percent are higher-efficiency (with
LED lighting).
No efficiency distributions assumed for standards compliant shipments. Shipped efficiencies for the forecasted shipments of refrigeration systems and components are
represented by a roll up to the minimum
standard level being analyzed.
DOE changed the daily load profile of the refrigeration system to 13.3 hours runtime per
day for coolers and 15 hours for freezers,
at full rated capacity corresponding to the
reference rating outside air temperatures.
Total Installed Cost per Unit ...............................
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Updated to RS Means Mechanical Cost Data
2012.
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TABLE IV–16—SUMMARY OF INPUTS AND KEY ASSUMPTIONS FOR THE NATIONAL IMPACT ANALYSIS—Continued
Inputs
Preliminary analysis
Annual Energy Cost per Unit .............................
Annual Energy consumption per unit was multiplied by the Annual energy cost. Costs
were discounted and summed over the
analysis period for the net present value
calculations.
Annualized repair and maintenance costs of
the combined system were derived from RS
Means 2009 walk-in cooler and freezer
maintenance data. Doors and refrigeration
systems could be replaced during the lifetime of the envelope.
Forecasted using AEO2009 price forecasts ....
Varies yearly and is generated by NEMS–BT
(2009); applied from 2014 through 2045.
3% and 7% real ...............................................
Future expenses discounted to 2010 ..............
Repair and Maintenance Cost per Unit ..............
Energy Prices .....................................................
Energy Site-to-Source Conversion Factor .........
Discount Rate .....................................................
Present Year ......................................................
Changes for the NOPR analysis
No change.
Updated to RS Means 2012 walk-in cooler
and freezer repair and maintenance data;
repair and maintenance costs for the refrigeration system and the envelope components were estimated separately.
Updated to AEO2013 forecasts.
Updated to modified NEMS–BT** (2012), and
applied from 2017 through 2073.
No change.
Future expenses discounted to 2013.
* EISA 2007 amended EPCA to establish prescriptive standards for walk-in coolers and freezers manufactured on or after January 1, 2009.
EISA shipments refer to the shipments complying with these prescriptive standards. This is in contrast to pre-EISA shipments, which would refer
to shipments before 2009 when there was no Federal energy efficiency standard in place.
** Site-to-source factors modified by Lawrence Berkley National Laboratories.
American Panel noted that the NIA
results in the preliminary analysis were
not meaningful because the refrigeration
system capacities were not properly
matched to the walk-in envelope. As
stated earlier in the LCC and PBP
sections, American Panel contended
that DOE should select the refrigeration
system capacity based on the envelope
heat load to make the economic
analyses realistic. (American Panel, No.
0048.1 at p. 11) In the NOPR, DOE
conducted the NIA analysis for the
refrigeration systems and the selected
envelope components independent of
each other and then combined the
results to arrive at the trial standard
levels. This approach did not directly
pair the walk-in units with the matched
capacity refrigeration system because
minor inconsistencies in the matching
of individual units could have large
effects on the overall NIA results, as
noted by American Panel. Rather, the
NOPR analysis involved combining the
results in the aggregate to arrive at a
more accurate estimate of overall energy
savings across the range of covered
equipment.
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1. Shipments
Forecasts of product shipments are
used to calculate the national impacts of
standards on energy use, NPV, and
future manufacturer cash flows. DOE
developed shipment forecasts for
refrigeration systems and envelope
components based on an analysis of
growth trends of specific building types
housing the walk-in units. In DOE’s
shipments model, shipments of walk-in
units and their components are driven
by new purchases and stock
replacements due to failures. The
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envelope component model and
refrigeration system shipments model
take an accounting approach, tracking
market shares of each equipment class
and the vintage of units in the existing
stock. Stock accounting uses product
shipments as inputs to estimate the age
distribution of in-service product stocks
for all years. The age distribution of inservice product stocks is a key input to
calculations of both the NES and NPV
because operating costs for any year
depend on the age distribution of the
stock. DOE also considers the impacts
on shipments from changes in product
purchase price and operating cost
associated with higher energy efficiency
levels.
American Panel, NEEA and NPCC
suggested that DOE contact the National
Association of Food Equipment
Manufacturers (NAFEM) and major
refrigeration system manufacturers such
as Heatcraft and Russell to obtain
shipment information. (American Panel,
Public Meeting Transcript, No. 0045 at
pp. 274–275; NEEA and NPCC, Public
Meeting Transcript, No. 0045 at p. 281)
DOE contacted NAFEM, which
provided DOE with copies of that
organization’s ‘‘Size and Shape of the
Industry’’ reports. These reports contain
data on the annual sales of walk-in units
in the food service sector for 2002–2010.
DOE analyzed the data received from
NAFEM and also obtained other data
from manufacturer interviews and other
sources. DOE used these data to develop
equipment class size share distributions,
and are documented in the current
shipment models.
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a. Share of Shipments and Stock Across
Equipment Classes
In response to the shipments analysis
results in the preliminary analysis, DOE
received several comments regarding
the share of shipments and stock across
equipment classes, dedicated
condensing and multiplex systems,
indoor and outdoor systems, cooler and
freezer envelopes, and envelope sizes.
In the preliminary analysis, DOE
estimated that 46 percent of the existing
stock of walk-in systems is served by
multiplex systems. American Panel
commented that the ratio between
multiplex to dedicated condensing
refrigeration systems was too high and
stated that, historically, 68 percent of
their sales are for dedicated condensing
refrigeration systems. American Panel
suggested that DOE’s estimate of the
share of stocks of dedicated condensing
refrigeration systems should be 70
percent. (American Panel, Public
Meeting Transcript, No. 0045 at pp. 192
and 275; American Panel, No. 0048.1 at
p. 4) Heatcraft supported this
observation by stating that multiplex
medium temperature refrigeration
system stock share should be only 15
percent. (Heatcraft, Public Meeting
Transcript, No. 0045 at p. 269)
DOE considered these comments and
re-examined its analyses in developing
its revised analysis for the NOPR. As
part of this revised analysis, DOE
developed a shipment model that
provided the key inputs required by the
shipment models for the envelope
components and refrigeration systems.
Based on this shipment analysis, DOE
estimated that dedicated condensing
units account for approximately 70
percent of the refrigeration market and
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the remaining 30 percent consists of
unit coolers connected to multiplex
condensing systems. DOE estimated that
medium temperature unit coolers
connected to multiplex systems account
for about 25 percent of the shipments
and stock. Regarding American Panel’s
comment on the relative shares of stock
between the multiplex and the
dedicated condensing refrigeration
systems shown in the preliminary TSD
(Table 3.2.8), DOE noted that Table 3.2.8
addressed shipments and not
refrigeration system stock data.
(American Panel, Public Meeting
Transcript, No. 0045 at p. 269)
DOE received two comments
regarding the stock share for outdoor
and indoor dedicated condensing
refrigeration systems. Heatcraft stated
that a 30 percent share for outdoor
dedicated condensing refrigeration
systems was a reasonable assumption
for DOE’s economic analyses. (Heatcraft,
Public Meeting Transcript, No. 0045 at
p. 268) Manitowoc stated that the share
of indoor dedicated condensing
refrigeration systems should be higher
than predicted, approximately 10
percent. (Manitowoc, Public Meeting
Transcript, No. 0045 at p. 274) DOE
considered these comments in light of
other available data and estimated for
the NOPR analysis that approximately
66 percent and 3 percent of the
shipments and stocks of the
refrigeration systems are accounted for
by the outdoor and indoor dedicated
condensing refrigeration systems,
respectively.
Regarding the relative shares of stock
or shipment between walk-in coolers
and freezers, American Panel
commented that DOE’s estimates of 70
percent and 30 percent shares for cooler
and freezer envelopes, respectively,
were reasonable. (American Panel,
Public Meeting Transcript, No. 0045 at
p. 275) DOE has slightly adjusted these
estimates in the NOPR shipment model
to 71 percent (coolers) and 29 percent
(freezers) based on updated calculations
and data.
NEEA and NPCC stated that DOE
correctly apportioned walk-ins by
business type in the preliminary
analysis, but noted that significant
market shifts are taking place in the
grocery and convenience store sectors.
(NEEA and NPCC, No. 0059.1 at p. 11)
NEEA and NPCC did not elaborate on
the significance or nature of the market
shifts. American Panel stated that DOE’s
estimate of twice as many large walk-in
coolers as small walk-in coolers seemed
inaccurate, and stated it would provide
data. (American Panel, Public Meeting
Transcript, No. 0045 at p. 293)
American Panel then submitted a
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written comment with its own historical
shipment data showing that walk-in
cooler and freezer shipments for small,
medium, and large units are 40 percent,
56 percent, and 4 percent, respectively,
which differs significantly from DOE’s
estimates of 14 percent, 58 percent, and
28 percent for small, medium, and large
units, respectively, in the preliminary
analysis. (American Panel, No. 0048.1 at
p. 11) In the NOPR analysis, DOE
adjusted its estimates based in part on
American Panel’s feedback. For the
NOPR, DOE estimated that size
distributions of stocks and shipments of
walk-in units are 52 percent, 40 percent,
and 8 percent for small, medium, and
large, respectively.
b. Lifetimes and Replacement Rates
As discussed in the previous section
on LCC and PBP analyses, the
preliminary analysis assumed an
envelope lifetime of approximately 15
years. American Panel agreed with
DOE’s 15-year lifetime estimate for the
envelopes. (American Panel, Public
Meeting Transcript, No. 0045 at p. 283)
Kysor mentioned that the envelope
lifetime could vary depending on the
traffic within it. For example, an 8- to
10-year envelope lifetime can be
expected if pallet jack or forklifts are
used in the walk-in, while a longer
envelope lifetime is likely if activity is
limited to foot traffic or lighter hand
trucks. (Kysor, Public Meeting
Transcript, No. 0045 at p. 287) MasterBilt suggested that most envelopes have
a 20-year lifetime. (Master-Bilt, No.
0046.1 at p. 1) American Panel
concurred with the 5 percent
replacement rate for walk-in cooler and
freezer envelopes, which corresponds to
a 20-year lifetime. (American Panel, No.
0048.1 at p. 11) AHRI commented that
based on its own experience, it believes
envelope wall and floor panels tend to
have a longer lifetime—12 to 25 years
would be typical—but provided no data
in support of this view. (AHRI, No.
0055.1 at p. 4) Hill Phoenix noted that
failure of envelope components is
usually evident by visual inspection,
and panels would not usually fail from
condensation or ice formation in the
insulation. (Hill Phoenix, No. 0066.1 at
p. 3) Given that most of these comments
provided only anecdotal evidence and
not supporting data, DOE continues to
assume a 15-year average lifetime for
panels in the current analysis.
DOE assumed the typical lifetime of
envelope doors to be 5 years in the
preliminary analysis. American Panel
commented that the door replacement
rate of 5 years is not supported by its inhouse data, which show a door
replacement rate of 5 percent, with the
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door lasting throughout the walk-in
cooler and freezer envelope lifetime.
(American Panel, No. 0048.1 at p. 9) In
addition, American Panel stated that the
number of replacement non-display
doors represented 5 percent of their
annual door shipments, which is
inconsistent with the assumption that
doors only last 5 years. (American
Panel, Public Meeting Transcript, No.
0045 at p. 14 and p. 284) In light of
these comments on the door
replacement rates, DOE has revised its
assumptions of door lifetimes to more
closely match envelope lifetimes. The
NOPR shipment model assumes an
average lifetime of approximately 14
years for both display and non-display
doors.
For refrigeration systems, DOE
assumed an average lifetime of 7 years
in the preliminary analysis. Master-Bilt
stated that refrigeration system lifetimes
were comparable to the envelope
lifetime of approximately 20 years—it
estimated that refrigeration system
lifetimes would be about 80–100
percent of envelope lifetimes. (MasterBilt, Public Meeting Transcript, No.
0045 at p. 287) Master-Bilt also stated
that a 15 percent replacement rate for
the refrigeration systems, which
corresponds to a lifetime of 7 years, is
too high, and actual replacement rates
should be only half as much. (MasterBilt, No. 0046.1 at p. 1) AHRI stated that
a typical mechanical equipment lifetime
is between 8 and 12 years. (AHRI, No.
0055.1 at p. 4) Master-Bilt also
mentioned that the economy has
reduced the frequency at which walk-in
coolers and freezers are completely
replaced with new equipment because
of the high cost. Instead, existing
equipment is often being refurbished
with users typically replacing only one
or a few individual components.
(Master-Bilt, No. 0046.1 at p. 1) MasterBilt also stated that doors are the most
commonly repaired or replaced
envelope component, while the most
common replacement part for a
refrigeration system is the compressor. It
noted that only 5 percent of refrigeration
systems require replacement
compressors over a 10-year span.
(Master-Bilt, Public Meeting Transcript,
No. 0045 at p. 287) American Panel
agreed that the entire refrigeration
system is not typically replaced and
only a compressor or fan motor is
replaced when the system fails.
Consequently, American Panel
disagreed with the 15 percent average
replacement rate used in the
preliminary analysis for the refrigeration
systems and suggested DOE use a
refrigeration system replacement rate of
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10 percent. (American Panel, No. 0048.1
at p. 11) In view of the comments
received from interested parties, DOE
revised its assumption of the average
lifetime of the refrigeration system to 12
years, corresponding to a replacement
rate of about 8 percent.
In the preliminary analysis, DOE
assumed a higher replacement rate for
refrigeration systems than for envelopes.
American Panel commented that DOE’s
estimated shipment ratio of 3 to 1
between refrigeration systems and
envelopes was too high and that a more
appropriate shipment ratio between
refrigeration systems and envelopes
would be about 1.3 to 1. (American
Panel, Public Meeting Transcript, No.
0045 at p. 192 and No. 0048.1 at p. 4)
As explained, in the NOPR shipment
model, the refrigeration system lifetime
has been revised downward from 15 to
12 years. (DOE has retained the 15-year
lifetime for envelopes.) In the revised
shipment model, refrigeration system
replacements account for about 30–41
percent of all refrigeration system
shipments. While this estimate exceeds
the suggested shipment ratio of 1.3, DOE
believes that the average lifetimes of
walk-in envelopes and refrigeration
systems, which are based on
manufacturer interviews and
stakeholder comments, are reasonable.
NEEA and NPCC stated that economic
lifetimes are different from physical
lifetimes and suggested that DOE use
both economic and physical lifetimes
depending on the building type in
which the walk-in cooler and freezer
resides. (NEEA and NPCC, No. 0059.1 at
p. 11) The physical lifetime refers to the
duration before the equipment fails or is
replaced, whereas the economic lifetime
refers to the duration before the walk-in
cooler and freezer equipment is taken
out of service because the owner is no
longer in business. In the event of an
economic lifetime failure, however, a
WICF would likely not leave the
national stock, but would instead be
sold to a third party, which would
represent a transfer of goods and would
not impact WICF shipments or stock at
a national level. For a more detailed
discussion of economic lifetimes see
life-cycle cost discussion in section
IV.F.7.
c. Growth Rates
The preliminary analysis used a
shipments growth rate of approximately
2 percent. Several interested parties
commented on this assumption.
American Panel agreed with DOE’s
assumption that walk-in growth will
match growth seen in building stock
square footage. (American Panel, No.
0048.1 at p. 11) Others stated that the
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preliminary analysis shipment growth
rate was overestimated. AHRI, NEEA
and NPCC predicted that the walk-in
market would be flat and any growth
would be less than 1 percent. (AHRI,
No. 0055.1 at p. 4; NEEA and NPCC,
Public Meeting Transcript, No. 0045 at
p. 292) Master-Bilt, NEEA and NPCC
stated that the shipment analysis should
use a maximum growth rate of 1
percent. (Master-Bilt, No. 0046.1 at p.1;
NEEA and NPCC, Public Meeting
Transcript, No. 0045 at p. 292) One
stakeholder stated that its business has
grown annually at a simple rate of 10
percent, although it added that this may
not be representative and may have
been driven by gaining market share
from other manufacturers. (American
Panel, Public Meeting Transcript, No.
0045 at pp. 290–291) American Panel
suggested that NAFEM may provide
walk-in growth rates across industry.
American Panel observed that
shipments grow about 7 percent in
normal financial times; however, they
can decline 10 percent per year during
a recession. In particular, the restaurant
sector business has dropped by 60
percent while walk-in cooler and freezer
business in the school sector has grown.
(American Panel, No. 0048.1 at p. 11)
Considering these stakeholder
comments, DOE modeled its growth rate
projections for the NOPR analysis using
the commercial building floor space
growth rates from the AEO 2013 NEMS–
BT model.
d. Other Issues
DOE developed a core shipment
model for estimating the annual
shipments and stocks of complete
WICFs that formed the basis for the
shipment analysis of refrigeration
systems and envelope components. DOE
expressed annual shipments and stocks
of refrigeration systems in terms of
installed refrigeration capacity (Btu/h)
which required DOE to estimate the
required refrigeration capacity for the
WICF units shipped. As part of the
process, product loads were estimated
for different envelope sizes and types.
In the preliminary analysis, product
load estimates were central to the
annual energy consumption projections
and were presented in the same context.
American Panel stated that while the
product-specific heat and product pulldown temperature values used in the
preliminary analysis were correct, it
disagreed with the product-loading
values assumed for various types of
equipment. American Panel suggested
that the product-loading estimates
should be 2 pounds per cubic foot for
small coolers and 1 pound per cubic
foot for medium and large coolers (not
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4 and 2 respectively, as DOE had
assumed), and 1 pound per cubic foot
for small, medium, and large freezers
(not 1 for small freezers and 0.5 for
medium and large freezers, as DOE had
assumed). (American Panel, Public
Meeting Transcript, No. 0045 at p. 209)
Master-Bilt stated that it is difficult to
have product load assumptions that are
valid for all applications and DOE
should explicitly state that the product
load assumptions currently used are
valid only for specific situations but
may not necessarily be representative of
all applications. (Master-Bilt, No. 0046.1
at p. 1)
DOE agrees with Master-Bilt’s
observation that it is difficult to make
assumptions on product load that are
valid for all sizes and all applications.
DOE revisited the issue and concluded
that the loading ratios indicated by
American Panel could be representative
of the food service segment of the
market, which accounts for about 35
percent of the aggregate installed
refrigeration capacity for the walk-ins.
From the available product brochures
and indicated product loads for
different sizes of WICF equipment, DOE
believes that the loading ratios used for
the other market segments are closer to
ratios used in the preliminary analysis.
Consequently, DOE did not change the
loading ratios for the NOPR analysis.
2. Forecasted Efficiency in the Base Case
and Standards Cases
A key component of the NIA is the
trend in energy efficiency forecasted for
the base and standards cases. Using data
collected from manufacturers and an
analysis of market information, DOE
developed a base-case energy efficiency
distribution (which yields a shipmentweighted average efficiency) for each of
the considered equipment classes for
the first year of the forecast period. To
project the efficiency trend over the
entire forecast period, DOE considered
the current market distribution and
recent trends. For envelope
components, all base case shipments are
assumed to have only a single EPCAcompliant efficiency level except for
display doors. For cooler display doors,
shipments would be a mix of 25 percent
EPCA-compliant equipment and 75
percent higher efficiency equipment.
For freezer display doors, shipments
would be a mix of 80 percent EPCAcompliant equipment and 20 percent
higher efficiency equipment. For
refrigeration systems, DOE assumed,
based on manufacturer interviews, that
in the absence of standards (the base
case), shipments would be a mix of 75
percent EPCA-compliant equipment and
25 percent higher efficiency equipment.
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For both refrigeration systems and
envelope components, DOE assumed no
improvement of energy efficiency in the
base case and held the base-case energy
efficiency distribution constant
throughout the forecast period. DOE
requests comment on this assumption.
To estimate efficiency trends in the
standards cases, DOE has used a ‘‘rollup’’ scenario in its standards
rulemakings. The roll-up scenario
represents a standards case in which all
product efficiencies in the base case that
do not meet the standard would roll up
to meet the new standard level.
Consumers in the base case who
purchase walk-in equipment above the
standard level are not affected as they
are assumed to continue to purchase the
same equipment. The roll-up scenario
characterizes consumers primarily
driven by the first-cost of the analyzed
products and characterizes the
efficiency trends currently found in the
market.
In summary, under the roll-up
scenario DOE assumes: (1) Product
efficiencies in the base case that do not
meet the standard level under
consideration would ‘‘roll-up’’ to meet
the new standard level and (2) product
efficiencies above the standard level
under consideration would not be
affected.
3. National Energy Savings
For each year in the forecast period,
DOE calculates the NES for each
standard level by multiplying the stock
of equipment affected by the energy
conservation standards by the per-unit
annual energy savings. DOE typically
considers the impact of a rebound effect,
introduced in the energy-use analysis,
in its calculation of national energy
savings for a given product. A rebound
effect occurs when users operate higher
efficiency equipment more frequently
and/or for longer durations, thus
offsetting estimated energy savings.
However, DOE assumed a rebound
factor of one, or no effect, because walkins must cool their contents at all times
and it is not possible for consumers to
operate them more frequently. For a
further discussion of the rebound effect,
see chapter 10 of the TSD. DOE seeks
comment on the assumption that there
is no rebound effect associated with
these products.
To estimate the national energy
savings expected from appliance
standards, DOE uses a multiplicative
factor to convert site energy
consumption (at the home or
commercial building) into primary or
source energy consumption (the energy
required to convert and deliver the site
energy). These conversion factors
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account for the energy used at power
plants to generate electricity and losses
in transmission and distribution, as well
as for natural gas losses from pipeline
leakage and energy used for pumping.
For electricity, the conversion factors
vary over time due to projected changes
in generation sources (that is, the power
plant types projected to provide
electricity to the country). The factors
that DOE developed are marginal
values, which represent the response of
the system to an incremental decrease in
consumption associated with appliance
standards.
In the preliminary analysis, DOE used
annual site-to-source conversion factors
based on the version of NEMS that
corresponds to AEO2009. For this
NOPR, DOE updated its conversion
factors based on the U.S. energy sector
model NEMS–BT corresponding to
AEO2013.
DOE has historically presented NES
in terms of primary energy savings. In
response to the recommendations of a
committee on ‘‘Point-of-Use and FullFuel-Cycle Measurement Approaches to
Energy Efficiency Standards’’ appointed
by the National Academy of Science,
DOE announced its intention to use fullfuel-cycle (FFC) measures of energy use
and greenhouse gas and other emissions
in the national impact analyses and
emissions analyses included in future
energy conservation standards
rulemakings. 76 FR 51281 (August 18,
2011) While DOE stated in that notice
that it intended to use the Greenhouse
Gases, Regulated Emissions, and Energy
Use in Transportation (GREET) model to
conduct the analysis, it also said it
would review alternative methods,
including the use of NEMS. After
evaluating both models and the
approaches discussed in the August 18,
2011 notice, DOE published a statement
of amended policy in the Federal
Register in which DOE explained its
determination that NEMS is a more
appropriate tool for its FFC analysis and
its intention to use NEMS for that
purpose. 77 FR 49701 (August 17, 2012).
DOE received one comment, which was
supportive of the use of NEMS for
DOE’s FFC analysis.20
The approach used for today’s NOPR,
and the FFC multipliers that were
applied, are described in appendix 10G
of the NOPR TSD. NES results are
presented in both primary and
summarized by TSL in terms of FFC
savings in section V.B.3.a.
20 Docket ID: EERE–2010–BT–NOA–0028,
comment by Kirk Lundblade.
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4. Net Present Value of Consumer
Benefit
The inputs for determining the NPV
of the total costs and benefits
experienced by walk-in equipment
consumers are: (1) Total annual
installed cost; (2) total annual savings in
operating costs; and (3) a discount
factor. DOE calculates net savings each
year as the difference between the base
case and each standards case in total
savings in operating costs and total
increases in installed costs. DOE
calculates operating cost savings over
the life of each product shipped during
the forecast period.
DOE multiplies the net savings in
future years by a discount factor to
determine their present value. For the
preliminary analysis, DOE estimated the
NPV of appliance consumer benefits
using both a 3 percent and a 7 percent
real discount rate. The 7 percent real
value is an estimate of the average
before-tax rate of return to private
capital in the U.S. economy. The 3
percent real value represents the
‘‘societal rate of time preference,’’ which
is the rate at which society discounts
future consumption flows to their
present. NEEA and NPCC urged DOE to
focus on the 3-percent discount rate as
the primary basis for the analyses
because the issues largely pertain to the
aggregate costs and benefits accruing to
society at large. (NEEA and NPCC, No.
0059.1 at p. 12) DOE uses these discount
rates in accordance with guidance
provided by the Office of Management
and Budget (OMB) to Federal agencies
on the development of regulatory
analysis.21 Therefore, for today’s NOPR,
DOE continued to estimate the NPV of
appliance consumer benefits using both
a 3 percent and a 7 percent real discount
rate as directed by OMB.
5. Benefits From Effects of Standards on
Energy Prices
The reduction in electricity
consumption associated with new
standards for walk-ins could reduce the
electricity prices charged to consumers
in all sectors of the economy and
thereby reduce their electricity
expenditures. In chapter 2 of the
preliminary TSD, DOE explained that,
because the power industry is a
complex mix of fuel and equipment
suppliers, electricity producers and
distributors, it did not plan to estimate
the value of potentially reduced
electricity costs for all consumers
21 OMB Circular A–4 (Sept. 17, 2003), section E,
‘‘Identifying and Measuring Benefits and Costs.’’
Available at: www.whitehouse.gov/omb/
memoranda/m03-21.html.
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associated with new or amended
standards for walk-ins.
For this rule, DOE used NEMS–BT to
assess the impacts of the reduced need
for new electric power plants and
infrastructure projected to result from
standards. In NEMS–BT, changes in
power generation infrastructure affect
utility revenue requirements, which in
turn affect electricity prices. DOE
estimated the impact on electricity
prices associated with each considered
TSL. Although the aggregate benefits for
electricity users are potentially large,
there may be negative effects on some
entities involved in electricity supply,
particularly power plant providers and
fuel suppliers. Given the uncertainty
about the extent to which the benefits
for electricity users from reduced
electricity prices would be a transfer
from those involved in electricity
supply to electricity users, DOE
continues to investigate the extent to
which electricity price changes
projected to result from standards
represent a net gain to society.
H. Consumer Subgroup Analysis
In analyzing the potential impact of
new or amended standards on
commercial consumers, DOE evaluates
the impact on identifiable groups (i.e.,
subgroups) of consumers, such as
different types of businesses that may be
disproportionately affected by an energy
conservation standard. DOE gathered
data for all business types identified in
the analysis: grocery stores; convenience
stores (including specialty food stores);
convenience stores without gasoline
stations; and restaurants that purchase
their own walk-in coolers or freezers.
Comments submitted by American
Panel and Manitowoc recommended
that DOE consider non-chain restaurants
independently of chain restaurants.
(American Panel, Public Meeting
Transcript, No. 0045 at p. 252;
Manitowoc, Public Meeting Transcript,
No. 0045 at p. 254) Further comments
by American Panel suggested that small
restaurants are more vulnerable to
potential economic consequences of an
efficiency standard. (American Panel,
No. 0048.1 at p. 10) DOE agrees with
these comments and believes that its
current models accurately represent
chain restaurants because data used to
characterize the restaurant business type
is dominated by multi-establishment
chain restaurants. Hence, small, nonchain restaurants are included in the
subgroup analysis.
After reviewing the data and
submitted comments (see TSD chapter
11 for more details), DOE identified
small restaurant owners because this
subgroup likely includes owners of
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high-cost walk-in coolers and freezers,
has the highest capital costs of all
subgroups, and potentially experiences
the shortest equipment economic
lifetimes. These conditions make it
likely that this subgroup will have the
lowest life-cycle cost savings of any
major consumer group.
DOE estimated the impact on the
identified consumer subgroup using the
LCC spreadsheet model. The standard
LCC and PBP analyses (described in
section IV.F) include various types of
businesses that own and use walk-in
coolers and freezers. The LCC
spreadsheet model allows for the
identification of one or more subgroups
of businesses, which can then be
analyzed by sampling only each
subgroup. The results of DOE’s LCC
subgroup analysis are summarized in
section V.B and described in detail in
chapter 11 of the TSD.
I. Manufacturer Impact Analysis
1. Overview
DOE performed an MIA to estimate
the financial impact of energy
conservation standards on
manufacturers of walk-in equipment
and to calculate the impact of such
standards on employment and
manufacturing capacity. Manufacturers
of panels, doors, and refrigeration, as
well as manufacturers of completed
walk-ins, were considered in the
analysis.
The MIA has both quantitative and
qualitative aspects. The quantitative
portion of the MIA primarily relies on
the Government Regulatory Impact
Model (GRIM), an industry cash-flow
model customized for this rulemaking.
The key GRIM inputs are data on the
industry cost structure, product costs,
shipments, and assumptions about
markups and conversion expenditures.
The key output is the industry net
present value (INPV). Different sets of
assumptions (markup scenarios) will
produce different results. The
qualitative portion of the MIA addresses
factors such as product characteristics
and industry and market trends. Chapter
12 of the NOPR TSD describes the
complete MIA.
DOE conducted the MIA for this
rulemaking in three phases. In Phase 1
of the MIA, DOE prepared a profile of
the walk-in cooler and freezer industry,
which includes a top-down cost
analysis of manufacturers that DOE used
to derive preliminary financial inputs
for the GRIM (e.g., sales general and
administration (SG&A) expenses;
research and development (R&D)
expenses; and tax rates). DOE used
public sources of information, including
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company Securities and Exchange
Commission (SEC) 10–K filings,
Moody’s company data reports,
corporate annual reports, the U.S.
Census Bureau’s Economic Census, and
Dun and Bradstreet reports.
In Phase 2 of the MIA, DOE prepared
an industry cash-flow analysis to
quantify the impacts of a new energy
conservation standard. In general, new
or more stringent energy conservation
standards can affect manufacturer cash
flow in three distinct ways: (1) Create a
need for increased investment, (2) raise
production costs per unit, and (3) alter
revenue due to higher per-unit prices
and possible changes in sales volumes.
In Phase 3 of the MIA, DOE
conducted interviews with a
representative cross-section of
manufacturers. During these interviews,
DOE discussed engineering,
manufacturing, procurement, and
financial topics to validate assumptions
used in the GRIM and to identify key
issues or concerns. See section IV.I.4 for
a description of the key issues
manufacturers raised during the
interviews.
Phase 3 also includes an evaluation of
sub-groups of manufacturers that may
be disproportionately impacted by
standards or that may not be accurately
represented by the average cost
assumptions used to develop the
industry cash-flow analysis. For
example, small manufacturers, niche
players, or manufacturers exhibiting a
cost structure that largely differs from
the industry average could be more
negatively affected. Thus, during Phase
3, DOE analyzed small manufacturers as
a subgroup.
The Small Business Administration
(SBA) defines a small business for North
American Industry Classification
System (NAICS) 333415 ‘‘AirConditioning and Warm Air Heating
Equipment and Commercial and
Industrial Refrigeration Equipment
Manufacturing’’ as having 750
employees or fewer. During its research,
DOE identified multiple companies that
manufacture products covered by this
rulemaking and qualify as a small
business under the SBA definition. The
small businesses were further subdivided into small manufacturers of
panels, doors, and refrigeration
equipment to better understand the
impacts of the rulemaking on those
entities. The small business subgroup is
discussed in sections V.B.2.d and VI.B
of today’s notice and in Chapter 12 of
the NOPR TSD.
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2. Government Regulatory Impact Model
Analysis
As discussed previously, DOE uses
the GRIM to quantify the changes in
cash flow that result in a higher or lower
industry value from new standards. The
GRIM analysis uses a discounted cashflow methodology that incorporates
manufacturer costs, markups,
shipments, and industry financial
information as inputs. The GRIM
models changes in costs, distribution of
shipments, investments, and
manufacturer margins that could result
from new energy conservation
standards. The GRIM spreadsheet uses
the inputs to arrive at a series of annual
cash flows beginning in 2013 (the base
year of the analysis) and continuing to
2046. DOE calculated INPVs by
summing the stream of annual
discounted cash flows during these
periods. DOE applied discount rates
derived from industry financials and
then modified them according to
feedback during manufacturer
interviews. Discount rates ranging from
9.4 to 10.5 percent were used depending
on the component being manufactured.
The GRIM calculates cash flows using
standard accounting principles and
compares changes in INPV between the
base case and each TSL (the standards
case). Essentially, the difference in INPV
between the base case and a standards
case represents the financial impact of
the new standard on manufacturers.
Additional details about the GRIM, the
discount rate, and other financial
parameters can be found in chapter 12
of the TSD.
DOE typically presents its estimates of
industry impacts by grouping the major
equipment classes served by the same
manufacturers. For the WICF industry,
DOE groups results by panels, doors,
and refrigeration systems.
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a. Government Regulatory Impact Model
Key Inputs
i. Manufacturer Production Costs
Manufacturing a higher-efficiency
product is typically more expensive
than manufacturing a baseline product
due to the use of more expensive
components and larger quantities of raw
materials. The changes in the
manufacturer production cost (MPC) of
the analyzed products can affect
revenues, gross margins, and cash flow
of the industry, making these product
cost data key GRIM inputs for DOE’s
analysis.
In the MIA, DOE used the MPCs for
each considered efficiency level
calculated in the engineering analysis,
as described in section IV.C and further
detailed in chapter 5 of the TSD. In
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addition, DOE used information from its
teardown analysis, described in section
IV.C.3.a, to disaggregate the MPCs into
material, labor, and overhead costs. To
calculate the MPCs for products above
the baseline, DOE added the
incremental material, labor, and
overhead costs from the engineering
cost-efficiency curves to the baseline
MPCs. These cost breakdowns and
product mark-ups were validated with
manufacturers during manufacturer
interviews.
ii. Shipments Forecast
The GRIM estimates manufacturer
revenues based on total unit shipment
forecasts and the distribution of
shipments by equipment class. For the
base-case analysis, the GRIM uses the
NIA base-case shipment forecasts from
2013, the base year for the MIA analysis,
to 2046, the last year of the analysis
period.
For the standards case shipment
forecast, the GRIM uses the NIA
standards case shipment forecasts. The
NIA assumes zero elasticity in demand
as explained in section 9.3.1 in chapter
9 of the TSD. Therefore, the total
number of shipments per year in the
standards case is equal to the total
shipments per year in the base case.
DOE assumes a new efficiency
distribution in the standards case,
however, based on the energy
conservation standard. DOE assumed
that product efficiencies in the base case
that did not meet the standard under
consideration would ‘‘roll up’’ to meet
the new standard in the standard year.
iii. Product and Capital Conversion
Costs
New energy conservation standards
will cause manufacturers to incur
conversion costs to bring product
designs into compliance. DOE evaluated
the level of conversion-related capital
expenditures needed to comply with
each efficiency level in each equipment
class. For the purpose of the MIA, DOE
classified these conversion costs into
two major groups: (1) Product
conversion costs and (2) capital
conversion costs. Product conversion
costs are investments in research,
development, testing, and marketing
focused on making product designs
comply with the new energy
conservation standards. Capital
conversion costs are investments in
property, plant, and equipment to adapt
or change existing production facilities
so that new equipment designs can be
fabricated and assembled.
To evaluate the level of capital
conversion expenditures manufacturers
would likely incur to comply with
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energy conservation standards, DOE
used the manufacturer interviews to
gather data on the level of capital
investment required at each efficiency
level. DOE validated manufacturer
comments through estimates of capital
expenditure requirements derived from
the product teardown analysis and
engineering model described in sections
IV.C.2 and IV.C.3.
DOE assessed the product conversion
costs at each level by integrating data
from quantitative and qualitative
sources. DOE considered feedback from
multiple manufacturers at each
efficiency level to determine conversion
costs such as R&D expenditures and
certification costs. Manufacturer
numbers were aggregated to better
reflect the industry as a whole and to
protect confidential information.
In general, DOE assumes that all
conversion-related investments occur
between the year of publication of the
final rule and the year by which
manufacturers must comply with the
standard. The investment figures used
in the GRIM can be found in section
V.B.2.a of today’s notice. For additional
information on the estimated product
conversion and capital conversion costs,
see chapter 12 of the TSD.
b. Government Regulatory Impact Model
Scenarios
i. Markup Scenarios
As discussed above, MSPs include
direct manufacturing production costs
(i.e., labor, material, and overhead
estimated in DOE’s MPCs) and all nonproduction costs (i.e., SG&A, R&D, and
interest), along with profit. To calculate
the MSPs in the GRIM, DOE applied
non-production cost markups to the
MPCs estimated in the engineering
analysis for each equipment class and
efficiency level. Modifying these
markups in the standards case yields
different sets of impacts on
manufacturers. For the MIA, DOE
modeled two standards case markup
scenarios to represent the uncertainty
regarding the potential impacts on
prices and profitability for
manufacturers following the
implementation of new energy
conservation standards: (1) A
preservation of gross margin percentage
and (2) a preservation of operating
profit. These scenarios lead to different
markups values which, when applied to
the input MPCs, result in varying
revenue and cash flow impacts.
Under the ‘‘preservation of gross
margin percentage’’ scenario, DOE
applied a single uniform gross margin
percentage markup across all efficiency
levels. As production costs increase
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with efficiency, this scenario implies
that the absolute dollar markup will
increase as well. DOE assumed the nonproduction cost markup—which
includes SG&A expenses, research and
development expenses, interest, and
profit—to be 1.32 for panels, 1.50 for
solid doors, 1.62 for display doors, and
1.35 for refrigeration. These markups are
consistent with the ones DOE assumed
in the engineering analysis.
Manufacturers have indicated that it is
optimistic to assume that, as
manufacturer production costs increase
in response to an energy conservation
standard, manufacturers would be able
to maintain the same gross margin
percentage markup. Therefore, DOE
assumes that this scenario represents a
high bound to industry profitability
under an energy conservation standard.
In the preservation of operating profit
scenario, manufacturer markups are set
so that operating profit one year after
the compliance date of the new energy
conservation standards is the same as in
the base case. Under this scenario, as
the cost of production and the cost of
sales rise, manufacturers are generally
required to reduce their markups to a
level that maintains base case operating
profit. The implicit assumption behind
this markup scenario is that the industry
can maintain only its operating profit in
absolute dollars after the standard.
Operating margin in percentage terms is
reduced between the base case and
standards case.
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3. Discussion of Comments
Interested parties commented on the
assumptions and results of the
preliminary analysis, particularly on the
cumulative regulatory burden, inventory
levels, and scope of the manufacturer
impact analysis.
a. Cumulative Regulatory Burden
AHRI stated that DOE must take into
account the impact of new regulations
that California is working on as part of
Title 20 that will establish new
prescriptive design requirements for
walk-in coolers and freezers in 2011.
(AHRI, Public Meeting Transcript, No.
0045 at p. 5)
DOE reviewed California Code of
Regulations Title 20, Section 1605,
which establishes walk-in requirements
for insulation levels, motor types, and
use of automatic door-closers. The latest
set of regulations, published in the 2010
Appliance Efficiency Regulations and
effective 2011, includes design
standards required for all walk-ins
manufactured on or after January 1,
2009. These state regulations are
identical to Federal regulations that are
set forth in EPCA (see 42 U.S.C. 6313(f)),
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and that are already in place. As a
practical matter, the Federal regulations
mirror those that the State of California
had previously prescribed. As a result
there was no incremental cost
differential between the Federal
standards promulgated in 2007 and
California standards. The energy
conservation standards that DOE is
considering in this standards
rulemaking are more stringent than the
already-prescribed levels.
AHRI also expressed concern over
California regulations to limit
greenhouse gas emissions, in particular
the California Air Resources Board
(CARB) provisions to reduce the use of
high global warming potential
refrigerants, such as hydrofluorocarbons
(HFCs). (AHRI, Public Meeting
Transcript, No. 0045 at p. 5)
CARB is currently limiting the in-state
use of high-GWP refrigerants in nonresidential refrigeration systems through
its Refrigerant Management Program,
effective January 1, 2011. According to
this new regulation, facilities with
refrigeration systems that have a
refrigerant capacity exceeding 50
pounds must repair leaks within 14
days of detection, maintain on-site
records of all leak repairs, and keep
receipts of all refrigerant purchases. The
regulation applies to any person or
company that installs, services, or
disposes of appliances with high-GWP
refrigerants. According to EPCA, walkin coolers and freezers are enclosed
storage spaces that can be walked into
and have a total chilled storage area of
less than 3,000 square feet. (42 U.S.C.
6311(20) (defining the term ‘‘walk-in
cooler; walk-in freezer’’)) Due to this
size limit, it is unlikely that a walk-in
refrigeration system will contain over 50
pounds of refrigerant, making
application of the CARB provisions
unlikely.22
b. Inventory Levels
In the preliminary analysis, DOE
determined from U.S. Census data that
the end-of-year inventory for the airconditioning and warm air heating
equipment and commercial and
industrial refrigeration equipment
manufacturing industry (NAICS code
333415) was approximately 10 percent
of shipment value from 2002 to 2007
(U.S. Census Bureau Annual Survey of
Manufacturers) and presented these data
in Table 12.3.3 of chapter 12 in the
preliminary TSD. American Panel
expressed concerns that the inventory
22 DOE estimates that walk-ins meeting the
statutory definition would likely use between 5 and
40 pounds of refrigerant, below the threshold
established under the California regulations.
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percentages shown in Table 12.3.3 of
chapter 12 in the Preliminary TSD are
inaccurate and noted that their end-ofyear inventory value has been only 2.5
percent of annual shipment value on
average. (American Panel, No. 0048.1 at
p. 11) The U.S. Census percentages
represent values for the air-conditioning
and warm-air heating equipment and
commercial and industrial refrigeration
equipment manufacturing industry,
which includes a wide range of
products and companies. DOE agrees
that the U.S. Census figures may not
necessarily be representative of
inventory levels for specific walk-in
cooler and freezer manufacturers. The
figure is used to characterize the
industry and is not a component of any
quantitative analysis. DOE has factored
American Panel’s inventory number
into its qualitative understanding of the
walk-in industry.
c. Manufacturer Subgroup Analysis
AHRI suggested that DOE should
enlarge the scope of the manufacturer
impact analysis to examine the impact
of the rulemaking on all manufacturers
of different equipment classes—
including panel, door, and refrigeration
system manufacturers. (AHRI, Public
Meeting Transcript, No. 0045 at p. 4)
To better reflect the structure of the
rulemaking, DOE has expanded its
analysis of manufacturers to include the
impact of the rulemaking on key
component suppliers, including panel
manufacturers, door manufacturers, and
refrigeration system manufacturers.
Additionally, small manufacturers of
panels, doors, and refrigeration systems
are considered as separate sub-groups in
the MIA.
4. Manufacturer Interviews
As part of the MIA, DOE discussed
potential impacts of standards with
eight panel manufacturers, six door
manufacturers, and three refrigeration
systems manufacturers. In the
interviews, DOE asked manufacturers to
describe their major concerns about this
rulemaking. The following sections
discuss manufacturers’ most significant
concerns.
a. Cost of Testing
All door, panel, and refrigeration
manufacturers expressed concern
regarding the cost of testing. The
majority of walk-ins sold are not
standard combinations of box sizes,
refrigeration components, and doors.
Almost every walk-in unit is tailored to
meet consumer specifications.
According to manufacturers, DOEmandated testing of every configuration
sold is not realistic and could become
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a financial burden that would negatively
impact manufacturers’ profitability.
The cost of compliance testing
includes the engineering support
necessary to design and run tests, the
cost of the units tested, and the cost of
third-party testing support. Some
manufacturers indicated that it may be
necessary to set up new test labs to deal
with compliance requirements. Beyond
DOE compliance testing, energy
conservation standards may lead to
product redesigns that require new
certifications, such as Underwriters
Laboratories (UL) fire safety, NSF 2 food
service, and NSF 7 commercial
refrigerator and freezer standards
compliance.
Multiple door, panel, and
refrigeration manufacturers expressed
concern that these compliance and
certification testing costs may lead to
less customization in the industry. As
an example, one door manufacturer was
concerned that walk-in manufacturers
would offer fewer door choices and
partner with fewer door companies to
reduce testing burden. As another
example, a manufacturer that produces
only unit coolers indicated that the need
to certify the complete refrigeration
system would force them to leave the
WICF market. As the unit cooler
supplier, the manufacturer does not
have the ability to certify the entire
system because they do not supply the
condensing unit portion of the system.
Today, the manufacturer’s consumers
pair the unit coolers with condensing
units from other suppliers to assemble
a walk-in refrigeration system. The
manufacturer speculated that, in a
regulated environment, their consumers
would switch from buying refrigeration
components from manufacturers of unit
coolers to buying complete systems with
matched unit coolers and condensing
units from larger competitors that build
complete systems rather than
components. Their customers would
make this change to avoid the test
burden on refrigeration systems. Other
manufacturers mentioned that the cost
of testing could ultimately lead to
conditions in which small panel
manufacturers would be forced out of
the market.
Finally, walk-in manufacturers were
concerned about pricing and availability
of third-party testing. Several walk-in
manufacturers noted that it is unclear
whether a sufficient number of qualified
third parties exist to carry out the
performance testing mandated by DOE
for the entire industry. One
manufacturer was concerned that an
insufficient number of test facilities
would lead to higher testing costs and
delays in achieving compliance.
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b. Enforcement and Compliance
All of the interviewed manufacturers
expressed concern that an energy
conservation standard rulemaking could
result in unfair competition if the
standard is not properly enforced.
Interviewed manufacturers claimed that
numerous manufacturers, particularly
small one-to-two person operations, are
not currently complying with the
existing walk-in regulations in EPCA,
which took effect January 1, 2009. The
manufacturers explained that smaller
operations often have an incentive to be
non-compliant. By using materials that
do not comply with existing regulations,
the non-compliant manufacturers
maintain a price advantage over
compliant manufacturers.
Manufacturers emphasized the need
to have well-defined compliance
responsibilities. WICF units can be
manufactured and delivered as per
standard by the manufacturer, but the
end user may decide to remove some of
the efficiency features, such as strip
curtains. Additionally, the quality of
installation at the client site is often a
factor that manufacturers cannot control
because field assembly is managed by
contractors. Manufacturers also noted
that, for some installations, the
contractors purchase the walk-in
envelope and refrigeration equipment
from separate suppliers, making it
impossible for the equipment
manufacturers to determine the
efficiency of the installed product.
Multiple manufacturers requested
clarification to better understand which
party bears responsibility for ensuring
field-assembled walk-ins meet federal
standards.
In this NOPR, DOE discusses issues
surrounding compliance and
enforcement. In particular, DOE
proposes that each component
manufacturer would be responsible for
certifying to DOE that the components
they manufacture comply with the
standards. DOE believes that the
component-based approach provides for
effective certification and enforcement
of any standards while ensuring that the
walk-in industry has sufficient
flexibility to meet the applicable
standards. For more details on DOE’s
proposed approach, see section III.D.
c. Profitability Impacts
Walk-in manufacturers discussed how
new energy conservation standards
could affect profit levels. Manufacturers
considered the walk-in industry to be a
low margin-business. Price competition
can be very aggressive, particularly for
large orders and for name-brand client
accounts. Manufacturers stated that low
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margins leave little room for the added
costs that energy conservation standards
could impose. Manufacturers noted that
they will have to absorb the additional
costs or pass the costs onto the
consumer.
Specifically, manufacturers
emphasized their concerns about the
impact of thicker panels, thicker doors,
and more efficient refrigeration on
profitability. Thicker panels require
more material and longer processing
times. The end result could be a
reduction in factory throughput coupled
with increased cost. Additionally,
manufacturers noted that thicker panels
are heavier, which leads to higher
shipping costs. Similar concerns exist
for solid doors. To achieve higher
refrigeration efficiencies, manufacturers
would have to purchase larger coils,
more efficient compressors, and more
expensive control systems. All these
components increase the cost of goods
sold for the completed walk-in.
Manufacturers speculated that passing
all these costs onto their customers
would lead to lower-volume orders, as
consumers with set budgets would not
be able to purchase as many walk-ins (in
the case of chain stores) or as much
walk-in space (in the case of individual
operations) for the same dollar amount.
Alternatively, absorbing these costs
would significantly reduce profit
margins.
In the manufacturer impact analysis,
DOE has examined the impacts of
standards on manufacturers’ profit
margins. For the results of DOE’s
analysis, see section V.B.2.a.
d. Excessive Conversion Cost
According to panel manufacturers, a
new energy conservation standard that
requires increased levels of thickness
could result in high conversion costs.
Much of the existing production
equipment is designed to produce
panels 3.5–5 inches thick. Panels that
are 6 or more inches thick are less
common in the industry. Any standard
that results in the market moving to 5inch thick panels would require some
conversion cost as factories that use
foam-in-place technology must
accommodate increased curing times.
Manufacturers indicated that the
conversion costs could range from
$100,000 to $500,000, depending on the
manufacturer’s existing equipment. Any
standard that requires 6-inch thick
panels would involve significant
additional investment by most
manufacturers. At this level of
thickness, manufacturers estimate
conversion costs would range from
$200,000 to $1 million. Any standard
that requires 7-inch thick panels would
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tkelley on DSK3SPTVN1PROD with PROPOSALS2
require all manufacturers to reevaluate
their manufacturing process. Conversion
costs would range from $1.5 million to
$4 million. Based on manufacturer
statements, any standard that moved the
industry to 6-inch thick panels would
likely put some of the top 10 panel
manufacturers out of business.
DOE considers conversion costs in the
manufacturer impact analysis. For
details on DOE’s findings, see section
V.B.2.a.
e. Disproportionate Impact on Small
Businesses
Most interviewed manufacturers
noted that new energy conservation
standards could have a disproportionate
impact on small businesses as compared
to larger businesses. The cost of testing,
the potential increase in materials, and
the potential need to obtain financing
are the factors that could affect small
business manufacturers producing
refrigeration systems, panels, and doors
more severely.
Manufacturers voiced concerns
regarding the cost of both compliance
testing and certification testing (e.g., UL
and NSF certifications) on small
businesses. According to manufacturers,
the price tag for testing is likely to be
similar for both small and large
companies due to the high level of
product customization in the industry.
For small businesses, the cost will
spread across smaller sales volumes,
making recuperation of the testing
investment more difficult. Some
manufacturers thought that compliance
testing costs alone could force small
manufacturers to exit the industry.
Additionally, small manufacturers
indicated that they face a significant
price disadvantage for foaming agents
(used for insulation) and components
due to their small purchasing quantities
when compared to large manufacturers.
Any standard that requires small
manufacturers to use more foam or more
expensive components will exacerbate
the pricing gap. Given the pricesensitive nature and low margin of the
industry, the small envelope
manufacturers were concerned that
requiring thicker panels provided a
competitive advantage to large
manufacturers that could obtain
foaming agents at a lower price based on
order quantities that are of larger
magnitude.
Several interviewed manufacturers
expressed concern that the current
tightness in financial markets and
reduced economic activity could
negatively impact their ability to obtain
the financing necessary to cover
compliance costs, particularly for small
business operations, which generally
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have greater difficulty obtaining
financing.
DOE has examined the impact on
small manufacturers in its manufacturer
sub-group analysis and regulatory
flexibility analysis. For the results of
these analyses, see sections V.B.2.d and
VI.B.
f. Refrigerant Phase-Out
Interviewed manufacturers noted the
impacts of mandated changes in
blowing agents and refrigerants.
Currently, walk-in manufacturers use
HFC–404 and HFC–134a refrigerants.
While HFC–404 is used exclusively as a
refrigerant, HFC–134a is used as both a
refrigerant and a blowing agent in the
walk-in manufacturing industry.
Several manufacturers expressed
concern about the impact of a potential
phase-down or phase-out of HFCs. The
concern is acute because manufacturers
stated that there is no clear alternative
or substitute to HFCs for the industry.
Without a clear replacement,
manufacturers are concerned that any
phase-out would create a period of
uncertainty as the industry identifies
suitable alternatives and then redesigns
both products and processes around the
replacement. In the manufacturers’
experience, past phase-outs have led to
more expensive and less efficient
refrigerant replacements.
Panel manufacturers expressed
concern that conversion to a new
blowing agent would be costly as they
would have to go through a transition
period in which foam would need to be
reformulated. Production processes and
facilities would need to adapt to the
new foam blend. Manufactures stated
that previous, replacement blowing
agents have been more expensive and
have presented challenges to the
production process because of different
flow characteristics from the agents they
replace. They also noted that blowing
agent substitutes have led to foam
blends with lower R-value, providing
less insulation. Panel manufacturers
were concerned that lower insulation
effectiveness results in thicker panels
needed to meet a standard, which leads
to increased production cost and lower
profit margins.
Refrigeration system manufacturers
expressed that an HFC phase-out would
be costly as it would require redesign of
all products. Some manufacturers stated
that an HFC phase-out would force them
to use flammable refrigerants.
Manufacturers noted that some
alternative refrigerants may require
substantially larger systems to achieve
the same levels of performance.
As discussed in section IV.A.2.b, DOE
has only considered HFC refrigerants in
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55841
the analysis. DOE did not consider
whether foam blowing agents would
cost more, less or stay the same and
DOE understands there is a range of
non-HFC foam blowing used already in
these applications.
J. Employment Impact Analysis
Employment impacts are one factor
DOE considers in selecting an efficiency
standard. Employment impacts include
direct and indirect impacts. Direct
employment impacts are any changes
that affect employment of WICF
manufacturers. Indirect impacts are
those employment changes in the larger
economy that occur because of the shift
in expenditures and capital investment
caused by the purchase and operation of
more efficient walk-ins. The MIA results
in section V.B.2.b of this notice and
chapter 12 of the TSD address only the
direct employment impacts on walk-in
manufacturers. Chapter 13 of the TSD
provides further information about
other, primarily indirect, employment
impacts discussed in this section.
Indirect employment impacts from
WICF standards consist of the net jobs
created or eliminated in the national
economy, excluding the manufacturing
sector being regulated, as a consequence
of (1) reduced spending by end-users on
electricity, which could potentially be
offset by the increased spending on
maintenance and repair of higher
efficiency equipment); (2) reduced
spending on new energy supply by the
utility industry; (3) increased spending
on the purchase price of new walk-in
coolers and freezers; and (4) the effects
of those three factors throughout the
economy. DOE expects the net monetary
savings from standards to stimulate
other forms of economic activity. DOE
also expects these shifts in spending
and economic activity to affect the
demand for labor.
In developing this analysis in the
NOPR, DOE estimated indirect national
employment impacts using an input/
output model of the U.S. economy,
called ImSET (Impact of Sector Energy
Technologies) developed by DOE’s
Building Technologies Program. ImSET
is a personal-computer based, economic
analysis model that characterizes the
interconnections among 188 sectors of
the economy as national input/output
structural matrices using data from the
U.S. Department of Commerce’s 1997
Benchmark U.S. input-output table. The
ImSET model estimates changes in
employment, industry output, and wage
income in the overall U.S. economy
resulting from changes in expenditures
in various sectors of the economy. DOE
estimated changes in expenditures using
the NIA model. ImSET then estimated
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the net national indirect employment
impacts efficiency standards would
have on employment by sector.
The ImSET input/output model
suggests that the proposed standards
could increase the net demand for labor
in the economy, and the gains would
most likely be very small relative to
total national employment. For more
details on the employment impact
analysis and its results, see chapter 13
of the TSD and section IV.J of this
notice.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
K. Utility Impact Analysis
The utility impact analysis estimates
several important effects on the utility
industry of the adoption of new or
amended standards. For this analysis,
DOE used the NEMS–BT model to
generate forecasts of electricity
consumption, electricity generation by
plant type, and electric generating
capacity by plant type, that would result
from each considered TSL. DOE
obtained the energy savings inputs
associated with efficiency
improvements to considered products
from the NIA. DOE conducts the utility
impact analysis as a scenario that
departs from the latest AEO Reference
case. In the analysis for today’s rule, the
estimated impacts of standards are the
differences between values forecasted
by NEMS–BT and the values in the
AEO2013 Reference case. For more
details on the utility impact analysis,
see chapter 14 of the TSD.
L. Emissions Analysis
In the emissions analysis, DOE
estimates the reduction in power sector
emissions of carbon dioxide (CO2),
nitrogen oxides (NOX), sulfur dioxide
(SO2), and mercury (Hg) from potential
energy conservation standards for walkin coolers and freezers. In addition, DOE
estimates emissions impacts in
production activities (extracting,
processing, and transporting fuels) that
provide the energy inputs to power
plants. These are referred to as
‘‘upstream’’ emissions. Together, these
emissions account for the full-fuel-cycle
(FFC). In accordance with DOE’s FFC
Statement of Policy (76 FR 51282 (Aug.
18, 2011)), the FFC analysis includes
impacts on emissions of methane (CH4)
and nitrous oxide (N2O), both of which
are recognized as greenhouse gases.
DOE conducted the emissions
analysis using emissions factors that
were derived from data in EIA’s Annual
Energy Outlook 2013 (AEO 2013),
supplemented by data from other
sources. DOE developed separate
emissions factors for power sector
emissions and upstream emissions. The
method that DOE used to derive
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emissions factors is described in chapter
15 of the NOPR TSD.
EIA prepares the Annual Energy
Outlook using the National Energy
Modeling System (NEMS). Each annual
version of NEMS incorporates the
projected impacts of existing air quality
regulations on emissions. AEO 2013
generally represents current legislation
and environmental regulations,
including recent government actions, for
which implementing regulations were
available as of December 31, 2011.
SO2 emissions from affected electric
generating units (EGUs) are subject to
nationwide and regional emissions capand-trade programs. Title IV of the
Clean Air Act sets an annual emissions
cap on SO2 for affected EGUs in the 48
contiguous States and the District of
Columbia (DC). SO2 emissions from 28
eastern states and DC were also limited
under the Clean Air Interstate Rule
(CAIR; 70 FR 25162 (May 12, 2005)),
which created an allowance-based
trading program that operates along
with the Title IV program. CAIR was
remanded to the U.S. Environmental
Protection Agency (EPA) by the U.S.
Court of Appeals for the District of
Columbia Circuit but it remained in
effect. See North Carolina v. EPA, 550
F.3d 1176 (DC Cir. 2008); North
Carolina v. EPA, 531 F.3d 896 (DC Cir.
2008). On August 21, 2012, the DC
Circuit issued a decision to vacate
CSAPR. See EME Homer City
Generation, LP v. EPA, 696 F.3d 7, 38
(DC Cir. 2012). The court ordered EPA
to continue administering CAIR. The
AEO 2013 emissions factors used for
today’s NOPR assume that CAIR
remains a binding regulation through
2040.
The attainment of emissions caps is
typically flexible among EGUs and is
enforced through the use of emissions
allowances and tradable permits. Under
existing EPA regulations, any excess
SO2 emissions allowances resulting
from the lower electricity demand
caused by the adoption of an efficiency
standard could be used to permit
offsetting increases in SO2 emissions by
any regulated EGU. In past rulemakings,
DOE recognized that there was
uncertainty about the effects of
efficiency standards on SO2 emissions
covered by the existing cap-and-trade
system, but it concluded that negligible
reductions in power sector SO2
emissions would occur as a result of
standards.
Beginning in 2015, however, SO2
emissions will fall as a result of the
Mercury and Air Toxics Standards
(MATS) for power plants, which were
announced by EPA on December 21,
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2011. 77 FR 9304 (Feb. 16, 2012).23 In
the final MATS rule, EPA established a
standard for hydrogen chloride as a
surrogate for acid gas hazardous air
pollutants (HAP), and also established a
standard for SO2 (a non-HAP acid gas)
as an alternative equivalent surrogate
standard for acid gas HAP. The same
controls are used to reduce HAP and
non-HAP acid gas; thus, SO2 emissions
will be reduced as a result of the control
technologies installed on coal-fired
power plants to comply with the MATS
requirements for acid gas. AEO 2013
assumes that, in order to continue
operating, coal plants must have either
flue gas desulfurization or dry sorbent
injection systems installed by 2015.
Both technologies, which are used to
reduce acid gas emissions, also reduce
SO2 emissions. Under the MATS, NEMS
shows a reduction in SO2 emissions
when electricity demand decreases (e.g.,
as a result of energy efficiency
standards). Emissions will be far below
the cap that would be established by
CSAPR, so it is unlikely that excess SO2
emissions allowances resulting from the
lower electricity demand would be
needed or used to permit offsetting
increases in SO2 emissions by any
regulated EGU. Therefore, DOE believes
that efficiency standards will reduce
SO2 emissions in 2015 and beyond.
CSAPR established a cap on NOX
emissions in 28 eastern States and the
District of Columbia. Energy
conservation standards are expected to
have little effect on NOX emissions in
those States covered by CSAPR because
excess NOX emissions allowances
resulting from the lower electricity
demand could be used to permit
offsetting increases in NOX emissions.
However, standards would be expected
to reduce NOX emissions in the States
not affected by the caps, so DOE
estimated NOX emissions reductions
from the standards considered in
today’s NOPR for these States.
The MATS limit mercury emissions
from power plants, but they do not
include emissions caps and, as such,
DOE’s energy conservation standards
would likely reduce Hg emissions. DOE
estimated mercury emissions reduction
using emissions factors based on AEO
2013, which incorporates the MATS.
23 On July 20, 2012, EPA announced a partial
stay, for a limited duration, of the effectiveness of
national new source emission standards for
hazardous air pollutants from coal- and oil-fired
electric utility steam generating units. https://
www.epa.gov/airquality/powerplanttoxics/pdfs/
20120727staynotice.pdf.
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M. Monetizing Carbon Dioxide and
Other Emissions Impacts
As part of the development of this
amended rule, DOE considered the
estimated monetary benefits likely to
result from the reduced emissions of
CO2 and NOX that are expected to result
from each of the TSLs considered. In
order to make this calculation similar to
the calculation of the NPV of consumer
benefit, DOE considered the reduced
emissions expected to result over the
lifetime of products shipped in the
forecast period for each TSL. This
section summarizes the basis for the
monetary values used for each of these
emissions and presents the values
considered in this rulemaking.
For today’s NOPR, DOE is relying on
a set of values for the social cost of
carbon (SCC) that was developed by an
interagency process. A summary of the
basis for these values is provided below,
and a more detailed description of the
methodologies used is provided as an
appendix to chapter 16 of the TSD.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
1. Social Cost of Carbon
The SCC is an estimate of the
monetized damages associated with an
incremental increase in carbon
emissions in a given year. It is intended
to include (but is not limited to) changes
in net agricultural productivity, human
health, property damages from
increased flood risk, and the value of
ecosystem services. Estimates of the
SCC are provided in dollars per metric
ton of carbon dioxide. A domestic SCC
value is meant to reflect the value of
damages in the United States resulting
from a unit change in carbon dioxide
emissions, while a global SCC value is
meant to reflect the value of damages
worldwide.
Under section 1(b) of Executive Order
12866, agencies must, to the extent
permitted by law, ‘‘assess both the costs
and the benefits of the intended
regulation and, recognizing that some
costs and benefits are difficult to
quantify, propose or adopt a regulation
only upon a reasoned determination
that the benefits of the intended
regulation justify its costs.’’ The purpose
of the SCC estimates presented here is
to allow agencies to incorporate the
monetized social benefits of reducing
CO2 emissions into cost-benefit analyses
of regulatory actions that have small, or
‘‘marginal,’’ impacts on cumulative
global emissions. The estimates are
presented with an acknowledgement of
the many uncertainties involved and
with a clear understanding that they
should be updated over time to reflect
increasing knowledge of the science and
economics of climate impacts.
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As part of the interagency process that
developed these SCC estimates,
technical experts from numerous
agencies met on a regular basis to
consider public comments, explore the
technical literature in relevant fields,
and discuss key model inputs and
assumptions. The main objective of this
process was to develop a range of SCC
values using a defensible set of input
assumptions grounded in the existing
scientific and economic literatures. In
this way, key uncertainties and model
differences transparently and
consistently inform the range of SCC
estimates used in the rulemaking
process.
a. Monetizing Carbon Dioxide Emissions
When attempting to assess the
incremental economic impacts of carbon
dioxide emissions, the analyst faces a
number of serious challenges. A report
from the National Research Council 24
points out that any assessment will
suffer from uncertainty, speculation,
and lack of information about (1) future
emissions of greenhouse gases, (2) the
effects of past and future emissions on
the climate system, (3) the impact of
changes in climate on the physical and
biological environment, and (4) the
translation of these environmental
impacts into economic damages. As a
result, any effort to quantify and
monetize the harms associated with
climate change will raise serious
questions of science, economics, and
ethics and should be viewed as
provisional.
Despite the serious limits of both
quantification and monetization, SCC
estimates can be useful in estimating the
social benefits of reducing carbon
dioxide emissions. Most Federal
regulatory actions can be expected to
have marginal impacts on global
emissions. For such policies, the agency
can estimate the benefits from reduced
(or costs from increased) emissions in
any future year by multiplying the
change in emissions in that year by the
SCC value appropriate for that year. The
net present value of the benefits can
then be calculated by multiplying each
of these future benefits by an
appropriate discount factor and
summing across all affected years. This
approach assumes that the marginal
damages from increased emissions are
constant for small departures from the
baseline emissions path, an
approximation that is reasonable for
policies that have effects on emissions
24 National Research Council. Hidden Costs of
Energy: Unpriced Consequences of Energy
Production and Use. National Academies Press:
Washington, DC (2009).
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that are small relative to cumulative
global carbon dioxide emissions. For
policies that have a large (non-marginal)
impact on global cumulative emissions,
there is a separate question of whether
the SCC is an appropriate tool for
calculating the benefits of reduced
emissions. This concern is not
applicable to this notice, however.
It is important to emphasize that the
interagency process is committed to
updating these estimates as the science
and economic understanding of climate
change and its impacts on society
improves over time. In the meantime,
the interagency group will continue to
explore the issues raised by this analysis
and consider public comments as part of
the ongoing interagency process.
b. Social Cost of Carbon Values Used in
Past Regulatory Analyses
Economic analyses for Federal
regulations have used a wide range of
values to estimate the benefits
associated with reducing carbon dioxide
emissions. The model year 2011
Corporate Average Fuel Economy final
rule, the U.S. Department of
Transportation (DOT) used both a
‘‘domestic’’ SCC value of $2 per metric
ton of CO2 and a ‘‘global’’ SCC value of
$33 per metric ton of CO2 for 2007
emission reductions (in 2007$),
increasing both values at 2.4 percent per
year. DOT also included a sensitivity
analysis at $80 per metric ton of CO2.25
A 2008 regulation proposed by DOT
assumed a domestic SCC value of $7 per
metric ton of CO2 (in 2006$) for 2011
emission reductions (with a range of $0–
$14 for sensitivity analysis), also
increasing at 2.4 percent per year.26 A
regulation for packaged terminal air
conditioners and packaged terminal
heat pumps finalized by DOE in 2008
used a domestic SCC range of $0 to $20
per metric ton CO2 for 2007 emission
reductions (in 2007$). 73 FR 58772,
58814 (Oct. 7, 2008) In addition, EPA’s
2008 Advance Notice of Proposed
Rulemaking on Regulating Greenhouse
Gas Emissions Under the Clean Air Act
identified what it described as ‘‘very
preliminary’’ SCC estimates subject to
revision. 73 FR 44354 (July 30, 2008).
EPA’s global mean values were $68 and
25 See Average Fuel Economy Standards
Passenger Cars and Light Trucks Model Year 2011,
74 FR 14196 (March 30, 2009) (Final Rule); Final
Environmental Impact Statement Corporate Average
Fuel Economy.
26 See, Average Fuel Economy Standards,
Passenger Cars and Light Trucks, Model Years
2011–2015, 73 FR 24352 (May 2, 2008) (Proposed
Rule); Draft Environmental Impact Statement
Corporate Average Fuel Economy Standards,
Passenger Cars and Light Trucks, Model Years
2011–2015 at 3–58 (June 2008) (Available at:
https://www.nhtsa.gov/fuel-economy)
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$40 per metric ton CO2 for discount
rates of approximately 2 percent and 3
percent, respectively (in 2006$ for 2007
emissions).
In 2009, an interagency process was
initiated to offer a preliminary
assessment of how best to quantify the
benefits from reducing carbon dioxide
emissions. To ensure consistency in
how benefits are evaluated across
agencies, the Administration sought to
develop a transparent and defensible
method, specifically designed for the
rulemaking process, to quantify avoided
climate change damages from reduced
CO2 emissions. The interagency group
did not undertake any original analysis.
Instead, it combined SCC estimates from
the existing literature to use as interim
values until a more comprehensive
analysis could be conducted. The
outcome of the preliminary assessment
by the interagency group was a set of
five interim values: global SCC
estimates for 2007 (in 2006$) of $55,
$33, $19, $10, and $5 per metric ton of
CO2. These interim values represented
the first sustained interagency effort
within the U.S. government to develop
an SCC for use in regulatory analysis.
The results of this preliminary effort
were presented in several proposed and
final rules.
c. Current Approach and Key
Assumptions
Since the release of the interim
values, the interagency group
reconvened on a regular basis to
generate improved SCC estimates.
Specifically, the group considered
public comments and further explored
the technical literature in relevant
fields. The interagency group relied on
three integrated assessment models
commonly used to estimate the SCC: the
FUND, DICE, and PAGE models. These
models are frequently cited in the peerreviewed literature and were used in the
last assessment of the Intergovernmental
Panel on Climate Change. Each model
was given equal weight in the SCC
values that were developed.
Each model takes a slightly different
approach to model how changes in
emissions result in changes in economic
damages. A key objective of the
interagency process was to enable a
consistent exploration of the three
models while respecting the different
approaches to quantifying damages
taken by the key modelers in the field.
An extensive review of the literature
was conducted to select three sets of
input parameters for these models:
climate sensitivity, socio-economic and
emissions trajectories, and discount
rates. A probability distribution for
climate sensitivity was specified as an
input into all three models. In addition,
the interagency group used a range of
scenarios for the socio-economic
parameters and a range of values for the
discount rate. All other model features
were left unchanged, relying on the
model developers’ best estimates and
judgments.
The interagency group selected four
sets of SCC values for use in regulatory
analyses. Three sets of values are based
on the average SCC from the three
integrated assessment models, at
discount rates of 2.5, 3, and 5 percent.
The fourth set, which represents the
95th percentile SCC estimate across all
three models at a 3-percent discount
rate, is included to represent higherthan-expected impacts from temperature
change further out in the tails of the
SCC distribution. The values estimated
for 2010 grow in real terms over time,
as depicted in Table IV–17.
Additionally, the interagency group
determined that a range of values from
7 percent to 23 percent should be used
to adjust the global SCC to calculate
domestic effects,27 although preference
is given to consideration of the global
benefits of reducing CO2 emissions.
Table IV–17 presents the values in the
2010 interagency group report,28 which
is reproduced in appendix 16–A of the
NOPR TSD.
TABLE IV–17—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050
[In 2007 dollars per metric ton]
Discount rate
5%
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2.5%
3%
Average
2010
2015
2020
2025
2030
2035
2040
2045
2050
3%
Average
Average
95th
percentile
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.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
4.7
5.7
6.8
8.2
9.7
11.2
12.7
14.2
15.7
21.4
23.8
26.3
29.6
32.8
36.0
39.2
42.1
44.9
35.1
38.4
41.7
45.9
50.0
54.2
58.4
61.7
65.0
64.9
72.8
80.7
90.4
100.0
109.7
119.3
127.8
136.2
The SCC values used for today’s
notice were generated using the most
recent versions of the three integrated
assessment models that have been
published in the peer-reviewed
literature.29 Table IV–18 shows the
updated sets of SCC estimates in five
year increments from 2010 to 2050. The
full set of annual SCC estimates between
2010 and 2050 is reported in appendix
16–A of the NOPR TSD. The central
value that emerges is the average SCC
across models at the 3 percent discount
rate. However, for purposes of capturing
the uncertainties involved in regulatory
impact analysis, the interagency group
emphasizes the importance of including
all four sets of SCC values.
27 It is recognized that this calculation for
domestic values is approximate, provisional, and
highly speculative. There is no a priori reason why
domestic benefits should be a constant fraction of
net global damages over time.
28 Social Cost of Carbon for Regulatory Impact
Analysis Under Executive Order 12866. Interagency
Working Group on Social Cost of Carbon, United
States Government, February 2010. https://
www.whitehouse.gov/sites/default/files/omb/
inforeg/for-agencies/Social-Cost-of-Carbon-forRIA.pdf.
29 Technical Update of the Social Cost of Carbon
for Regulatory Impact Analysis Under Executive
Order 12866. Interagency Working Group on Social
Cost of Carbon, United States Government. May
2013. https://www.whitehouse.gov/sites/default/
files/omb/inforeg/social_cost_of_carbon_for_ria_
2013_update.pdf.
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TABLE IV–18—ANNUAL SCC VALUES FROM 2013 INTERAGENCY UPDATE, 2010–2050
[In 2007 dollars per metric ton CO2]
Discount rate %
5
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2010
2015
2020
2025
2030
2035
2040
2045
2050
3
2.5
3
Average
Year
Average
Average
95th
percentile
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
.................................................................................................................................
It is important to recognize that a
number of key uncertainties remain, and
that current SCC estimates should be
treated as provisional and revisable
since they will evolve with improved
scientific and economic understanding.
The interagency group also recognizes
that the existing models are imperfect
and incomplete. The National Research
Council report mentioned above points
out that there is tension between the
goal of producing quantified estimates
of the economic damages from an
incremental ton of carbon and the limits
of existing efforts to model these effects.
There are a number of concerns and
problems that should be addressed by
the research community, including
research programs housed in many of
the Federal agencies participating in the
interagency process to estimate the SCC.
The interagency group intends to
periodically review and reconsider
those estimates to reflect increasing
knowledge of the science and
economics of climate impacts, as well as
improvements in modeling.
In summary, in considering the
potential global benefits resulting from
reduced CO2 emissions, DOE used the
values from the 2013 interagency report,
adjusted to 2012$ using the GDP price
deflator. For each of the four cases
specified, the values used for emissions
in 2015 were $12.9, $40.8, $62.2, and
$117 per metric ton avoided (values
expressed in 2012$). DOE derived
values after 2050 using the relevant
growth rates for the 2040–2050 period
in the interagency update.
DOE multiplied the CO2 emissions
reduction estimated for each year by the
SCC value for that year in each of the
four cases. To calculate a present value
of the stream of monetary values, DOE
discounted the values in each of the
four cases using the specific discount
rate that had been used to obtain the
SCC values in each case.
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2. Valuation of Other Emissions
Reductions
DOE investigated the potential
monetary benefit of reduced NOX
emissions from the potential standards
it considered. As noted above, DOE has
taken into account how new or
amended energy conservation standards
would reduce NOX emissions in those
22 states not affected by the CAIR. DOE
estimated the monetized value of NOX
emissions reductions resulting from
each of the TSLs considered for today’s
NOPR based on estimates found in the
relevant scientific literature. Available
estimates suggest a very wide range of
monetary values per ton of NOX from
stationary sources, ranging from $468 to
$4809 per ton in 2012$).30 In
accordance with OMB guidance,31 DOE
calculated the monetary benefits using
each of the economic values for NOX
and real discount rates of 3 percent and
7 percent.
DOE is evaluating appropriate
monetization of SO2 and Hg emissions
in energy conservation standards
rulemakings. It has not included
monetization in the current analysis.
V. Analytical Results
A. Trial Standard Levels
As discussed in section III.B, DOE is
proposing to set separate performance
standards for the refrigeration system
and for the envelope’s doors and panels.
The manufacturers of these components
would be required to comply with the
applicable performance standards. For a
fully assembled WICF unit in service,
the aggregate energy consumption
30 For
additional information, refer to U.S. Office
of Management and Budget, Office of Information
and Regulatory Affairs, 2006 Report to Congress on
the Costs and Benefits of Federal Regulations and
Unfunded Mandates on State, Local, and Tribal
Entities, Washington, DC.
31 OMB, Circular A–4: Regulatory Analysis (Sept.
17, 2003).
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11
12
12
14
16
19
21
24
27
33
38
43
48
52
57
62
66
71
52
58
65
70
76
81
87
92
98
90
109
129
144
159
176
192
206
221
would depend on the individual
efficiency levels of both the refrigeration
system and the components of the
envelope.
The refrigeration system removes heat
from the interior of the envelope and
accounts for most of the walk-in’s
energy consumption. However, the
refrigeration system and envelope
interact with each other and affect each
other’s energy performance. On the one
hand, because the envelope components
reduce the transmission of heat from the
exterior to the interior of the walk-in,
the energy savings benefit for any
efficiency improvement for these
envelope components depends on the
efficiency level of the refrigeration
system. Thus, any potential standard
level for the refrigeration system would
affect the energy that could be saved
through standards for the envelope
components. On the other hand, the
economics of higher-efficiency
refrigeration systems depend on the
refrigeration load profile of the WICF
unit as a whole, which is partially
impacted by the envelope components.
To accurately characterize the total
benefits and burdens for each of its
proposed standard levels, DOE
developed TSLs that each consist of a
combination of standard levels for both
the refrigeration system and the set of
envelope components that comprise a
walk-in. In other words, each TSL DOE
proposes in this NOPR consists of a
standard for refrigeration systems, a
standard for panels, a standard for nondisplay doors, and a standard for
display doors.
1. Trial Standard Level Selection
Process
The paragraphs that follow describe
how DOE selected the TSLs. First, DOE
selected seven potential levels for
refrigeration systems by performing LCC
and NIA analyses for refrigeration
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each corresponding to an added
applicable design option (described in
section IV.C). DOE also analyzed three
competing compressor technologies for
each dedicated condensing refrigeration
system class. These compressor
technologies are: hermetic reciprocating,
semi-hermetic, and scroll.
At a given efficiency level, the
compressor with the best life-cycle cost
result was selected to represent the
equipment at that efficiency level. From
the set of possible efficiency levels for
a given class, DOE selected seven for
further analysis. For analyzed
equipment having less than seven
engineering design options (e.g., in the
multiplex refrigeration system classes),
the same efficiency level appeared more
than once in the suite of seven
efficiency levels. Five of the seven
refrigeration system levels were based
on their relative energy saving potential.
The other two were based on
maximizing the national net present
value (‘‘Max NPV’’), and on achieving
the maximum energy savings that is
possible using all of the compressor
technologies (‘‘All Compressors’’).
DOE decided to include an allcompressors criterion for the
refrigeration systems in response to
stakeholder comments that DOE did not
consider all types of compressors in the
TABLE V–1—REFRIGERATION
preliminary analysis (these comments
EQUIPMENT CLASS CAPACITIES
were discussed in sections IV.C.4.b and
IV.C.5.b). In particular, interested
Analyzed
parties noted that the choice of
Equipment class
capacities
compressor could affect the potential
(kBtu/hr)
energy savings, but that it was
DC.M.I, < 9,000 ........................
6 inappropriate to treat compressor choice
DC.M.I, ≥ 9,000 ........................
18 as a design option because not all
DC.M.O, < 9,000 ......................
6 compressor types are available at all
DC.M.O, ≥ 9,000 ......................
18,54 capacities for all types of equipment. In
DC.L.I, < 9,000 .........................
6 response to these comments, DOE
DC.L.I, ≥ 9,000 .........................
9
developed performance curves in the
DC.L.O, < 9,000 .......................
6
DC.L.O, ≥ 9,000 .......................
9,54 engineering analysis for refrigeration
MC.M ........................................
9 systems with each compressor type
MC.L .........................................
9 independently—identifying the
maximum efficiency level for systems
DOE enumerated seven potential
with each compressor type. The highest
levels for each of the refrigeration
refrigeration system efficiency level that
system classes. Each analyzed capacity
could be obtained by any compressor
point in any refrigeration system class
type for a given capacity unit was
has between 3 and 13 efficiency levels,
identified. In its set of TSL options, DOE
systems. Second, DOE selected four
levels for the envelope components by
performing LCC and NIA analyses for
the envelope components paired with
each of the seven selected refrigeration
system levels alone. Third, DOE chose
six composite TSLs from the
combinations of the seven potential
levels for the refrigeration systems and
the four potential levels for the envelope
components. This process accounts for
the fact that, as described above, the
choice of refrigeration efficiency level
affects the energy savings and NPV of
the envelope component levels. These
steps are described below.
In selecting potential levels for the
refrigeration systems, DOE focused on
certain capacity points in the range it
considered in the engineering analysis.
(For a list of all points considered in the
engineering analysis, see section
IV.C.1.b.) In selecting the refrigeration
capacity points for further analysis, DOE
chose capacities with the highest
relative shares of shipments in each
equipment class. The proposed standard
levels for each equipment class were
then based on the analyzed capacities in
each capacity range. The cost-efficiency
tradeoff for the design options is similar
over the range of sizes analyzed in the
engineering analysis.
included a highest efficiency level for
the refrigeration systems at which all
compressor technologies can compete
(‘‘All Compressors’’). See chapter 10 of
the TSD for further details on DOE’s
process for selecting potential TSLs.
After the seven potential efficiency
levels for each refrigeration system class
were selected as described above, DOE
proceeded with the LCC and NIA
analysis of the envelope components
(panels and doors). DOE conducted the
LCC and NIA analyses on the envelope
components by pairing them with each
of the seven refrigeration system
efficiency levels. Each panel and door
class has between five and nine
potential efficiency levels, each
corresponding to an engineering design
option applicable to that class
(described in section IV.C). These LCC
and NPV results represent the entire
range of the economic benefits to the
consumer at various combinations of
efficiency levels of the refrigeration
systems and the envelope components.
The pairing of refrigeration system
efficiency levels with the efficiency
levels of envelope component classes is
discussed in detail in chapter 10 of the
TSD.
DOE selected envelope component
levels for further analysis based on the
following criteria: maximum NPV,
maximum NES with positive NPV, and
Max Tech. DOE also considered a fourth
criterion: maximum NES with positive
NPV for display doors only, and no new
standard for panels and non-display
doors. DOE considered this level
because it observed that, due to the
nature of the panel and non-display
door industry, any standard could have
a large effect on small panel and door
manufacturers. This effect is described
in detail in chapter 12 of the TSD,
Manufacturer Impact Analysis.
Finally, DOE chose six composite
TSLs by selecting from the
combinations of the seven potential
levels for the refrigeration systems and
the four potential levels for the envelope
components. The composite TSLs and
criteria for each one are shown in Table
V–2.
TABLE V–2—CRITERIA DESCRIPTION FOR THE COMPOSITE TSLS
Refrigeration system criteria
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Component criteria
All compressors
Max NPV
Display Doors Only ............
...........................................
Maximum NPV ...................
1: All compressors, max
NPV.
2: All display doors only at
NPV>0.
4: Maximum NPV for both
refrigeration system and
components.
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TABLE V–2—CRITERIA DESCRIPTION FOR THE COMPOSITE TSLS—Continued
Refrigeration system criteria
Component criteria
All compressors
Max NPV
Max NES with NPV>0 *
Maximum NES with NPV>0
3: All compressors, NPV>0
...........................................
Max–Tech ..........................
...........................................
...........................................
5: Max NES with NPV>0
for both Refrigeration
system and Components.
...........................................
Max tech
6: Max-tech for both Refrigeration system and
Components.
* Not counted as a separate efficiency level for the refrigeration system, as it corresponds to the Max Tech level in the current analysis.
corresponds to the efficiency level with
the maximum NPV for refrigeration
system classes and the efficiency level
with the maximum NPV for envelope
component classes. TSL 3 is the highest
efficiency level for refrigeration systems
at which all compressor technologies
can compete, combined with the
maximum efficiency level with a
positive NPV at a 7-percent discount
rate for each envelope component. TSL
2 is the efficiency level with the
maximum NPV at a 7-percent discount
rate for refrigeration systems, combined
with the efficiency level with a
maximum NPV at a 7-percent discount
rate for display doors only, and does not
include a new energy standard for
panels and non-display doors. DOE is
considering TSL 2 because a standard
for panels and non-display doors may
be unduly burdensome to a large
number of small business manufacturers
(see sections V.B.2.d and VI.B for
further discussion of the impact of the
rule on small manufacturers). TSL 1 is
the highest efficiency level for
refrigeration systems at which all
compressor technologies can compete,
combined with the efficiency level with
the maximum NPV at a 7-percent
discount rate for each envelope
component when the components are
combined with the selected refrigeration
efficiency level. For more details on the
criteria for the proposed TSLs, see
chapter 10 of the TSD.
The form of the equation allows the
efficiency requirements to be
determined for panels of any dimension
within an equipment class. Coefficients
A, B, and C were uniquely derived for
each equipment class by plotting the Ufactor of each representative size in an
equipment class versus the edge area to
core area ratio of the representative size
and modeling the relationship as a
polynomial equation. The core and edge
areas for both floor and structural panels
are defined in the walk-in cooler and
freezer test procedure final rule. 76 FR
at 33632 (June 9, 2011).
For display and non-display doors,
respectively, the normalization metric is
the surface area of the door. The TSLs
are expressed in terms of linear
equations that establish maximum daily
energy consumption (MEC) limits in the
form of:
MEC = D × (Surface Area) + E
classes based DOE’s expectation that
small sized equipment may have
difficulty meeting the same efficiency
standard as large equipment (see section
IV.A.3.b for details). Specifically, DOE
observed that higher-capacity
equipment tended to be more efficient
because of the availability of scroll
compressors above a certain capacity.
DOE expressed the AWEF for large
capacity dedicated condensing systems
as a single value corresponding to the
AWEF of the lowest capacity system
analyzed in the large capacity class.
DOE expressed the AWEF for the small
capacity dedicated condensing systems
as a linear equation normalized to the
system gross capacity, where the
equation was based on the AWEFs for
the smallest two capacities analyzed but
adjusted such that the equation would
be continuous with the standard level
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Coefficients D and E were uniquely
derived for each equipment class by
plotting the energy consumption at a
given performance level versus the
surface area of the door and determining
the slope of the relationship, D, and the
offset, E, where the offset represents the
theoretical energy consumption of a
door with no surface area (the offset is
necessary because not all energyconsuming components of the door
scale directly with surface area). The
surface area is defined in the walk-in
cooler and freezer test procedure final
rule. 76 FR at 33632.
For refrigeration systems, the
proposed TSLs are expressed as a
minimum efficiency level (AWEF) that
the system must meet. For dedicated
condensing systems, DOE calculated the
AWEF differently for small and large
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2. Trial Standard Level Equations
For panels and doors, DOE expresses
the TSLs in terms of a normalization
metric. For panels, the normalization
metric is the ratio of the edge area to the
core area. The TSLs are expressed in
terms of polynomial equations that
establish maximum U-factor limits in
the form of:
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In Table V–2, the column headings
identify the criteria for the TSL option
for the refrigeration system and the row
headings identify the criteria for the
TSL option for the envelope
components. The intersection of the row
and the column define the respective
choices for the composite TSL. The
composite TSLs are numbered from 1 to
6 in order of least to most energy
savings.
DOE describes each TSL, from highest
to lowest energy savings, as follows.
TSL 6 is the max-tech level for each
equipment class for all components.
TSL 5 represents the maximum
efficiency level of the refrigeration
system equipment classes with a
positive NPV at a 7-percent discount
rate, combined with the maximum
efficiency level with a positive NPV at
a 7-percent discount rate for each
envelope component (panel, nondisplay door, or display door). TSL 4
Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
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for the large capacity class at the
boundary capacity point between the
classes (i.e., 9,000 Btu/h). DOE
calculated a single minimum efficiency
for each class of multiplex condensing
systems because DOE found that
equipment capacity did not have a
significant effect on the efficiency of the
equipment. See appendix 10D of the
TSD for further details on how the
AWEF values were calculated. DOE
requests comment on the AWEF
equations and the methodology for
determining them. In particular, DOE
asks interested parties to submit data on
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how the efficiency of typical
refrigeration systems varies by capacity.
Based on comments and additional data
DOE receives on the NOPR, DOE may
consider other methods of calculating
the minimum AWEF associated with the
TSLs for each equipment class.
The following tables present the
equations and AWEFs for all TSLs
under consideration. Table V–3, Table
V–4, Table V–5, Table V–6, Table V–7,
and Table V–8 show the standards
equations for structural cooler panels,
structural freezer panels, freezer floor
panels, display doors, non-display
passage doors, and non-display freight
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doors, respectively. Table V–9 shows
the AWEFs for refrigeration systems and
indicates that the equations and AWEFs
for a particular class of equipment may
be the same across more than one TSL.
This occurs when the criteria for two
different TSLs are satisfied by the same
efficiency level for a particular
component. For example, for all
refrigeration classes the max-tech level
has a positive NPV; thus, the efficiency
level with the maximum energy savings
with positive NPV (TSL 5) is the same
as the efficiency level corresponding to
max-tech (TSL 6).
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TABLE V–6—EQUATIONS FOR ALL DISPLAY DOOR TSLS
Equations for maximum energy consumption
(kWh/day)
TSL
DD.M
Baseline ..................................................................................................................................
TSL 1 ......................................................................................................................................
TSL 2 ......................................................................................................................................
TSL 3 ......................................................................................................................................
TSL 4 ......................................................................................................................................
TSL 5 ......................................................................................................................................
TSL 6 ......................................................................................................................................
0.14 × Add + 0.82
0.049 × Add + 0.39
0.049 × Add + 0.39
0.049 × Add + 0.39
0.049 × Add + 0.39
0.049 × Add + 0.39
0.0080 × Add + 0.29
DD.L
0.36
0.33
0.33
0.06
0.33
0.33
0.11
×
×
×
×
×
×
×
Add
Add
Add
Add
Add
Add
Add
+
+
+
+
+
+
+
0.88
0.38
0.38
3.8
3.8
0.38
0.32
TABLE V–7—EQUATIONS FOR ALL PASSAGE DOOR TSLS
Equations for maximum energy consumption
(kWh/day)
TSL
PD.M
Baseline ..................................................................................................................................
TSL 1 ......................................................................................................................................
TSL 2 ......................................................................................................................................
TSL 3 ......................................................................................................................................
TSL 4 ......................................................................................................................................
TSL 5 ......................................................................................................................................
TSL 6 ......................................................................................................................................
0.0040 × And + 0.24
0.0032 × And + 0.22
0.0040 × And + 0.24
0.0032 × And + 0.22
0.0032 × And + 0.22
0.0032 × And + 0.22
0.00093 × And + 0.0083
PD.L
×
×
×
×
×
×
×
0.141
0.138
0.141
0.135
0.138
0.135
0.131
And
And
And
And
And
And
And
+
+
+
+
+
+
+
4.81
4.04
4.81
3.91
4.04
3.91
3.88
TABLE V–8—EQUATIONS FOR ALL FREIGHT DOOR TSLS
Equations for maximum energy consumption
(kWh/day)
TSL
FD.M
Baseline ..................................................................................................................................
TSL 1 ......................................................................................................................................
TSL 2 ......................................................................................................................................
TSL 3 ......................................................................................................................................
TSL 4 ......................................................................................................................................
TSL 5 ......................................................................................................................................
TSL 6 ......................................................................................................................................
0.0078 × And + 0.11
0.0073 × And + 0.082
0.0078 × And + 0.11
0.0073 × And + 0.082
0.0073 × And + 0.082
0.0073 × And + 0.082
0.00092 × And + 0.13
FD.L
0.12 × And + 5.6
0.11 × And + 5.3
0.12 × And + 5.6
0.10 × And + 5.2
0.11 × And + 5.4
0.10 × And + 5.2
0.094 × And + 5.2
TABLE V–9—AWEFS FOR ALL REFRIGERATION SYSTEM TSLS
Equations for minimum AWEF (Btu/W-h)
Equipment class
Baseline
tkelley on DSK3SPTVN1PROD with PROPOSALS2
DC.M.I, < 9,000 .............................
DC.M.I, ≥ 9,000 ..............................
DC.M.O, < 9,000 ............................
DC.M.O, ≥ 9,000 ............................
DC.L.I, < 9,000 ..............................
DC.L.I, ≥ 9,000 ...............................
DC.L.O, < 9,000 .............................
DC.L.O, ≥ 9,000 .............................
MC.M ..............................................
MC.L ...............................................
2.47
4.52
2.50
4.91
1.43
2.77
1.70
2.91
6.80
4.66
× 10¥4 × Q + 2.30
× 10¥4 × Q + 2.66
× 10¥4 × Q + 1.48
× 10¥4 × Q + 1.38
B. Economic Justification and Energy
Savings
1. Economic Impacts on Commercial
Customers
a. Life-Cycle Cost and Payback Period
Consumers affected by new or
amended standards usually incur higher
purchase prices and experience lower
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TSLs 1 and 3
4.37 ×
6.19
6.10 ×
9.06
1.10 ×
3.15
2.43 ×
4.35
10.82
5.91
10¥4 × Q + 2.26
10¥4 × Q + 3.57
10¥4 × Q + 2.16
10¥4 × Q + 2.16
TSLs 2 and 4
2.63 ×
6.90
1.34 ×
12.21
1.93 ×
3.63
5.70 ×
6.15
10.74
5.53
operating costs. DOE evaluates these
impacts on individual consumers by
calculating changes in LCC and the PBP
associated with the TSLs. Using the
approach described in section IV.F, DOE
calculated the LCC impacts and PBPs
for the efficiency levels considered in
this NOPR. Inputs used for calculating
the LCC include total installed costs
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10¥4 × Q + 4.53
10¥3 × Q + 0.12
10¥4 × Q + 1.89
10¥4 × Q + 1.02
TSLs 5 and 6
2.63 ×
6.90
9.23 ×
12.21
1.93 ×
3.67
4.53 ×
6.25
10.82
5.91
10¥4 × Q + 4.53
10¥4 × Q + 3.90
10¥4 × Q + 1.93
10¥4 × Q + 2.17
(i.e., equipment price plus installation
costs), annual energy savings, and
average electricity costs by consumer,
energy price trends, repair costs,
maintenance costs, equipment lifetime,
and consumer discount rates. DOE
based the LCC and PBP analyses on
energy consumption under conditions
of actual product use. DOE created
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distributions of values for some inputs,
with probabilities attached to each
value, to account for their uncertainty
and variability. DOE used probability
distributions to characterize equipment
lifetime, discount rates, sales taxes and
several other inputs to the LCC model.
The computer model DOE uses to
calculate the LCC and PBP, which
incorporates Crystal Ball (a
commercially available software
program), relies on a Monte Carlo
simulation to incorporate uncertainty
and variability into the analysis. The
Monte Carlo simulations randomly
sample input values from the
probability distributions of the input
variables and calculate the LCC and PBP
from these. Details of the spreadsheet
model, and of all the inputs to the LCC
and PBP analyses, are contained in TSD
chapter 8 and its appendices.
DOE’s LCC and PBP analysis results
for each refrigeration system are
reported in Table V–10 through Table
IV–14 at each TSL for the representative
sizes of walk-in refrigeration systems in
each equipment class. Each table
includes the installed cost, total LCC,
average LCC savings, the median
payback period, and also the percentage
of customers who will experience a
benefit, cost, or no change under a
proposed standard by performing a
Monte Carlo analysis. DOE noted that
for all classes of refrigeration systems,
consumer LCCs were positive up
through TSL 6, which corresponds to
the maximum technologically feasible
level (max-tech) refrigeration level. The
median PBP values vary between 2–6
years for the dedicated condensing unit
(DC) classes and were less than 1 year
for the multiplex classes for all TSLs for
medium temperature systems and for
TSL2 and TSL 4 for low temperature
systems. The median PBP exceeded 2
year only for the other TSLs considered.
55851
DOE also noted that higher benefits are
experienced by users of larger capacity
systems than by the smaller capacity
systems. The LCC savings and PBP for
all the sizes analyzed by DOE are shown
in TSD chapter 8.
DOE’s LCC and PBP analysis results
for all envelope component equipment
classes at each TSL are reported in
Table V–15 through Table V–17. DOE
analyzed three sizes (small, medium
and large) in each component
equipment class. Results for the
components of different sizes in the
equipment class are averaged on the
basis of their shipment weights and
reported in these tables. LCC and PBP
results for all sizes may be found in
chapter 8 of the TSD. Table V–10
through Table V–17 show that for all the
components, LCC savings are
significantly negative and payback
periods are very high at the max-tech
level (TSL 6).
TABLE V–10—SUMMARY LCC AND PBP RESULTS FOR MEDIUM TEMPERATURE DEDICATED CONDENSING REFRIGERATION
SYSTEMS—OUTDOOR CONDENSER
Life-cycle cost (2012$)
Trial standard level
Installed
cost
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
4,368
4,891
5,387
4,992
5,286
5,532
5,532
Discounted
operating
cost
Life-cycle cost savings (2012$)
LCC
7,363
5,791
4,766
5,622
4,936
4,591
4,591
11,731
10,682
10,153
10,614
10,222
10,123
10,123
% of Consumers that experience
Payback
period
(years)
Average
savings
Net cost
No impact
Net benefit
Median
....................
1,048
1,577
1,117
1,509
1,608
1,608
....................
0
0
0
0
1
1
....................
0
0
0
0
0
0
....................
100
100
100
100
99
99
....................
1.3
2.5
1.8
2.0
3.0
3.0
TABLE V–11—SUMMARY LCC AND PBP RESULTS FOR MEDIUM-TEMPERATURE DEDICATED CONDENSING REFRIGERATION
SYSTEMS—INDOOR CONDENSER
Life-cycle cost (2012$)
Trial standard level
Installed
cost
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
4,033
4,501
4,931
4,501
4,931
4,931
4,931
Discounted
operating
cost
Life-cycle cost savings (2012$)
LCC
7,746
6,998
6,238
6,998
6,238
6,238
6,238
11,779
11,499
11,169
11,499
11,169
11,169
11,169
% of Consumers that experience
Payback
period
(years)
Average
savings
Net cost
No impact
Net benefit
Median
....................
280
611
280
611
611
611
....................
1
4
1
4
4
4
....................
0
0
0
0
0
0
....................
99
96
99
96
96
96
....................
3.2
4.4
3.2
4.4
4.4
4.4
tkelley on DSK3SPTVN1PROD with PROPOSALS2
TABLE V–12—SUMMARY OF LCC AND PBP RESULTS FOR LOW-TEMPERATURE DEDICATED-CONDENSING REFRIGERATION
SYSTEMS—OUTDOOR CONDENSER
Life-cycle cost (2012$)
Trial standard level
Installed
cost
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
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operating
cost
Life-cycle cost savings (2012$)
LCC
10,471
8,564
6,791
8,564
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13,236
12,168
13,236
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% of Consumers that experience
Payback
period
(years)
Average
savings
Net cost
No impact
Net benefit
Median
....................
1,328
2,001
1,328
....................
5
5
5
....................
0
0
0
....................
95
95
95
....................
1.2
2.3
1.2
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TABLE V–12—SUMMARY OF LCC AND PBP RESULTS FOR LOW-TEMPERATURE DEDICATED-CONDENSING REFRIGERATION
SYSTEMS—OUTDOOR CONDENSER—Continued
Life-cycle cost (2012$)
Trial standard level
Installed
cost
TSL4 .................................
TSL5 .................................
TSL6 .................................
5,377
5,591
5,591
Discounted
operating
cost
Life-cycle cost savings (2012$)
LCC
6,791
6,584
6,584
12,168
12,175
12,175
Payback
period
(years)
% of Consumers that experience
Average
savings
Net cost
2,001
1,994
1,994
No impact
5
5
5
Net benefit
0
0
0
95
95
95
Median
2.3
2.8
2.8
TABLE V–13—SUMMARY OF LCC AND PBP RESULTS FOR LOW-TEMPERATURE DEDICATED-CONDENSING REFRIGERATION
SYSTEMS—INDOOR CONDENSER
Life-cycle cost (2012$)
Trial standard level
Installed
cost
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
4,161
4,688
5,187
4,688
5,187
5,272
5,272
Discounted
operating
cost
Life-cycle cost savings (2012$)
LCC
13,051
12,019
11,018
12,019
11,018
10,970
10,970
17,212
16,707
16,205
16,707
16,205
16,242
16,242
% of Consumers that experience
Payback
period
(years)
Average
savings
Net cost
No impact
Net benefit
Median
....................
505
1,117
505
1,117
1,080
1,080
....................
0
0
0
0
0
0
....................
0
0
0
0
0
0
....................
100
100
100
100
100
100
....................
2.8
2.7
2.8
2.7
3.1
3.1
TABLE V–14—SUMMARY LCC AND PBP RESULTS FOR MEDIUM- AND LOW-TEMPERATURE MULTIPLEX REFRIGERATION
SYSTEMS
[Unit coolers only]
Life-cycle cost (2012$)
Trial standard level
Efficiency
level
Installed
cost
Discounted
operating
cost
Life-cycle cost savings (2012$)
LCC
% of Consumers that experience
Average
savings
Payback
period
(years)
Net cost
No impact
Net benefit
Median
....................
0
0
0
0
0
0
....................
0
0
0
0
0
0
....................
100
100
100
100
100
100
....................
0.6
0.5
0.6
0.5
0.6
0.6
....................
0
0
0
0
0
0
....................
0
0
0
0
0
0
....................
100
100
100
100
100
100
....................
2.5
0.4
2.5
0.4
2.5
2.5
Medium Temperature Multiplex
..............
TSL1 .........
TSL2 .........
TSL3 .........
TSL4 .........
TSL5 .........
TSL6 .........
Baseline
EL2
EL2
EL2
EL2
EL3
EL3
1,583
2,251
2,231
2,251
2,231
2,251
2,251
6,143
3,759
3,771
3,759
3,771
3,759
3,759
7,726
6,010
6,002
6,010
6,002
6,010
6,010
....................
1,715
1,724
1,715
1,724
1,715
1,715
Low Temperature Multiplex
..............
TSL1 .........
TSL2 .........
TSL3 .........
TSL4 .........
TSL5 .........
TSL6 .........
Baseline
EL2
EL2
EL2
EL2
EL5
EL5
1,583
2,776
2,231
2,776
2,231
2,776
2,776
10,295
7,252
7,585
7,252
7,585
7,252
7,252
11,878
10,028
9,817
10,028
9,817
10,028
10,028
....................
1,849
2,061
1,849
2,061
1,849
1,849
TABLE V–15—SUMMARY LCC AND PBP RESULTS FOR STRUCTURAL AND FLOOR PANELS
[Weighted across all sizes]
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Life-cycle cost (2012$)
Trial standard level
Installed
cost
Discounted
operating
cost
Life-cycle cost savings (2012$)
LCC
% of Consumers that experience
Average
savings
Net cost
Payback
period
(years)
No impact
Net benefit
Median
....................
14
0
....................
0
100
....................
86
0
....................
3.8
0.0
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Medium Temperature Structural Panel
Baseline ...........................
TSL1 .................................
TSL2 .................................
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1,104
1,095
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TABLE V–15—SUMMARY LCC AND PBP RESULTS FOR STRUCTURAL AND FLOOR PANELS—Continued
[Weighted across all sizes]
Life-cycle cost (2012$)
Trial standard level
TSL3
TSL4
TSL5
TSL6
Installed
cost
.................................
.................................
.................................
.................................
Discounted
operating
cost
1,043
1,007
1,043
3,206
Life-cycle cost savings (2012$)
85
80
65
19
% of Consumers that experience
Average
savings
LCC
1,128
1,088
1,109
3,225
Payback
period
(years)
Net cost
¥9
8
¥22
¥2,139
No impact
Net benefit
Median
75
34
93
100
0
0
0
0
25
66
7
0
6.8
4.5
9.0
146.4
....................
2
0
79
7
94
100
....................
0
100
0
0
0
0
....................
98
0
21
93
6
0
....................
2.9
0.0
7.4
3.6
10.0
43.0
....................
0
100
0
0
0
0
....................
94
0
38
72
12
0
....................
3.5
0.0
6.0
4.5
8.0
48.7
Low Temperature Structural Panel
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
1,122
1,122
1,010
1,373
1,122
1,373
3,208
278
278
399
215
216
161
76
1,400
1,400
1,410
1,588
1,338
1,533
3,284
....................
122
0
¥66
72
¥140
¥1,890
Low Temperature Floor Panel
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
1,202
1,202
1,103
1,348
1,202
1,348
2,982
243
243
318
166
189
124
79
1,445
1,445
1,421
1,515
1,390
1,473
3,061
....................
66
0
¥4
30
¥65
¥1,653
....................
6
0
62
28
88
100
TABLE V–16—SUMMARY LCC AND PBP RESULTS FOR DISPLAY DOORS
[Weighted across all sizes]
Life-cycle cost (2012$)
Trial standard level
Installed
cost
Discounted
operating
cost
Life-Cycle Cost Savings (2012$)
% of consumers that experience
Average
savings
LCC
Net cost
Payback
period
(years)
No impact
Net benefit
Median
....................
0
0
0
0
0
0
....................
100
100
100
100
100
0
....................
2.1
2.2
2.1
2.2
2.2
37.6
....................
0
0
0
0
0
0
....................
100
100
36
100
100
0
....................
N/A
N/A
6.0
N/A
N/A
18.5
Medium Temperature Display Door
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
1,100
1,205
1,205
1,205
1,205
1,205
4,182
530
186
180
186
180
177
73
1,630
1,391
1,385
1,391
1,385
1,382
4,255
....................
239
228
239
228
222
¥2,650
....................
0
0
0
0
0
100
Low Temperature Display Door
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
1,594
1,756
1,756
2,046
1,756
1,756
4,242
1,412
1,033
954
972
954
942
371
3,006
2,789
2,710
3,019
2,710
2,698
4,613
....................
217
200
¥12
200
198
¥1,717
....................
0
0
64
0
0
100
TABLE V–17—SUMMARY LCC AND PBP RESULTS FOR NON-DISPLAY DOORS
tkelley on DSK3SPTVN1PROD with PROPOSALS2
[Weighted across all sizes]
Life-cycle cost (2012$)
Trial standard level
Installed
cost
Discounted
operating
cost
Life-cycle cost savings (2012$)
% of consumers that experience
Average
savings
LCC
Net cost
Payback
period
(years)
No impact
Net benefit
Median
....................
....................
....................
....................
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Medium Temperature Passage Door
Baseline ...........................
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TABLE V–17—SUMMARY LCC AND PBP RESULTS FOR NON-DISPLAY DOORS—Continued
[Weighted across all sizes]
Life-cycle cost (2012$)
Trial standard level
TSL1
TSL2
TSL3
TSL4
TSL5
TSL6
Installed
cost
.................................
.................................
.................................
.................................
.................................
.................................
Discounted
operating
cost
691
683
691
691
691
1,637
Life-cycle cost savings (2012$)
LCC
89
91
89
83
80
19
780
774
780
774
772
1,655
Payback
period
(years)
% of consumers that experience
Average
savings
Net cost
2
0
2
0
0
¥884
No impact
Net benefit
Median
27
0
27
52
64
100
0
100
0
0
0
0
73
0
73
48
36
0
4.5
0.0
4.5
5.5
6.0
78.7
....................
14
0
66
27
75
100
....................
0
100
0
0
0
0
....................
86
0
34
73
25
0
....................
4.3
0.0
6.2
4.7
7.0
18.3
....................
0
100
0
0
0
0
....................
75
0
75
50
38
0
....................
4.5
0.0
4.5
5.4
5.9
81.5
....................
0
100
0
0
0
0
....................
94
0
44
99
31
0
....................
3.8
0.0
5.8
2.9
6.5
21.7
Low Temperature Passage Door
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
1,070
1,070
880
1,226
1,070
1,226
1,863
2,205
2,205
2,261
2,138
2,020
1,937
1,913
3,274
3,274
3,142
3,364
3,090
3,163
3,776
....................
74
0
¥16
52
¥52
¥665
Medium Temperature Freight Door
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
1,277
1,277
1,265
1,277
1,277
1,277
2,511
147
143
144
143
131
126
49
1,424
1,420
1,409
1,420
1,408
1,403
2,560
....................
3
0
3
1
0
¥1,157
....................
25
0
25
50
62
100
Low Temperature Freight Door
Baseline ...........................
TSL1 .................................
TSL2 .................................
TSL3 .................................
TSL4 .................................
TSL5 .................................
TSL6 .................................
1,670
1,670
1,426
1,914
1,543
1,914
3,273
3,424
3,424
3,491
3,305
3,237
2,987
2,932
....................
152
0
28
136
¥32
¥1,337
....................
6
0
56
1
69
100
Using the LCC spreadsheet model,
DOE estimated the impact of increased
WICF efficiency standards at each TSL
on the following consumer subgroup:
small restaurants that purchase their
own walk-in units. These restaurants are
typically identified by the Small
Business Administration as restaurants
with annual receipts of $10 million or
less.32 The small restaurant subgroup
was analyzed because in the ‘‘food
service and drinking places’’ business
class in the 2007 Census,33 almost 60
percent of employment and sales can be
attributed to small restaurants and more
than 78 percent of these establishments
are considered small businesses.
Furthermore, DOE received comments
suggesting small restaurant owners
could be particularly vulnerable to
potential negative consequences of
higher efficiency standards and
potentially face shorter equipment
lifetimes. DOE’s LCC analysis shows
that restaurants had among the highest
financing costs (based on weighted
average cost of capital of entities using
walk-in coolers and freezers). Therefore,
this group was expected to have the
least LCC savings and longest PBP of
any identifiable consumer group.
DOE estimated the LCC and PBP for
the small restaurants subgroup. Table
V–18 and Table V–19 show the LCC
savings for refrigeration systems and
envelope component equipment,
respectively, which meet the proposed
energy conservation standards for the
small restaurant subgroup. Table V–20
and Table V–21 show the corresponding
PBPs (in years) for this subgroup.
For example, DOE’s analysis shows
that at TSL 4, structural cooler panels
for small restaurants have lower LCC
savings and longer payback periods than
other business types; however, LCC
savings values are still positive for this
subgroup at this TSL for panels. In
addition, payback periods are typically
increased by less than 10 percent
compared with the walk-in market as a
whole. For a more detailed discussion
on the LCC subgroup analysis and its
results, see chapter 11 of the TSD.
32 Small Business Administration. ‘‘Table of
Small business Size Standards.’’ SBA.gov. https://
www.sba.gov/content/guide-size-standards.
Accessed July 2011.
33 U.S. CENSUS. 2007. U.S. Census Bureau
American Fact Finder, 2002 Economic CensusSector 44: Retail Trade: Subject Series–Estab & Firm
Size: Single Unit and Multiunit Firms for the
United States: 2007, Washington, DC, Accessed July
2011. https://www.census.gov/econ/census07/www/
data_release_schedule/whats_been_
released.html#44.
b. Life-Cycle Cost Subgroup Analysis
tkelley on DSK3SPTVN1PROD with PROPOSALS2
5,094
5,094
4,917
5,219
4,780
4,901
6,205
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TABLE V–18—LIFE-CYCLE COST SAVINGS FOR WICF REFRIGERATION SYSTEMS
[2012$]
Equipment class
Business
DC.M.I.006 ........
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
DC.M.I.018 ........
DC.M.O.006 ......
DC.M.O.018 ......
DC.M.O.054 ......
DC.L.I.006 .........
DC.L.I.009 .........
DC.L.O.006 .......
DC.L.O.009 .......
DC.L.O.054 .......
TSL1
TSL2
$67.25
70.30
1,294.98
1,350.45
567.37
589.85
1,749.53
1,817.33
12,021.21
12,493.74
754.45
788.39
136.23
142.04
1,764.83
1,833.48
1,022.91
1,059.59
13,619.19
14,125.72
TSL3
$352.58
370.28
1,762.74
1,837.93
718.28
748.02
2,761.13
2,874.34
12,566.27
13,068.28
1,073.48
1,120.12
1,031.11
1,112.07
1,747.88
1,814.48
2,218.75
2,307.72
14,061.17
14,590.39
$67.25
70.30
1,294.98
1,350.45
567.37
748.02
1,749.53
1,817.33
12,021.21
12,493.74
754.45
788.39
136.23
142.04
1,764.83
1,833.48
1,022.91
1,059.59
13,619.19
14,125.72
TSL4
$352.58
370.28
1,762.74
1,837.93
718.28
589.85
2,761.13
2,874.34
12,566.27
13,068.28
1,073.48
1,120.12
1,031.11
1,112.07
1,747.88
1,814.48
2,218.75
2,307.72
14,061.17
14,590.39
TSL5
$352.58
370.28
1,762.74
1,837.93
784.16
818.57
2,761.13
2,874.34
12,566.27
13,068.28
1,035.60
1,081.45
1,031.11
1,077.14
1,773.85
1,843.63
2,184.74
2,273.00
13,231.20
13,760.51
TSL6
$352.58
370.28
1,762.74
1,837.93
784.16
818.57
2,761.13
2,874.34
12,566.27
13,068.28
1,035.60
1,081.45
1,031.11
1,077.14
1,773.85
1,843.63
2,184.74
2,273.00
13,231.20
13,760.51
* Multiplex refrigeration systems are not typically used in small restaurants.
TABLE V–19—LIFE-CYCLE COST SAVINGS FOR WICF ENVELOPE COMPONENTS (PANELS AND DOORS)
[2012$]
Equipment class
Business
SP.M .................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
SP.L ..................
FP.L ..................
DD.M .................
DD.L ..................
PD.M .................
PD.L ..................
FD.M .................
FD.L ..................
TSL1
TSL2
$12.65
15.55
109.66
121.93
58.43
65.59
225.18
238.77
210.44
217.30
1.80
2.13
64.25
73.75
2.96
3.46
137.63
152.18
TSL3
....................
....................
....................
....................
....................
....................
214.71
227.69
193.37
200.08
....................
....................
....................
....................
....................
....................
....................
....................
($8.05)
(8.98)
(75.54)
(65.50)
(12.64)
(4.45)
225.17
238.77
(11.78)
(12.17)
1.80
2.13
(37.17)
(15.74)
2.96
3.46
13.37
27.62
TSL4
$6.20
7.63
67.73
71.61
26.98
30.28
214.71
227.69
193.37
200.08
0.11
0.32
42.91
51.91
0.35
0.70
126.39
136.42
TSL5
($16.17)
(22.44)
(92.45)
(139.77)
(52.29)
(64.89)
209.52
222.46
191.01
197.59
(0.88)
(0.30)
(65.11)
(51.65)
(6.14)
(0.24)
(58.05)
(32.13)
TSL6
($2,141.42)
(2,138.75)
(1,901.81)
(1,890.34)
(1,661.22)
(1,652.86)
(2,660.23)
(2,650.38)
(1,739.58)
(1,716.84)
(886.46)
(883.91)
(677.42)
(664.59)
(1,160.14)
(1,156.91)
(1,357.39)
(1,337.03)
Note: Dashes represent components at baseline efficiency and therefore do not have a payback period. Numbers in parentheses indicate negative values.
TABLE V–20—PAYBACK PERIOD FOR WICF REFRIGERATION SYSTEMS
[Years]
Equipment
Business
DC.M.I.006 ........
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
DC.M.I.018 ........
tkelley on DSK3SPTVN1PROD with PROPOSALS2
DC.M.O.006 ......
DC.M.O.018 ......
DC.M.O.054 ......
DC.L.I.006 .........
DC.L.I.009 .........
DC.L.O.006 .......
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TSL1
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3.63
3.40
2.31
2.17
2.20
2.11
1.02
0.98
1.02
0.98
3.52
3.32
2.19
2.07
2.10
Fmt 4701
TSL2
TSL3
5.20
4.88
2.28
2.14
3.35
3.21
2.64
2.54
1.79
1.74
2.74
2.58
2.22
2.78
1.77
Sfmt 4702
3.63
3.40
2.31
2.17
5.52
3.21
1.02
0.98
1.02
0.98
3.52
3.32
2.19
2.07
2.10
E:\FR\FM\11SEP2.SGM
TSL4
5.20
4.88
2.28
2.14
0.02
2.11
2.64
2.54
1.79
1.74
2.74
2.58
2.22
2.78
1.77
11SEP2
TSL5
5.20
4.88
2.28
2.14
4.46
4.30
2.64
2.54
1.79
1.74
3.16
2.98
3.35
3.16
2.88
TSL6
5.46
4.88
2.28
2.14
4.46
4.30
2.64
2.54
1.79
1.74
3.16
2.98
3.35
3.16
2.88
55856
Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
TABLE V–20—PAYBACK PERIOD FOR WICF REFRIGERATION SYSTEMS—Continued
[Years]
Equipment
Business
DC.L.O.009 .......
DC.L.O.054 .......
TSL1
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
TSL2
2.03
0.76
0.74
0.50
0.48
TSL3
1.72
2.93
2.84
0.63
0.61
TSL4
2.03
0.76
0.74
0.50
0.48
1.72
2.93
2.84
0.63
0.61
TSL5
2.80
3.12
3.02
3.23
3.15
TSL6
2.80
3.12
3.02
3.23
3.15
* Multiplex refrigeration systems are not typically used in small restaurants.
TABLE V–21—PAYBACK PERIOD FOR WICF ENVELOPE COMPONENTS (PANELS AND DOORS)
[Years]
Equipment
Business
SP.M .................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
Small Business .................................
All Business Types ...........................
SP,L ..................
FP.L ..................
DD.M .................
DD.L ..................
PD.M .................
PD.L ..................
FD.M .................
FD.L ..................
TSL1
3.77
3.81
2.82
2.85
3.47
3.50
2.10
2.13
N/A
N/A
4.52
4.54
4.26
4.27
4.44
4.46
3.76
3.76
TSL2
TSL3
....................
....................
....................
....................
....................
....................
2.17
2.19
N/A
N/A
....................
....................
....................
....................
....................
....................
....................
....................
TSL4
6.77
6.80
7.33
7.43
5.88
5.96
2.10
2.13
6.20
6.01
4.52
4.54
6.22
6.23
4.44
4.46
5.76
5.77
4.46
4.49
3.60
3.63
4.42
4.46
2.17
2.19
N/A
N/A
5.48
5.51
4.70
4.69
5.38
5.41
2.92
2.92
TSL5
8.92
8.95
9.86
9.95
7.92
7.99
2.21
2.22
N/A
N/A
6.01
6.03
7.02
7.02
5.90
5.92
6.54
6.54
TSL6
146.06
146.40
42.58
42.97
48.28
48.69
37.28
37.56
18.91
18.48
78.77
78.73
18.26
18.31
81.55
81.51
21.62
21.70
Note: Dashes represent components at baseline efficiency and therefore do not have a payback period.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
2. Economic Impacts on Manufacturers
DOE performed a manufacturer
impact analysis (MIA) to estimate the
impact of new energy conservation
standards on manufacturers of walk-in
cooler and freezer refrigeration, panels,
and doors. The section below describes
the expected impacts on manufacturers
at each considered TSL. Chapter 12 of
the TSD explains the analysis in further
detail.
a. Industry Cash-Flow Analysis Results
Table V–22 through Table V–24
depict the financial impacts on
manufacturers and the conversion costs
DOE estimates manufacturers would
incur at each TSL. The financial impacts
on manufacturers are represented by
changes in industry net present value
(INPV).
The impact of energy efficiency
standards were analyzed under two
markup scenarios: (1) The preservation
of gross margin percentage and (2) the
preservation of operating profit. As
discussed in section IV.I.2.b, DOE
considered the preservation of gross
margin percentage scenario by applying
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a uniform ‘‘gross margin percentage’’
markup across all efficiency levels. As
production cost increases with
efficiency, this scenario implies that the
absolute dollar markup will increase.
DOE assumed the nonproduction cost
markup—which includes SG&A
expenses; research and development
expenses; interest; and profit to be 1.32
for panels, 1.50 for solid doors, 1.62 for
display doors, and 1.35 for refrigeration.
These markups are consistent with the
ones DOE assumed in the engineering
analysis and the base case of the GRIM.
Manufacturers have indicated that it is
optimistic to assume that as their
production costs increase in response to
an efficiency standard, they would be
able to maintain the same gross margin
percentage markup. Therefore, DOE
assumes that this scenario represents a
high bound to industry profitability
under an energy-conservation standard.
The preservation of earnings before
interest and taxes (EBIT) scenario
reflects manufacturer concerns about
their inability to maintain their margins
as manufacturing production costs
increase to reach more-stringent
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efficiency levels. In this scenario, while
manufacturers make the necessary
investments required to convert their
facilities to produce new standardscompliant equipment, operating profit
does not change in absolute dollars and
decreases as a percentage of revenue.
Each of the modeled scenarios results
in a unique set of cash flows and
corresponding industry values at each
TSL. In the following discussion, the
INPV results refer to the difference in
industry value between the base case
and each standards case that result from
the sum of discounted cash flows from
the base year 2013 through 2046, the
end of the analysis period. To provide
perspective on the short-run cash flow
impact, DOE includes in the discussion
of the results a comparison of free cash
flow between the base case and the
standards case at each TSL in the year
before new standards take effect.
Table V–22 through Table V–24 show
the MIA results for each TSL using the
markup scenarios described above for
WICF panel, door and refrigeration
manufacturers, respectively:
E:\FR\FM\11SEP2.SGM
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
55857
TABLE V–22—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF PANELS
Trial standard level
Base
case
1
2
3
4
5
2012 $M
2012 $M
% ...........
2012 $M
207.3
............
............
18.4
182.2 to 195.8 .....
¥25.0 to ¥11.5 ..
¥12.1 to ¥5.6 ....
10.7 .....................
207.3 to 207.3 .....
0.0 to 0.0 .............
0.0 to 0.0 .............
18.4 .....................
144.1 to 177.0 .....
¥63.1 to ¥30.2 ..
¥30.5 to ¥14.6 ..
¥3.4 ....................
182.2 to 195.8 .....
¥25.0 to ¥11.5 ..
¥12.1 to ¥5.6 ....
10.7 .....................
144.1 to 177.0 ......
¥63.1 to ¥30.2 ...
¥30.5 to ¥14.6 ...
¥3.4 .....................
¥212.9 to 441.9.
¥420.2 to 234.7.
¥202.7 to 113.2.
¥54.6.
2012 $M
............
¥7.7 ....................
0.0 .......................
¥21.8 ..................
¥7.7 ....................
¥21.8 ...................
¥73.0.
% ...........
2012 $M
............
............
¥41.6 ..................
21 ........................
0.0 .......................
0 ..........................
¥118.7 ................
58 ........................
¥41.6 ..................
21 ........................
¥118.7 .................
58 .........................
¥396.9.
195.
Units
INPV ..................
Change in INPV
Free Cash Flow
(FCF) (2016).
Change in FCF
(2016).
Conversion
Costs.
6
TABLE V–23—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF DOORS
Trial standard level
Base
case
1
2
3
4
5
2012 $M
2012 $M
% ...........
2012 $M
2012 $M
454.6
............
............
36.1
............
437.6 to 470.7 .....
¥17.0 to 16.1 .....
¥3.7 to 3.5 .........
34.1 .....................
¥2.07 ..................
446.2 to 470.2 .....
¥8.4 to 15.6 .......
¥1.8 to 3.4 .........
36.1 .....................
0.00 .....................
428.2 to 467.8 .....
¥26.4 to 13.2 .....
¥5.8 to 2.9 .........
30.4 .....................
¥5.7 ....................
437.8 to 470.6 .....
¥16.8 to 16.0 .....
¥3.7 to 3.5 .........
34.1 .....................
¥2.1 ....................
427.3 to 466.4 ......
¥27.3 to 11.8 ......
¥6.0 to 2.6 ..........
30.5 ......................
¥5.7 .....................
260.8 to 1145.1.
¥193.8 to 690.5.
¥42.6 to 151.9.
0.6.
¥35.6.
% ...........
2012 $M
............
............
¥5.7 ....................
6 ..........................
0.0 .......................
0.0 .......................
¥15.8 ..................
15 ........................
¥5.7 ....................
6 ..........................
¥15.7 ...................
15 .........................
¥98.5.
92.
Units
INPV ..................
Change in INPV
FCF (2016) .......
Change in FCF
(2016).
Conversion
Costs.
6
TABLE V–24—MANUFACTURER IMPACT ANALYSIS RESULTS FOR WICF REFRIGERATION SYSTEMS
Trial standard level
Units
INPV ..................
Change in INPV
FCF (2016) .......
Change in FCF
(2016).
Conversion
Costs.
Base
case
1
2
3
4
5
2012 $M
2012 $M
% ...........
2012 $M
2012 $M
189.1
............
............
16.3
............
170.9 to 183.3 .....
¥18.3 to ¥5.9 ....
¥9.7 to ¥3.1 ......
11.7 .....................
¥4.6 ....................
153.6 to 184.8 .....
¥35.5 to ¥4.4 ....
¥18.8 to ¥2.3 ....
9.1 .......................
¥7.2 ....................
170.9 to 183.3 .....
¥18.3 to ¥5.9 ....
¥9.7 to ¥3.1 ......
11.7 .....................
¥4.6 ....................
153.6 to 184.8 .....
¥35.5 to ¥4.4 ....
¥18.8 to ¥2.3 ....
9.1 .......................
¥7.2 ....................
145.8 to 188.3 ......
¥43.3 to ¥0.8 .....
¥22.9 to ¥0.4 .....
8.0 ........................
¥8.3 .....................
145.8 to 188.3.
¥43.3 to ¥0.8.
¥22.9 to ¥0.4.
8.0.
¥8.3.
% ...........
2012 $M
............
............
¥28.2 ..................
15 ........................
¥44.0 ..................
24 ........................
¥28.2 ..................
15 ........................
¥44.0 ..................
24 ........................
¥51.0 ...................
28 .........................
¥51.0.
28.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Walk-In Cooler and Freezer Panel MIA
Results
At TSL 1, DOE models the impacts on
panel INPV to be negative under both
mark-up scenarios. The change in panel
INPV ranges from ¥$25.0 million to
¥$11.5 million, or a change in INPV of
¥12.1 percent to ¥5.6 percent. At this
level, panel industry free cash flow 34 is
estimated to decrease by as much as
$7.7 million, or 41.6 percent compared
to the base-case value of $18.4 million
in 2016, the year before the compliance
date. The primary driver of the drop in
INPV is the standard for lowtemperature side panels, which goes up
to EL 2. At EL 2, manufacturers would
likely use 5-inch thick side panels for
low-temperature applications to meet
the panel standard. At this level, DOE
34 Free cash flow (FCF) is a metric commonly
used in financial valuation. DOE calculates this
value by adding back depreciation to net operating
profit after tax and subtracting increases in working
capital and capital expenditures.
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estimates conversion costs to be $21
million for the industry.
At TSL 2, the standard for all panel
equipment classes are set to the baseline
efficiency. As a result, there are no
changes to INPV, no changes in industry
free cash flow, and no conversion costs.
At TSL 3, DOE estimates impacts on
panel INPV to range from ¥$63.1
million to ¥$30.2 million, or a change
in INPV of ¥30.5 percent to ¥14.6
percent. At this level, panel industry
free cash flow is estimated to decrease
by as much as $21.8 million, or 118.7%
compared to the base-case value of
$18.4 million in the year before the
compliance date. The large percentage
drop in cash flow in the GRIM indicates
that conversion costs are high relative to
the size of the industry and relative to
annual operating profits. Conversion
costs are expected to total $58 million.
The conversion costs are driven by the
need for 6-inch panels for both low
temperature floor and side panels, as
described in section 12.4.8 of the TSD.
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6
During manufacturer interviews, some
panel manufacturers stated they would
evaluate leaving the industry rather than
make the required investments to meet
the standard.
At TSL 4, the standard for all panel
equipment classes are identical to those
at TSL 1.
DOE estimates TSL 5 impacts on
panel INPV to be range from ¥$63.1
million to ¥$30.2 million, or a change
in INPV of ¥30.5 percent to ¥14.6
percent. At this level, panel industry
free cash flow is estimated to decrease
by as much as $21.8 million, or 118.7
percent compared to the base-case value
of $18.4 million in the year before the
compliance date. At this TSL,
conversion costs total $58 million for
the industry. These conversion costs are
based on DOE’s analysis indicating that
industry would likely adopt 6-inch side
floor panels to meet the standard. As in
TSL 3, some panel manufacturers would
likely leave the industry at this level of
burden.
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tkelley on DSK3SPTVN1PROD with PROPOSALS2
TSL 6 represents the use of max-tech
design options for all equipment classes.
DOE estimates impacts on panel INPV
to be range from ¥$420.2 million to
$234.7 million, or a change in INPV of
¥202.7 percent to 113.2 percent. At this
level, panel industry free cash flow is
estimated to decrease by as much as
$73.0 million, or 396.9 percent
compared to the base-case value of
$18.4 million in the year before the
compliance date. Impacts at the most
negative end of the range would likely
force many manufacturers out of the
industry.
Walk-In Cooler and Freezer Door MIA
Results
For TSL 1, DOE models the change in
INPV for doors to range from ¥$17.0
million to $16.1 million, or a change in
INPV of ¥3.7 percent to 3.5 percent. At
this standard level, door industry free
cash flow is estimated to decrease by as
much as $2.1 million, or 5.7 percent
compared to the base case value of $36.1
million in the year before the
compliance date. DOE expects solid
door manufacturers to pursue design
options that reduce the loss of heat
through door frames and through
embedded windows. Changes to door
frame design may require new tooling.
Total conversion costs for the door
industry are expected to reach $6
million.
At TSL 2, DOE estimates the impacts
on door INPV to range from ¥$8.4
million to $15.6 million, or a change in
INPV of ¥1.8 percent to 3.4 percent. At
this level, door industry free cash flow
is estimated to decrease by a negligible
amount in the year before the
compliance year. Furthermore, there are
minimal conversion costs. To meet the
standard, display door manufacturers
would need to replace existing lighting
with LEDs and reduce anti-sweat wire
energy consumption. For solid door
manufacturers, the standard is set at the
baseline. Total conversion costs are
expected to total $0.1 million for the
industry. These costs are primarily
product conversion costs associated
incorporating heater wire controls and
updating marketing literature.
For TSL 3, DOE estimates the change
in door INPV to range from ¥$26.4
million to $13.2 million, or a change in
INPV of ¥5.8 percent to 2.9 percent. At
this level, door industry free cash flow
is estimated to decrease by as much as
$5.7 million, or 15.8 percent compared
to the base-case value of $36.1 million
in the year before the compliance date.
At this level, display doors would need
to incorporate lighting sensors. Solid
doors for low temperature walk-ins
would likely need to be redesigned to 6-
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inches of thickness. The additional
production equipment and the cost of
product redesigns drive conversion
costs up to $15 million, more than
double the conversion costs at TSL 1
and TSL 2. This conversion cost number
assumes that manufacturers that
produce both panels and solid doors
would use the same foaming equipment
and presses to produce both products
since DOE models panel manufacturers
also going to 6-inch side panels for low
temperature applications at TSL 3.
Manufacturers that exclusively produce
freight doors and passage doors will not
be able to spread their investment over
as many equipment classes.
For TSL 4, DOE estimates impacts on
door INPV to range from ¥$16.8 million
to $16.0 million, or a change in INPV of
¥3.7 percent to 3.5 percent. At this
considered level, door industry free
cash flow is estimated to decrease by as
much as $2.1 million, or 5.7 percent
compared to the base-case value of
$36.1 million in the year before the
compliance date. The standard levels for
doors at TSL 4 are nearly identical to
the standard levels at TSL 2, except that
the standard is one efficiency level
lower for the low temperature freight
door equipment class. As mentioned
above, DOE expects display door
manufacturers to pursue design changes
that do not require new manufacturing
equipment. Manufacturers are expected
to use LEDs in display doors and reduce
anti-sweat wire energy consumption for
medium temperature applications. DOE
expects solid door manufacturers to
pursue design options that reduce the
loss of heat through door frames and
through embedded windows. Changes
to door frame design may require new
tooling. Total conversion costs are
expected to reach $6 million for the
industry.
For TSL 5, DOE estimates impacts on
door INPV to range from ¥$27.3 million
to $11.8 million, or a change in INPV of
¥6.0 percent to 2.6 percent, at TSL 5.
At this level, door industry free cash
flow is estimated to decrease by as
much as $5.7 million, or 15.7 percent
compared to the base-case value of
$36.1 million in the year before the
compliance date. This standard level for
doors at TSL 5 is nearly identical to the
standard levels at TSL 3. Total
conversion costs are expected to reach
$15 million.
For TSL 6, DOE estimates impacts on
door INPV to range from ¥$193.8
million to $690.5 million, or a change in
INPV of ¥42.6 percent to 151.9 percent.
At this level, door industry free cash
flow is estimated to decrease by as
much $35.6 million, or 98.5 percent
compared to the base-case value of
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$36.1 million in the year before the
compliance date. Conversion costs
would total $92 million. At this level,
some door manufacturers would likely
choose to leave the industry rather than
make the necessary investments to
comply with standards.
Walk-In Cooler and Freezer
Refrigeration MIA Results
At TSL 1, DOE estimates impacts on
refrigeration INPV to range from ¥$18.3
million to ¥$5.9 million, or a change in
INPV of ¥9.7 percent to ¥3.1 percent.
At this level, refrigeration industry free
cash flow is estimated to decrease by as
much as $4.6 million, or 28.2 percent
compared to the base-case value of
$16.3 million in 2016, the year before
the compliance year. For dedicated
condensing, medium temperature,
indoor refrigeration systems, DOE’s
engineering analysis indicates that
manufacturers would need to
incorporate multiple design options to
achieve this standard. The design
options would likely include variable
speed evaporator fan motors and larger
condensing coils. For dedicated
condensing, low temperature, indoor
refrigeration systems, manufacturers
may need to further include improved
condenser fan, improved evaporator fan
blades, and electronically commutated
motors. For dedicated condensing,
medium temperature, outdoor
refrigeration systems, design options
necessary to meet TSL 1 would include
variable speed evaporator fan motors,
improved condenser fan blades,
electronically commutated condenser
fan motors, and improved evaporator
fan blades. For dedicated condensing,
low temperature, outdoor refrigeration
systems, additional design options
required to meet the trial standard level
include ambient sub-cooling, variable
speed condenser fans, and defrost
control strategies. For multiplex
refrigeration, manufacturers would need
to evaluate design improvements, such
as variable speed evaporator fan motors,
improved fan blade designs, defrost
control, and hot gas defrost. Integration
of these design options across
equipment classes will require extensive
engineering investments. As a result,
conversion costs total $15 million for
the industry.
At TSL 2, DOE estimates impacts on
refrigeration INPV to range from ¥$35.5
million to ¥$4.4 million, or a change in
INPV of ¥18.8 percent to ¥2.3 percent.
At this level, refrigeration industry free
cash flow is estimated to decrease by as
much as $7.2 million, or 44.0 percent
compared to the base-case value of
$16.3 million in the year before the
compliance date. From TSL 1 to TSL 2,
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standards increase for most equipment
classes. For dedicated condensing,
medium temperature, indoor systems, a
manufacturer would need to consider
including electronically commutated
condenser fan motors, improved
condenser fan blades, and improved
evaporator fan blades. For dedicated
condensing, medium temperature,
outdoor systems, the most cost effective
options include using ambient
subcooling, variable speed condenser
fan motors, and floating head pressure
with electronic expansion valves. For
dedicated condensing, low temperature,
outdoor systems, manufacturers will
need to consider incorporating
improved evaporator fan blades, larger
condenser coils, and floating head
pressure with electronic expansion
valves. The range of changes does not
require significant amounts of new
production equipment, but could
require substantial development and
engineering time. DOE estimates the
WICF refrigeration industry’s
conversion costs to increase to $24
million.
At TSL 3, the standards and the
impacts on the walk-in refrigeration
industry are identical to those at TSL 1.
At TSL 4, the standards and the
impacts on the walk-in refrigeration
industry are identical to those at TSL 2.
TSL 5 and TSL 6 represent max-tech
for WICF refrigeration systems. DOE
estimates impacts on refrigeration INPV
to range from ¥$43.3 million to ¥$0.8
million, or a change in INPV of ¥22.9
percent to ¥0.4 percent. At this level,
refrigeration industry free cash flow is
estimated to decrease by as much as
$8.3 million, or 51.0 percent compared
to the base-case value of $16.3 million
in the year before the compliance year.
DOE’s engineering analysis indicates
that manufacturers would need to
incorporate design changes beyond
those for TSL 4 and TSL 3 to achieve
this standard. Additional design
changes for dedicated condensing, low
temperature, indoor and outdoor
refrigeration would include defrost
controls. For multiplex units, the
standard levels at TSL 5 and 6 are
identical to those at TSL 1. Total
conversion costs are expected to reach
$28 million for the industry.
b. Impacts on Direct Employment
Methodology
To quantitatively assess the impacts
of energy conservation standards on
employment, DOE used the GRIM to
estimate the domestic labor
expenditures and number of employees
in the base case and at each TSL from
2013 through 2046. DOE used statistical
data from the U.S. Census Bureau’s 2011
Annual Survey of Manufacturers (ASM),
the results of the engineering analysis,
and interviews with manufacturers to
determine the inputs necessary to
calculate industry-wide labor
expenditures and domestic employment
levels. Labor expenditures related to
manufacturing of the product are a
function of the labor intensity of the
product, the sales volume, and an
assumption that wages remain fixed in
real terms over time. The total labor
expenditures in each year are calculated
by multiplying the MPCs by the labor
percentage of MPCs.
The total labor expenditures in the
GRIM were then converted to domestic
production employment levels by
dividing production labor expenditures
by the annual payment per production
55859
worker (production worker hours
multiplied by the labor rate found in the
U.S. Census Bureau’s 2011 ASM). The
estimates of production workers in this
section cover workers, including line
supervisors who are directly involved in
fabricating and assembling a product
within the OEM facility. Workers
performing services that are closely
associated with production operations,
such as materials handling tasks using
forklifts, are also included as production
labor. DOE’s estimates only account for
production workers who manufacture
the specific products covered by this
rulemaking. To further establish a lower
bound to negative impacts on
employment, DOE reviewed design
options, conversion costs, and market
share information to determine the
maximum number of manufacturers that
would leave the industry at each TSL.
In evaluating the impact of energy
efficiency standards on employment,
DOE performed separate analyses on all
three walk-in component manufacturer
industries: panels, doors and
refrigeration systems.
Using the GRIM, DOE estimates in the
absence of new energy conservation
standards, there would be 3,482
domestic production workers for walkin panels, 1,187 domestic production
workers for walk-in doors, and 346
domestic production workers for walkin refrigeration systems in 2017.
Table V–25, Table V–26, and Table V–
27 show the range of the impacts of
potential new energy conservation
standards on U.S. production workers in
the panel, door, and refrigeration system
markets, respectively. Additional detail
on the analysis of direct employment
can be found in chapter 12 of the TSD.
TABLE V–25—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR PANELS
TSL
1
2
3
4
5
6
Potential Changes in Domestic Production
Workers 2017 (from a base case employment
of 3,462).
¥435 to 134 .....
0 ........................
¥871 to 490 .....
¥435 to 134 .....
¥871 to 490 .....
¥1,741 to 3,243
TABLE V–26—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR DOORS
1
2
3
4
5
Potential Changes in Domestic Production
Workers 2017 (from a base case employment
of 1,187).
tkelley on DSK3SPTVN1PROD with PROPOSALS2
TSL
¥60 to 149 .......
0 to 97 ...............
¥120 to 196 .....
¥60 to 146 .......
¥120 to 192 .....
6
¥349 to 2,409
TABLE V–27—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC PRODUCTION WORKERS IN 2017 FOR
REFRIGERATION SYSTEMS
TSL
1
2
3
4
5
Potential Changes in Domestic Production
Workers 2017 (from a base case employment
of 346).
0 to 31 ...............
¥88 to 74 .........
0 to 31 ...............
¥88 to 74 .........
¥116 to 99 .......
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The employment impacts shown in
Table V–25 through Table V–27
represent the potential production
employment changes that could result
following the compliance date of new
energy conservation standards. The
upper end of the results in the table
estimates the maximum increase in the
number of production workers after the
implementation of new energy
conservation standards and it assumes
that manufacturers would continue to
produce the same scope of covered
products within the United States. The
lower end of the range represents the
maximum decrease to the total number
of U.S. production workers in the
industry due to manufacturers leaving
the industry. However, in the long-run,
DOE would expect the manufacturers
that do not leave the industry to add
employees to cover lost capacity and to
meet market demand.
The employment impacts shown are
independent of the employment impacts
from the broader U.S. economy, which
are documented in the Employment
Impact Analysis, chapter 13 of the TSD.
c. Impacts on Manufacturing Capacity
Panels
Manufacturers indicated that design
options that necessitate thicker panels
could lead to longer production times
for panels. In general, every additional
inch of foam increases panel cure times
by roughly 20 minutes. DOE
understands from manufacturer
interviews, however, that the industry is
not currently operating at full capacity.
Given this fact, and the number of
manufacturers able to produce panels
above the baseline today, an increase in
thickness at lower panel standards—that
is, a standard that is based on 4-inch or
5-inch panels—is not likely to lead to
product shortages in the industry.
However, a standard that necessitates 6inch panels for any of the panel
equipment classes would require
manufacturers to add equipment to
maintain throughput due to longer
curing times or to purchase all new
tooling to enable production if the
manufacturer’s current equipment
cannot accommodate 6-inch panels.
These conversion costs are discussed
further in chapter 12 of the TSD.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Doors
Display door manufacturers did not
identify any design options which
would lead to capacity constraints.
However, manufacturers commented on
differences between the two types of
low-emittance coatings analyzed: hard
low emittance coating (‘‘hard-coat’’), the
baseline option, and soft low emittance
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coating (‘‘soft-coat’’), the corresponding
design option. Hard-coat is applied to
the glass pane at high temperatures
during the formation of the pane and is
extremely durable, while soft-coat is
applied in a separate step after the glass
pane is formed and is less durable than
hard low emittance coating but has
better performance characteristics.
Manufacturers indicated that soft-coat is
significantly more difficult to work with
and may require new conveyor
equipment. As manufacturers adjust to
working with soft-coat, longer lead
times may occur.
The production of solid doors is very
similar to the production of panels and
faces the same capacity challenges as
panels. As indicated in the panel
discussion above, DOE does not
anticipate capacity constraints at a
standard that moves manufacturers to 5
inches of thickness.
Refrigeration
DOE did not identify any significant
capacity constraints for the design
options being evaluated for this
rulemaking. For most refrigeration
manufacturers, the walk-in market
makes up a relatively small percentage
of their overall revenues. Additionally,
most of the design options being
evaluated are available as product
options today. As a result, the industry
should not experience capacity
constraints directly resulting from an
energy conservation standard.
d. Impacts on Small Manufacturer SubGroup
As discussed in section IV.I.1, using
average cost assumptions to develop an
industry cash-flow estimate may not be
adequate for assessing differential
impacts among manufacturer subgroups. Small manufacturers, niche
equipment manufacturers, and
manufacturers exhibiting a cost
structure substantially different from the
industry average could be affected
disproportionately. DOE used the
results of the industry characterization
to group manufacturers exhibiting
similar characteristics. Consequently,
DOE analyzes small manufacturers as a
sub-group.
DOE evaluated the impact of new
energy conservation standards on small
manufacturers, specifically ones defined
as ‘‘small businesses’’ by the SBA. The
SBA defines a ‘‘small business’’ as
having 750 employees or less for NAICS
333415, ‘‘Air-Conditioning and Warm
Air Heating Equipment and Commercial
and Industrial Refrigeration Equipment
Manufacturing.’’ Based on this
definition, DOE identified 2
refrigeration system manufacturers, 42
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panel manufacturers, and 5 door
manufacturers in the WICF industry that
are small businesses. DOE describes the
differential impacts on these small
businesses in today’s notice at section
VI.B, Review Under the Regulatory
Flexibility Act.
Section VI.B concludes that larger
manufacturers could have a competitive
advantage in multiple component
markets due to their size, engineering
and testing resources, and ability to
access capital. Additionally, in some
market segments, larger manufacturers
have significantly higher production
volumes over which to spread costs. In
particular, DOE’s analysis shows that
this rule could drive consolidation in
the walk-in cooler and freezer panel
industry. While DOE cannot certify that
today’s rule would not have a
significant economic impact on a
substantial number of small
manufacturers, DOE has considered
these potential impacts and sought to
mitigate any such impacts in choosing
the TSL proposed in today’s rule. For
example, DOE specifically considered
TSL 2, which would not raise the
efficiency requirement on panel
manufacturers above the base case level
in order to minimize impacts on panel
manufacturers. . In addition to the range
of TSLs considered, alternatives to the
proposed rule that were considered
include the following policy
alternatives: (1) No new regulatory
action, (2) commercial consumer
rebates, and (3) commercial consumer
tax credits. Chapter 17 of the TSD
associated with this proposed rule
includes a report referred to in Section
VI.A in the preamble as the regulatory
impact analysis (RIA). The energy
savings of these regulatory alternatives
are one to two orders of magnitude
smaller than those expected from the
standard levels under consideration.
The range of economic impacts of these
regulatory alternatives is an order of
magnitude smaller than the range of
impacts expected from the standard
levels under consideration. For a
complete discussion of the impacts on
small businesses, see section VI.B and
chapter 12 of the TSD.
e. Cumulative Regulatory Burden
While any one regulation may not
impose a significant burden on
manufacturers, the combined effects of
several impending regulations may have
serious consequences for some
manufacturers, groups of manufacturers,
or an entire industry. Assessing the
impact of a single regulation may
overlook this cumulative regulatory
burden. Multiple regulations affecting
the same manufacturer can strain profits
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and can lead companies to abandon
product lines or markets with lower
expected future returns than competing
products. For these reasons, DOE
conducts an analysis of cumulative
regulatory burden as part of its
rulemakings pertaining to appliance and
equipment efficiency.
For the cumulative regulatory burden
analysis, DOE looks at other regulations
that could affect walk in cooler and
freezer manufacturers that will take
effect approximately 3 years before or
after the compliance date of new energy
conservation standards for these
products. In addition to the new energy
conservation regulations on walk-ins,
several other Federal regulations apply
to these products and other equipment
produced by the same manufacturers.
While the cumulative regulatory burden
focuses on the impacts on
manufacturers of other Federal
requirements, DOE also describes a
number of other regulations in section
VI.B because it recognizes that these
regulations also impact the products
covered by this rulemaking.
Companies that produce a wide range
of regulated products may be faced with
more capital and product development
expenditures than competitors with a
narrower scope of products. Regulatory
burdens can prompt companies to exit
the market or reduce their product
offerings, potentially reducing
competition. Smaller companies in
particular can be affected by regulatory
costs since these companies have lower
sales volumes over which they can
amortize the costs of meeting new
regulations. DOE discusses below the
regulatory burdens manufacturers could
experience, mainly, DOE regulations for
other products or equipment produced
by walk-in manufacturers and other
Federal requirements including the
United States Clean Air Act, the Energy
Independence and Security Act of 2007.
While this analysis focuses on the
impacts on manufacturers of other
Federal requirements, in this section
DOE also describes a number of other
regulations that could also impact the
WICF equipment covered by this
rulemaking: potential climate change
and greenhouse gas legislation, State
conservation standards, and food safety
regulations. DOE discusses these and
other requirements, and includes the
full details of the cumulative regulatory
burden, in chapter 12 of the NOPR TSD.
DOE Regulations for Other Products
Produced by Walk-In Cooler and Freezer
Manufacturers
In addition to the new energy
conservation standards on walk in
cooler and freezer equipment, several
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other Federal regulations apply to other
products produced by the same
manufacturers. DOE recognizes that
each regulation can significantly affect a
manufacturer’s financial operations.
Multiple regulations affecting the same
manufacturer can strain manufacturers’
profits and possibly cause an exit from
the market. DOE is conducting an
energy conservation standard
rulemaking for commercial refrigeration
equipment. In its Notice of Proposed
Rulemaking for commercial refrigeration
equipment, DOE initially estimated
conversion costs for the CRE industry to
total $87.5 million. Conversion costs are
one-time expenses the industry will
bear between the announcement date of
the standard and the effective date of
the standard.
Federal Clean Air Act
The Clean Air Act defines the EPA’s
responsibilities for protecting and
improving the nation’s air quality and
the stratospheric ozone layer. The most
significant of these additional
regulations is the EPA-mandated phaseout of hydrochlorofluorocarbons
(HCFCs). The Act requires that, on a
quarterly basis, any person who
produced, imported, or exported certain
substances, including HCFC
refrigerants, report the amount
produced, imported and exported.
Additionally—effective January 1,
2015—selling, manufacturing, and using
any such substance is banned unless
such substance (1) has been used,
recovered, and recycled; (2) is used and
entirely consumed in the production of
other chemicals; or (3) is used as a
refrigerant in appliances manufactured
prior to January 1, 2020. Finally,
production phase-outs will continue
until January 1, 2030 when such
production will be illegal. These bans
could trigger design changes to natural
or low global warming potential
refrigerants and could impact the
insulation used in products covered by
this rulemaking.
State Conservation Standards
Since 2004, the State of California has
had established energy standards for
walk-in coolers and freezers.
California’s Code of Regulations (Title
20, Section 1605) prescribe
requirements for insulation levels,
motor types, and use of automatic doorclosers used for WICF applications.
These requirements have since been
amended and mirror those standards
that Congress prescribed as part of EISA
2007. Other States, notably,
Connecticut, Maryland, and Oregon,
have recently established energy
efficiency standards for walk-ins that
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are also identical to the ones contained
in EPCA. These standards would not be
preempted until any Federal standards
that DOE may adopt take effect. See 42
U.S.C. 6316(h)(2). Once DOE’s standards
are finalized, all other State standards
that are in effect would be pre-empted.
As a result, these State standards do not
pose any regulatory burden above that
which has already been established in
EPCA.
Food Safety Standards
Manufacturers expressed concern
regarding Federal, State, and local food
safety regulations. A walk-in must
perform to the standards set by NSF,
state, country, and city health
regulations. There is general concern
among manufacturers about conflicting
regulation scenarios as new energy
conservation standards may potentially
prevent or make it more difficult for
them to comply with food safety
regulations.
3. National Impact Analysis
a. Amount and Significance of Energy
Savings
To estimate the national energy
savings attributable to the TSLs under
consideration, DOE compared the
energy consumption of the refrigeration
systems under the base case to their
anticipated energy consumption under
each TSL. Because all the TSLs except
TSL 6 combine high efficiency
refrigeration systems with envelope
components having small efficiency
gains over the baseline levels, DOE
projected that the additional impact
from higher efficiency levels for
envelope components on the capacity of
refrigeration systems sold for each
system, and subsequently on the
aggregate shipped capacity, would not
significantly impact the energy savings
estimate for each TSL. Consequently,
DOE calculated the baseline energy
consumption and the energy savings for
higher efficiency refrigeration systems
independent of the envelope component
efficiency level at the TSLs considered.
DOE did, however, estimate this
reduction in capacity from improved
envelope component efficiency on an
aggregate basis at each TSL and
accounted for the economic benefit in
the calculation of the national net
present value for each TSL as discussed
in section V.3.b.
By contrast, the energy savings
benefits for the envelope components
are influenced directly by the efficiency
of the refrigeration system. Because of
this, the energy savings for the envelope
levels are calculated such that both the
baseline and the higher efficiency
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envelope components are paired with
the refrigeration system at the efficiency
level corresponding to the specific TSL.
Table V–28 through Table V–30
present DOE’s forecasts of the national
primary energy savings for each TSL of
were calculated using the approach
described in section IV.G. Chapter 10 of
the NOPR TSD presents tables that also
show the magnitude of the energy
savings.
the refrigeration systems and selected
envelope components, and the
combination of refrigeration systems
and envelope components. In addition
Table V–30 shows the FFC energy
savings for each TSL. These forecasts
TABLE V–28—WICF REFRIGERATION SYSTEMS: CUMULATIVE NATIONAL ENERGY SAVINGS IN QUADS
[Primary energy savings]
Trial standard levels
Equipment class
1,3
DC.M.I* ............................................................................................................
DC.M.O* ...........................................................................................................
DC.L.I* .............................................................................................................
DC.L.O* ............................................................................................................
MC.M ...............................................................................................................
MC.L ................................................................................................................
2,4
0.024
1.825
0.009
0.768
0.378
0.099
5
0.041
2.446
0.016
1.162
0.376
0.084
6
0.041
2.524
0.017
1.256
0.378
0.099
0.041
2.524
0.017
1.256
0.378
0.099
* For DC refrigeration systems, results include both capacity ranges.
TABLE V–29—COMPONENT EQUIPMENT CLASS: CUMULATIVE NATIONAL ENERGY SAVINGS IN QUADS
[Primary energy savings]
Trial standard levels
Equipment class
1
SP.M ................................................................................
SP.L .................................................................................
FP.L ..................................................................................
DD.M ................................................................................
DD.L .................................................................................
PD.M ................................................................................
PD.L .................................................................................
FD.M ................................................................................
FD.L .................................................................................
2
0.259
0.447
0.048
0.405
0.021
0.009
0.113
0.000
0.010
3
0.000
0.000
0.000
0.394
0.020
0.000
0.000
0.000
0.000
4
0.324
0.564
0.069
0.405
0.029
0.009
0.141
0.000
0.013
5
0.221
0.380
0.040
0.394
0.020
0.007
0.106
0.000
0.007
6
0.273
0.447
0.055
0.394
0.020
0.007
0.128
0.000
0.012
0.553
0.619
0.069
0.620
0.095
0.073
0.140
0.004
0.013
TABLE V–30—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: CUMULATIVE NATIONAL PRIMARY AND FULL-FUEL
CYCLE ENERGY SAVINGS IN QUADS
Trial standard levels
Application
1
2
3
4
5
6
2.900
1.515
4.415
0.072
3.257
1.283
4.540
0.074
2.965
1.692
4.658
0.076
3.486
1.816
5.302
0.086
3.617
2.032
5.649
0.092
4.193
2.308
6.501
0.106
FFC Total ..................................................................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Medium Temperature .......................................................
Low Temperature .............................................................
Primary Energy Savings Total .........................................
Upstream Energy Savings ...............................................
4.487
4.614
4.734
5.388
5.741
6.607
Circular A–4 requires agencies to
present analytical results, including
separate schedules of the monetized
benefits and costs that show the type
and timing of benefits and costs.
Circular A–4 also directs agencies to
consider the variability of key elements
underlying the estimates of benefits and
costs. For this rulemaking, DOE
undertook a sensitivity analysis using
nine rather than 30 years of product
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shipments. The choice of a 9-year
period is a proxy for the timeline in
EPCA for the review of certain energy
conservation standards and potential
revision of and compliance with such
revised standards. We would note that
the review timeframe established in
EPCA generally does not overlap with
the product lifetime, product
manufacturing cycles or other factors
specific to walk-in coolers and freezers.
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Thus, this information is presented for
informational purposes only and is not
indicative of any change in DOE’s
analytical methodology. The NES of
estimated primary energy savings
results based on a 9-year analytical
period are presented in Table V–31
through Table V–33. The impacts are
counted over the lifetime of products
purchased in 2017–2025.
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
55863
TABLE V–31—WICF REFRIGERATION SYSTEMS: CUMULATIVE NATIONAL PRIMARY ENERGY SAVINGS IN QUADS FOR UNITS
SOLD IN 2017–2025
Trial standard levels
Equipment class
1,3
DC.M.I* ............................................................................................................
DC.M.O* ...........................................................................................................
DC.L.I* .............................................................................................................
DC.L.O* ............................................................................................................
MC.M ...............................................................................................................
MC.L ................................................................................................................
2,4
0.007
0.547
0.003
0.230
0.113
0.030
5
0.012
0.733
0.005
0.348
0.113
0.025
6
0.012
0.756
0.005
0.376
0.113
0.030
0.012
0.756
0.005
0.376
0.113
0.030
* For DC refrigeration systems, results include multiple capacity ranges.
TABLE V–32—COMPONENT EQUIPMENT CLASS: CUMULATIVE NATIONAL PRIMARY ENERGY SAVINGS IN QUADS FOR UNITS
SOLD IN 2017–2025
[Primary energy savings]
Trial standard levels
Equipment class
1
SP.M ........................................................
SP.L .........................................................
FP.L ..........................................................
DD.M ........................................................
DD.L .........................................................
PD.M ........................................................
PD.L .........................................................
FD.M ........................................................
FD.L .........................................................
2
0.063
0.108
0.012
0.123
0.006
0.003
0.033
0.000
0.002
3
0.000
0.000
0.000
0.119
0.006
0.000
0.000
0.000
0.000
4
0.079
0.137
0.017
0.123
0.009
0.003
0.041
0.000
0.003
5
0.054
0.092
0.010
0.119
0.006
0.002
0.031
0.000
0.002
6
0.066
0.108
0.013
0.119
0.006
0.002
0.037
0.000
0.003
0.134
0.150
0.017
0.188
0.029
0.021
0.041
0.001
0.003
TABLE V–33—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: CUMULATIVE NATIONAL PRIMARY AND FULL-FUEL
CYCLE ENERGY SAVINGS IN QUADS FOR UNITS SOLD IN 2017–2025
Trial standard levels
Application
1
2
3
4
5
6
0.855
0.425
1.280
0.021
0.977
0.384
1.361
0.022
0.871
0.470
1.341
0.022
1.033
0.519
1.552
0.025
1.069
0.579
1.648
0.027
1.226
0.651
1.877
0.031
FFC Total ..........................................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Medium Temperature ...............................
Low Temperature .....................................
Primary Energy Savings Total .................
Upstream Energy Savings .......................
1.301
1.383
1.363
1.577
1.675
1.908
b. Net Present Value of Consumer Costs
and Benefits
DOE estimated the cumulative NPV to
the nation of the total costs and savings
for consumers that would result from
particular composite standard levels for
the refrigeration systems and
components. In accordance with OMB
guidelines on regulatory analysis (OMB
Circular A–4, section E, September 17,
2003), DOE calculated NPV using both
a 7-percent and a 3-percent real
discount rate. The 7-percent rate is an
estimate of the average before-tax rate of
return on private capital in the U.S.
economy, and reflects the returns on
real estate and small business capital,
including corporate capital. DOE used
this discount rate to approximate the
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opportunity cost of capital in the private
sector, since recent OMB analysis has
found the average rate of return on
capital to be near this rate. In addition,
DOE used the 3-percent rate to capture
the potential effects of standards on
private consumption. This rate
represents the rate at which society
discounts future consumption flows to
their present value. It can be
approximated by the real rate of return
on long-term government debt (i.e.,
yield on Treasury notes minus annual
rate of change in the Consumer Price
Index), which has averaged about 3
percent on a pre-tax basis for the last 30
years.
Table V–34 through Table V–39 show
the consumer NPV results for each of
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the TSLs DOE considered for the
combination of refrigeration systems
and envelope components, using both a
7-percent and a 3-percent discount rate.
In each case, the impacts cover the
lifetime of products purchased in 2017–
2046. For a particular TSL combination,
improving component efficiency should
result in reduced refrigeration load on
the paired refrigeration system and
consequently, the refrigeration system
can be downsized, resulting in
additional consumer benefits. In
estimating the ‘‘first cost benefits,’’ DOE
made several assumptions and has
shown the results only in the summary
table. For a discussion of these
assumptions, see chapter 10 of the TSD.
E:\FR\FM\11SEP2.SGM
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
TABLE V–34—WICF REFRIGERATION SYSTEMS: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT DISCOUNT
RATE FOR UNITS SOLD IN 2017–2046
Trial standard levels
Equipment classes
1,3
DC.M.I * ............................................................................................................
DC.M.O * ..........................................................................................................
DC.L.I * .............................................................................................................
DC.L.O * ...........................................................................................................
MC.M ...............................................................................................................
MC.L ................................................................................................................
2,4
38
3,417
12
1,488
835
161
5
6
52
3,943
19
1,995
843
189
52
3,937
19
1,913
835
161
52
3,937
19
1,913
835
161
* For DC refrigeration systems, results include both capacity ranges.
TABLE V–35—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT
DISCOUNT RATE FOR UNITS SOLD IN 2017–2046
Trial standard levels
Equipment class
1
SP.M ........................................................
SP.L .........................................................
FP.L ..........................................................
DD.M ........................................................
DD.L .........................................................
PD.M ........................................................
PD.L .........................................................
FD.M ........................................................
FD.L .........................................................
2
3
289
662
63
571
54
4
106
0
10
0
0
0
545
51
0
0
0
0
4
5
121
269
52
571
0
4
38
0
5
6
207
520
48
545
51
1
88
0
9
11
21
22
543
50
1
6
0
2
¥17,715
¥4,298
¥578
¥11,200
¥395
¥1,764
¥513
¥106
¥59
TABLE V–36—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: NET PRESENT VALUE IN MILLIONS (2012$) AT A
7-PERCENT DISCOUNT RATE FOR UNITS SOLD IN 2017–2046
Trial standard levels
Application
1
2
3
4
5
6
Medium temperature
Combined NPV ........................................
First cost benefits .....................................
5,155
6
5,384
3
4,987
18
5,592
34
5,380
45
¥25,961
153
Sub-Total ..........................................
5,161
5,386
5,004
5,627
5,425
¥25,809
Low temperature
Combined NPV ........................................
First cost benefits .....................................
2,555
49
2,255
0
2,025
89
2,919
96
2,193
246
¥3,751
344
Sub-Total ..........................................
2,604
2,255
2,114
3,015
2,438
¥3,408
Total—All ...................................
7,765
7,641
7,118
8,642
7,864
¥29,217
TABLE V–37—WICF REFRIGERATION SYSTEMS: NET PRESENT VALUE IN MILLIONS (2012$) AT A 3-PERCENT DISCOUNT
RATE FOR UNITS SOLD IN 2017–2046
Trial standard levels
Equipment class
tkelley on DSK3SPTVN1PROD with PROPOSALS2
1,3
DC.M.I * ............................................................................................................
DC.M.O * ..........................................................................................................
DC.L.I * .............................................................................................................
DC.L.O * ...........................................................................................................
MC.M ...............................................................................................................
MC.L ................................................................................................................
2,4
107
9,161
36
3,951
2,143
450
5
159
11,047
61
5,483
2,157
483
* For DC refrigeration systems, results include both capacity ranges.
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6
159
11,147
60
5,455
2,143
450
159
11,147
60
5,455
2,143
450
Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
55865
TABLE V–38—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 3-PERCENT
DISCOUNT RATE FOR UNITS SOLD IN 2017–2046
Trial standard levels
Equipment class
1
SP.M ........................................................
SP.L .........................................................
FP.L ..........................................................
DD.M ........................................................
DD.L .........................................................
PD.M ........................................................
PD.L .........................................................
FD.M ........................................................
FD.L .........................................................
2
3
990
2,151
219
1,667
135
21
364
1
36
4
0
0
0
1,602
128
0
0
0
0
5
779
1,468
216
1,667
41
21
270
1
31
6
770
1,694
167
1,602
128
13
319
1
32
484
797
134
1,597
126
12
189
1
23
¥32,834
¥7,144
¥985
¥20,987
¥640
¥3,329
¥803
¥200
¥92
TABLE V–39—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: NET PRESENT VALUE IN MILLIONS (2012$) AT A
3-PERCENT DISCOUNT RATE FOR UNITS SOLD IN 2017–2046
Trial standard levels
Application
1
2
3
4
5
6
Medium temperature
Combined NPV ........................................
First cost benefits .....................................
14,091
12
14,965
5
13,880
34
15,748
66
15,543
87
¥43,901
294
Sub-Total ..........................................
14,102
14,970
13,914
15,814
15,630
¥43,607
Low temperature
Combined NPV ........................................
First cost benefits .....................................
7,191
94
6,155
0
6,464
172
8,297
185
7,234
473
¥3,700
663
Sub-Total ..........................................
7,285
6,155
6,636
8,482
7,707
¥3,037
Total—All ...................................
21,387
21,125
20,550
24,296
23,337
¥46,644
The NPV results based on the
aforementioned 9-year analytical period
are presented in Table V–40 through
Table V–45. The impacts are counted
over the lifetime of products purchased
in 2017–2025. As mentioned previously,
this information is presented for
informational purposes only and is not
indicative of any change in DOE’s
analytical methodology or decision
criteria.
TABLE V–40—WICF REFRIGERATION SYSTEMS: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT DISCOUNT
RATE FOR UNITS SOLD IN 2017–2025
Trial standard levels
Equipment classes
1,3
DC.M.I * ............................................................................................................
DC.M.O * ..........................................................................................................
DC.L.I * .............................................................................................................
DC.L.O * ...........................................................................................................
MC.M ...............................................................................................................
MC.L ................................................................................................................
2,4
21
1,864
7
810
451
89
5
30
2,175
11
1,095
455
102
6
30
2,178
11
1,060
451
89
30
2,178
11
1,060
451
89
* For DC refrigeration systems, results include both capacity ranges.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
TABLE V–41—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT
DISCOUNT RATE FOR UNITS SOLD IN 2017–2025
Trial standard levels
Equipment class
1
SP.M ........................................................
SP.L .........................................................
FP.L ..........................................................
DD.M ........................................................
DD.L .........................................................
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2
128
306
29
326
29
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0
0
0
312
28
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4
35
92
21
326
3
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5
89
238
21
312
28
11SEP2
6
¥17
¥27
6
311
27
¥9,275
¥2,293
¥307
¥5,473
¥186
55866
Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
TABLE V–41—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 7-PERCENT
DISCOUNT RATE FOR UNITS SOLD IN 2017–2025—Continued
Trial standard levels
Equipment class
1
PD.M ........................................................
PD.L .........................................................
FD.M ........................................................
FD.L .........................................................
2
3
3
62
0
5
0
0
0
0
4
3
30
0
2
5
1
53
0
4
6
¥870
¥244
¥53
¥30
1
13
0
0
TABLE V–42—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: NET PRESENT VALUE IN MILLIONS (2012$) AT A
7-PERCENT DISCOUNT RATE FOR UNITS SOLD IN 2017–2025
Trial standard levels
Application
1
2
3
4
5
6
Medium temperature
Combined NPV ........................................
2,883
3,061
2,791
3,156
3,153
¥12,843
First cost benefits .....................................
3
1
9
17
23
77
Sub-Total ..........................................
2,886
3,062
2,800
3,174
3,176
¥12,766
Low temperature
Combined NPV ........................................
First cost benefits .....................................
1,322
23
1,125
0
1,045
42
1,479
33
1,416
124
¥1,829
174
Sub-Total ..........................................
1,345
1,125
1,087
1,512
1,540
¥1,655
Total—All ...................................
4,230
4,188
3,887
4,686
4,716
¥14,421
TABLE V–43—WICF REFRIGERATION SYSTEMS: NET PRESENT VALUE IN MILLIONS (2012$) AT A 3-PERCENT DISCOUNT
RATE FOR UNITS SOLD IN 2017–2025
Trial standard levels
Equipment class
1,3
DC.M.I * ............................................................................................................
DC.M.O * ..........................................................................................................
DC.L.I * .............................................................................................................
DC.L.O * ...........................................................................................................
MC.M ...............................................................................................................
MC.L ................................................................................................................
2,4
42
3,564
14
1,535
828
177
5
63
4,330
24
2,143
832
187
6
63
4,377
24
2,145
828
177
63
4,377
24
2,145
828
177
* For DC refrigeration systems, results include both capacity ranges.
TABLE V–44—ENVELOPE COMPONENT EQUIPMENT CLASSES: NET PRESENT VALUE IN MILLIONS (2012$) AT A 3-PERCENT
DISCOUNT RATE FOR UNITS SOLD IN 2017–2025
Trial standard levels
Equipment class
tkelley on DSK3SPTVN1PROD with PROPOSALS2
1
SP.M ........................................................
SP.L .........................................................
FP.L ..........................................................
DD.M ........................................................
DD.L .........................................................
PD.M ........................................................
PD.L .........................................................
FD.M ........................................................
FD.L .........................................................
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2
296
651
64
675
52
9
147
0
11
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0
0
0
650
50
0
0
0
0
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4
197
385
61
675
21
9
118
0
8
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5
224
503
48
650
50
6
129
0
10
11SEP2
6
101
167
34
648
49
5
87
0
6
¥12,538
¥2,879
¥392
¥7,204
¥203
¥1,161
¥261
¥71
¥35
Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
55867
TABLE V–45—REFRIGERATION SYSTEMS AND COMPONENTS COMBINED: NET PRESENT VALUE IN MILLIONS (2012$) AT A
3-PERCENT DISCOUNT RATE FOR UNITS SOLD IN 2017–2025
Trial standard levels
Application
1
2
3
4
5
6
Medium temperature
Combined NPV ........................................
First cost benefits .....................................
5,414
4
5,875
2
5,315
12
6,106
24
6,022
32
¥15,707
107
Sub-Total ..........................................
5,418
5,877
5,328
6,130
6,054
¥15,600
Low temperature
Combined NPV ........................................
First cost benefits .....................................
2,624
34
2,403
0
2,319
62
3,092
67
2,688
172
¥1,425
240
Sub-Total ..........................................
2,658
2,403
2,382
3,159
2,859
¥1,185
Total—All ...................................
8,076
8,281
7,709
9,289
8,913
¥16,785
c. Employment Impacts
Besides the direct impacts on
manufacturing employment discussed
in section V.B.2.b, DOE develops
general estimates of the indirect
employment impacts of proposed
standards on the economy. As discussed
above, DOE expects energy conservation
standards for walk-ins to reduce energy
bills for commercial consumers, and the
resulting net savings to be redirected to
other forms of economic activity. DOE
also realizes that these shifts in
spending and economic activity by
WICF owners could affect the demand
for labor. Thus, indirect employment
impacts may result from expenditures
shifting between goods (the substitution
effect) and changes in income and
overall expenditure levels (the income
effect) that occur due to the imposition
of standards. These impacts may affect
a variety of businesses not directly
involved in the decision to make,
operate, or pay the utility bills for walkins. To estimate these indirect economic
effects, DOE used an input/output
model of the U.S. economy using U.S.
Department of Commerce, Bureau of
Economic Analysis (BEA) and Bureau of
Labor Statistics (BLS) data (as described
in section IV.J; see chapter 13 of the
TSD for more details).
In this input/output model, the
dollars saved on utility bills from more
efficient walk-in equipment are centered
in economic sectors that create more
jobs than are lost in the electric utility
industry when spending is shifted from
electricity to other products and
services. Thus, the proposed walk-in
energy conservation standards are likely
to slightly increase the net demand for
labor in the economy. However, the net
increase in jobs might be offset by other,
unanticipated effects on employment.
Neither the BLS data nor the input/
output model used by DOE indicates the
quality of jobs lost or gained. As shown
in Table V–46, DOE estimates that net
indirect employment impacts from a
proposed WICF standard are small
relative to the national economy.
TABLE V–46—NET CHANGE IN JOBS FROM INDIRECT EMPLOYMENT EFFECTS UNDER WICF TSLS
Year
2017 .................................................................................................
tkelley on DSK3SPTVN1PROD with PROPOSALS2
4. Impact on Utility or Performance of
Equipment
In performing the engineering
analysis, DOE generally considers
design options that would not lessen the
utility or performance of the individual
classes of equipment. See 42 U.S.C.
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Envelope
components
1
2
3
4
5
6
1
2
3
4
5
6
2021 .................................................................................................
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Net national change in jobs
(thousands)
Trial standard
level
6295(o)(2)(B)(i)(IV). As presented in the
screening analysis (chapter 4 of the
TSD), DOE eliminates design options
that reduce the utility of the equipment
from consideration. For this notice, DOE
tentatively concludes that none of the
efficiency levels proposed for walk-in
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Refrigeration
systems
0.2
0.1
0.2
0.2
0.2
0.3
0.8
0.3
1.0
0.8
0.9
1.4
0.5
0.7
0.5
0.7
0.8
0.8
2.5
3.4
2.5
3.4
3.6
3.6
Total
0.7
0.8
0.7
0.9
1.0
1.1
3.4
3.7
3.5
4.2
4.4
5.0
cooler and freezer equipment would be
likely to reduce the utility or
performance of the equipment.
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
5. Impact of Any Lessening of
Competition
DOE has also considered any
lessening of competition that is likely to
result from amended standards. The
Attorney General determines the
impact, if any, of any lessening of
competition likely to result from a
proposed standard, and transmits such
determination to the Secretary, together
with an analysis of the nature and
extent of such impact. (42 U.S.C.
6295(o)(2)(B)(i)(V) and (ii))
To assist the Attorney General in
making such determination, DOE will
provide DOJ with copies of this NOPR
and the TSD for review. DOE will
consider DOJ’s comments on the
proposed rule in preparing the final
rule, and DOE will publish and respond
to DOJ’s comments in that document.
DOE also notes that during MIA
interviews, domestic manufacturers
indicated that foreign manufacturers do
not generally enter the walk-in market
and have not done so for the past
several years; however, some walk-in
equipment may be manufactured in
Mexico or Canada. Manufacturers also
stated that consolidation has occurred
among walk-in manufacturers in recent
years, due largely to the competitive
nature of the industry and the recently
enacted standards established by
Congress. DOE believes that these trends
will continue in this market regardless
of the proposed standard levels chosen,
but could accelerate if higher standard
levels are set.
DOE does not believe that the
proposed standards would result in
domestic firms moving their production
facilities outside the United States. The
vast majority of walk-ins sold in the
United States are manufactured in the
United States, in large part because
walk-in equipment is generally bulky,
making it difficult and expensive to ship
internationally. Manufacturers generally
indicated during interviews that they
would modify their existing facilities to
comply with the amended energy
conservation standards that DOE
develops.
6. Need of the Nation To Conserve
Energy
An improvement in the energy
efficiency of the products subject to
today’s rule is likely to improve the
security of the nation’s energy system by
reducing overall demand for energy.
Reduced electricity demand may also
improve the reliability of the electricity
system. Reductions in national electric
generating capacity estimated for each
considered TSL are reported in chapter
14 of the TSD.
Energy savings from amended
standards for WICF equipment classes
covered in today’s NOPR could also
produce environmental benefits in the
form of reduced emissions of air
pollutants and greenhouse gases
associated with electricity production.
Table V–47 provides DOE’s estimate of
cumulative emissions reductions
projected to result from the TSLs
considered in this rulemaking. The table
includes both power sector emissions
and upstream emissions. The upstream
emissions were calculated using the
multipliers discussed in section IV.G.
DOE reports annual CO2, NOX, and Hg
emissions reductions for each TSL in
chapter 15 of the NOPR TSD. As
discussed in section IV.J, DOE did not
include NOX emissions reduction from
power plants in States subject to CAIR,
because an energy conservation
standard would not affect the overall
level of NOX emissions in those States
due to the emissions caps mandated by
CSAPR.
TABLE V–47—CUMULATIVE EMISSIONS REDUCTION FOR WICF TSLS FOR EQUIPMENT PURCHASED IN 2017–2046
TSL
1
2
3
4
5
6
240.95
183.22
0.53
5.33
29.98
322.01
246.75
188.62
0.54
5.51
30.74
329.61
281.35
214.60
0.62
6.26
35.03
375.89
299.79
228.76
0.66
6.67
37.33
400.52
345.05
263.66
0.76
7.70
42.98
460.93
14.27
196.36
0.01
0.14
1,192.72
3.06
14.61
201.02
0.01
0.15
1,221.16
3.13
16.66
229.24
0.01
0.17
1,392.52
3.57
17.75
244.26
0.01
0.18
1,483.77
3.80
20.43
281.10
0.01
0.21
1,707.59
4.38
255.22
379.58
0.54
5.48
1,222.70
325.06
261.36
389.64
0.55
5.65
1,251.90
332.74
298.01
443.84
0.63
6.43
1,427.56
379.46
317.54
473.02
0.67
6.85
1,521.10
404.32
365.48
544.76
0.77
7.90
1,750.57
465.31
Power Sector and Site Emissions *
CO2 (million metric tons) ..............................................................
NOX (thousand tons) ...................................................................
Hg (tons) ......................................................................................
N2O (thousand tons) ....................................................................
CH4 (thousand tons) ....................................................................
SO2 (thousand tons) ....................................................................
234.32
178.96
0.52
5.22
29.18
313.03
Upstream Emissions
CO2 (million metric tons) ..............................................................
NOX (thousand tons) ...................................................................
Hg (tons) ......................................................................................
N2O (thousand tons) ....................................................................
CH4 (thousand tons) ....................................................................
SO2 (thousand tons) ....................................................................
13.87
190.90
0.01
0.14
1,159.66
2.97
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Total Emissions
CO2 (million metric tons) ..............................................................
NOX (thousand tons) ...................................................................
Hg (tons) ......................................................................................
N2O (thousand tons) ....................................................................
CH4 (thousand tons) ....................................................................
SO2 (thousand tons) ....................................................................
As part of the analysis for this NOPR,
DOE estimated monetary benefits likely
to result from the reduced emissions of
CO2 and NOX that DOE estimated for
each of the TSLs considered. As
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248.19
369.85
0.52
5.36
1,188.84
316.00
discussed in section IV.M.1, DOE used
values for the SCC developed by an
interagency process. The interagency
group selected four sets of SCC values
for use in regulatory analyses. Three sets
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are based on the average SCC from three
integrated assessment models, at
discount rates of 2.5 percent, 3 percent,
and 5 percent. The fourth set, which
represents the 95th-percentile SCC
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estimate across all three models at a 3percent discount rate, is included to
represent higher-than-expected impacts
from temperature change further out in
the tails of the SCC distribution. The
four values for CO2 emissions
reductions in 2015, expressed in 2012$,
are $12.9/ton, $40.8/ton, $62.2/ton, and
$117.0/ton. The values for later years
are higher due to increasing damages as
the magnitude of climate change
increases.
Table V–48 presents the global value
of CO2 emissions reductions at each
TSL. DOE calculated domestic values as
a range from 7 percent to 23 percent of
the global values, and these results are
presented in chapter 16 of the NOPR
TSD.
TABLE V–48—CUMULATIVE EMISSIONS REDUCTION FOR WICF TSLS
[2017 through 2073]
SCC case *
5% discount
rate,
average *
TSL
3% discount
rate,
average *
2.5% discount
rate, average *
3% discount
rate, 95th
percentile *
Primary Energy Emissions
Million 2012$
1
2
3
4
5
6
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
1,477.1
1,532.4
1,552.5
1,777.9
1,892.8
2,173.0
7,031.6
7,269.9
7,396.3
8,455.6
9,004.8
10,348.6
11,276.4
11,648.3
11,863.3
13,556.7
14,438.5
16,597.3
21,608.4
22,334.5
22,730.2
25,982.3
27,670.6
31,802.7
86.8
90.0
91.2
104.4
111.2
127.7
415.1
429.1
436.7
499.1
531.6
610.9
665.9
687.8
700.6
800.6
852.7
980.2
1,277.0
1,319.6
1,343.3
1,535.4
1,635.2
1,879.4
1,563.8
1,622.4
1,643.7
1,882.4
2,003.9
2,300.7
7,446.7
7,698.9
7,832.9
8,954.8
9,536.4
10,959.5
11,942.3
12,336.1
12,563.9
14,357.3
15,291.2
17,577.5
22,885.4
23,654.1
24,073.6
27,517.7
29,305.8
33,682.1
Upstream Emissions
1
2
3
4
5
6
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
Total Emissions
1
2
3
4
5
6
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
.......................................................................................................................
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.9, $40.8, $62.2 and $117.0 per metric ton (2012$).
DOE is well aware that scientific and
economic knowledge about the
contribution of CO2 and other GHG
emissions to changes in the future
global climate and the potential
resulting damages to the world economy
continues to evolve rapidly. Thus, any
value placed in this NOPR on reducing
CO2 emissions is subject to change.
DOE, together with other Federal
agencies, will continue to review
various methodologies for estimating
the monetary value of reductions in CO2
and other GHG emissions. This ongoing
review will consider the comments on
this subject that are part of the public
record for this NOPR and other
rulemakings, as well as other
methodological assumptions and issues.
However, consistent with DOE’s legal
obligations, and taking into account the
uncertainty involved with this
particular issue, DOE has included in
this NOPR the most recent values and
analyses resulting from the ongoing
interagency review process.
DOE also estimated a range for the
cumulative monetary value of the
economic benefits associated with NOX
and Hg emissions reductions
anticipated to result from amended
ballast standards. Table V–49 presents
the present value of cumulative NOX
emissions reductions for each TSL
calculated using the average dollar-perton values at 7-percent and 3-percent
discount rates.
TABLE V–49—CUMULATIVE PRESENT VALUE OF NOX EMISSIONS REDUCTION FOR WICF TSLS
tkelley on DSK3SPTVN1PROD with PROPOSALS2
[2017 through 2073]
3% discount
rate
TSL
7% discount
rate
Power Sector Emissions
Million 2012$
1 ...........................................................................................................................................................................
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TABLE V–49—CUMULATIVE PRESENT VALUE OF NOX EMISSIONS REDUCTION FOR WICF TSLS—Continued
[2017 through 2073]
3% discount
rate
TSL
2
3
4
5
6
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
7% discount
rate
227.7
231.0
264.4
281.5
323.3
101.0
100.9
116.2
123.6
141.4
240.1
249.4
252.3
289.1
307.7
353.1
105.4
110.5
110.5
127.2
135.3
154.8
459.8
477.1
483.3
553.5
589.2
676.5
201.6
211.4
211.4
243.5
258.9
296.3
Upstream Emissions
1
2
3
4
5
6
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
Total Emissions
1
2
3
4
5
6
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
...........................................................................................................................................................................
Note: Present value of NOX emissions calculated with at $2,639 per ton.
The NPV of the monetized benefits
associated with emissions reductions
can be viewed as a complement to the
NPV of the consumer savings calculated
for each TSL considered in this NOPR.
Table V–50 presents the NPV values
that result from adding the estimates of
the potential economic benefits
resulting from reduced CO2 and NOX
emissions in each of four valuation
scenarios to the NPV of consumer
savings calculated for each TSL
considered in this rulemaking, at both a
7-percent and a 3-percent discount rate.
The CO2 values used in the columns of
each table correspond to the four
scenarios for the valuation of CO2
emission reductions discussed above.
TABLE V–50—WICF TSLS: NET PRESENT VALUE OF CONSUMER SAVINGS COMBINED WITH NET PRESENT VALUE OF
MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS
Consumer NPV at 3% discount rate added with:
TSL
SCC Value of $12.9/
metric ton CO2* and low
value for NOX**
SCC Value of $40.8/
metric ton CO2* and
medium value for NOX**
SCC Value of $62.2/
metric ton CO2* and
medium value for NOX**
SCC Value of $117.0/
metric ton CO2* and
high value for NOX**
billion 2012$
1
2
3
4
5
6
.......................................................
.......................................................
.......................................................
.......................................................
.......................................................
.......................................................
23.03
22.83
22.28
26.28
25.45
¥44.22
29.29
29.30
28.87
33.80
33.46
¥35.01
33.79
33.94
33.60
39.21
39.22
¥28.39
45.11
45.65
45.50
52.82
53.72
¥11.73
Consumer NPV at 7% discount rate added with:
TSL
SCC Value of $12.9/
metric ton CO2* and low
value for NOX**
SCC Value of $40.8/
metric ton CO2* and
medium value for NOX**
SCC Value of $62.2/
metric ton CO2* and
medium value for NOX**
SCC Value of $117.0/
metric ton CO2* and
high value for NOX**
tkelley on DSK3SPTVN1PROD with PROPOSALS2
billion 2012$
1
2
3
4
5
6
.......................................................
.......................................................
.......................................................
.......................................................
.......................................................
.......................................................
9.36
9.30
8.80
10.57
9.91
¥26.86
15.41
15.55
15.16
17.84
17.66
¥17.96
19.91
20.19
19.89
23.24
23.41
¥11.34
31.02
31.68
31.58
36.60
37.64
5.01
Note: Low Value corresponds to $468 per ton of NOX emissions. Medium Value corresponds to $2,639 per ton of NOX emissions. High Value
corresponds to $4,809 per ton of NOX emissions.
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55871
* These label values represent the global SCC in 2015, in 2012$. The present values have been calculated with scenario-consistent discount
rates.
Although adding the value of
consumer savings to the values of
emission reductions provides a valuable
perspective, the following should be
considered: (1) The national consumer
savings are domestic U.S. consumer
monetary savings found in market
transactions, while the values of
emissions reductions are based on
estimates of marginal social costs,
which, in the case of CO2, are based on
a global value; and (2) the assessments
of consumer savings and emissionrelated benefits are performed with
different computer models, leading to
different timeframes for analysis. For
walk-ins, the present value of national
consumer savings is measured for the
period in which units shipped (2017–
2046) continue to operate. However, the
time frames of the benefits associated
with the emission reductions differ. For
example, the value of CO2 emissions
reductions reflects the present value of
all future climate-related impacts due to
emitting a ton of CO2 in that year, out
to 2300.
Chapter 15 of the NOPR TSD presents
calculations of the combined NPV,
including benefits from emissions
reductions for each TSL.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
7. Other Factors
Consistent with EPCA, DOE examined
whether other factors might be relevant
in determining whether the proposed
standards are economically justified.
See generally 42 U.S.C.
6295(o)(2)(B)(i)(VII). DOE identified
none other than those discussed above.
DOE prepared a regulatory impact
analysis (RIA) for this rulemaking,
which is contained in the TSD. The RIA
is subject to review by the Office of
Information and Regulatory Affairs
(OIRA) in the OMB. The RIA consists of
(1) a statement of the problem addressed
by this regulation and the mandate for
Government action, (2) a description
and analysis of policy alternatives to
this regulation, (3) a quantitative review
of the potential impacts of the
alternatives, and (4) the national
economic impacts of the proposed
standard.
The RIA assesses the effects of
feasible policy alternatives to walk-in
equipment standards and provides a
comparison of the impacts of the
alternatives. DOE evaluated the
alternatives in terms of their ability to
achieve significant energy savings at
reasonable cost, and compared them to
the effectiveness of the proposed rule.
DOE analyzed these alternatives with
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reference to the particular market
dynamics of the WICF industry.
DOE identified the following major
policy alternatives for achieving
increased WICF efficiency:
• No new regulatory action
• Commercial consumer tax credits
• Commercial consumer rebates
• Voluntary energy efficiency targets
• Bulk government purchases
• Early replacement
DOE qualitatively evaluated each
alternative’s ability to achieve
significant energy savings at reasonable
cost and compared it to the effectiveness
of the proposed rule. DOE assumed that
each alternative policy would induce
commercial consumers to voluntarily
purchase at least some higher efficient
at any of the trial standard levels (TSLs).
In contrast to a standard at one of the
TSLs, the adoption rate of the
alternative non-regulatory policy cases
may not be 100 percent, which would
result in lower energy savings than a
standard. The following paragraphs
discuss each policy alternative. (See
chapter 17 of the TSD, Regulatory
Impact Analysis, for further details.)
No new regulatory action. The case in
which no regulatory action is taken for
WICF equipment constitutes the base
case (or no action) scenario. By
definition, no new regulatory action
yields zero energy savings and a net
present value of zero dollars.
Commercial consumer tax credits.
Consumer tax credits are considered a
viable non-regulatory market
transformation program. From a
consumer perspective, the most
important difference between rebate and
tax credit programs is that a rebate can
be obtained quickly, whereas receipt of
tax credits is delayed until income taxes
are filed or a tax refund is provided by
the Internal Revenue Service (IRS).
From a societal perspective, tax credits
(like rebates) do not change the installed
cost of the equipment, but rather
transfer a portion of the cost from the
consumer to taxpayers as a whole. DOE,
therefore, assumed that equipment costs
in the consumer tax credits scenario
were identical to the NIA base case.
Commercial consumer rebates.
Consumer rebates cover a portion of the
difference in incremental product price
between products meeting baseline
efficiency levels and those meeting
higher efficiency levels, resulting in a
higher percentage of consumers
purchasing more efficient models and
decreased aggregated energy use
compared to the base case. Although a
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rebate program would reduce the total
installed cost to the consumer, it is
financed by tax revenues. Therefore,
from a societal perspective, the installed
cost at any efficiency level does not
change with the rebate program; rather,
part of the cost is transferred from the
consumer to taxpayers as a whole.
Consequently, DOE assumed that
equipment costs in the rebates scenario
were identical to the NIA base case.
Voluntary energy efficiency targets.
While it is possible that voluntary
programs for equipment would be
effective, DOE lacks a quantitative basis
to determine how effective such a
program might be. As noted previously,
broader economic and social
considerations are in play than simple
economic return to the equipment
purchaser. DOE lacks the data necessary
to quantitatively project the degree to
which such voluntary programs for
more expensive, higher efficiency
equipment would modify the market.
Bulk Government purchases and early
replacement incentive programs. DOE
also considered, but did not analyze, the
potential of bulk Government purchases
and early replacement incentive
programs as alternatives to the proposed
standards. Bulk purchases would have
very limited impact on improving the
overall market efficiency of WICF
equipment because they are a negligible
part of the total. In the case of
replacement incentives, several policy
options exist to promote early
replacement, including a direct national
program of consumer incentives,
incentives paid to utilities to promote
an early replacement program, market
promotions through equipment
manufacturers, and replacement of
government-owned equipment. In
considering early replacements, DOE
estimates that the energy savings
realized through a one-time early
replacement of existing stock equipment
does not result in energy savings
commensurate to the cost to administer
the program. Consequently, DOE did not
analyze this option in detail.
C. Proposed Standard
‘‘When considering proposed
standards, the new or amended energy
conservation standard that DOE adopts
for any type (or class) of walk-in coolers
and freezers shall be designed to
achieve the maximum improvement in
energy efficiency that the Secretary of
Energy determines is technologically
feasible and economically justified. (42
U.S.C. 6313(f)(4)(A)) In determining
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whether a standard is economically
justified, the Secretary must determine
whether the benefits of the standard
exceed its burdens to the greatest extent
practicable, considering the seven
statutory factors discussed previously.
(42 U.S.C. 6295(o)(2)(B)(i) and 6316(a))
The new or amended standard must also
‘‘result in significant conservation of
energy.’’ (42 U.S.C. 6295(o)(3)(B) and
6316(a))
DOE considered the impacts of
standards at each TSL, beginning with
the maximum technologically feasible
level, to determine whether that level
met the evaluation criteria. If the max
tech level was not justified, DOE then
considered the next most efficient level
and undertook the same evaluation until
it reached the highest efficiency level
that is both technologically feasible and
economically justified and saves a
significant amount of energy.
DOE discusses the benefits and/or
burdens of each TSL in the remainder
of this section. DOE bases its discussion
of each TSL on quantitative analytical
results such as national energy savings,
net present value (discounted at 3 and
7 percent), emissions reductions,
industry net present value, life-cycle
cost, and consumers’ installed price
increases. Beyond the quantitative
results, DOE also considers other
burdens and benefits that affect
economic justification, including how
technological feasibility, manufacturer
costs, and impacts on competition may
affect the economic results presented.
DOE has included a table below that
presents a summary of the results of
DOE’s quantitative analysis for each
TSL. In addition to the quantitative
results presented in the tables, DOE also
considers other burdens and benefits
that affect economic justification.
Section V.B presents the estimated
impacts of each TSL on commercial
customers and manufacturers, and
subgroups thereof, as well as the Nation.
TABLE V–51—SUMMARY OF RESULTS FOR WICF REFRIGERATION SYSTEMS AND ENVELOPE COMPONENTS, TSLS 1–6
Category
TSL 1
TSL 2
TSL 3
TSL 4
TSL 5
TSL 6
National Full-Fuel Cycle Energy Savings (quads)
Total-All ....................................................
4.49
4.61
4.73
5.39
5.74
6.61
20.6
7.1
24.3
8.6
23.3
7.9
¥46.6
¥29.2
¥108 to ¥23
¥13 to ¥3
¥77 to 0
¥9 to 0
¥134 to ¥19
¥16 to ¥2
¥657 to 924
¥77 to 109
298.0
443.8
0.6
379.5
6.4
1,917.5
1,427.56
35,688.0
317.5
473.0
0.7
404.3
6.9
2,044.5
1,521.10
38,026.65
365.5
544.8
0.8
465.3
7.90
2,357.9
1,750.57
43,763.14
1.88 to 27.52
553
243
2.00 to 29.31
589
259
2.41 to 33.68
676
296
280
1,117
505
1,328
1,715
1,849
611
1,509
1,117
2,001
1,724
2,061
611
1,608
1,080
1,994
1,715
1,849
611
1,608
1,080
1,994
1,715
1,849
¥9
¥66
¥4
239
¥12
2
¥16
3
8
72
30
228
200
0
52
1
¥22
¥140
¥65
222
198
0
¥52
0
¥2,139
¥1,890
¥1,653
¥2,650
¥1,717
¥884
¥665
¥1,157
NPV of Consumer Benefits (2012$ billion)
3% discount rate ......................................
7% discount rate ......................................
21.4
7.8
21.1
7.6
Industry Impacts
Change in Industry NPV (2012$ million)
Change in Industry NPV (%) ...................
¥60 to ¥1
¥7 to 0
¥44 to 11
¥5 to 1
Cumulative Emissions Reduction
CO2 (MMt) ................................................
NOX (kt) ...................................................
Hg (t) ........................................................
SO2 (kt) ....................................................
N2O (kt) ....................................................
N2O (kt CO2 eq)@ ....................................
CH4 (kt) ....................................................
CH4 (kt CO2 eq)@ ....................................
248.2
369.9
0.5
316.0
5.4
1,600.0
1,188.84
29,720.25
255.2
379.6
0.5
325.1
5.5
1,634.5
1,222.70
30,566.82
261.4
389.6
0.6
332.7
5.7
1,687.2
1,251.90
31,296.66
Value of Cumulative Emissions Reduction *
CO2 (2012$ billion) * ................................
NOX—3% discount rate (2012$ million) ..
NOX—7% discount rate (2012$ million) ..
1.56 to 22.89
460
202
1.62 to 23.65
477
211
1.64 to 24.07
483
211
LCC Savings (2012$) **
Refrigeration Systems
DC.M.I *** .................................................
DC.M.O *** ...............................................
DC.L.I *** ..................................................
DC.L.O *** ................................................
MC.M ........................................................
MC.L .........................................................
280
1,048
505
1,328
1,715
1,849
611
1,577
1,117
2,001
1,724
2,061
tkelley on DSK3SPTVN1PROD with PROPOSALS2
Envelope Components
SP.M ........................................................
SP.L .........................................................
FP.L ..........................................................
DD.M ........................................................
DD.L .........................................................
PD.M ........................................................
PD.L .........................................................
FD.M ........................................................
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122
66
239
217
2
74
3
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0
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0
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TABLE V–51—SUMMARY OF RESULTS FOR WICF REFRIGERATION SYSTEMS AND ENVELOPE COMPONENTS, TSLS 1–6—
Continued
Category
TSL 1
FD.L .........................................................
TSL 2
152
TSL 3
TSL 4
TSL 5
TSL 6
28
136
¥32
¥1,337
3.2
1.8
2.8
1.2
0.6
2.5
4.4
2.0
2.7
2.3
0.5
0.4
4.4
3.0
3.1
2.8
0.6
2.5
4.4
3.0
3.1
2.8
0.6
2.5
6.8
7.4
6.0
2.1
6.0
4.5
6.2
4.5
5.8
0
4.5
3.6
4.5
2.2
N/A
5.5
4.7
5.4
2.9
9.0
10.0
8.0
2.2
N/A
6.0
7.0
5.9
6.5
146.4
43.0
48.7
37.6
18.5
78.7
18.3
81.5
21.7
0
0
100
1
0
99
1
0
99
28
0
72
93
0
7
100
0
0
0
0
100
0
0
100
100
0
0
45
0
55
67
0
33
100
0
0
28
0
72
65
0
35
100
0
0
PBP (years) †
Refrigeration Systems
DC.M.I *** .................................................
DC.M.O *** ...............................................
DC.L.I *** ..................................................
DC.L.O *** ................................................
MC.M ........................................................
MC.L .........................................................
3.2
1.3
2.8
1.2
0.6
2.5
4.4
2.5
2.7
2.3
0.5
0.4
Envelope Components
SP.M ........................................................
SP.L .........................................................
FP.L ..........................................................
DD.M ........................................................
DD.L .........................................................
PD.M ........................................................
PD.L .........................................................
FD.M ........................................................
FD.L .........................................................
3.8
2.9
3.5
2.1
N/A
4.5
4.3
4.5
3.8
N/A
N/A
N/A
2.2
N/A
N/A
N/A
N/A
N/A
Distribution of Consumer LCC Impacts
All Medium and Low Temperature Refrigeration Systems
Net Cost (%) .....................................
No Impact (%) ...................................
Net Benefit (%) .................................
0
0
100
0
0
100
0
0
100
All Medium and Low Temperature Panels
Net Cost (%) .....................................
No Impact (%) ...................................
Net Benefit (%) .................................
11
0
89
0
100
0
76
0
24
All Medium and Low Temperature Display Doors
Net Cost (%) .....................................
No Impact (%) ...................................
Net Benefit (%) .................................
0
0
100
0
0
100
4
0
96
All Medium and Low Temperature Passage Doors
Net Cost (%) .....................................
No Impact (%) ...................................
Net Benefit (%) .................................
23
0
77
0
100
0
39
0
61
All Medium and Low Temperature Freight Doors
Net Cost (%) .....................................
No Impact (%) ...................................
Net Benefit (%) .................................
16
0
84
0
100
0
39
0
61
tkelley on DSK3SPTVN1PROD with PROPOSALS2
* Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.
** For LCCs, DOE did not consider variability of input parameters and used fixed input values. For the panels the unit of analysis is 100 ft2, for
other items it is a single unit of a refrigeration system or a door.
*** For DC refrigeration systems, results include both capacity ranges.
† For PBPs, DOE did not consider variability of input parameters and used fixed input values.
@ CO2eq is the quantity of CO2 that would have the same global warming potential (GWP).
DOE also notes that the economics
literature provides a wide-ranging
discussion of how consumers trade off
upfront costs and energy savings in the
absence of government intervention.
Much of this literature attempts to
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explain why consumers appear to
undervalue energy efficiency
improvements. This undervaluation
suggests that regulation that promotes
energy efficiency can produce
significant net private gains (as well as
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producing social gains by, for example,
reducing pollution). There is evidence
that consumers undervalue future
energy savings as a result of (1) a lack
of information, (2) a lack of sufficient
salience of the long-term or aggregate
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benefits, (3) a lack of sufficient savings
to warrant accelerating or altering
investments in energy saving
equipment, (4) excessive focus on the
short term, in the form of inconsistent
weighing of future energy cost savings
relative to available returns on other
investments; (5) computational or other
difficulties associated with the
evaluation of relevant tradeoffs; and (6)
a divergence in incentives (e.g., renter
versus building owner; builder versus
home buyer). Other literature indicates
that with less than perfect foresight and
a high degree of uncertainty about the
future, it may be rational for consumers
to trade off these types of investments
at a higher than expected rate between
current consumption and uncertain
future energy cost savings. Some studies
suggest that this seeming
undervaluation may be explained in
certain circumstances by differences
between tested and actual energy
savings, or by uncertainty and
irreversibility of energy investments.
There may also be ‘‘hidden’’ welfare
losses to customers if newer energy
efficient equipment is an imperfect
substitute for the less efficient
equipment it replaces. In the abstract, it
may be difficult to say how a welfare
gain from correcting potential underinvestment in energy conservation
compares in magnitude to the potential
welfare losses associated with no longer
purchasing equipment or switching to
an imperfect substitute, both of which
still exist in this framework.
While DOE is not prepared at present
to provide a fully quantifiable
framework for estimating the benefits
and costs of changes in consumer
purchase decisions due to an energy
conservation standard, DOE has posted
a paper that discusses the issue of
consumer welfare impacts of appliance
energy efficiency standards, and
potential enhancements to the
methodology by which these impacts
are defined and estimated in the
regulatory process.35 DOE is committed
to developing a framework that can
support empirical quantitative tools for
improved assessment of the consumer
welfare impacts of appliance standards.
DOE welcomes comments on how to
more fully assess the potential impact of
energy conservation standards on
consumer choice and how to quantify
this impact in its regulatory analysis in
future rulemakings. In particular, DOE
requests comment on whether there are
35 Alan Sanstad, Notes on the Economics of
Household Energy Consumption and Technology
Choice. Lawrence Berkeley National Laboratory.
2010. https://www1.eere.energy.gov/buildings/
appliance_standards/pdfs/consumer_ee_theory.pdf
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features or attributes of the more energy
efficient walk-in coolers and walk-in
freezers that manufacturers would
produce to meet the standards in this
proposed rule that might affect the
welfare, positively or negatively, of
consumers who purchase WICFs.
First, DOE considered TSL 6, the max
tech level for WICF refrigeration
systems and the covered envelope
components combined together. TSL 6
would save an estimated 6.61 quads of
energy through 2073, an amount DOE
considers significant. For the Nation as
a whole, DOE projects that TSL 6 would
have a negative NPV for consumers, i.e.,
result in increased costs of $29.2 billion,
using a discount rate of 7 percent. The
emissions reductions at TSL 6 are 365.5
MMt of CO2, up to 545 kt of NOX, 465
kt of SO2, and up to 0.8 tons of Hg.
These reductions are valued from $2.41
to $33.68 billion for CO2. For NOX the
emissions reductions are valued at $296
million at a discount rate of 7 percent.
At TSL 6, DOE projects that
consumers of WICF envelope
components will experience an increase
in LCC, ranging from $665 (low
temperature passage door) to $2,650
(medium temperature display door)
compared to the baseline. For
refrigeration systems, however, DOE
estimates that consumers would
experience a decrease in LCC ranging
from $611 to $1,994.
At TSL 6, manufacturers expect
diminished profitability due to large
increases in product costs, capital
investments in equipment and tooling,
and expenditures related to engineering
and testing. The projected change in
INPV ranges from a decrease of $657
million to an increase of $924 million
based on DOE’s manufacturer mark-up
scenarios. The upper bound of $924
million is considered an optimistic
scenario by manufacturers because it
assumes manufacturers can fully pass
on substantial increases in product
costs. DOE recognizes the risk of large
negative impacts on industry if
manufacturers’ expectations concerning
reduced profit margins are realized. TSL
6 could reduce the walk-in refrigeration,
panel, and door INPV by up to 77
percent, if the most negative impacts are
realized.
After carefully considering the
analysis and weighing the benefits and
burdens of TSL 6, DOE finds that the
benefits to the Nation of TSL 6 (i.e.,
energy savings and emissions
reductions (including environmental
and monetary benefits)) are small
compared to the burdens (i.e., a
decrease of $29.2 billion in NPV and a
decrease of 77 percent in INPV).
Because the burdens of TSL 6 far
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outweigh the benefits, TSL 6 is not
economically justified. Therefore, DOE
is not proposing to adopt TSL 6.
DOE then considered TSL 5, which
combines refrigeration systems and
envelope components at the highest
efficiency level for each that would
generate positive NPV to the Nation.
TSL 5 would likely save an estimated
5.74 quads of energy through 2073, an
amount DOE considers significant. For
the Nation as a whole, DOE projects that
TSL 5 would result in a net increase of
$7.9 billion in NPV, using a discount
rate of 7 percent. The estimated
emissions reductions at TSL 5 are 317.5
MMt of CO2, up to 473 kt of NOX, 404
kt of SO2, and up to 0.7 tons of Hg.
These reductions are valued from $2.00
to $29.31 billion for CO2. For NOX the
emissions reductions are valued at $259
million at a discount rate of 7 percent.
At TSL 5, DOE projects that the
customers of WICF equipment will
experience an increase in LCC for
panels and low temperature passage and
freight doors and either unchanged or
decreased LCC for display doors and
medium temperature passage and
freight doors. For the refrigeration
systems, DOE estimates that the
consumers would experience a decrease
in LCC ranging from $611 to $1,994.
At TSL 5, the projected change in
INPV ranges from a decrease of $134
million to a decrease of $19 million. At
TSL 5, DOE recognizes the risk of
negative impacts if manufacturers’
expectations concerning reduced profit
margins are realized. If the negative end
of the range of impacts is reached as
DOE expects, TSL 5 could result in a net
loss of 16 percent in INPV to the walkin cooler and freezer industry.
Additionally, DOE is concerned about
TSL 5 causing disproportionate burdens
on small business panel manufacturers,
as explained in the Regulatory
Flexibility analysis in section VI.B.4.
After carefully considering the
analysis and weighing the benefits and
burdens of TSL 5, DOE finds that the
benefits to the Nation at TSL 5 (i.e.,
energy savings and emissions
reductions (including environmental
and monetary benefits)) are too low
compared to the burdens (i.e., a
decrease of 16 percent in INPV for the
walk-in cooler and freezer industry with
disproportionate impacts on the panel
industry). Because the burdens of TSL 5
outweigh the benefits, TSL 5 is not
economically justified. Therefore, DOE
is not proposing TSL 5.
Next, DOE considered TSL 4, which
combines the refrigeration systems at
the maximum NPV level with the
envelope components also at the
maximum NPV level. TSL 4 would
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
likely save an estimated 5.39 quads of
energy through 2073, an amount DOE
considers significant. For the Nation as
a whole, DOE projects that TSL 4 would
result in a net increase of $8.6 billion in
NPV, using a discount rate of 7 percent.
The estimated emissions reductions at
TSL 4 are 298 MMt of CO2, up to 444
kt of NOX, 379.5 kt of SO2, and up to
0.6 tons of Hg. These reductions are
valued from $1.88 to $27.52 billion for
CO2. For NOX the emissions savings are
valued at $243 million at a discount rate
of 7 percent.
At TSL 4, DOE projects that
consumers of WICF equipment will
experience a decrease of LCC for all
equipment classes. At TSL 4, the
projected change in INPV ranges from a
decrease of $77 million to an increase of
$0.01 million. At TSL 4, DOE recognizes
the risk of negative impacts if
manufacturers’ expectations concerning
reduced profit margins are realized. If
the negative end of the range of impacts
is reached as DOE expects, TSL 4 could
result in a net loss of 9 percent of INPV
to walk-in manufacturers.
After carefully considering the
analysis and weighing the benefits and
burdens of TSL 4, DOE tentatively
believes that setting levels for both the
refrigeration system and envelope
components at TSL 4 represents the
maximum improvement in energy
efficiency that DOE’s analysis projects
to be technologically feasible and
economically justified. TSL 4 is
technologically feasible because the
technologies required to achieve these
levels are already in existence. TSL 4 is
economically justified because the
benefits to the Nation (i.e., increased
energy savings of 5.39 quads, emissions
reductions including environmental and
monetary benefits of, for example, 298
MMt of carbon dioxide emissions
reduction with an associated value of up
to $27.52 billion at a discount rate of 3
percent, and an increase of $8.6 billion
in NPV) outweigh the costs (i.e., a
decrease of 9 percent in INPV).
Therefore, DOE has tentatively
decided to propose the adoption of
energy conservation standards at TSL 4
for WICF refrigeration systems and the
considered envelope components. DOE
may re-examine this level depending on
the nature of the information it receives
during the comment period and make
adjustments to its final levels in
response to that information.
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VI. Procedural Issues and Regulatory
Review
A. Review Under Executive Orders
12866 and 13563
Section 1(b)(1) of Executive Order
12866, ‘‘Regulatory Planning and
Review,’’ 58 FR 51735 (Oct. 4, 1993),
requires each agency to identify the
problem that it intends to address,
including, where applicable, the failures
of private markets or public institutions
that warrant new agency action, as well
as to assess the significance of that
problem. The problems that today’s
standards address are as follows:
(1) There is a lack of consumer
information and/or information
processing capability about energy
efficiency opportunities in the walk-in
cooler and freezer market.
(2) There is asymmetric information
(one party to a transaction has more and
better information than the other) and/
or high transactions costs (costs of
gathering information and effecting
exchanges of goods and services).
(3) There are external benefits
resulting from improved energy
efficiency of walk-in coolers and
freezers that are not captured by the
users of such equipment. These benefits
include externalities related to
environmental protection that are not
reflected in energy prices, such as
reduced emissions of greenhouse gases.
In addition, DOE has determined that
today’s regulatory action is an
‘‘economically significant regulatory
action’’ under section 3(f)(1) of
Executive Order 12866. Accordingly,
section 6(a)(3) of the Executive Order
requires that DOE prepare a regulatory
impact analysis (RIA) on today’s rule
and that the Office of Information and
Regulatory Affairs (OIRA) in the Office
of Management and Budget (OMB)
review this rule. DOE presented to OIRA
for review the proposed rule and other
documents prepared for this
rulemaking, including the RIA, and has
included these documents in the
rulemaking record. The assessments
prepared pursuant to Executive Order
12866 can be found in the technical
support document for this rulemaking.
DOE has also reviewed this proposed
regulation pursuant to Executive Order
13563, issued on January 18, 2011 (76
FR 3281, Jan. 21, 2011). EO 13563 is
supplemental to and explicitly reaffirms
the principles, structures, and
definitions governing regulatory review
established in Executive Order 12866.
To the extent permitted by law, agencies
are required by Executive Order 13563
to: (1) Propose or adopt a regulation
only upon a reasoned determination
that its benefits justify its costs
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55875
(recognizing that some benefits and
costs are difficult to quantify); (2) tailor
regulations to impose the least burden
on society, consistent with obtaining
regulatory objectives, taking into
account, among other things, and to the
extent practicable, the costs of
cumulative regulations; (3) select, in
choosing among alternative regulatory
approaches, those approaches that
maximize net benefits (including
potential economic, environmental,
public health and safety, and other
advantages; distributive impacts; and
equity); (4) to the extent feasible, specify
performance objectives, rather than
specifying the behavior or manner of
compliance that regulated entities must
adopt; and (5) identify and assess
available alternatives to direct
regulation, including providing
economic incentives to encourage the
desired behavior, such as user fees or
marketable permits, or providing
information upon which choices can be
made by the public.
DOE emphasizes as well that
Executive Order 13563 requires agencies
to use the best available techniques to
quantify anticipated present and future
benefits and costs as accurately as
possible. In its guidance, the Office of
Information and Regulatory Affairs has
emphasized that such techniques may
include identifying changing future
compliance costs that might result from
technological innovation or anticipated
behavioral changes. For the reasons
stated in the preamble, DOE believes
that today’s NOPR is consistent with
these principles, including the
requirement that, to the extent
permitted by law, benefits justify costs
and that net benefits are maximized.
B. Review Under the Regulatory
Flexibility Act
The Regulatory Flexibility Act (5
U.S.C. 601 et seq.) requires preparation
of an initial regulatory flexibility
analysis (IRFA) for any rule that by law
must be proposed for public comment,
unless the agency certifies that the rule,
if promulgated, will not have a
significant economic impact on a
substantial number of small entities. As
required by Executive Order 13272,
‘‘Proper Consideration of Small Entities
in Agency Rulemaking,’’ 67 FR 53461
(August. 16, 2002), DOE published
procedures and policies on February 19,
2003 to ensure that the potential
impacts of its rules on small entities are
properly considered during the
rulemaking process. 68 FR 7990. DOE
has made its procedures and policies
available on the Office of the General
Counsel’s Web site (https://energy.gov/
gc/office-general-counsel).
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tkelley on DSK3SPTVN1PROD with PROPOSALS2
For manufacturers of walk-in coolers
and freezers, the Small Business
Administration (SBA) has set a size
threshold, which defines those entities
classified as ‘‘small businesses’’ for the
purposes of the statute. DOE used the
SBA’s small business size standards to
determine whether any small entities
would be subject to the requirements of
the rule. 65 FR 30836, 30848 (May 15,
2000), as amended at 65 FR 53533,
53544 (Sept. 5, 2000) and codified at 13
CFR part 121.The size standards are
listed by North American Industry
Classification System (NAICS) code and
industry description and are available at
https://www.sba.gov/idc/groups/public/
documents/sba_homepage/serv_sstd_
tablepdf.pdf. Walk-in cooler and freezer
manufacturing is classified under
NAICS 333415, ‘‘Air-Conditioning and
Warm Air Heating Equipment and
Commercial and Industrial Refrigeration
Equipment Manufacturing.’’ The SBA
sets a threshold of 750 employees or
fewer for an entity to be considered as
a small business for this category.
DOE determined that it could not
certify that the proposed rule, if
promulgated, would not have a
significant effect on a substantial
number of small entities that
manufacture WICF panels and doors.
Therefore, DOE has prepared an IRFA
(sections VI.B.1 through VI.B.6 below)
for this rulemaking. The IRFA describes
potential impacts on small businesses
associated with walk-in cooler and
freezer energy conservation standards.
1. Reasons for the Proposed Rule
Title III of the Energy Policy and
Conservation Act of 1975, as amended,
(EPCA or the Act) sets forth a variety of
provisions designed to improve energy
efficiency. Part B of Title III (42 U.S.C.
6291–6309) provides for the Energy
Conservation Program for Consumer
Products Other Than Automobiles. The
National Energy Conservation Policy
Act (NECPA), Public Law 95–619,
amended EPCA to add Part C of Title III,
which established an energy
conservation program for certain
industrial equipment. (42 U.S.C. 6311–
6317) (For purposes of codification in
Title 42 of the U.S. Code, these parts
were subsequently redesignated as Parts
A and A–1, respectively, for editorial
reasons.) Section 312 of the Energy
Independence and Security Act of 2007
(EISA 2007) further amended EPCA by
adding certain equipment to this energy
conservation program, including walkin coolers and walk-in freezers
(collectively ‘‘walk-in equipment’’ or
‘‘walk-ins’’), which are the subject of
this rulemaking. (42 U.S.C. 6311(1),
(20), 6313(f) and 6314(a)(9)) The
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proposed rule would establish energy
conservation standards for walk-in
coolers and walk-in freezers.
2. Objectives of, and Legal Basis for, the
Proposed Rule
EPCA provides that DOE must
publish performance-based standards
for walk-in coolers and walk-in freezers
that achieve the maximum improvement
in energy that is technologically feasible
and economically justified. (42 U.S.C.
6313(f)(4)(A)) However, in general, DOE
may not adopt any standard that would
not result in the significant conservation
of energy. (42 U.S.C. 6295(o)(3))
(Regarding provisions contained only in
the consumer products section of the
U.S. Code, DOE is proposing to apply
those provisions to walk-in coolers and
walk-in freezers in the same manner.)
Moreover, DOE may not prescribe a
standard: (1) For certain products,
including walk-in coolers and freezers,
if no test procedure has been established
for the product; or (2) if DOE determines
by rule that the proposed standard is not
technologically feasible or economically
justified. (42 U.S.C. 6295(o)(3)(A)–(B))
In deciding whether a proposed
standard is economically justified, DOE
must determine whether the benefits of
the standard exceed its burdens after
receiving comments on the proposed
standard. (42 U.S.C. 6295(o)(2)(B)(i)) To
determine whether economic
justification exists, DOE reviews
comments received and conducts
analysis to determine whether DOE
must make this determination, and by
considering, to the greatest extent
practicable, the seven factors set forth in
42 U.S.C.6295(o)(2)(B) (see section II of
this preamble).
EPCA also states that the Secretary
may not prescribe a standard if
interested persons have established by a
preponderance of the evidence that the
standard is likely to result in the
unavailability in the United States of
any covered product type (or class) of
performance characteristics (including
reliability), features, sizes, capacities,
and volumes that are substantially the
same as those generally available in the
United States. (42 U.S.C. 6295(o)(4))
Further information concerning the
background of this rulemaking is
provided in chapter 1 of the TSD.
3. Description and Estimated Number of
Small Entities Regulated
DOE used available public
information and information from
confidential interviews to identify
potential small manufacturers. DOE’s
research involved industry trade
association membership directories
(including AHRI and NAFEM), the NSF
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Section 7 certification database,
individual company Web sites, and
marketing research tools (e.g., Dun and
Bradstreet reports) to create a list of
companies that manufacture or sell
walk-in cooler or freezer panels, doors,
and refrigeration systems covered by
this rulemaking. DOE also asked
stakeholders and industry
representatives if they were aware of
any other small manufacturers during
manufacturer interviews and at previous
DOE public meetings. DOE reviewed the
publicly available data and contacted
select companies on its list, as
necessary, to determine whether they
met the SBA’s definition of a small
business manufacturer of WICF
equipment. DOE screened out
companies that did not offer products
covered by this rulemaking, did not
meet the definition of a ‘‘small
business,’’ or are foreign owned and
operated.
Based on this information, DOE
identified 52 panel manufacturers and
found 42 of the identified panel
manufacturers to be small businesses.
As part of the MIA interviews, the
Department interviewed nine panel
manufacturers, including three small
business operations. During MIA
interviews, multiple manufacturers
claimed that there are ‘‘hundreds of
two-man garage-based operations’’ that
produce WICF panels in small
quantities. They asserted that these
small manufacturers do not typically
comply with EISA 2007 standards and
do not obtain UL or NSF certifications
for their equipment. DOE was not able
to identify these small businesses and
did not consider them in its analysis.
Based on the purported number of small
panel manufacturers and the potential
scope of the impact (as described in
section VI.B.4 below), DOE could not
certify that the proposed standards
would not have a significant impact on
a substantial number of small
businesses with respect to the panel
industry.
DOE identified 59 walk-in door
manufacturers. Fifty-five of those
produce solid doors and four produce
display doors. Of the fifty-five solid
door manufacturers, fifty-two produce
panels as their primary business and are
considered in the category of panel
manufacturers above. The remaining
three solid door manufacturers are all
considered to be small businesses. Of
the four display door manufacturers,
two are considered small businesses.
Therefore, of the seven manufacturers
that exclusively produce WICF doors
(three producing solid doors and four
producing display doors), DOE
determined that five are small
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businesses. As part of the MIA
interviews, the Department interviewed
six door manufacturers, including four
small business operations. Based on the
large proportion of small door
manufacturers in the door market and
the potential scope of the impact (as
described in section VI.B.4 below), DOE
could not certify that the proposed
standards would not have a significant
impact on a large number of small
businesses with respect to the door
industry.
DOE identified nine refrigeration
system manufacturers in the WICF
industry. Based on publicly available
information, two of the manufacturers
are small businesses. One small
business focuses on large warehouse
refrigeration systems, which are outside
the scope of this rulemaking. However,
at its smallest capacity, this company’s
units can be sold to the walk-in market.
The other small business specializes in
building evaporators and unit coolers
for a range of refrigeration applications,
including the walk-in market. As part of
the MIA interviews, the Department
interviewed five refrigeration
manufacturers, including the two small
business operations. Both small
businesses expressed concern that the
rulemaking would negatively impact
their businesses and one small business
indicated it would exit the walk-in
industry as a result of any standard that
would directly impact walk-in
refrigeration system energy efficiency.
However, due to the small number of
small businesses that manufacture WICF
refrigeration systems and the fact that
only one of two focuses on WICF
refrigeration as a key market segment
and constitutes a very small share of the
overall walk-in market, DOE certifies
that the proposed standards would not
have a significant impact on a
substantial number of small businesses
with respect to the refrigeration
equipment industry.
4. Description and Estimate of
Compliance Requirements
Given the significant role of small
businesses in the walk-in panel and
walk-in door industries, DOE provides a
detailed analysis of the impacts of the
proposed standard on these industries
below.
Panels
In the walk-in industry, panel
manufacturers typically use the same
production lines to manufacture all
three equipment classes (SP.M, SP.L,
and FP.L). The equipment class with the
55877
most stringent standard drives
conversion costs. The design options
considered include reducing heat loss
through the panel frame (typically by
using high density polyurethane
framing materials or by moving to a
frameless design), increasing the
thickness of panels, and incorporating
vacuum-insulated technology.
Small manufacturers tend to be at a
disadvantage when adapting to a new
standard requiring fixed cost
investments. Small manufacturers may
have greater difficulty obtaining credit
or may obtain less favorable terms than
larger competitors when capital
expenditures are necessary to meet the
standard. Additionally, product testing
costs stemming from the energy
conservation standard tend to be fixed
and do not scale with sales volume. As
a result, these product conversion costs
would be the same in absolute terms for
small and large panel manufacturers.
The small businesses would have to
recoup these over smaller sales
volumes, leading to higher per unit
costs and potentially putting them at a
pricing disadvantage. The projected
conversion cost impacts on panel
manufacturers are shown in Table VI–1
and Table VI–2 below.
TABLE VI–1—IMPACTS OF CONVERSION COSTS ON A SMALL PANEL MANUFACTURER
Capital conversion cost
as a percentage of
annual capital
expenditures
TSL
TSL
TSL
TSL
TSL
TSL
1
2
3
4
5
6
Product conversion cost
as a percentage of
annual R&D expense
Total conversion cost as
a percentage of annual
revenue
Total conversion cost as
a percentage of annual
operating income
565
0
1695
565
1695
5461
122
0
230
122
230
995
9
0
26
9
26
87
242
0
669
242
669
2262
...............................................
...............................................
...............................................
...............................................
...............................................
...............................................
TABLE VI–2—IMPACTS OF CONVERSION COSTS ON A LARGE PANEL MANUFACTURER
Capital conversion cost
as a percentage of
annual capital
expenditures
tkelley on DSK3SPTVN1PROD with PROPOSALS2
TSL
TSL
TSL
TSL
TSL
TSL
1
2
3
4
5
6
Product conversion cost
as a percentage of
annual R&D expense
Total conversion cost as
a percentage of annual
revenue
Total conversion cost as
a percentage of annual
operating income
22
0
66
22
66
213
5
0
9
5
9
39
0
0
1
0
1
3
9
0
26
9
26
88
...............................................
...............................................
...............................................
...............................................
...............................................
...............................................
At the proposed standard (TSL 4), the
engineering analysis suggests that
manufacturers would shift to high
density rails for all products to achieve
the minimum U-factors. The capital
conversion costs would be 565% of the
typical annual capital expenditures for
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a small manufacturer while only 22% of
the typical annual capital expenditures
for a large manufacturer. The product
conversion costs would be 122% of the
typical small manufacturer’s annual
R&D budget and only 5% of the typical
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large manufacturer’s annual R&D
budget.
In addition to these conversion cost
impacts, small manufacturers typically
have a significant price disadvantage for
raw materials, such as foaming agents.
Any standard that requires small
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manufacturers to use more insulation or
add a different foam formulation for
high density rails will accentuate the
difference in material costs for large
manufacturers versus small
manufacturers.
Based on the large number of small
panel manufacturers and the potential
scope of the impact (as described in
section VI.B.2 below), DOE could not
certify that the proposed standards
would not have a significant impact on
a substantial number of small
businesses with respect to the panel
industry.
Doors
For the walk-in door industry, DOE
identified seven small manufacturers
that produce doors as their primary
product, as described in section VI.B.4.
Three companies produce solid doors
and four companies produce display
doors.
In the solid door market, all three
manufacturers of customized passage
doors and freight doors are small. The
potential impacts on these three
manufacturers are illustrated in Table
VI–3.
TABLE VI–3—IMPACTS OF CONVERSION COSTS ON A SMALL SOLID DOOR MANUFACTURER
Capital conversion cost
as a percentage of
annual capital
expenditures
TSL
TSL
TSL
TSL
TSL
TSL
1
2
3
4
5
6
Product conversion cost
as a percentage of
annual R&D expense
Total conversion cost as
a percentage of annual
revenue
Total conversion cost as
a percentage of annual
operating income
52
0
626
157
626
4086
47
0
47
47
47
142
2
0
5
2
5
27
25
0
63
25
63
369
...............................................
...............................................
...............................................
...............................................
...............................................
...............................................
At the proposed standard (TSL 4), the
engineering analysis suggests that
manufacturers would shift to high
density frames to achieve the minimum
energy consumption for all solid doors.
Additionally, for low-temperature
passage doors, manufacturers would
need to incorporate enhanced windows
to reduce heat transmission;
manufacturers of low-temperature
freight doors would need to add
controls to minimize anti-sweat heater
energy usage. The capital conversion
costs would be 157% of the typical
annual capital expenditures for a small
manufacturer and the product
conversion costs would be 47% of the
typical manufacturer’s annual R&D
budget.
In the display door market, two of the
four manufacturers are small. If
conversion costs for display door
manufacturers were large, the small
manufacturers could be at a
disadvantage due to the fixed
investments necessary for capital
conversion and product conversion
costs. However, as illustrated in Table
VI–4, conversion costs for display door
manufacturers are negligible for most
TSLs. This is because the considered
design options primarily consist of
component swaps and component
additions. To make these design
changes, no costly equipment or tooling
is necessary. As a result, the conversion
costs do not cause small businesses to
be at a significant disadvantage relative
to larger businesses when adapting to
the proposed standard.
TABLE VI–4—IMPACTS OF CONVERSION COSTS ON A SMALL DISPLAY DOOR MANUFACTURER
Capital conversion cost
as a percentage of
annual capital
expenditures
TSL
TSL
TSL
TSL
TSL
TSL
1
2
3
4
5
6
Product conversion cost
as a percentage of
annual R&D expense
Total conversion cost as
a percentage of annual
revenue
Total conversion cost as
a percentage of annual
operating income
0
0
0
0
0
501
2
2
2
2
2
19
0
0
0
0
0
3
0
0
0
0
0
20
...............................................
...............................................
...............................................
...............................................
...............................................
...............................................
TABLE VI–5—IMPACTS OF CONVERSION COSTS ON A LARGE DISPLAY DOOR MANUFACTURER
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Capital conversion cost
as a percentage of
annual capital
expenditures
TSL
TSL
TSL
TSL
TSL
TSL
1
2
3
4
5
6
Product conversion cost
as a percentage of
annual R&D expense
Total conversion cost as
a percentage of annual
revenue
Total conversion cost as
a percentage of annual
operating income
0
0
0
0
0
88
0
0
0
0
0
3
0
0
0
0
0
0
0
0
0
0
0
4
...............................................
...............................................
...............................................
...............................................
...............................................
...............................................
At the proposed standard (TSL 4), the
engineering analysis suggests that
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manufacturers would need to purchase
more efficient components, such as LED
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lights, and incorporate anti-sweat heater
controllers. There are no anticipated
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capital conversion costs, and product
conversion costs appear to be
manageable for both small and large
businesses door manufacturers.
Based on the number of small door
manufacturers and the potential scope
of the impact on solid door
manufacturers, DOE could not certify
that the proposed standards would not
have a significant impact on a
significant number of small businesses
with respect to the walk-in door
industry.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
5. Duplication, Overlap, and Conflict
With Other Rules and Regulations
DOE is not aware of any rules or
regulations that duplicate, overlap, or
conflict with the rule being considered
today.
6. Significant Alternatives to the
Proposed Rule
The primary alternatives to the
proposed rule considered by DOE are
the other TSLs besides the one being
considered today, proposed TSL 4. DOE
explicitly considered the role of small
businesses in its selection of TSL 4
rather than TSL 5. Though TSL 5 results
in greater energy savings for the
country, the standard would place
excessive burdens on manufacturers,
including small manufacturers, of walkin refrigeration, panels, and doors. In
particular, DOE considered the increase
in conversion costs and potential
negative impacts on small businesses
that occurred between TSL 4 and TSL
5 for the solid door and panel
industries, which have a significant
number of small businesses. As another
alternative to the proposed standard,
DOE also considered lower TSLs; in
particular, TSL 1, which does not set
standards for panels and non-display
doors. Chapter 12 of the TSD contains
additional information about the impact
of this rulemaking on manufacturers.
In addition to the other TSLs
considered, alternatives to the proposed
rule include the following policy
alternatives: (1) No new regulatory
action, (2) commercial consumer
rebates, and (3) commercial consumer
tax credits. Chapter 17 of the TSD
associated with this proposed rule
includes a report referred to in Section
VI.A in the preamble as the regulatory
impact analysis (RIA). The energy
savings of these regulatory alternatives
are one to two orders of magnitude
smaller than those expected from the
standard levels under consideration.
The range of economic impacts of these
regulatory alternatives is an order of
magnitude smaller than the range of
impacts expected from the standard
levels under consideration.
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C. Review Under the Paperwork
Reduction Act
Manufacturers of walk-in coolers and
freezers must certify to DOE that their
products comply with any applicable
energy conservation standards. In
certifying compliance, manufacturers
must test their products according to the
DOE test procedures for walk-in coolers
and freezers, including any amendments
adopted for those test procedures. DOE
has established regulations for the
certification and recordkeeping
requirements for all covered consumer
products and commercial equipment,
including walk-in coolers and freezers.
76 FR 12422 (March 7, 2011). The
collection-of-information requirement
for the certification and recordkeeping
is subject to review and approval by
OMB under the Paperwork Reduction
Act (PRA). This requirement has been
approved by OMB under OMB control
number 1910–1400. Public reporting
burden for the certification is estimated
to average 20 hours per response,
including the time for reviewing
instructions, searching existing data
sources, gathering and maintaining the
data needed, and completing and
reviewing the collection of information.
Notwithstanding any other provision
of the law, no person is required to
respond to, nor shall any person be
subject to a penalty for failure to comply
with, a collection of information subject
to the requirements of the PRA, unless
that collection of information displays a
currently valid OMB Control Number.
D. Review Under the National
Environmental Policy Act of 1969
DOE has prepared a draft
environmental assessment (EA) of the
impacts of the proposed rule pursuant
to the National Environmental Policy
Act of 1969 (42 U.S.C. 4321 et seq.), the
regulations of the Council on
Environmental Quality (40 CFR parts
1500–1508), and DOE’s regulations for
compliance with the National
Environmental Policy Act of 1969 (10
CFR part 1021). This assessment
includes an examination of the potential
effects of emission reductions likely to
result from the rule in the context of
global climate change, as well as other
types of environmental impacts. The
draft EA has been incorporated into the
NOPR TSD as chapter 15. Before issuing
a final rule for walk-in coolers and
freezers, DOE will consider public
comments and, as appropriate,
determine whether to issue a finding of
no significant impact (FONSI) as part of
a final EA or to prepare an
environmental impact statement (EIS)
for this rulemaking.
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55879
E. Review Under Executive Order 13132
Executive Order 13132, ‘‘Federalism’’
64 FR 43255 (Aug. 10, 1999), imposes
certain requirements on Federal
agencies formulating and implementing
policies or regulations that preempt
State law or that have Federalism
implications. The Executive Order
requires agencies to examine the
constitutional and statutory authority
supporting any action that would limit
the policymaking discretion of the
States and to carefully assess the
necessity for such actions. The
Executive Order also requires agencies
to have an accountable process to
ensure meaningful and timely input by
State and local officials in the
development of regulatory policies that
have Federalism implications. On
March 14, 2000, DOE published a
statement of policy describing the
intergovernmental consultation process
it will follow in the development of
such regulations. 65 FR 13735. EPCA
governs and prescribes Federal
preemption of State regulations as to
energy conservation for the products
that are the subject of today’s proposed
rule. See 42 U.S.C. 6316(h)(1)(A)(2), 42
U.S.C. 6316(h)(2)(B), and 42 U.S.C.
6316(h)(3). No further action is required
by Executive Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing
regulations and the promulgation of
new regulations, section 3(a) of
Executive Order 12988, ‘‘Civil Justice
Reform,’’ imposes on Federal agencies
the general duty to adhere to the
following requirements: (1) Eliminate
drafting errors and ambiguity; (2) write
regulations to minimize litigation; and
(3) provide a clear legal standard for
affected conduct rather than a general
standard and promote simplification
and burden reduction. 61 FR 4729 (Feb.
7, 1996). Section 3(b) of Executive Order
12988 specifically requires that
Executive agencies make every
reasonable effort to ensure that the
regulation: (1) Clearly specifies the
preemptive effect, if any; (2) clearly
specifies any effect on existing Federal
law or regulation; (3) provides a clear
legal standard for affected conduct
while promoting simplification and
burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately
defines key terms; and (6) addresses
other important issues affecting clarity
and general draftsmanship under any
guidelines issued by the Attorney
General. Section 3(c) of Executive Order
12988 requires Executive agencies to
review regulations in light of applicable
standards in section 3(a) and section
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tkelley on DSK3SPTVN1PROD with PROPOSALS2
3(b) to determine whether they are met
or it is unreasonable to meet one or
more of them. DOE has completed the
required review and determined that, to
the extent permitted by law, this
proposed rule meets the relevant
standards of Executive Order 12988.
G. Review Under the Unfunded
Mandates Reform Act of 1995
Title II of the Unfunded Mandates
Reform Act of 1995 (UMRA) requires
each Federal agency to assess the effects
of Federal regulatory actions on State,
local, and Tribal governments and the
private sector. Public Law 104–4, sec.
201 (codified at 2 U.S.C. 1531). For a
proposed regulatory action likely to
result in a rule that may cause the
expenditure by State, local, and Tribal
governments, in the aggregate, or by the
private sector of $100 million or more
in any one year (adjusted annually for
inflation), section 202 of UMRA requires
a Federal agency to publish a written
statement that estimates the resulting
costs, benefits, and other effects on the
national economy. (2 U.S.C. 1532(a), (b))
The UMRA also requires a Federal
agency to develop an effective process
to permit timely input by elected
officers of State, local, and Tribal
governments on a proposed ‘‘significant
intergovernmental mandate,’’ and
requires an agency plan for giving notice
and opportunity for timely input to
potentially affected small governments
before establishing any requirements
that might significantly or uniquely
affect small governments. On March 18,
1997, DOE published a statement of
policy on its process for
intergovernmental consultation under
UMRA. 62 FR 12820. DOE’s policy
statement is also available at https://
energy.gov/gc/office-general-counsel.
Although today’s proposed rule does
not contain a Federal intergovernmental
mandate, it may require expenditures of
$100 million or more on the private
sector. Specifically, the proposed rule
will likely result in a final rule that
could require expenditures of $100
million or more. Such expenditures may
include: (1) Investment in research and
development and in capital
expenditures by walk-in cooler and
freezer manufacturers in the years
between the final rule and the
compliance date for the new standards,
and (2) incremental additional
expenditures by customers to purchase
higher-efficiency walk-in coolers and
freezers, starting at the compliance date
for the applicable standard.
Section 202 of UMRA authorizes a
Federal agency to respond to the content
requirements of UMRA in any other
statement or analysis that accompanies
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the proposed rule. 2 U.S.C. 1532(c). The
content requirements of section 202(b)
of UMRA relevant to a private sector
mandate substantially overlap the
economic analysis requirements that
apply under section 325(o) of EPCA and
Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of
the NOPR and the ‘‘Regulatory Impact
Analysis’’ section of the TSD for this
proposed rule respond to those
requirements.
Under section 205 of UMRA, the
Department is obligated to identify and
consider a reasonable number of
regulatory alternatives before
promulgating a rule for which a written
statement under section 202 is required.
2 U.S.C. 1535(a). DOE is required to
select from those alternatives the most
cost-effective and least burdensome
alternative that achieves the objectives
of the proposed rule unless DOE
publishes an explanation for doing
otherwise, or the selection of such an
alternative is inconsistent with law. As
required by 42 U.S.C. 6313(f)(4)(A),
today’s proposed rule would establish
energy conservation standards for walkin coolers and walk-in freezers that are
designed to achieve the maximum
improvement in energy efficiency that
DOE has determined to be both
technologically feasible and
economically justified. A full discussion
of the alternatives considered by DOE is
presented in the ‘‘Regulatory Impact
Analysis’’ section of the TSD for today’s
proposed rule.
H. Review Under the Treasury and
General Government Appropriations
Act, 1999
Section 654 of the Treasury and
General Government Appropriations
Act, 1999 (Pub. L. 105–277) requires
Federal agencies to issue a Family
Policymaking Assessment for any rule
that may affect family well-being. This
rule would not have any impact on the
autonomy or integrity of the family as
an institution. Accordingly, DOE has
concluded that it is not necessary to
prepare a Family Policymaking
Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive
Order 12630, ‘‘Governmental Actions
and Interference with Constitutionally
Protected Property Rights’’ 53 FR 8859
(Mar. 18, 1988), that this regulation
would not result in any takings that
might require compensation under the
Fifth Amendment to the U.S.
Constitution.
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J. Review Under the Treasury and
General Government Appropriations
Act, 2001
Section 515 of the Treasury and
General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note)
provides for Federal agencies to review
most disseminations of information to
the public under guidelines established
by each agency pursuant to general
guidelines issued by OMB. OMB’s
guidelines were published at 67 FR
8452 (Feb. 22, 2002), and DOE’s
guidelines were published at 67 FR
62446 (Oct. 7, 2002). DOE has reviewed
today’s NOPR under the OMB and DOE
guidelines and has concluded that it is
consistent with applicable policies in
those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ‘‘Actions
Concerning Regulations That
Significantly Affect Energy Supply,
Distribution, or Use’’ 66 FR 28355 (May
22, 2001) requires Federal agencies to
prepare and submit to OIRA at OMB a
Statement of Energy Effects for any
proposed significant energy action. A
‘‘significant energy action’’ is defined as
any action by an agency that
promulgates or is expected to lead to
promulgation of a final rule, and that:
(1) Is a significant regulatory action
under Executive Order 12866, or any
successor order; and (2) is likely to have
a significant adverse effect on the
supply, distribution, or use of energy; or
(3) is designated by the Administrator of
OIRA as a significant energy action. For
any proposed significant energy action,
the agency must give a detailed
statement of any adverse effects on
energy supply, distribution, or use
should the proposal be implemented,
and of reasonable alternatives to the
action and their expected benefits on
energy supply, distribution, and use.
DOE has tentatively concluded that
today’s regulatory action, which sets
forth energy conservation standards for
walk-in coolers and freezers, is not a
significant energy action because the
proposed standards are not likely to
have a significant adverse effect on the
supply, distribution, or use of energy,
nor has it been designated as such by
the Administrator at OIRA. Accordingly,
DOE has not prepared a Statement of
Energy Effects on the proposed rule.
L. Review Under the Information
Quality Bulletin for Peer Review
On December 16, 2004, OMB, in
consultation with the Office of Science
and Technology Policy (OSTP), issued
its Final Information Quality Bulletin
for Peer Review (the Bulletin). 70 FR
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2664 (Jan. 14, 2005). The Bulletin
establishes that certain scientific
information shall be peer reviewed by
qualified specialists before it is
disseminated by the Federal
Government, including influential
scientific information related to agency
regulatory actions. The purpose of the
bulletin is to enhance the quality and
credibility of the Government’s
scientific information. Under the
Bulletin, the energy conservation
standards rulemaking analyses are
‘‘influential scientific information,’’
which the Bulletin defines as scientific
information the agency reasonably can
determine will have, or does have, a
clear and substantial impact on
important public policies or private
sector decisions. 70 FR 2667.
In response to OMB’s Bulletin, DOE
conducted formal in-progress peer
reviews of the energy conservation
standards development process and
analyses and has prepared a Peer
Review Report pertaining to the energy
conservation standards rulemaking
analyses. Generation of this report
involved a rigorous, formal, and
documented evaluation using objective
criteria and qualified and independent
reviewers to make a judgment as to the
technical/scientific/business merit, the
actual or anticipated results, and the
productivity and management
effectiveness of programs or projects.
The ‘‘Energy Conservation Standards
Rulemaking Peer Review Report’’ dated
February 2007 has been disseminated
and is available at the following Web
site: www1.eere.energy.gov/buildings/
appliance_standards/peer_review.html.
tkelley on DSK3SPTVN1PROD with PROPOSALS2
VII. Public Participation
A. Attendance at the Public Meeting
The time, date, and location of the
public meeting are listed in the DATES
and ADDRESSES sections at the beginning
of this notice. If you plan to attend the
public meeting, please notify Ms.
Brenda Edwards at (202) 586–2945 or
Brenda.Edwards@ee.doe.gov. Please
note that foreign nationals visiting DOE
Headquarters are subject to advance
security screening procedures. Any
foreign national wishing to participate
in the meeting should advise DOE as
soon as possible by contacting Ms.
Edwards to initiate the necessary
procedures. Please also note that those
wishing to bring laptops into the
Forrestal Building will be required to
obtain a property pass. Visitors should
avoid bringing laptops, or allow an extra
45 minutes. Persons can attend the
public meeting via webinar.
Webinar registration information,
participant instructions, and
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information about the capabilities
available to webinar participants will be
published on DOE’s Web site at: https://
www1.eere.energy.gov/buildings/
appliance_standards/rulemaking.aspx/
ruleid/30. Participants are responsible
for ensuring their systems are
compatible with the webinar software.
B. Procedure for Submitting Prepared
General Statements for Distribution
Any person who has plans to present
a prepared general statement may
request that copies of his or her
statement be made available at the
public meeting. Such persons may
submit requests, along with an advance
electronic copy of their statement in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format, to the appropriate address
shown in the ADDRESSES section at the
beginning of this notice. The request
and advance copy of statements must be
received at least one week before the
public meeting and may be emailed,
hand-delivered, or sent by mail. DOE
prefers to receive requests and advance
copies via email. Please include a
telephone number to enable DOE staff to
make follow-up contact, if needed.
C. Conduct of the Public Meeting
DOE will designate a DOE official to
preside at the public meeting and may
also use a professional facilitator to aid
discussion. The meeting will not be a
judicial or evidentiary-type public
hearing, but DOE will conduct it in
accordance with section 336 of EPCA
(42 U.S.C. 6306). A court reporter will
be present to record the proceedings and
prepare a transcript. DOE reserves the
right to schedule the order of
presentations and to establish the
procedures governing the conduct of the
public meeting. After the public
meeting, interested parties may submit
further comments on the proceedings as
well as on any aspect of the rulemaking
until the end of the comment period.
The public meeting will be conducted
in an informal, conference style. DOE
will present summaries of comments
received before the public meeting,
allow time for prepared general
statements by participants, and
encourage all interested parties to share
their views on issues affecting this
rulemaking. Each participant will be
allowed to make a general statement
(within time limits determined by DOE),
before the discussion of specific topics.
DOE will allow, as time permits, other
participants to comment briefly on any
general statements.
At the end of all prepared statements
on a topic, DOE will permit participants
to clarify their statements briefly and
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comment on statements made by others.
Participants should be prepared to
answer questions by DOE and by other
participants concerning these issues.
DOE representatives may also ask
questions of participants concerning
other matters relevant to this
rulemaking. The official conducting the
public meeting will accept additional
comments or questions from those
attending, as time permits. The
presiding official will announce any
further procedural rules or modification
of the above procedures that may be
needed for the proper conduct of the
public meeting.
A transcript of the public meeting will
be included in the docket, which can be
viewed as described in the Docket
section at the beginning of this notice.
In addition, any person may buy a copy
of the transcript from the transcribing
reporter.
D. Submission of Comments
DOE will accept comments, data, and
information regarding this proposed
rule before or after the public meeting,
but no later than the date provided in
the DATES section at the beginning of
this proposed rule. Interested parties
may submit comments, data, and other
information using any of the methods
described in the ADDRESSES section at
the beginning of this notice.
Submitting comments via
regulations.gov. The regulations.gov
Web page will require you to provide
your name and contact information.
Your contact information will be
viewable to DOE Building Technologies
staff only. Your contact information will
not be publicly viewable except for your
first and last names, organization name
(if any), and submitter representative
name (if any). If your comment is not
processed properly because of technical
difficulties, DOE will use this
information to contact you. If DOE
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, DOE may not be
able to consider your comment.
However, your contact information
will be publicly viewable if you include
it in the comment itself or in any
documents attached to your comment.
Any information that you do not want
to be publicly viewable should not be
included in your comment, nor in any
document attached to your comment.
Otherwise, persons viewing comments
will see only first and last names,
organization names, correspondence
containing comments, and any
documents submitted with the
comments.
Do not submit to regulations.gov
information for which disclosure is
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restricted by statute, such as trade
secrets and commercial or financial
information (hereinafter referred to as
Confidential Business Information
(CBI)). Comments submitted through
regulations.gov cannot be claimed as
CBI. Comments received through the
Web site will waive any CBI claims for
the information submitted. For
information on submitting CBI, see the
Confidential Business Information
section.
DOE processes submissions made
through regulations.gov before posting.
Normally, comments will be posted
within a few days of being submitted.
However, if large volumes of comments
are being processed simultaneously,
your comment may not be viewable for
up to several weeks. Please keep the
comment tracking number that
regulations.gov provides after you have
successfully uploaded your comment.
Submitting comments via email, hand
delivery/courier, or mail. Comments and
documents submitted via email, hand
delivery, or mail also will be posted to
regulations.gov. If you do not want your
personal contact information to be
publicly viewable, do not include it in
your comment or any accompanying
documents. Instead, provide your
contact information in a cover letter.
Include your first and last names, email
address, telephone number, and
optional mailing address. The cover
letter will not be publicly viewable as
long as it does not include any
comments.
Include contact information each time
you submit comments, data, documents,
and other information to DOE. If you
submit via mail or hand delivery or
courier, please provide all items on a
CD, if feasible. It is not necessary to
submit printed copies. No facsimiles
(faxes) will be accepted.
Comments, data, and other
information submitted to DOE
electronically should be provided in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format. Provide documents that are not
secured, that are written in English, and
that are free of any defects or viruses.
Documents should not contain special
characters or any form of encryption
and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit
campaign form letters by the originating
organization in batches of between 50 to
500 form letters per PDF or as one form
letter with a list of supporters’ names
compiled into one or more PDFs. This
reduces comment processing and
posting time.
Confidential Business Information.
According to 10 CFR 1004.11, any
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person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit via email, postal mail, or
hand delivery or courier two wellmarked copies: One copy of the
document marked confidential
including all the information believed to
be confidential, and one copy of the
document marked non-confidential with
the information believed to be
confidential deleted. Submit these
documents via email or on a CD, if
feasible. DOE will make its own
determination about the confidential
status of the information and treat it
according to its determination.
Factors of interest to DOE when
evaluating requests to treat submitted
information as confidential include: (1)
A description of the items; (2) whether
and why such items are customarily
treated as confidential within the
industry; (3) whether the information is
generally known by or available from
other sources; (4) whether the
information has previously been made
available to others without obligation
concerning its confidentiality; (5) an
explanation of the competitive injury to
the submitting person that would result
from public disclosure; (6) when such
information might lose its confidential
character due to the passage of time; and
(7) why disclosure of the information
would be contrary to the public interest.
It is DOE’s policy that all comments
may be included in the public docket,
without change and as received,
including any personal information
provided in the comments (except
information deemed to be exempt from
public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments
on any aspect of this proposal, DOE is
particularly interested in receiving
comments and views of interested
parties concerning the following issues:
1. Component Level Standards
In this NOPR, DOE proposes to set
separate standards for the panels,
display doors, non-display doors, and
refrigeration system of a walk-in, but is
not proposing to establish an overall
performance standard for the envelope
or for the walk-in as a whole. DOE
requests that interested parties submit
comments about this approach. See
section III.A for further details.
2. Market Performance Data
As part of the market assessment,
DOE collects information that provides
an overall picture of the market for the
walk-in coolers and freezers. DOE’s
analysis of market data uses catalogue
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and performance data to determine the
number of products on the market at
varying efficiency levels. However,
WICF equipment has not previously
been rated for efficiency by
manufacturers, nor has an efficiency
metric been established for the
equipment. DOE requests that interested
parties submit market performance data
to help inform DOE’s analysis. See
section IV.A for further details.
3. Definitions
In this NOPR, DOE proposes to amend
the existing definition of display door
and to add definitions of passage door
and freight door, as follows.
DOE proposes to amend the existing
definition of display door to include all
doors that are composed of 50 percent
or more glass or another transparent
material. This amendment is intended
to classify passage doors that are mostly
composed of glass as display doors
because the utility and construction of
glass passage doors more closely
resemble that of a display door. DOE
proposes the following amended
definition of display door: ‘‘Display
door means a door that—(1) is designed
for product display; or (2) has 50
percent or more of its surface area
composed of glass or another
transparent material.’’ The amended
definition would affect both the test
procedure (by potentially subjecting a
broader range of equipment to testing)
and the energy conservation standards.
DOE requests comment on the proposed
definition of display door.
DOE is also proposing a definition for
passage doors in order to differentiate
passage doors from freight doors.
Passage doors are mostly intended for
the passage of people and small
machines such as hand carts. DOE
proposes the following definition of
passage door: ‘‘Passage door means a
door that is used as a means of access
for people and is less than 4 feet wide
and 8 feet tall.’’ DOE requests comment
on the proposed definition of passage
door.
Freight doors tend to be larger than
passage doors and are typically used to
allow machines, such as forklifts, into
walk-ins. DOE is proposing a definition
of ‘‘freight door’’ to distinguish it from
a passage door. DOE proposes the
following definition of freight door:
‘‘Freight door means a door that is not
a passage door and is equal to or larger
than 4 feet wide and 8 feet tall.’’ DOE
requests comment on the proposed
definition of freight door.
See section IV.A.1 for further
information on the definitions.
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4. Equipment Included in the
Rulemaking
DOE proposes not to include certain
types of equipment in the rulemaking
analysis. DOE identified three types of
panels used in the walk-in industry:
display panels, floor panels, and nonfloor panels. Based on its research, DOE
determined that Display panels,
typically found in beer caves (walk-ins
used for the display and storage of beer
or other alcoholic beverages often found
in a supermarket) make up a small
percentage of all panels currently
present in the market. Therefore,
because of the extremely limited energy
savings potential currently projected to
result from amending the requirements
that these panels must meet, DOE is not
proposing standards for walk-in display
panels in this NOPR. Also, DOE is
declining to set a performance-based
standard for walk-in cooler floor panels.
All other types of panels, freezer floor
and non-floor, will be subject to a
performance standard. DOE requests
comment on this approach and requests
market data to better understand the
market share of display panels and
walk-in cooler floor panels.
DOE also proposes not to include
blast freezer refrigeration systems,
which are designed to quickly freeze
food and then store it at a holding
temperature, in this rulemaking
analysis. DOE received comments
regarding the performance difference
and the higher energy consumption of
blast freezers as compared to storage
freezers. DOE questions whether blast
freezer refrigeration systems would be
less efficient than storage freezers and
seeks information regarding whether
blast freezers would face difficulty in
complying with DOE’s proposed
standards. Furthermore, if blast freezers
cannot comply with those proposed
standards, DOE requests test procedure
data confirming the same. See section
IV.A.2 for details.
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5. Type of Refrigerant Analyzed
DOE based its analysis on
refrigeration equipment using R404A, a
hydrofluorocarbon (HFC) refrigerant, as
it is widely used in the walk-ins
industry. DOE received comments
supporting the use of HFC refrigerants,
but also suggested considering
refrigerants with lower global warming
potential (GWP) due to the shift in the
marketplace toward these products.
DOE acknowledges that there are
government-wide efforts to reduce
emissions of HFCs, and such actions are
being pursued both through
international diplomacy as well as
domestic actions. DOE, in concert with
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other relevant agencies, will continue to
work with industry and other
stakeholders to identify safer and more
sustainable alternatives to HFCs while
evaluating energy efficiency standards
for this equipment. DOE requests
comment on the extent of current use or
future availability of lower GWP
refrigerants and asks manufacturers and
chemical producers to submit data
related to the ability of equipment
(existing or redesigned) using HFC
alternative refrigerants to meet the
proposed standard. See section IV.A.2.b
for further details. DOE also requests
data and evidence to support estimates
of the cost of any incremental
technology or equipment redesign that
may be needed in order to compensate
for any energy efficiency losses
associated with the use of alternative
refrigerants to meet the standards
proposed in this notice.
6. Refrigeration Classes
DOE has proposed separate classes for
dedicated condensing refrigeration
systems and unit coolers connected to
multiplex condensing systems.
However, DOE does not propose to
create separate classes for dedicated
packaged systems (where the unit cooler
and condensing unit are integrated into
a single piece of equipment) and
dedicated split systems (where the unit
cooler and condensing unit are separate
pieces of equipment connected by
refrigerant piping). Due to the small
market share of packaged systems, DOE
proposes to base the standard for
dedicated condensing systems on an
analysis of split systems. DOE requests
comment on its proposal not to consider
dedicated packaged systems and
dedicated split systems as separate
classes, and specifically asks whether
this proposal would unfairly
disadvantage any manufacturers.
In addition, DOE proposes one
standard level for high-capacity
equipment and another for low-capacity
equipment within the dedicated
condensing category (because the
compressor is covered only for DC
systems). High- and low-capacity
equipment would thus also be
considered different equipment classes,
with the classes divided at a threshold
of 9,000 Btu/h. DOE requests comment
on this proposal, particularly the
capacity threshold between high- and
low-capacity equipment.
See section IV.A.3.b for details about
the refrigeration system equipment
classes.
7. Cycle Efficiency
DOE considered design options
manufacturers could use to improve
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cycle efficiency; for example,
economizer cooling. In the screening
analysis, DOE screened out economizer
cooling based on utility to the
consumer, one of the four screening
criteria. Specifically, economizer
cooling is not effective in areas of the
country where the temperature does not
drop below a walk-in’s temperature.
DOE did not identify any other options
to improve cycle efficiency beyond what
was already considered. However, DOE
realizes that there may be other methods
and designs manufacturers could use to
improve cycle efficiency and requests
specific recommendations on such
methods and designs, as well as how
they could be incorporated into the
analysis of standard levels. See section
IV.B.2.b for details.
8. Envelope Representative Sizes
DOE used three different panel sizes
to represent the variation in panels
within each equipment class. DOE
determined the sizes based on market
research and calculated the impact of
size on the test metric, U-factor. DOE
requests comment on the representative
sizes used in the analysis and whether
other sizes should be considered.
Similar to panels, DOE used three
different sizes to represent the
differences in doors within each class
for walk-in display and non-display
doors. The sizes of the doors were
determined by market research, and can
be found in section IV.C.1.a for display
and non-display doors. DOE requests
comment on the representative
equipment sizes analyzed in the
proposed analysis. See section IV.C.1.a
for further details.
9. Performance Data for Envelope
Components
DOE’s engineering model separately
analyzes panels, display doors, and nondisplay doors. The models estimate the
performance of the baseline equipment
and levels of performance above the
baseline associated with specific design
options that are added cumulatively to
the baseline equipment. Results for
performance of all components can be
found in appendix 5A of the TSD. DOE
requests comment on the performance
data and requests any data
manufacturers can provide about the
performance of panels, display doors, or
non-display doors and their design
options. See section IV.A for further
details.
10. Refrigeration Metric
The refrigeration energy model
calculates the annual energy
consumption and the Annual Walk-In
Energy Factor (AWEF) of walk-in
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coolers and freezers at various
performance levels using a design
option approach. AWEF is the ratio of
the total heat, not included in the heat
generated by the operation of the
refrigeration system, removed, in Btu,
from a walk-in box during a one-year
period of usage to the total energy input
of refrigeration systems, in watt-hours,
during the same period. DOE proposes
using AWEF as the metric to set
standards for the refrigeration system
and requests comment on this proposal.
See section IV.C.2.a for further details.
11. Manufacturing Markups
DOE calculated the manufacturer’s
selling price of the walk-in cooler and
freezer equipment by multiplying the
manufacturer’s production cost by a
markup and adding the equipment’s
shipping cost. The markup affects the
manufacturer’s selling price, which is a
critical input to the downstream
economic analyses. DOE calculated an
average markup for panels to be 32
percent, for display doors to be 50
percent, for non-display doors to be 62
percent, and for refrigeration to be 35
percent. DOE requests comment on the
proposed markups. See section IV.C.3.d
for further details.
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12. Envelope Component Shipping
Prices
DOE has found through its research
that most panel, display door, and nondisplay door manufacturers use less
than truck load freight to ship their
respective components. DOE also found
that typically none of the manufacturers
mark up the shipments for profit, and
instead include the cost of shipping as
part of the price quote. DOE has
conducted its analysis accordingly and
requests comment on the shipping
prices found in chapter 5 of the NOPR
TSD. See section IV.C.3.e for further
details.
13. Panel and Door Baseline
Assumptions
In the NOPR analysis, DOE used
wood framing members as the baseline
framing material in panels. DOE’s
analysis assumes the typical wood
frame completely borders the insulation
and is 1.5 inches wide. DOE requests
comment on its baseline specifications
for walk-in panels, specifically the
assumptions about framing material and
framing dimensions.
DOE assumed that the baseline nondisplay doors are constructed in a
similar manner to baseline panels.
Baseline non-display doors consist of
wood framing materials 1.5 inches wide
that completely border foamed-in-place
polyurethane insulation. For non-
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display doors, DOE also proposes to
include a 2.25 ft2 window that conforms
to the standards set by EPCA on all nondisplay passage doors regardless of the
passage door’s size. DOE analyzed two
different size windows for non-display
freight doors. DOE assumed that a small
freight door has a 2.25 ft2 window and
that both medium and large freight
doors have 4 ft2 windows. DOE requests
comment on the baseline specifications
for non-display doors, specifically on
the size of the windows included in the
baseline door.
DOE made several assumptions about
baseline display doors in its analysis.
First it assumed that baseline display
cooler doors are composed of two panes
of glass with argon gas fill and hard coat
low-e coating. Second, DOE assumed
that the baseline cooler display door
requires 2.9 W/ft2 of anti-sweat heater
wire and does not have a heater wire
controller. Baseline display freezer
doors in DOE’s analysis are composed of
three panes of glass, argon gas, and soft
coat low-e coating. Third, DOE assumed
that baseline freezer doors use 15.23 W/
ft2 of anti-sweat heater wire power and
require an anti-sweat heater wire
controller. Finally, DOE assumed that
each baseline door is associated with
one fluorescent light with an electronic
ballast, and that a door shorter than 6.5
feet has a 5-foot fluorescent bulb and a
door equal to or taller than 6.5 feet has
a 6-foot fluorescent bulb. DOE requests
comment on the baseline assumptions
for display cooler and freezer doors. In
particular, DOE requests data
illustrating the energy or power
consumption of anti-sweat heaters
found on cooler and freezer display
doors.
See section IV.C.4.a for further details
on the baseline assumptions.
14. Condensing Unit and Unit Cooler
Components
In its analysis of baseline equipment,
DOE included all necessary components
of the refrigeration system that came
from the manufacturer. However, DOE
has tentatively decided against
including components in its engineering
analysis that are not specifically part of
the unit cooler or condensing unit; for
example, refrigerant piping connecting a
unit cooler to a multiplex condensing
system. DOE assumes that these are not
included in the manufacturer’s selling
price of the equipment, and would be
supplied by the contractor upon
installation. DOE requests comment on
this assumption. See section IV.C.4.b for
further details.
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15. Refrigeration Temperature
Difference Assumption
In determining appropriate
temperature set points, DOE considered
information from various sources in
formulating its assumptions: Comments,
research, and confidential and nonconfidential discussions with
manufacturers and other parties. DOE
notes that the ambient temperature
specified in the test procedure is 90 or
95 degrees for indoor and outdoor
condensing units, respectively. Given
that the system must maintain a
reasonable temperature difference (TD)
between the SCT and the ambient
temperature, the SCT during the test
procedure would be higher than the 90–
95 degree assumption recommended.
Even though the set point during actual
use may be lower, equipment is rated—
and evaluated for meeting the
standard—at the test procedure rating
points. DOE requests comment on this
assumption, particularly whether the
TDs for baseline and higher efficiency
equipment are appropriate. See section
IV.C.4.b for further details.
16. Panel Design Options
In the proposed engineering analysis
for walk-in panels, DOE included design
options that increase the baseline
insulation thickness, change the
baseline insulation material from foamin-place polyurethane to a hybrid of
polyurethane and VIP, change the
baseline framing material from wood to
high-density polyurethane, and
eliminate a non-floor-panel’s framing
material. DOE proposes that floor panels
must retain some type of framing
material, and that high-density
polyurethane framing materials found in
a panel have the same dimensions as the
wood framing materials. DOE requests
comment on the design options for
panels, including the specifications for
high-density polyurethane framing
materials, manufacturer conversion
costs for increasing the baseline panel
thickness, and any estimated changes in
repair, maintenance, or installation
costs. DOE also requests comment on
the technological feasibility of the panel
options analyzed and whether the
design options selected would cause
any lessening of the utility or the
performance of the walk-ins. See section
IV.C.5.a for further details.
17. Display and Non-Display Door
Design Options
The design options that DOE proposes
for display doors include improved
glass packs, anti-sweat heater controls
for cooler doors, LED lighting, and
lighting sensors. DOE does not propose
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anti-sweat heater controls for freezer
display doors because baseline freezer
doors are required to have a controller
due to the amount of power consumed
by the anti-sweat heater wire. DOE
requests comment on the proposed
design options, specifically any heat
transfer data for the improved glass
packs detailed in chapter 5 of the TSD.
The design options that DOE proposes
for non-display doors include increased
insulation thickness, changing the
insulation material from baseline to a
hybrid of polyurethane and VIP,
changing the baseline framing material
from wood to high-density
polyurethane, improving the window’s
glass pack, and adding an anti-sweat
heater wire controller to the door. DOE
requests comment on the proposed
design options for non-display doors,
and specifically requests comment on
the manufacturer conversion
investments required to update product
designs and manufacturing lines in
order to product compliant products;
information regarding any changes in
repair, maintenance, or installation
costs of the window improvements
detailed in chapter 5 of the TSD. DOE
also requests comment on the
technological feasibility of the panel
options analyzed and whether the
design options selected would cause
any lessening of the utility or the
performance of the walk-ins.
See section IV.C.5.a and chapter 5 of
the TSD for further details on the
display and non-display door design
options.
18. Refrigeration System Design Options
DOE is proposing to include the use
of improved condenser coils as a design
option, wherein the condenser coil
increases by a certain percentage from
its original size. After performing
analytical calculations, DOE tentatively
believes that increasing the coil size of
the condenser would not require an
increase in the coil size of the
evaporator. However, DOE requests
comment on this assumption,
particularly from manufacturers that
currently utilize larger condenser coils.
DOE is proposing to use highefficiency condenser fan motors as a
design option, and it is critical to
accurately estimate the input power due
to the energy savings associated with
this option. DOE calculated the input
power from the efficiency ratings
provided. However, DOE received
comments that this approach may not
provide an accurate method to measure
input power and requests feedback on
how it should determine input power.
DOE also considered a design option
which modulates or adjusts the speed of
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the evaporator fans when the
compressor is off. DOE is aware of the
potential effects of evaporator fan
control on food safety but has
tentatively concluded that the controls
it analyzed are limited (to 50 percent fan
cycling or 50 percent fan speed when
the compressor is off) such that food
temperatures could be adequately
maintained in either control case. DOE
requests comment from interested
parties as to whether food temperatures
would be adequately maintained in the
specific control cases it has analyzed,
and, if not, what would be an
appropriate control strategy. DOE
particularly requests any data interested
parties can provide to show the
relationship between fan controls and
food temperatures. DOE also seeks
information on whether other
components may be necessary to ensure
food temperatures would be adequately
maintained, such as extra thermostats
located in certain areas of the walk-in.
DOE has adjusted its analysis of the
floating head pressure design option
after taking commenters’
recommendations into account. DOE
included components and analytical
changes with respect to fan power,
temperature differences, and SCT in
response to stakeholder comments. DOE
requests comment on its revised
assumptions and implementation of this
option, particularly regarding the cost to
implement various floating head
pressure control schemes and the energy
savings that would be achieved. DOE
requests comment on the technological
feasibility of the panel options analyzed
and whether the design options selected
would cause any lessening of the utility
or the performance of the walk-ins. DOE
also requests information on any
changes in repair, maintenance, or
installation costs associated with the
technologies needed to meet the
proposed standards.
See section IV.C.5.b and chapter 5 of
the TSD for further details on the
refrigeration system design options.
19. Relative Equipment Sizing
In the Energy Use Analysis, DOE
calculates the expected energy
consumption of the covered equipment,
as installed. To do so, DOE makes
certain assumptions about the relative
sizing of refrigeration systems with
envelopes, which determines how often
the compressor runs during a day,
which in turn affects the energy use of
the equipment. For the NOPR analysis,
DOE assumed that the runtime of the
refrigeration system is 13.3 hours per
day for coolers and 15 hours per day for
freezers at full design point capacity and
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requests comment on this assumption.
See section IV.E.1 for further details.
20. Equipment Price Trends
DOE assumes in its price forecasts for
this NOPR that the real prices of walkin cooler and freezer equipment
decrease slightly over time. DOE
performed price trends sensitivity
calculations to examine the dependence
of the analysis results on different
analytical assumptions. DOE invites
comment on methods to improve its
equipment price forecasting, as well as
any data supporting alternate methods.
For more details, see section IV.F.1.
21. Refrigerant Charge Maintenance
Costs
DOE received comments on
maintenance costs associated with
refrigerant leakage and refrigerant
charge and assumed a certain
maintenance cost for the refrigeration
system. DOE requests that interested
parties submit data on refrigerant charge
maintenance costs. See section IV.F.6
for further details.
22. Compliance Date of Standards
DOE’s proposed standards will apply
to products that are manufactured
beginning on the date 3 years after the
final rule is published unless DOE
determines, by rule, that a 3-year period
is inadequate, in which case DOE may
extend the compliance date for that
standard by an additional 2 years. (42
U.S.C. 6314(f)(4)(B)) DOE proposes to
provide 3 years for compliance with this
standard, but seeks comment on
whether it should consider a longer
compliance date as authorized, and, if
so, by how much. See section IV.F.9 for
details.
23. Base-Case Efficiency Distributions
To accurately estimate the share of
consumers who would likely be
impacted by a standard at a particular
efficiency level, DOE’s LCC analysis
considers the projected distribution of
product efficiencies that consumers
purchase under the base case (i.e., the
case without new energy efficiency
standards). DOE examined the range of
standard and optional equipment
features offered by refrigeration
manufacturers and estimated that for
refrigeration systems, 75 percent of the
equipment sold under the base case
would be at DOE’s assumed baseline
level—that is, the equipment would
comply with the existing standards in
EPCA, but have no additional features
that improve efficiency. The remaining
25 percent of equipment would have
features that would increase its
efficiency to a level commensurate with
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the first design option in each
equipment class. For envelope
components, all base case shipments are
assumed to have only a single EPCAcompliant efficiency level except for
cooler display doors. For cooler display
doors, shipments in the base case would
be a mix of 80 percent EPCA-compliant
equipment and 20 percent higher
efficiency equipment. For both
refrigeration systems and envelope
components, DOE assumed that the
base-case energy efficiency distribution
would remain constant throughout the
forecast period. DOE requests comment
on its assumptions about base-case
efficiency distributions. See sections
IV.F.10 and IV.G.2 for details.
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24. Trial Standard Level Equations
In this NOPR, DOE proposes standard
levels for different classes of
refrigeration systems. DOE expressed
the AWEF for large capacity dedicated
condensing systems as a single value
and expressed the AWEF for the small
capacity dedicated condensing systems
as a linear equation normalized to the
system gross capacity. DOE calculated a
single minimum AWEF for each class of
multiplex condensing systems. The
methodology DOE used to develop the
AWEF values and equations is detailed
in appendix 10D of the TSD. DOE
requests comment on the AWEF
equations and the methodology for
determining them. In particular, DOE
asks interested parties to submit data on
how the efficiency of typical
refrigeration systems varies by capacity.
Based on comments and additional data
DOE receives on the NOPR, DOE may
consider other methods of calculating
the minimum AWEF associated with the
TSLs for each equipment class. See
section V.A.2 for details.
25. Proposed Standard
In this NOPR, DOE proposes TSL 4 as
the energy conservation standard for
equipment covered under this
rulemaking. DOE proposes this standard
because it tentatively believes that it
represents the maximum improvement
in energy efficiency that is
technologically feasible and
economically justified, and that the
benefits outweigh the burdens. For a full
description of the benefits and burdens
of TSL 4, see section V.C.
We seek comment, information and
data on whether other combinations of
standards for refrigeration units, panels,
or doors can improve energy efficiency
that is technologically feasible and
economically justified, taking into
consideration effects on the
manufacturers and the end users of
walk-in coolers and freezers.
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26. Product Attributes
DOE requests comment on whether
there are features or attributes of the
more energy efficient walk-in coolers
and freezers that manufacturers would
produce to meet the standards in this
proposed rule that might lessen the
utility or performance of these products
in current uses (i.e., restaurants, food
service providers, grocery stores and
convenience stores). An example of
such an effect might be that grocers or
restaurant operators would change
where, how, how much and for how
long food items would be stored or
whether thicker panels would
detrimentally reduce the refrigerated
area of a walk-in making higher
efficiency panels less desirable. DOE
requests comment specifically on how
any such effects should be weighed in
the choice of standards for these walkin coolers and freezers for the final rule.
27. Impact of Amended Standards on
Future Shipments
DOE welcomes stakeholder input and
estimates on the effect of amended
standards on future walk-in cooler and
freezer shipments. We are seeking
information on what factors drive the
demand for walk-in coolers and freezers
and whether those factors are likely to
remain unchanged in the relevant
analytic time period of 30 years. For
example, a commenter submitted that
70 percent of all restaurants and 90
percent of all small restaurants fail due
to insufficient up-front capital. In light
of this information, are there better ways
and data to project future shipments of
walk-in coolers and freezers than the
current method which is based on the
number of buildings projected to house
walk-in coolers and freezers? DOE also
welcomes input and data on the
demand elasticity estimates used in the
analysis.
28. Learning Impacts on Price Forecast
for Future Shipments
Currently, DOE projects future prices
by subtracting the cost reductions
associated with learning effects from the
cost associated with the amended
standards. DOE analyzes learning effects
using PPI, a quality adjusted index of
wholesale prices, as a proxy for price of
commercial refrigerators. DOE is seeking
input, and price data that could be used
in place of PPI. Also DOE is seeking
input on the magnitude of the price data
and the cause of those price changes.
29. Analytic Timeline
For this rulemaking, DOE analyzed
the effects of this proposal assuming
that the walk-in coolers and freezers
would be available to purchase starting
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Sfmt 4702
2017 until 2047 and includes the useful
life of the last unit sold, extending the
analysis to 2073. DOE also undertook a
sensitivity analysis using nine rather
than 30 years of product shipments. The
choice of a 30-year period is consistent
with the DOE analysis for other
products and commercial equipment.
The choice of a 9-year period is a proxy
for the timeline in EPCA for the review
of certain energy conservation standards
and potential revision of and
compliance with such revised
standards. We are seeking input,
information and data on whether there
are ways to refine the analytic timeline
further.
In particular, given that walk-in
coolers and freezers are largely used by
the food service industry, convenience
stores and small grocers, we are seeking
information on whether the turnover
rates in the food service industry,
convenience stores and small grocers
affects the useful life of walk-in coolers
and freezers.
30. Markets for Used Walk-In Coolers
and Freezers
DOE is seeking information on
whether there is a significant market for
used walk-in coolers and freezers. Given
the high turnover rate of food service
industry (e.g., a commenter noted 70 to
90 percent failure rates for restaurants),
we are seeking to understand whether it
is reasonable to assume that the useful
life of the refrigeration system would be
12 years and other components 15 years
due to active used equipment markets.
31. Small Businesses
During the Framework and
preliminary analysis public meetings,
DOE received many comments
regarding the potential impacts of
amended energy conservation standards
on small business manufacturers of
walk-in coolers and freezers. DOE notes
that the small businesses could be
disproportionately affected by this
standard because of the cost of testing,
potential increase in materials and
potential difficulty in obtaining
financing. DOE seeks comment and, in
particular, data, in its efforts to quantify
the impacts of this rulemaking on small
business manufacturers.
32. Rebound Effect
DOE assumed a rebound factor of one,
or no effect, because walk-ins must cool
their contents at all times and it is not
possible for consumers to operate them
more frequently. A rebound effect
occurs when users operate higher
efficiency equipment more frequently
and/or for longer durations, thus
offsetting estimated energy savings. DOE
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
33. Update to Social Cost of Carbon
Values
DOE solicits comment on the
application of the new SCC values used
to determine the social benefits of CO2
emissions reductions over the
rulemaking analysis period. The
rulemaking analysis period covers from
2017 to 2046 plus an additional 15 years
to account for the lifetime of the
equipment purchased between 2017 and
2046. In particular, the agency solicits
comment on the agency’s derivation of
SCC values after 2050 where the agency
applied the average annual growth rate
of the SCC estimates in 2040–2050
associated with each of the four sets of
values.
List of Subjects in 10 CFR Part 431
Administrative practice and
procedure, Confidential business
information, Energy conservation,
Imports, Intergovernmental relations,
Reporting and recordkeeping
requirements.
Issued in Washington, DC, on August 29,
2013.
Mike Carr,
Acting Assistant Secretary, Energy Efficiency
and Renewable Energy.
For the reasons set forth in the
preamble, DOE proposes to amend part
431 of chapter II of title 10, of the Code
of Federal Regulations, as set forth
below:
PART 431—ENERGY EFFICIENCY
PROGRAM FOR CERTAIN
COMMERCIAL AND INDUSTRIAL
EQUIPMENT
1. The authority citation for part 431
continues to read as follows:
■
Authority: 42 U.S.C. 6291–6317.
34. Cumulative Regulatory Burdens
The agency seeks input on the
cumulative regulatory burden that may
be imposed on industry either from
recently implemented rulemakings for
this product class or other rulemakings
that affect the same industry.
2. Section 431.302 is amended by
revising the definition for ‘‘Display
door’’ and adding, in alphabetical order,
definitions for ‘‘Freight door’’ and
‘‘Passage door’’ to read as follows:
§ 431.302 Definitions concerning walk-in
coolers and freezers.
VIII. Approval of the Office of the
Secretary
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The Secretary of Energy has approved
publication of today’s proposed rule.
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■
*
*
*
*
*
Display door means a door that:
(1) Is designed for product display; or
(2) Has 75 percent or more of its
surface area composed of glass or
another transparent material.
*
*
*
*
*
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Fmt 4701
Sfmt 4725
Freight door means a door that is not
a display door and is equal to or larger
than 4 feet wide and 8 feet tall.
*
*
*
*
*
Passage door means a door that is not
a freight or display door.
*
*
*
*
*
■ 3. In § 431.304, revise paragraph (a) to
read as follows:
§ 431.304 Uniform test method for the
measurement of energy consumption of
walk-in coolers and walk-in freezers.
(a) Scope. This section provides test
procedures for measuring, pursuant to
EPCA, the energy consumption of walkin coolers and walk-in freezers.
*
*
*
*
*
■ 4. In § 431.306, revise paragraph
(a)(3), and add paragraphs (c), (d), (e),
and (f) to read as follows:
§ 431.306 Energy conservation standards
and their effective dates.
(a) * * *
(3) Contain wall, ceiling, and door
insulation of at least R–25 for coolers
and R–32 for freezers, except that this
paragraph shall not apply to:
(i) Glazed portions of doors not to
structural members and
(ii) A walk-in cooler or walk-in freezer
component if the component
manufacturer has demonstrated to the
satisfaction of the Secretary in a manner
consistent with applicable requirements
that the component reduces energy
consumption at least as much as if such
insulation requirements of subparagraph
(a)(3) were to apply.
(b) * * *
(c) Walk-in cooler and freezer panels.
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EP11SE13.007
seeks comment on this assumption and
whether other factors should be
considered in the rebound effect, such
as a decision to buy a larger system due
to increased lifetime costs savings, or
money saved in electricity bills with
more efficient walk-in coolers and
freezers being used for other electricity
consuming activities.
55887
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Federal Register / Vol. 78, No. 176 / Wednesday, September 11, 2013 / Proposed Rules
(d) Walk-in cooler and freezer display
doors.
Class descriptor
Class
Equations for
maximum
energy consumption
(kWh/day)*
DD.M
DD.L
0.049 × Add + 0.39
0.33 × Add + 0.38
Class
Display Door, Medium Temperature ...............................................................................................
Display Door, Low Temperature ......................................................................................................
Equations for
maximum
energy consumption
(kWh/day)*
*Add represents the surface area of the display door.
(e) Walk-in cooler and freezer nondisplay doors.
Class descriptor
Passage Door, Medium Temperature ...........................................................................
Passage Door, Low Temperature .................................................................................
Freight Door, Medium Temperature ..............................................................................
Freight Door, Low Temperature ....................................................................................
0.0032 × And + 0.22
0.14 × And + 4.0
0.0073 × And + 0.082
0.11 × And + 5.4
PD.M
PD.L
FD.M
FD.L
* And represents the surface area of the non-display door.
(f) Walk-in cooler and freezer
refrigeration systems.
Class descriptor
Class
Dedicated Condensing, Medium Temperature, Indoor System, < 9,000 Btu/h Capacity ...............
DC.M.I, < 9,000
Dedicated Condensing, Medium Temperature, Indoor System, ≥ 9,000 Btu/h Capacity ...............
Dedicated Condensing, Medium Temperature, Outdoor System, < 9,000 Btu/h Capacity ............
DC.M.I, ≥ 9,000
DC.M.O, < 9,000
Dedicated Condensing, Medium Temperature, Outdoor System, ≥ 9,000 Btu/h Capacity ............
Dedicated Condensing, Low Temperature, Indoor System, < 9,000 Btu/h Capacity .....................
DC.M.O, ≥ 9,000
DC.L.I, < 9,000
Dedicated Condensing, Low Temperature, Indoor System, ≥ 9,000 Btu/h Capacity .....................
Dedicated Condensing, Low Temperature, Outdoor System, < 9,000 Btu/h Capacity ..................
DC.L.I, ≥ 9,000
DC.L.O, < 9,000
Dedicated Condensing, Low Temperature, Outdoor System, ≥ 9,000 Btu/h Capacity ..................
Multiplex Condensing, Medium Temperature ..................................................................................
Multiplex Condensing, Low Temperature ........................................................................................
DC.L.O, ≥ 9,000
MC.M
MC.L
* Q represents the system gross capacity as calculated by the procedures set forth in AHRI 1250.
[FR Doc. 2013–21530 Filed 9–10–13; 8:45 am]
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BILLING CODE 6450–01–P
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Equations for
minimum AWEF
(Btu/W–h)*
2.63 × 10¥4
4.53
6.90
1.34 × 10¥3
0.12
12.21
1.93 × 10¥4
1.89
3.63
5.70 × 10¥4
1.02
6.15
10.74
5.53
×Q+
×Q+
×Q+
×Q+
Agencies
[Federal Register Volume 78, Number 176 (Wednesday, September 11, 2013)]
[Proposed Rules]
[Pages 55781-55888]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-21530]
[[Page 55781]]
Vol. 78
Wednesday,
No. 176
September 11, 2013
Part II
Department of Energy
-----------------------------------------------------------------------
10 CFR Part 431
Energy Conservation Program: Energy Conservation Standards for Walk-In
Coolers and Freezers; Proposed Rule
Federal Register / Vol. 78 , No. 176 / Wednesday, September 11, 2013
/ Proposed Rules
[[Page 55782]]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
10 CFR Part 431
[Docket No. EERE-2008-BT-STD-0015]
RIN 1904-AB86
Energy Conservation Program: Energy Conservation Standards for
Walk-In Coolers and Freezers
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking (NOPR) and public meeting.
-----------------------------------------------------------------------
SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as
amended, prescribes energy conservation standards for various consumer
products and certain commercial and industrial equipment, including
walk-in coolers and walk-in freezers. EPCA also requires the U.S.
Department of Energy (DOE) to determine whether more-stringent, amended
standards would be technologically feasible and economically justified,
and would save a significant amount of energy. In this notice, DOE
proposes amended energy conservation standards for walk-in coolers and
walk-in freezers. The notice also announces a public meeting to receive
comment on these proposed standards and associated analyses and
results.
DATES: DOE will hold a public meeting on Wednesday, October 9, 2013,
from 9 a.m. to 4 p.m., in Washington, DC. The meeting will also be
broadcast as a webinar. See section VII, ``Public Participation,'' for
webinar registration information, participant instructions, and
information about the capabilities available to webinar participants.
DOE will accept comments, data, and information regarding this
notice of proposed rulemaking (NOPR) before and after the public
meeting, but no later than November 12, 2013. See section VII, ``Public
Participation,'' for details.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue SW.,
Washington, DC 20585. To attend, please notify Ms. Brenda Edwards at
(202) 586-2945. For more information, refer to section VII, Public
Participation.
Any comments submitted must identify the NOPR for Energy
Conservation Standards for walk-in coolers and freezers, and provide
docket number EERE-2008-BT-STD-0015 and/or regulatory information
number (RIN) number 1904-AB86. Comments may be submitted using any of
the following methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: WICF-2008-STD-0015@ee.doe.gov. Include the docket number
and/or RIN in the subject line of the message.
3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building
Technologies Office, Mailstop EE-2J, 1000 Independence Avenue SW.,
Washington, DC, 20585-0121. If possible, please submit all items on a
CD. It is not necessary to include printed copies.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Office, 950 L'Enfant Plaza SW., Suite
600, Washington, DC 20024. Telephone: (202) 586-2945. If possible,
please submit all items on a CD, in which case it is not necessary to
include printed copies.
Written comments regarding the burden-hour estimates or other
aspects of the collection-of-information requirements contained in this
proposed rule may be submitted to Office of Energy Efficiency and
Renewable Energy through the methods listed above and by email to
Chad_S_Whiteman@omb.eop.gov.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section VII of this document
(Public Participation).
Docket: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at regulations.gov. All
documents in the docket are listed in the regulations.gov index.
However, some documents listed in the index, such as those containing
information that is exempt from public disclosure, may not be publicly
available.
A link to the docket Web page can be found at: https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/30. This Web page contains a link to the docket for this notice
on the regulations.gov site. The regulations.gov Web page contains
instructions on how to access all documents, including public comments,
in the docket. See section VII for further information on how to submit
comments through www.regulations.gov.
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT:
Mr. Charles Llenza, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Program, EE-2J,
1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone:
(202) 586-2192. Email: walk-in_coolers_and_walk-in_freezers@EE.Doe.Gov.
Mr. Michael Kido, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 586-8145. Email: Michael.Kido@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for Walk-In Coolers and
Freezers
III. General Discussion
A. Component Level Standards
B. Test Procedures and Metrics
1. Panels
2. Doors
3. Refrigeration
C. Prescriptive Versus Performance Standards
D. Certification, Compliance, and Enforcement
E. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
F. Energy Savings
1. Determination of Savings
2. Significance of Savings
G. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Life-Cycle Costs
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need of the Nation to Conserve Energy
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion
A. Market and Technology Assessment
1. Definitions Related to Walk-In Coolers and Freezers
a. Display Doors
b. Freight Doors
c. Passage Doors
2. Equipment Included in this Rulemaking
a. Panels and Doors
b. Refrigeration System
3. Equipment Classes
a. Panels and Doors
b. Refrigeration Systems
[[Page 55783]]
4. Technology Assessment
B. Screening Analysis
1. Technologies That Do Not Affect Rated Performance
2. Screened-Out Technologies
a. Panels and Doors
b. Refrigeration
3. Screened-In Technologies
C. Engineering Analysis
1. Representative Equipment
a. Panels and Doors
b. Refrigeration
2. Energy Modeling Methodology
a. Refrigeration
3. Cost Assessment Methodology
a. Teardown Analysis
b. Cost Model
c. Manufacturing Production Cost
d. Manufacturing Markup
e. Shipping Costs
4. Baseline Specifications
a. Panels and Doors
b. Refrigeration
5. Design Options
a. Panels and Doors
b. Refrigeration
6. Cost-Efficiency Results
a. Panels and Doors
b. Refrigeration
c. Numerical Results
D. Markups Analysis
E. Energy Use Analysis
1. Sizing Methodology for the Refrigeration System
2. Oversize Factors
3. Product Load
4. Other Issues
F. Life-Cycle Cost and Payback Period Analyses
1. Equipment Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Energy Price Projections
6. Maintenance and Repair Costs
7. Product Lifetime
8. Discount Rates
9. Compliance Date of Standards
10. Base-Case and Standards-Case Efficiency Distributions
11. Inputs to Payback Period Analysis
12. Rebuttable-Presumption Payback Period
G. National Impact Analysis--National Energy Savings and Net
Present Value
1. Shipments
a. Share of Shipments and Stock Across Equipment Classes
b. Lifetimes and Replacement Rates
c. Growth Rates
d. Other Issues
2. Forecasted Efficiency in the Base Case and Standards Cases
3. National Energy Savings
4. Net Present Value of Consumer Benefit
5. Benefits from Effects of Standards on Energy Prices
H. Consumer Subgroup Analysis
I. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model Analysis
a. Government Regulatory Impact Model Key Inputs
b. Government Regulatory Impact Model Scenarios
3. Discussion of Comments
a. Cumulative Regulatory Burden
b. Inventory Levels
c. Manufacturer Subgroup Analysis
4. Manufacturer Interviews
a. Cost of testing
b. Enforcement and Compliance
c. Profitability Impacts
d. Excessive Conversion Cost
e. Disproportionate Impact on Small Businesses
f. Refrigerant Phase-Out
J. Employment Impact Analysis
K. Utility Impact Analysis
L. Emissions Analysis
M. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
V. Analytical Results
A. Trial Standard Levels
1. Trial Standard Level Selection Process
2. Trial Standard Level Equations
B. Economic Justification and Energy Savings
1. Economic Impacts on Commercial Customers
a. Life-Cycle Cost and Payback Period
b. Life-Cycle Cost Subgroup Analysis
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Direct Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Small Manufacturer Sub-Group
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Amount and Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Employment Impacts
4. Impact on Utility or Performance of Equipment
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Other Factors
C. Proposed Standard
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Summary of the Proposed Rule
DOE proposes creating new performance-based energy conservation
standards for walk-in coolers and walk-in freezers (collectively,
``walk-ins'' or ``WICFs''). The proposed standards, which are expressed
as an annual walk-in energy factor (AWEF) for refrigeration systems,
the maximum allowable U-factor expressed as a function of the ratio of
edge area to core area for panels, and the maximum allowable daily
energy use expressed as a function of the surface area for non-display
and display doors, are shown in Table I.1. These proposed standards, if
adopted, would apply to all products listed in Table I.1 and
manufactured in, or imported into, the United States on or after 3
years after the publication date of any final rule establishing energy
conservation standards for walk-ins. Appendix 10D of the TSD lists the
technologies that DOE assumes manufacturers will use to meet the
proposed standards.
[[Page 55784]]
[GRAPHIC] [TIFF OMITTED] TP11SE13.000
[[Page 55785]]
[GRAPHIC] [TIFF OMITTED] TP11SE13.001
A. Benefits and Costs to Consumers
Table I-2 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of walk-in coolers and freezers, as
measured by the shipment-weighted average life-cycle cost (LCC) savings
\1\ and the median payback period.\2\ The average LCC savings are
positive for all equipment classes. At TSL 4, the percentage of
customers who experience net benefits or no impacts ranges from 55 to
100 percent, and the percentage of customers experiencing a net cost
ranges from 0 to 45 percent. Chapter 11 presents the LCC subgroup
analysis on groups of customers that may be disproportionately affected
by the proposed standard. The installed cost increase over the 9-year
analysis period (2017-2025) for the proposed TSL is 1.98 billion
discounted at 7 percent.
---------------------------------------------------------------------------
\1\ Life-cycle cost (LCC) of commercial refrigeration equipment
is the cost to customers of owning and operating the equipment over
the entire life of the equipment. Life-cycle cost savings are the
reductions in the life-cycle costs due to amended energy
conservation standards when compared to the life-cycle costs of the
equipment in the absence of amended energy conservation standards.
Further discussion of the LCC analysis can be found in Chapter 8 of
the TSD.
\2\ Payback period (PBP) refers to the amount of time (in years)
it takes customers to recover the increased installed cost of
equipment associated with new or amended standards through savings
in operating costs. Further discussion of the PBP can be found in
Chapter 8 of the TSD.
Table I-2--Shipment-Weighted Average Impacts of Proposed Standards (TSL 4) on Consumers of Walk-In Coolers and
Walk-In Freezers
----------------------------------------------------------------------------------------------------------------
Average LCC savings Median payback period
Equipment class (2012$) (years)
----------------------------------------------------------------------------------------------------------------
Refrigeration System Class:*
DC.M.I.................................................... $611 4.4
DC.M.O.................................................... 3,195 2.2
DC.L.I.................................................... 1,117 2.7
DC.L.O.................................................... 2,664 2.3
MC.M...................................................... 1,724 0.5
MC.L...................................................... 2,061 0.4
Panel Class:
SP.M**.................................................... 8 4.5
SP.L**.................................................... 72 3.6
FP.L**.................................................... 30 4.5
Non-Display Door Class:
PD.M...................................................... 0.3 5.5
PD.L...................................................... 52 4.7
FD.M...................................................... 1 5.4
FD.L...................................................... 136 2.9
Display Door Class:
DD.M...................................................... 228 2.2
DD.L...................................................... 200 N/A
----------------------------------------------------------------------------------------------------------------
* For dedicated condensing (DC) refrigeration systems, results include both capacity ranges.
** Results are per 100 square feet.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the base year through the end of the
analysis period (2013 to 2046). Using real discount rates of 10.5
percent for panels, 9.4 percent for doors, and 10.4 percent for
refrigeration \3\, DOE estimates that the industry net present value
(INPV) for manufacturers of walk-in cooler and freezer refrigeration
systems, panels, and doors in the base case (without new standards) is
$851 million in 2012$. Under the proposed standards, DOE expects the
impact on INPV to range from no change to a 9 percent decrease.
[[Page 55786]]
Total industry conversion costs estimated to be $51 million are assumed
to be incurred in the years prior to the start of compliance with the
standards. Based on DOE's interviews with the manufacturers of walk-in
coolers and walk-in freezers, DOE does not expect significant loss of
employment.
---------------------------------------------------------------------------
\3\ These rates were used to discount future cash flows in the
Manufacturer Impact Analysis. The discount rates were calculated
from SEC filings and then adjusted based on cost of capital feedback
collected from walk-in door, panel, and refrigeration manufacturers
in MIA interviews. For a detailed explanation of how DOE arrived at
these discount rates, refer to Chapter 12 of the NOPR TSD.
---------------------------------------------------------------------------
C. National Benefits \4\
---------------------------------------------------------------------------
\4\ All monetary values in this section are expressed in 2012
dollars and are discounted to 2013.
---------------------------------------------------------------------------
DOE's analyses indicate that the proposed standards would save a
significant amount of energy. The lifetime full-fuel-cycle energy
savings for walk-in coolers and freezers purchased in the 30-year
period that begins in the year of compliance with new standards (2017-
2046) amount to 5.39 quadrillion British thermal units (quads). The
average annual energy savings over the life of walk-in coolers and
freezers purchased in 2017 through 2046 is 0.18 quads, which is
equivalent to 14.8 percent of the annual U.S commercial refrigeration
sector energy.\5\
---------------------------------------------------------------------------
\5\ Total U.S. commercial sector energy (source energy) used for
refrigeration in 2010 was 1.21 quads. Source: U.S. Department of
Energy--Office of Energy Efficiency and Renewable Energy. Buildings
Energy Data Book, Table 3.1.4, 2010 Commercial Energy End-Use
Splits, by Fuel Type (Quadrillion Btu). 2012. (Last accessed April
23, 2013.) https://buildingsdatabook.eren.doe.gov/TableView.aspx?table=3.1.4
---------------------------------------------------------------------------
The cumulative net present value (NPV) of total consumer costs and
savings of the proposed standards ranges from $8.6 billion (at a 7-
percent discount rate) to $24.3 billion (at a 3-percent discount rate)
for walk-in coolers and freezers. This NPV expresses the estimated
total value to customers of future operating cost savings minus the
estimated increased product costs for products purchased in 2017-2046.
In addition, the proposed standards would have significant
environmental benefits. The energy savings would result in cumulative
emission reductions of 298 million metric tons (Mt) \6\ of carbon
dioxide (CO2), 1,428 thousand tons of methane, 379.5
thousand tons of sulfur dioxide (SO2), 443.8 thousand tons
of nitrogen oxides (NOX), and 0.6 tons of mercury
(Hg).7 8
---------------------------------------------------------------------------
\6\ A metric ton is equivalent to 1.1 short tons. Results for
NOX and Hg are presented in short tons.
\7\ DOE calculates emissions reductions relative to the Annual
Energy Outlook (AEO) 2013 Reference case, which generally represents
current legislation and environmental regulations for which
implementing regulations were available as of December 31, 2012.
\8\ DOE also estimated CO2 and CO2
equivalent (CO2eq) emissions that occur through 2030
(CO2eq includes greenhouse gases such as CH4
and N2O). The estimated emissions reductions through 2030
are 79 million metric tons CO2, 7,897 thousand tons
CO2eq for CH4, and 338 thousand tons
CO2eq for N2O.
---------------------------------------------------------------------------
The value of the CO2 reductions is calculated using a
range of values per metric ton of CO2 (otherwise known as
the Social Cost of Carbon, or SCC) developed by an interagency process.
The derivation of the SCC values is discussed in section IV.M. DOE
estimates the net present monetary value of the CO2
emissions reduction is between $1.9 billion and $27.5 billion,
depending on the SCC value used, over a 30-year analysis period. DOE
also estimates the net present monetary value of the NOX
emissions reduction is $243 million at a 7-percent discount rate and
$553 million at a 3-percent discount rate over a 30-year analysis
period. Over a 9-year analysis period, DOE estimates the net present
monetary value of the CO2 emissions reduction is between
$0.33 billion and $4.07 billion, depending on the SCC value used, while
the net present monetary value of the NOX emissions
reduction is $70.5 million at a 7-percent discount rate and $99.8
million at a 3-percent discount rate.\9\ DOE notes that the estimated
total social benefits of the rule outweigh the costs whether a 30-year
or a 9-year analysis period is used.
---------------------------------------------------------------------------
\9\ DOE has decided to await further guidance regarding
consistent valuation and reporting of Hg emissions before it
monetizes Hg in its rulemakings.
---------------------------------------------------------------------------
Table I-3 summarizes the national economic costs and benefits
expected to result from the proposed standards for walk-in coolers and
walk-in freezers.
Table I-3--Summary of National Economic Benefits and Costs of Walk-In Cooler and Walk-In Freezer Energy
Conservation Standards
----------------------------------------------------------------------------------------------------------------
Present value Billion
Category 2012$ Discount rate (percent)
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings....................................... 12.4 7
31.6 3
CO2 Reduction Monetized Value (at $12.9/t case)*............. 1.9 5
CO2 Reduction Monetized Value (at $40.8/t case)*............. 9.0 3
CO2 Reduction Monetized Value (at $62.2/t case)*............. 14.4 2.5
CO2 Reduction Monetized Value (at $117.0/t case)*............ 27.5 3
NOX Reduction Monetized Value (at $2,639/Ton)**.............. 0.24 7
0.55 3
--------------------------------------------------
Total Benefits[dagger]................................... 21.6 7
41.1 3
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Incremental Installed Costs.................................. 3.8 7
7.2 3
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Including CO2 and NOX Reduction Monetized Value.............. 17.8 7
33.9 3
----------------------------------------------------------------------------------------------------------------
* The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values
are based on the average SCC from the integrated assessment models, at discount rates of 2.5, 3, and 5
percent. The fourth set, which represents the 95th percentile SCC estimate across all three models at a 3-
percent discount rate, is included to represent higher-than-expected impacts from temperature change further
out in the tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time
series incorporate an escalation factor.
[[Page 55787]]
** The value represents the average of the low and high NOX values used in DOE's analysis.
[dagger] Total Benefits for both the 3 percent and 7 percent cases are derived using the CO2 reduction monetized
value series corresponding to average SCC with 3-percent discount rate.
The benefits and costs of today's proposed standards, for equipment
sold in 2017-2046, can also be expressed in terms of annualized values.
The annualized monetary values are the sum of (1) the annualized
national economic value of the benefits from consumer operation of
equipment that meets the proposed standards (consisting primarily of
operating cost savings from using less energy, minus increases in
equipment purchase and installation costs, and (2) the annualized
monetary value of the benefits of emission reductions, including
CO2 emission reductions.\10\
---------------------------------------------------------------------------
\10\ DOE used a two-step calculation process to convert the
time-series of costs and benefits into annualized values. First, DOE
calculated a present value in 2013, the year used for discounting
the NPV of total consumer costs and savings, for the time-series of
costs and benefits using discount rates of three and seven percent
for all costs and benefits except for the value of CO2
reductions. For the latter, DOE used a range of discount rates, as
shown in Table I.3. From the present value, DOE then calculated the
fixed annual payment over a 30-year period (2014 through 2043) that
yields the same present value. The fixed annual payment is the
annualized value. Although DOE calculated annualized values, this
does not imply that the time-series of cost and benefits from which
the annualized values were determined is a steady stream of
payments.
---------------------------------------------------------------------------
Although combining the values of operating savings and
CO2 emission reductions provides a useful perspective, two
issues should be considered. First, the national operating savings are
domestic U.S. consumer monetary savings that occur as a result of
market transactions while the value of CO2 reductions is
based on a global value. Second, the assessments of operating cost
savings and CO2 savings are performed with different methods
that use different time frames for analysis. The national operating
cost savings is measured for the lifetime of walk-ins shipped from
2017-2046. The SCC values, on the other hand, reflect the present value
of some future climate-related impacts resulting from the emission of
one ton of carbon dioxide in each year. These impacts continue well
beyond 2100.
Table I-4 shows the estimates of annualized benefits and costs of
the proposed standards. (All monetary values below are expressed in
2012$.) The results under the primary estimate are as follows. Using a
7-percent discount rate for benefits and costs other than
CO2 reduction, for which DOE used a 3-percent discount rate
along with the average SCC series that uses a 3-percent discount rate,
the cost of the standards proposed in today's rule is $367 million per
year in increased equipment costs, while the annualized benefits are
$1.225 billion per year in reduced equipment operating costs, $499
million in CO2 reductions, and $24 million in reduced
NOX emissions. In this case, the net benefit amounts to
$1.382 billion per year. Using a 3-percent discount rate for all
benefits and costs and the average SCC series, the cost of the
standards proposed in today's rule is $399 million per year in
increased equipment costs, while the benefits are $1.606 billion per
year in reduced operating costs, $499 million in CO2
reductions, and $31 million in reduced NOX emissions. In
this case, the net benefit amounts to $1.737 billion per year.
Table I-4--Annualized Benefits and Costs of Proposed Standards for Walk-In Coolers and Walk-In Freezers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Primary estimate*
Discount rate ------------------------- Low net benefits High net benefits
(million 2012$/year) estimate* estimate*
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Operating Cost Savings...................... 7%............................. 1,225 1,188 1,279
3%............................. 1,606 1,544 1,687
CO2 Reduction Monetized Value (at $12.9t 5%............................. 142 142 142
case)**.
CO2 Reduction Monetized Value (at $40.8/t 3%............................. 499 499 499
case)**.
CO2 Reduction Monetized Value (at $62.2/t 2.50%.......................... 739 739 739
case)**.
CO2 Reduction Monetized Value (at $117.0/t 3%............................. 1,534 1,534 1,534
case)**.
NOX Reduction Monetized Value (at $2,639/ 7%............................. 24 24 24
Ton)**.
3%............................. 31 31 31
Total Benefits[dagger].................. 7% plus CO2 range.............. 1,748 1,712 1,803
7%............................. 1,249 1,212 1,303
3%............................. 1,637 1,574 1,718
3% plus CO2 range.............. 2,136 2,074 2,217
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total Incremental Installed Costs........... 7%............................. 367 377 357
3%............................. 399 414 385
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total[dagger]............................... 7% plus CO2 range.............. 1,382 1,335 1,446
7%............................. 883 835 946
3%............................. 1,238 1,160 1,333
[[Page 55788]]
3% plus CO2 range.............. 1,737 1,660 1,832
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with walk-in coolers and freezers shipped in 2017-2046. These results include
benefits to consumers which accrue after 2046 from the walk-in coolers and freezers purchased in 2017-2046. Costs incurred by manufacturers, some of
which may be incurred in preparation for the rule, are not directly included, but are indirectly included as part of incremental equipment costs. The
Primary, Low Benefits, and High Benefits Estimates utilize projections of energy prices from the AEO2013 Reference case, Low Estimate, and High
Estimate, respectively. In addition, incremental product costs reflect a medium decline rate for projected product price trends in the Primary
Estimate, a low decline rate for projected product price trends using a Low Benefits Estimate, and a high decline rate for projected product price
trends using a High Benefits Estimate.
** The interagency group selected four sets of SCC values for use in regulatory analyses. Three sets of values are based on the average SCC from the
three integrated assessment models, at discount rates of 2.5, 3, and 5 percent. The fourth set, which represents the 95th percentile SCC estimate
across all three models at a 3-percent discount rate, is included to represent higher-than-expected impacts from temperature change further out in the
tails of the SCC distribution. The values in parentheses represent the SCC in 2015. The SCC time series incorporate an escalation factor. The value
for NOX is the average of the low and high values used in DOE's analysis.
[dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount
rate. In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,'' the operating cost and NOX benefits are calculated using the labeled
discount rate, and those values are added to the full range of CO2 values.
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified. DOE further notes that
manufacturers already produce commercially available equipment that
achieve these levels for most, if not all, equipment classes covered by
today's proposal. Based on the analyses described above, DOE has
tentatively concluded that the benefits of the proposed standards to
the Nation (energy savings, positive NPV of consumer benefits, consumer
LCC savings, and emission reductions) would outweigh the burdens (loss
of INPV for manufacturers).
DOE also considered more-stringent and less-stringent efficiency
levels as trial standard levels (TSLs), and is still considering them
in this rulemaking. However, DOE has tentatively concluded that the
potential burdens of the more-stringent efficiency levels would
outweigh the projected benefits. Based on consideration of the public
comments DOE receives in response to this notice and related
information collected and analyzed during the course of this rulemaking
effort, DOE may adopt efficiency levels presented in this notice that
are either higher or lower than the proposed standards, or some
combination of level(s) that incorporate the proposed standards in
part.
II. Introduction
The following section briefly discusses the statutory authority
underlying today's proposal, as well as some of the relevant historical
background related to walk-ins.
A. Authority
Title III, Part C of EPCA, Public Law 94-163 (42 U.S.C. 6311-6317,
as codified), added by Public Law 95-619, Title IV, section 441(a),
established the Energy Conservation Program for Certain Industrial
Equipment, a program covering certain industrial equipment, which
includes the walk-in coolers and walk-in freezers that are the focus of
this notice.11 12 (42 U.S.C. 6311(1), (20), 6313(f) and
6314(a)(9)) Walk-ins consist of two major pieces--the structural
``envelope'' within which items are stored and a refrigeration system
that cools the air in the envelope's interior.
---------------------------------------------------------------------------
\11\ All references to EPCA in this document refer to the
statute as amended through the American Energy Manufacturing
Technical Corrections Act (AEMTCA), Public Law 112-210 (Dec. 18,
2012).
\12\ For editorial reasons, upon codification in the U.S. Code,
Part C was re-designated Part A-1.
---------------------------------------------------------------------------
DOE's energy conservation program for covered equipment generally
consists of four parts: (1) Testing; (2) labeling; (3) the
establishment of Federal energy conservation standards; and (4)
certification and enforcement procedures. For walk-ins, DOE is
responsible for the entirety of this program. The DOE test procedures
for walk-ins, including those prescribed by Congress in EISA 2007 and
those established by DOE in the test procedure final rule, currently
appear at title 10 of the Code of Federal Regulations (CFR) part 431,
section 304.
Any new or amended performance standards that DOE prescribes for
walk-ins must achieve the maximum improvement in energy efficiency that
is technologically feasible and economically justified. (42 U.S.C.
6313(f)(4)(A)) For purposes of this rulemaking, DOE also plans to adopt
those standards that are likely to result in a significant conservation
of energy that satisfies both of these requirements. See 42 U.S.C.
6295(o)(3)(B).
Technological feasibility is determined by examining technologies
or designs that could be used to improve the efficiency of the covered
equipment. DOE considers a design to be technologically feasible if it
is in use by the relevant industry or if research has progressed to the
development of a working prototype.
In ascertaining whether a particular standard is economically
justified, DOE considers, to the greatest extent practicable, the
following factors:
1. The economic impact of the standard on manufacturers and
consumers of the equipment subject to the standard;
2. The savings in operating costs throughout the estimated average
life of the covered equipment in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered equipment that are likely to result from the imposition of the
standard;
3. The total projected amount of energy or, as applicable, water
savings likely to result directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered
equipment likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
6. The need for national energy and water conservation; and
[[Page 55789]]
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i) (I)-(VII))
DOE does not plan to prescribe an amended or new standard if
interested persons have established by a preponderance of the evidence
that the standard is likely to result in the unavailability in the
United States of any covered product type (or class) of performance
characteristics (including reliability), features, sizes, capacities,
and volumes that are substantially the same as those generally
available in the United States. Further, under EPCA's provisions for
consumer products, there is a rebuttable presumption that a standard is
economically justified if the Secretary finds that the additional cost
to the consumer of purchasing a product complying with an energy
conservation standard level will be less than three times the value of
the energy savings during the first year that the consumer will receive
as a result of the standard, as calculated under the applicable test
procedure. (42 U.S.C. 6295(o)(2)(B)(iii)) For purposes of its walk-in
analysis, DOE plans to account for these factors.
Additionally, when a type or class of covered equipment such as
walk-ins has two or more subcategories, in promulgating standards for
such equipment, DOE often specifies more than one standard level. DOE
generally will adopt a different standard level than that which applies
generally to such type or class of products for any group of covered
products that have the same function or intended use if DOE determines
that products within such group (A) consume a different kind of energy
than that consumed by other covered products within such type (or
class) or (B) have a capacity or other performance-related feature that
other products within such type (or class) do not have, and which
justifies a higher or lower standard. Generally, in determining whether
a performance-related feature justifies a different standard for a
group of products, DOE considers such factors as the utility to the
consumer of the feature and other factors DOE deems appropriate. In a
rule prescribing such a standard, DOE typically includes an explanation
of the basis on which such higher or lower level was established. DOE
plans to follow a similar process in the context of today's rulemaking.
DOE notes that since the inception of the statutory requirements
setting standards for walk-ins, Congress has since made one additional
amendment to those provisions. That amendment provides that the wall,
ceiling, and door insulation requirements detailed in 42 U.S.C.
6313(f)(1)(C) do not apply to the given component if the component's
manufacturer has demonstrated to the Secretary's satisfaction that
``the component reduces energy consumption at least as much'' if those
specified requirements were to apply to that manufacturer's component.
American Energy Manufacturing Technology Corrections Act, Public Law
112-210, Section 2 (Dec. 18, 2012) (codified at 42 U.S.C. 6313(f)(6))
(AEMTCA). Manufacturers seeking to avail themselves of this provision
must ``provide to the Secretary all data and technical information
necessary to fully evaluate its application.'' Id. DOE is proposing to
codify this amendment into its regulations.
Since its codification, one company, HH Technologies, submitted
data on May 24, 2013, demonstrating that its RollSeal doors satisfied
this new AEMTCA provision. DOE reviewed these data and all other
submitted information and concluded that the RollSeal doors at issue
satisfied 42 U.S.C. 6313(f)(6). Accordingly, DOE issued a determination
letter on June 14, 2013, indicating that these doors met Section
6313(f)(6) and that the applicable insulation requirements did not
apply to the RollSeal doors HH Technologies identified. Nothing in this
proposed rule affects the previous determination regarding HH
Technologies.
Federal energy conservation requirements generally pre-empt state
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a); 42 U.S.C. 6316(b)) However, EPCA
provides that for walk-ins in particular, any state standard issued
before publication of the final rule shall not be pre-empted until the
standards established in the final rule take effect. (42 U.S.C
6316(h)(2)(B))
Where applicable, DOE generally considers standby and off mode
energy use for certain covered products or equipment when developing
energy conservation standards. See 42 U.S.C. 6295(gg)(3). Because the
vast majority of walk-in coolers and walk-in freezers operate
continuously to keep their contents cold at all times, DOE is not
proposing standards for standby and off mode energy use.
B. Background
1. Current Standards
EPCA defines a walk-in cooler and a walk-in freezer as an enclosed
storage space refrigerated to temperatures above, and at or below,
respectively, 32[emsp14][deg]F that can be walked into. The statute
also defines walk-in coolers and freezers as having a total chilled
storage area of less than 3,000 square feet, excluding products
designed and marketed exclusively for medical, scientific, or research
purposes. (42 U.S.C 6311(20)) EPCA also provides prescriptive standards
for walk-in coolers and freezers manufactured on or after January 1,
2009, which are described below.
First, EPCA sets forth general prescriptive standards for walk-ins.
Walk-ins must have automatic door closers that firmly close all walk-in
doors that have been closed to within 1 inch of full closure, for all
doors narrower than 3 feet 9 inches and shorter than 7 feet; walk-ins
must also have strip doors, spring hinged doors, or other methods of
minimizing infiltration when doors are open. Walk-ins must also contain
wall, ceiling, and door insulation of at least R-25 for coolers and R-
32 for freezers, excluding glazed portions of doors and structural
members, and floor insulation of at least R-28 for freezers. Walk-in
evaporator fan motors of under 1 horsepower and less than 460 volts
must be electronically commutated motors (brushless direct current
motors) or three-phase motors, and walk-in condenser fan motors of
under 1 horsepower must use permanent split capacitor motors,
electronically commutated motors, or three-phase motors. Interior light
sources must have an efficacy of 40 lumens per watt or more, including
any ballast losses; less-efficacious lights may only be used in
conjunction with a timer or device that turns off the lights within 15
minutes of when the walk-in is unoccupied. See 42 U.S.C. 6313(f)(1).
Second, EPCA sets forth new requirements related to electronically
commutated motors for use in walk-ins. See 42 U.S.C. 6313(f)(2)).
Specifically, in those walk-ins that use an evaporator fan motor with a
rating of under 1 horsepower and less than 460 volts, that motor must
be either a three-phase motor or an electronically commutated motor
unless DOE determined prior to January 1, 2009 that electronically
commutated motors are available from only one manufacturer. (42 U.S.C.
6313(f)(2)(A)) DOE determined by January 1, 2009 that these motors were
available from more than one manufacturer; thus, according to EPCA,
walk-in evaporator fan motors with a rating of under 1 horsepower and
less than 460 volts must be either three-phase motors or electronically
commutated motors. DOE documented this determination in the rulemaking
docket as docket ID EERE-2008-BT-STD-0015-0072. This document can be
[[Page 55790]]
found at https://www.regulations.gov/#!documentDetail;D=EERE-2008-BT-
STD-0015-0072. Additionally, EISA provided DOE with the authority to
permit the use of other types of motors as evaporative fan motors--if
DOE determines that, on average, those other motor types use no more
energy in evaporative fan applications than electronically commutated
motors. (42 U.S.C. 6313(f)(2)(B)) DOE is unaware of any other motors
that would offer performance levels comparable to the electronically
commutated motors required by Congress. Accordingly, all evaporator
motors rated at under 1 horsepower and under 460 volts must be
electronically commutated motors or three-phase motors.
Third, EPCA sets forth additional requirements for walk-ins with
transparent reach-in doors. Freezer doors must have triple-pane glass
with either heat-reflective treated glass or gas fill for doors and
windows for freezers. Cooler doors must have either double-pane glass
with treated glass and gas fill or triple-pane glass with treated glass
or gas fill. (42 U.S.C. 6313(f)(3)(A)-(B)) For walk-ins with
transparent reach-in doors, EISA also prescribed specific anti-sweat
heater-related requirements: Walk-ins without anti-sweat heater
controls must have a heater power draw of no more than 7.1 or 3.0 watts
per square foot of door opening for freezers and coolers, respectively.
Walk-ins with anti-sweat heater controls must either have a heater
power draw of no more than 7.1 or 3.0 watts per square foot of door
opening for freezers and coolers, respectively, or the anti-sweat
heater controls must reduce the energy use of the heater in a quantity
corresponding to the relative humidity of the air outside the door or
to the condensation on the inner glass pane. See 42 U.S.C.
6313(f)(3)(C)-(D).
2. History of Standards Rulemaking for Walk-In Coolers and Freezers
EPCA directs the Secretary to issue performance-based standards for
walk-ins that would apply to equipment manufactured 3 years after the
final rule is published, or 5 years if the Secretary determines by rule
that a 3-year period is inadequate. (42 U.S.C. 6313(f)(4))
DOE initiated the current rulemaking by publishing a notice
announcing the availability of its ``Walk-In Coolers and Walk-In
Freezers Energy Conservation Standard Framework Document'' and a
meeting to discuss the document. The notice also solicited comment on
the matters raised in the document. 74 FR 411 (Jan 6, 2009). More
information on the framework document is available at: https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/30. The framework document described the procedural and
analytical approaches that DOE anticipated using to evaluate energy
conservation standards for walk-ins and identified various issues to be
resolved in conducting this rulemaking.
DOE held the framework public meeting on February 4, 2009, in which
it: (1) Presented the contents of the framework document; (2) described
the analyses it planned to conduct during the rulemaking; (3) sought
comments from interested parties on these subjects; and (4) in general,
sought to inform interested parties about, and facilitate their
involvement in, the rulemaking. Major issues discussed at the public
meeting included: (1) The scope of coverage for the rulemaking; (2)
development of a test procedure and appropriate test metrics; (3)
manufacturer and market information, including distribution channels;
(4) equipment classes, baseline units, and design options to improve
efficiency; and (5) life-cycle costs to consumers, including
installation, maintenance, and repair costs, and any consumer subgroups
DOE should consider. At the meeting and during the comment period on
the framework document, DOE received many comments that helped it
identify and resolve issues pertaining to walk-ins relevant to this
rulemaking.
DOE then gathered additional information and performed preliminary
analyses to help develop potential energy conservation standards for
this equipment. This process culminated in DOE's announcement of
another public meeting to discuss and receive comments on the following
matters: (1) The equipment classes DOE planned to analyze; (2) the
analytical framework, models, and tools that DOE used to evaluate
standards; (3) the results of the preliminary analyses performed by
DOE; and (4) potential standard levels that DOE could consider. 75 FR
17080 (April 5, 2010) (the April 2010 Notice). DOE also invited written
comments on these subjects and announced the availability on its Web
site of a preliminary technical support document (preliminary TSD) it
had prepared to inform interested parties and enable them to provide
comments. Id. (More information about the preliminary TSD is available
at: https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/30.)Finally, DOE sought views on other relevant
issues that participants believed either would impact walk-in standards
or that the proposal should address. Id. at 17083.
The preliminary TSD provided an overview of the activities DOE
undertook to develop standards for walk-ins and discussed the comments
DOE received in response to the framework document. The preliminary TSD
also addressed separate standards for the walk-in envelope and the
refrigeration system, as well as compliance and enforcement
responsibilities and food safety regulatory concerns. The document also
described the analytical framework that DOE used (and continues to use)
in considering standards for walk-in coolers and freezers, including a
description of the methodology, the analytical tools, and the
relationships between the various analyses that are part of this
rulemaking. Additionally, the preliminary TSD presented in detail each
analysis that DOE had performed for these products up to that point,
including descriptions of inputs, sources, methodologies, and results.
These analyses were as follows:
A market and technology assessment addressed the scope of
this rulemaking, identified the potential classes for walk-in coolers
and freezers, characterized the markets for these products, and
reviewed techniques and approaches for improving their efficiency;
A screening analysis reviewed technology options to
improve the efficiency of walk-in coolers and freezers, and weighed
these options against DOE's four prescribed screening criteria;
An engineering analysis estimated the manufacturer selling
prices (MSPs) associated with more energy-efficient walk-in coolers and
freezers;
An energy use analysis estimated the annual energy use of
walk-in coolers and freezers;
A markups analysis converted estimated MSPs derived from
the engineering analysis to consumer prices;
A life-cycle cost analysis calculated, for individual
consumers, the discounted savings in operating costs throughout the
estimated average life of walk-in coolers and freezers, compared to any
increase in installed costs likely to result directly from the
imposition of a given standard;
A payback period analysis estimated the amount of time it
takes individual consumers to recover the higher purchase price expense
of more energy-efficient products through lower operating costs;
A shipments analysis estimated shipments of walk-in
coolers and freezers over the time period examined in the analysis, and
was used in performing the national impact analysis;
[[Page 55791]]
A national impact analysis assessed the national energy
savings and the national net present value of total consumer costs and
savings that are expected to result from specific potential energy
conservation standards for walk-in coolers and freezers; and
A preliminary manufacturer impact analysis (MIA) took the
initial steps in evaluating the effects on manufacturers of new
efficiency standards.
The public meeting announced in the April 2010 Notice took place on
May 19, 2010. At this meeting, DOE presented the methodologies and
results of the analyses set forth in the preliminary TSD. Interested
parties that participated in the public meeting discussed a variety of
topics, but the comments centered on the following issues: (1) Separate
standards for the refrigeration system and the walk-in envelope; (2)
responsibility for compliance; (3) equipment classes; (4) technology
options; (5) energy modeling; (6) installation, maintenance, and repair
costs; (7) markups and distributions chains; (8) walk-in cooler and
freezer shipments; and (9) test procedures. The comments received since
publication of the April 2010 Notice, including those received at the
May 2010 public meeting, have contributed to DOE's proposed resolution
of the issues in this rulemaking as they pertain to walk-ins. This NOPR
responds to the issues raised by the commenters. (A parenthetical
reference at the end of a quotation or paraphrase provides the location
of the item in the public record.)
III. General Discussion
In preparing today's notice, DOE considered input from the various
interested parties who commented on the framework document and
preliminary analysis, information obtained from manufacturer
interviews, and additional research that DOE conducted. The interested
parties who provided comments to DOE during the framework document and
preliminary analysis phases included the following:
Table III-1--Framework and Preliminary Analysis Commenters
----------------------------------------------------------------------------------------------------------------
Comment number(s) in
Commenter(s) Abbreviated designation Affiliation docket
----------------------------------------------------------------------------------------------------------------
AFM Corporation...................... AFM.................... Manufacturer........... 0012.1
Air-Conditioning, Heating, and AHRI................... Trade Association...... 0036.1, 0055.1
Refrigeration Institute.
American Chemistry Council........... ACC.................... Material Supplier...... 0062.1
American Chemistry Council Center for CPI.................... Material Supplier...... 0052.1
the Polyurethanes Industry.
American Council for an Energy Joint Advocates........ Energy Efficiency 0070.1
Efficient Economy, Appliance Advocates.
Standards Awareness Project,
Alliance to Save Energy, Natural
Resources Defense Council, Northwest
Energy Efficiency Alliance.
American Panel Corporation........... American Panel......... Manufacturer........... 0039.1, 0048.1
AmeriKooler, Inc..................... AmeriKooler............ Manufacturer........... 0065.1
Appliance Standards Awareness Project ASAP................... Energy Efficiency 0024.1
Advocate.
Bally Refrigerated Boxes, Inc........ Bally.................. Manufacturer........... 0023.1
Carpenter Co. Chemical Systems Carpenter.............. Material Supplier...... 0068.1
Division.
Craig Industries, Inc. and U.S. Craig Industries....... Manufacturer........... 0064.1
Cooler Company.
Craig Industries, Inc. and US Cooler Craig Industries....... Manufacturer........... 0011.1, 0025.1, 0038.1,
Company. 0064.1, 0071.1
CrownTonka Walk-Ins.................. CrownTonka............. Manufacturer........... 0026.1, 0057.1
Earthjustice......................... Earthjustice........... Energy Efficiency 0027.1, 0047.1
Advocate.
Edison Electric Institute............ EEI.................... Energy Efficiency 0028.1
Advocate.
Eliason Corporation.................. Eliason................ Manufacturer........... 0013.1, 0022.1
Foam Supplies, Inc................... FSI.................... Material Supplier...... 0029.1
Heatcraft Refrigeration Products LLC. Heatcraft.............. Manufacturer........... 0058.1, 0069.1
Heating, Air-conditioning & HARDI.................. Trade Association...... 0031.1
Refrigeration Distributors
International.
Hill Phoenix Walk-Ins................ Hill Phoenix........... Manufacturer........... 0066.1
Hired Hand Technologies.............. Hired Hand............. Manufacturer........... 0030.1, 0050.1
Hussmann and Ingersoll Rand.......... Ingersoll Rand......... Manufacturer........... 0053.1
Kason Industries, Inc................ Kason.................. Component Supplier..... 0009.1, 0019.1
Kysor Panel Systems.................. Kysor.................. Manufacturer........... 0032.1, 0054.1
Manitowoc Ice........................ Manitowoc.............. Manufacturer........... 0056.1
Master-Bilt Products, Inc............ Master-Bilt............ Manufacturer........... 0033.1, 0046.1
NanoPore Insulation, LLC............. NanoPore............... Material Supplier...... 0067.1
Nor-Lake, Incorporated............... Nor-Lake............... Manufacturer........... 0049.1
Owens Corning Foam Insulation, LLC... Owens Corning.......... Material Supplier...... 0034.1
Southern California Edison and SCE.................... Utility................ 0035.1
Technology Test Centers.
Southern California Edison, San Diego Joint Utilities........ Utility Group.......... 0061.1
Gas & Electric, Pacific Gas &
Electric Company, Sacramento
Municipal Utility District.
The Northwest Energy Efficiency NEEA and NPCC.......... Utility Representative. 0021.1, 0059.1
Alliance and the Northeast Power
Coordinating Council.
Zero-Zone, Inc....................... Zero-Zone.............. Manufacturer........... 0051.1
----------------------------------------------------------------------------------------------------------------
A. Component Level Standards
In the framework document, DOE considered setting standards that
would apply to the entire walk-in. See the framework document at https://www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/wicf_framework_doc.pdf. Several interested parties expressed concern
about this approach because of the variety among assembled walk-ins,
which would make compliance with
[[Page 55792]]
such a walk-in standard difficult and burdensome. Stakeholders also
stated that different components of each walk-in would likely be
manufactured by different entities, which would make it difficult to
enforce any standard that applied to an entire walk-in.
After considering the comments submitted on the framework document,
DOE modified its approach in the preliminary analysis. During that
phase, it had tentatively identified two primary components of a walk-
in: the envelope (the insulated box that separates the exterior from
the interior) and the refrigeration system (the mechanical equipment
that cools the envelope's interior). DOE also indicated that it was
tentatively considering developing separate standards for refrigeration
systems and envelopes.
Several interested parties agreed with this general approach.
Manitowoc supported separate standards for the envelope and
refrigeration system, stating that the envelope is typically supplied
by one manufacturer and the refrigeration system is typically supplied
by one or more manufacturers. (Manitowoc, Public Meeting Transcript,
No. 0045 at p. 38 and No. 0056.1 at p. 1) Manitowoc further stated that
it would not be practical to regulate the energy used by the entire
walk-in assembly because walk-ins are highly customized. Manitowoc
estimated that fewer than 20 percent of its walk-ins use a standard
envelope and refrigeration system combination. (Manitowoc, No. 0056.1
at p. 1) Pacific Gas and Electric Company, Southern California Edison,
Sempra Energy Utility, and the Sacramento Municipal Utility District
(hereafter referred to as the ``Joint Utilities'') also agreed with
DOE's proposal to separate the refrigeration system standards from the
envelope standards because the components are separately produced and
often separately sold. (Joint Utilities, No. 0061.1 at pp. 2-3)
American Panel stated that the envelope and refrigeration systems must
be considered separately because the majority of WICFs are custom-made.
(American Panel, No. 0048.1 at p. 4) Kysor, Master-Bilt, AHRI, and
CrownTonka all supported separate standards for the envelope and
refrigeration systems. (Kysor, Public Meeting Transcript, No. 0045 at
p. 39; Master-Bilt, No. 0046.1 at p. 1; AHRI, No. 0055.1 at p. 2;
CrownTonka, No. 0057.1 at p. 1) One interested party did not agree with
this approach. Craig Industries, also doing business as U.S. Cooler,
commented that DOE should establish a combination standard for the
envelope and refrigeration system to permit manufacturers greater
flexibility when designing walk-ins. Under this combination approach, a
more efficient envelope could be paired with a less efficient
refrigeration system, or vice versa, to achieve the same overall
efficiency at a lower cost. (Craig Industries, No. 0064.1 at p. 1)
Additionally, interested parties suggested that DOE extend the idea
of separate standards to subcomponents of envelopes and refrigeration
systems. The Joint Utilities stated that a component performance
approach would accurately capture efficiency measurements associated
with the components, and that energy savings associated with targeted
components would apply to different configurations of whole walk-ins
and possibly even to repairs and retrofits. (Joint Utilities, No.
0061.1 at p. 4) The Joint Utilities further added that DOE should
consider component performance standards for major walk-in components
that could be enforced at the level of the manufacturer's catalog and
could be labeled for easy inspection. (Joint Utilities, No. 0061.1 at
p. 12) Hill Phoenix also recommended that large construction-based
envelopes (i.e., those constructed in a manner similar to a building)
be regulated at the component level, asserting that these envelopes may
need many different options and design flexibility, without which a
whole-envelope calculation would likely limit the accuracy of any
estimate of a walk-in's total energy use. (Hill Phoenix, No. 0066.1 at
p. 1) As stated previously, Manitowoc agreed that it would not be
practical to regulate the energy used by the entire walk-in assembly
because walk-ins are highly customized. (Manitowoc, No. 0056.1 at p. 1)
Manitowoc also remarked that performance metrics could be developed for
sub-classes of the components of an envelope, and the component
manufacturers should be responsible for their own components.
(Manitowoc, Public Meeting Transcript, No. 0045 at p. 46)
Other stakeholders discussed specific sub-components of the
envelope or the refrigeration system that could be regulated. Kysor
mentioned panels and doors as envelope components that should be
considered separately and stated that because these components are
often manufactured by separate parties, the manufacturer of each
component should be responsible for the performance of that component.
(Kysor, Public Meeting Transcript, No. 0045 at p. 41) The Northwest
Energy Efficiency Alliance (NEEA) and Northwest Power Conservation
Council (NPCC) recommended that DOE develop efficiency performance
standards for display and solid doors separately so that an envelope
manufacturer could certify that the envelope meets specified standards.
(NEEA and NPCC, No. 0059.1 at p. 2)
Likewise, with regard to the refrigeration system, NEAA and NPCC
recommended that DOE regulate the efficiency of the cooling system
components separately, an example of which would be setting a
performance requirement for the specific efficiency of unit coolers
based on control algorithms. (NEAA and NPCC, No. 0059.1 at pp. 2 and 7)
The Joint Utilities also stated that a refrigeration system requirement
should not be based on a single metric and added that the indoor unit
(i.e., unit cooler) could have a minimum efficiency requirement
regardless of other components of the refrigeration system. (Joint
Utilities, No. 0061.1 at p. 4 and Public Meeting Transcript, No. 0045
at p. 64) Manitowoc, on the other hand, recommended that manufacturers
have the option of rating the entire refrigeration system and that
considering the condensing unit separately would not allow
manufacturers to implement options that would improve the efficiency of
a matched system. (Manitowoc, Public Meeting Transcript, No. 0045 at p.
38) Manitowoc further remarked that testing the refrigeration system as
an integrated, single component and calculating the overall annual
efficiency has the greatest potential for optimizing energy efficiency,
but added that DOE should permit the individual components to be tested
and the performance stated for the individual parts. (Manitowoc, Public
Meeting Transcript, No. 0045 at p. 59)
After carefully considering the comments described above, DOE
proposes an approach for the envelope that would set separate standards
for panels, display doors, and non-display doors for the reasons set
forth below.
Different manufacturers typically produce panels and doors (both
display and non-display types) for use in walk-in applications. In
particular, display doors are commonly manufactured separately because
their unique construction and materials require specialized
manufacturing methods. Additionally, the modular nature of a walk-in
envelope means that it is constructed of relatively standardized
components that can be assembled in a virtually infinite number of
configurations that may affect the overall consumption of a given walk-
in unit. By regulating the performance of those standardized
components, manufacturers will be able to choose
[[Page 55793]]
compliant components that should help ensure that whatever walk-in
configuration is built satisfies the minimal level of energy
consumption and efficiency that DOE may prescribe. Because of the large
number of possible combinations of panels and doors that could make up
an envelope, the burdens presented by a system-based approach for the
entire walk-in unit would also likely be significantly greater than the
burdens of the proposed approach because each walk-in envelope
configuration would need to be separately certified as compliant.
Alternatively, if DOE were to establish a set envelope of specified
dimensions for a manufacturer to build and then to certify as
compliant, the efficiency or energy usage measurement from that
envelope would not only be more costly to obtain, but it would also not
necessarily reflect the actual energy usage or efficiency of a given
walk-in that is installed in the field.
DOE also notes that requiring an overall envelope performance
standard would be likely to present significant enforcement burdens, as
it would likely require DOE to test several fully constructed envelopes
in order to ascertain the energy efficiency performance of a given
envelope. DOE tentatively believes that such an approach, at this time,
would be unduly burdensome.
DOE is not, however, proposing to set standards for the constituent
components of refrigeration systems separately. To ensure that
manufacturers have sufficient flexibility to improve the energy
efficiency performance of their systems, DOE proposes to set a
performance standard for the overall refrigeration system and to
regulate that system as a single component. This approach would help
ensure that the final refrigeration system assembled by the
manufacturer would meet a given level of efficiency and would account
for the interactive effects of the numerous components comprising the
overall system. For example, some refrigeration systems implement
complex control strategies, the benefits of which could not be
adequately demonstrated if the condensing unit and unit cooler were
considered separately for purposes of setting standards.
In summary, DOE proposes to set specific component standards for
the panels, display doors, and non-display doors of a walk-in, and a
single standard to assess the overall performance of the refrigeration
system. DOE acknowledges that, by not establishing a standard for the
energy use of the entire walk-in, manufacturers cannot meet the
standard by pairing a more-efficient envelope with a less-efficient
refrigeration system, and vice versa. Also, DOE would not account for
the energy use of some components, such as the electricity use of
overhead lighting or heat load due to the infiltration of warm air into
the walk-in, and would not consider design options whose efficacy
depends on the interaction between the different covered components.
Including these factors as part of the current rulemaking would likely
introduce significant complications with respect to compliance and
enforcement while yielding a comparatively small benefit in energy
savings. DOE believes, however, that the proposed approach would help
ensure that the walk-in components used by manufacturers satisfy some
minimal level of energy efficiency and reduce the overall certification
and enforcement burden on manufacturers. DOE may reconsider this issue
in the future, particularly if accurate computer modeling, such as
through an alternative efficiency determination method, becomes
possible with respect to predicting the energy usage and efficiency of
fully constructed walk-in units. DOE continues to invite comments on
the approach presented in this NOPR.
B. Test Procedures and Metrics
While Congress had initially prescribed certain performance
standards and test procedures concerning walk-ins as part of the EISA
2007 amendments, Congress also instructed DOE to develop specific test
procedures to cover walk-in equipment. DOE subsequently established a
test procedure for walk-ins. See 76 FR 21580 (April 15, 2011). See also
76 FR 33631 (June 9, 2011) (final technical corrections). The test
procedure lays out an approach that bases compliance on the ability of
component manufacturers to produce components that meet the required
standards. This approach is also consistent with the framework
established by Congress, which set specific energy efficiency
performance requirements on a component-level basis. (42 U.S.C.
6313(f)) The approach is discussed more fully below.
1. Panels
In the final test procedure rule for walk-ins, DOE defines
``panel'' as a construction component, excluding doors, used to
construct the envelope of the walk-in (i.e., elements that separate the
interior refrigerated environment of the walk-in from the exterior). 76
FR 33631 (June 9, 2011). The rule explains that panel manufacturers
would test their panels to obtain a thermal transmittance metric--known
as U-factor, measured in Btu/h-ft\2\-[deg]F--and identifies three types
of panels: display panels, floor panels, and non-floor panels. A
display panel is defined as a panel that is entirely or partially
comprised of glass, a transparent material, or both, and is used for
display purposes. Id. It is considered equivalent to a window and the
U-factor is determined by NFRC 100-2010-E0A1, ``Procedure for
Determining Fenestration Product U-factors.'' 76 FR at 33639. Floor
panels are used for walk-in floors, whereas non-floor panels are used
for walls and ceilings.
The U-factor for floor and non-floor panels accounts for any
structural members internal to the panel and the long-term thermal
aging of foam. This value is determined by a three-step process. First,
both floor and non-floor panels must be tested using ASTM C1363-10,
``Standard Test Method for Thermal Performance of Building Materials
and Envelope Assemblies by Means of a Hot Box Apparatus.'' The panel's
core and edge regions must be used during testing. Second, the panel's
core U-factor must be adjusted with a degradation factor to account for
foam aging. The degradation factor is determined by EN 13165:2009-02,
``Thermal Insulation Products for Buildings--Factory Made Rigid
Polyurethane Foam (PUR) Products--Specification,'' or EN 13164:2009-02,
``Thermal Insulation Products for Buildings--Factory Made Products of
Extruded Polystyrene Foam (XPS)--Specification,'' as applicable. Third,
the edge and modified core U-factors are then combined to produce the
panel's overall U-factor. All industry protocols were incorporated by
reference most recently in the test procedure final rule correction. 76
FR 33631.
2. Doors
The walk-in test procedure final rule addressed two door types:
display and non-display doors. Within the general context of walk-ins,
a door consists of the door panel, glass, framing materials, door plug,
mullion, and any other elements that form the door or part of its
connection to the wall. DOE defines display doors as doors designed for
product movement, display, or both, rather than the passage of persons;
a non-display door is interpreted to mean any type of door that is not
captured by the definition of a display door. 76 FR at 33631.
The test metric for doors is in terms of energy use, measured in
kilowatt-hours per day (kWh/day). The energy use accounts for thermal
transmittance through the door and the electricity use
[[Page 55794]]
of any electrical components associated with the door. The thermal
transmittance is measured by NFRC 100-2010-E0A1, and is converted to
energy consumption via conduction losses using an assumed efficiency of
the refrigeration system in accordance with the test procedure. See 76
FR at 33636-33637. The electrical energy consumption of the door is
calculated by summing each electrical device's individual consumption
and accounts for all device controls by applying a ``percent time off''
value to the appropriate device's energy consumption. For any device
that is located on the internal face of the door or inside the door, 75
percent of its power is assumed to contribute to an additional heat
load on the compressor. Finally, the total energy consumption of the
door is found by combining the conduction load, electrical load, and
additional compressor load.
3. Refrigeration
The test procedure incorporates an industry test procedure applied
to walk-in refrigeration systems: AHRI 1250 (I-P)-2009, ``2009 Standard
for Performance Rating of Walk-In Coolers and Freezers'' (``AHRI 1250-
2009''). 76 FR at 33631. This procedure applies to unit coolers and
condensing units sold together as a matched system, unit coolers and
condensing units sold separately, and unit coolers connected to
compressor racks or multiplex condensing systems. It also describes
methods for measuring the refrigeration capacity, on-cycle electrical
energy consumption, off-cycle fan energy, and defrost energy. Standard
test conditions, which are different for indoor and outdoor locations
and for coolers and freezers, are also specified.
The test procedure includes a calculation methodology to compute an
annual walk-in energy factor (AWEF), which is the ratio of heat removed
from the envelope to the total energy input of the refrigeration system
over a year. AWEF is measured in Btu/W-h and measures the efficiency of
a refrigeration system. DOE established a metric based on efficiency,
rather than energy use, for describing refrigeration system
performance, because a refrigeration system's energy use would be
expected to increase based on the size of the walk-in and on the heat
load that the walk-in produces. An efficiency-based metric would
account for this relationship and would simplify the comparison of
refrigeration systems to each other. Therefore, DOE proposes to use an
energy conservation standard for refrigeration systems that would be
presented in terms of AWEF.
C. Prescriptive Versus Performance Standards
EPCA established standards for certain WICF components, while also
directing the Secretary to establish ``performance-based standards,''
which are the subject of this rulemaking. (42 U.S.C. 6313(f)(4)(A))
Some interested parties suggested that DOE establish prescriptive
standards for certain components in addition to the performance-based
standards that DOE is proposing. NEEA and NPCC stated that DOE should
establish a prescriptive (i.e., design) standard for electronically
commutated motors. (NEEA and NPCC, No. 0059.1 at p. 7) The Joint
Utilities recommended that DOE consider the precedent set by EPCA, as
the EPCA provisions include both prescriptive and performance
standards, and further recommended that DOE include additional
prescriptive requirements for various components of a walk-in as
necessary to maximize energy savings, and performance standards for the
unit cooler. (Joint Utilities, No. 0061.1 at p. 11) The Joint Utilities
also recommended that DOE base new standards using those design
requirements already prescribed by Title 20 of California's Code as the
baseline when developing a performance standard. (Joint Utilities, No.
0061.1 at p. 13) SCE also referred to the prescriptive standards in
Title 20, and suggested that because EPCA already established
prescriptive measures, there will be limited additional benefit from
performance measures. SCE further recommended that a standard for
infiltration should be implemented through ASHRAE 90.1 (SCE, Public
Meeting Transcript, No. 0045 at p. 63) The Joint Utilities recommended
other specific prescriptive requirements that DOE should implement,
including a minimum solar reflective index for the roof of a walk-in
located outdoors, adjustable variable speed fan control for unit
coolers, and floating head pressure control (a control that allows the
pressure of the refrigerant at the compressor exit point to reach an
optimal level). (Joint Utilities, No. 0061.1 at pp. 5 and 12; Public
Meeting Transcript, No. 0045 at p. 29) The Joint Utilities also asked
DOE to examine how controls could be specified in a performance
standard. (Joint Utilities, No. 0061.1 at p. 13)
DOE notes that EPCA requires the promulgation of ``performance-
based standards'' for walk-ins. That phrase indicates that DOE must set
standards based on energy-related performance. See 42 U.S.C.
6313(f)(4). Accordingly, the design requirements suggested by
commenters would be inconsistent with this requirement.
D. Certification, Compliance, and Enforcement
Walk-ins consist primarily of panels, display and non-display
doors, and a refrigeration system, as described in section III.A. A
number of arrangements exist for manufacturing walk-ins. One company
may manufacture the panels, purchase the display and/or non-display
doors and refrigeration system, assemble the walk-in at the factory,
and ship the walk-in to a consumer. Alternatively, the same company may
ship the walk-in without a refrigeration system, which is then
purchased separately by the consumer and installed on the walk-in. A
contractor may purchase all the components from the component
manufacturers and assemble the walk-in on-site. Other scenarios may
also exist. Given the wide variety of scenarios under which a walk-in
is manufactured, it is important to identify an entity or entities
responsible for complying with standards and certifying compliance to
DOE, and against whom a possible enforcement action could be taken.
During the preliminary analysis public meeting, many interested
parties expressed concern about compliance responsibilities and whether
those burdens would fall on the envelope and refrigeration
manufacturers individually, the installer, or another party.
Additionally, the Joint Advocates submitted a comment urging DOE to
ensure that the separate system components would be compliant with the
energy conservation standards, and stating that each manufacturer
should be held accountable for their products (e.g., door manufacturers
are responsible for compliance with door standards). (Joint Advocates,
No. 0070.1 at pp. 2-3) Craig Industries recommended that the definition
of a manufacturer be expanded to include the installer of the unit,
because the installer has the ability to ensure that the installed unit
meets the energy conservation standards. (Craig Industries, No. 0071.1
at p. 1). Comments on this issue were summarized in the 2011
Certification, Compliance, and Enforcement for Consumer Products and
Commercial and Industrial Equipment (referred to hereafter as the CCE
final rule), and are not repeated here. 76 FR 12422, 12442-12446 (March
7, 2011).
DOE notes that within the context of today's proposal, the agency
is contemplating an approach that would place the primary certification
and compliance burden on those entities that manufacture particular key
components of a walk-in--that is, the
[[Page 55795]]
panels, doors, and refrigeration system. This approach dovetails with
that outlined in the recent test procedure final rule. The various
requirements that manufacturers would need to follow are detailed in
the 2011 final rule noted above regarding manufacturer certification,
compliance, and enforcement-related responsibilities. 76 FR 12422. For
further details, see 76 FR at 12491.
E. Technological Feasibility
1. General
In each standards rulemaking, DOE conducts a screening analysis,
which it bases on information gathered on all current technology
options and prototype designs that could improve the efficiency of the
products or equipment that are the subject of the rulemaking. As the
first step in such analysis, DOE develops a list of design options for
consideration in consultation with manufacturers, design engineers, and
other interested parties. DOE then determines which of these means for
improving efficiency are technologically feasible. DOE considers
technologies incorporated in commercial products or in working
prototypes to be technologically feasible. 10 CFR 430, subpart C,
appendix A, section 4(a)(4)(i) Although DOE considers technologies that
are proprietary, it will not consider efficiency levels that can only
be reached through the use of proprietary technologies (i.e., a unique
pathway), as it could allow a single manufacturer to monopolize the
market.
Once DOE has determined that particular design options are
technologically feasible, it generally evaluates each of these design
options in light of the following additional screening criteria: (1)
Practicability to manufacture, install, or service; (2) adverse impacts
on product utility or availability; and (3) adverse impacts on health
or safety. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(ii)-
(iv) Section IV.B of this notice discusses the results of the screening
analyses for walk-in coolers and freezers. Specifically, it presents
the designs DOE considered, those it screened out, and those that are
the basis for the TSLs in this rulemaking. For further details on the
screening analysis for this rulemaking, see chapter 4 of the TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt a new or amended or new energy
conservation standard for a type or class of covered equipment such as
walk-ins, it determines the maximum improvement in energy efficiency
that is technologically feasible for such equipment. Accordingly, DOE
determined the maximum technologically feasible (max-tech) improvements
in energy efficiency for walk-ins by applying those design parameters
that passed the screening analysis to the engineering analysis that DOE
prepared as part of the preliminary analysis.
In a comment on the max-tech levels in the preliminary analysis,
AHRI commented that max-tech efficiency levels would be achieved only
by a few units, and it requested that DOE demonstrate that max-tech
levels can be achieved by commonly used products. (AHRI, No. 0055.1 at
p. 3)
As indicated previously, whether efficiency levels exist or can be
achieved in commonly used products does not determine whether they are
max-tech levels. DOE considers technologies to be technologically
feasible if they are incorporated in any commercially available
equipment or working prototypes. A maximum technologically feasible
level results from the combination of design options that result in the
highest efficiency level for an equipment class, with such design
options consisting of technologies already incorporated in commercial
products or working prototypes. DOE notes that it re-evaluated the
efficiency levels, including the max-tech levels, when it updated its
results for this NOPR. See chapter 5 of the NOPR TSD for the results of
the analysis.
For panels, non-display doors, display doors, and refrigeration
systems, the max-tech efficiency levels DOE has identified represent
products with the most efficient design options available on the
market, or previously offered for sale, in the given equipment class.
No products at higher efficiencies are available or have been in the
past, and DOE is not aware of any working prototype designs that would
allow manufacturers to achieve higher efficiencies. Table III-2, Table
III-3, Table III-4, and Table III-5 list the max-tech levels for
panels, display doors, non-display doors, and refrigeration systems,
respectively. (See section IV.A.3 for a description of the equipment
classes.)
For structural cooler and freezer panels, the max-tech level is
represented by a single value for U-factor. For all other TSLs (and for
all floor panel levels including the max-tech level), the level is
represented by a polynomial equation expressing the U-factor in terms
of certain panel dimensions, but the max tech level does not result in
a polynomial equation because the U-factor does not vary with the size
of the panel. (See section V.A.2 for a list of equations for all TSLs.)
At max-tech, panels are designed without structural members, making the
panel uniformly comprised of hybrid insulation. See section IV.C.5 and
chapter 5 of the TSD for the list of technologies included in max-tech
equipment.
[GRAPHIC] [TIFF OMITTED] TP11SE13.002
[[Page 55796]]
Table III-3--Max-Tech Levels for Display Doors
------------------------------------------------------------------------
Equations for maximum energy
Equipment class consumption (kWh/day) *
------------------------------------------------------------------------
Display Door, Medium Temperature... 0.0080 x Add + 0.29
Display Door, Low Temperature...... 0.11 x Add + 0.32
------------------------------------------------------------------------
* Add represents the surface area of the display door.
Table III-4--Max-Tech Levels for Non-Display Doors
------------------------------------------------------------------------
Equations for maximum energy
Equipment class consumption (kWh/day) *
------------------------------------------------------------------------
Passage Door, Medium Temperature... 0.00093 x And + 0.0083
Passage Door, Low Temperature...... 0.13 x And + 3.9
Freight Door, Medium Temperature... 0.00092 x And + 0.13
Freight Door, Low Temperature...... 0.094 x And + 5.2
------------------------------------------------------------------------
* And represents the surface area of the non-display door.
Table III-5--Max-Tech Levels for Refrigeration Systems
------------------------------------------------------------------------
Equations for minimum AWEF (Btu/W-
Equipment class h) *
------------------------------------------------------------------------
Dedicated Condensing, Medium 2.63 x 10-4 x Q + 4.53
Temperature, Indoor System, <
9,000 Btu/h Capacity.
Dedicated Condensing, Medium 6.90
Temperature, Indoor System, >=
9,000 Btu/h Capacity.
Dedicated Condensing, Medium 9.23 x 10-4 x Q + 3.90
Temperature, Outdoor System, <
9,000 Btu/h Capacity.
Dedicated Condensing, Medium 12.21
Temperature, Outdoor System, >=
9,000 Btu/h Capacity.
Dedicated Condensing, Low 1.93 x 10-4 x Q + 1.93
Temperature, Indoor System, <
9,000 Btu/h Capacity.
Dedicated Condensing, Low 3.67
Temperature, Indoor System, >=
9,000 Btu/h Capacity.
Dedicated Condensing, Low 4.53 x 10-4 x Q + 2.17
Temperature, Outdoor System, <
9,000 Btu/h Capacity.
Dedicated Condensing, Low 6.25
Temperature, Outdoor System, >=
9,000 Btu/h Capacity.
Multiplex Condensing, Medium 10.82
Temperature.
Multiplex Condensing, Low 5.91
Temperature.
------------------------------------------------------------------------
* Q represents the system gross capacity as calculated in AHRI 1250.
F. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the products that
are the subject of this rulemaking purchased in the 30-year period that
begins in the year of compliance with new standards (2017-2046). The
savings are measured over the entire lifetime of products purchased in
the 30-year period.\13\ DOE quantified the energy savings attributable
to each TSL as the difference in energy consumption between each
standards case and the base case. The base case represents a projection
of energy consumption in the absence of amended mandatory efficiency
standards and considers market forces and policies that affect demand
for more efficient products.
---------------------------------------------------------------------------
\13\ In the past DOE presented energy savings results for only
the 30-year period that begins in the year of compliance. In the
calculation of economic impacts, however, DOE considered operating
cost savings measured over the entire lifetime of products purchased
in the 30-year period. DOE has chosen to modify its presentation of
national energy savings to be consistent with the approach used for
its national economic analysis.
---------------------------------------------------------------------------
DOE used its national impact analysis (NIA) spreadsheet model to
estimate energy savings from amended standards for the products that
are the subject of this rulemaking. The NIA spreadsheet model
(described in section IV.G of this notice and chapter 10 of the TSD)
calculates energy savings in site energy, which is the energy directly
consumed by products at the locations where they are used. For
electricity, DOE reports national energy savings in terms of the
savings in the energy that is used to generate and transmit the site
electricity. To calculate this quantity, DOE derives annual conversion
factors from the model used to prepare the Energy Information
Administration's (EIA) Annual Energy Outlook (AEO).
DOE has begun to also estimate full-fuel-cycle (FFC) energy
savings. 76 FR 51282 (Aug. 18, 2011), as amended at 77 FR 49701 (August
17, 2012). The FFC metric includes the energy consumed in extracting,
processing, and transporting primary fuels (i.e., coal, natural gas,
petroleum fuels), and thus presents a more complete picture of the
impacts of energy efficiency standards. DOE's approach is based on
calculation of an FFC multiplier for each of the energy types used by
covered products. For more information on FFC energy savings, see
sections IV.G.3 and IV.L and appendix 10G of the TSD.
2. Significance of Savings
DOE may not adopt a standard that would not result in significant
additional energy savings. While the term ``significant'' is not
defined in the Act, the U.S. Circuit Court of Appeals for the District
of Columbia in Natural Resources Defense Council v. Herrington, 768
F.2d 1355, 1373 (DC Cir. 1985), indicated that Congress intended
significant energy savings to be savings that were not ``genuinely
trivial.'' The estimated energy savings in the analysis period for the
trial standard levels considered in this rulemaking range from 4.28 to
6.37 quadrillion Btu (quads), an amount DOE considers significant.
[[Page 55797]]
G. Economic Justification
1. Specific Criteria
As discussed in section II.A, EPCA provides seven factors to be
evaluated in determining whether a potential energy conservation
standard is economically justified. The following sections generally
discuss how DOE addresses each of those seven factors in this
rulemaking. For further details and the results of DOE's analyses
pertaining to economic justification, see sections IV and V of today's
notice.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of an amended standard on manufacturers,
DOE first uses an annual cash-flow approach to determine the
quantitative impacts. This step includes both a short-term assessment--
based on the cost and capital requirements during the period between
when a regulation is issued and when entities must comply with the
regulation--and a long-term assessment over a 30-year period. The
industry-wide impacts analyzed include industry net present value
(INPV), which values the industry on the basis of expected future cash
flows; cash flows by year; changes in revenue and income; and other
measures of impact, as appropriate. Second, DOE analyzes and reports
the impacts on different types of manufacturers, including impacts on
small manufacturers. Third, DOE considers the impact of standards on
domestic manufacturer employment and manufacturing capacity, as well as
the potential for standards to result in plant closures and loss of
capital investment. Finally, DOE takes into account cumulative impacts
of various DOE regulations and other regulatory requirements on
manufacturers.
For individual consumers, measures of economic impact include the
changes in LCC and the PBP associated with new or amended standards.
The LCC, which is also separately specified as one of the seven factors
to be considered in determining the economic justification for a new or
amended standard, is discussed in the following section. For consumers
in the aggregate, DOE also calculates the net present value from a
national perspective of the economic impacts on consumers over the
forecast period used in a particular rulemaking. For the results of
DOE's analyses related to the economic impact on consumers, see section
V.B.1 of this notice and chapters 8 and 11 of the TSD. For the results
of DOE's analyses related to the economic impact on manufacturers, see
section V.B.2 of this notice and chapter 12 of the TSD.
b. Life-Cycle Costs
The LCC is the sum of the purchase price of equipment (including
the cost of its installation) and the operating expense (including
energy and maintenance and repair expenditures) discounted over the
lifetime of the equipment. The LCC savings for the considered
efficiency levels are calculated relative to a base case that reflects
likely trends in the absence of new standards. The LCC analysis
requires a variety of inputs, such as equipment prices, equipment
energy consumption, energy prices, maintenance and repair costs,
equipment lifetime, and consumer discount rates. DOE assumes in its
analysis that consumers purchase the equipment in the year in which
compliance with the new standard is required.
To account for uncertainty and variability in specific inputs, such
as equipment lifetime and discount rate, DOE uses a distribution of
values with probabilities attached to each value. A distinct advantage
of this approach is that DOE can identify the percentage of consumers
estimated to receive LCC savings or experience an LCC increase. In
addition to identifying ranges of impacts, DOE evaluates the LCC
impacts of potential standards on identifiable subgroups of consumers
that may be disproportionately affected by a new national standard. For
the results of DOE's analyses related to the life-cycle costs of
equipment, see section V.B.1.a of this notice and chapter 8 of the TSD.
c. Energy Savings
While significant conservation of energy is a separate statutory
requirement for imposing an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. DOE uses the NIA spreadsheet results in its
consideration of total projected savings. For the results of DOE's
analyses related to the potential energy savings, see section V.B.3.a
of this notice and chapter 10 of the TSD.
d. Lessening of Utility or Performance of Products
In establishing classes of equipment, and in evaluating design
options and the impact of potential standard levels, DOE seeks to
develop standards that would not lessen the utility or performance of
the equipment under consideration. None of the TSLs presented in
today's NOPR would reduce the utility or performance of the equipment
considered in the rulemaking. During the screening analysis, DOE
eliminated from consideration any technology that would adversely
impact consumer utility. For the results of DOE's analyses related to
the potential impact of new standards on equipment utility and
performance, see section IV.B of this notice and chapter 4 of the TSD.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from the imposition of a standard. It also directs the
Attorney General to determine the impact, if any, of any lessening of
competition likely to result from a proposed standard and to transmit
such determination to the Secretary within 60 days of the publication
of a proposed rule, together with an analysis of the nature and extent
of the impact. DOE will transmit a copy of today's proposed rule to the
Attorney General with a request that the Department of Justice (DOJ)
provide its determination on this issue. DOE will address the Attorney
General's determination in the final rule.
f. Need of the Nation To Conserve Energy
The energy savings from the proposed standards are likely to
provide improvements to the security and reliability of the nation's
energy system. Reductions in the demand for electricity also may result
in reduced costs for maintaining the reliability of the nation's
electricity system. DOE conducts a utility impact analysis to estimate
how standards may affect the nation's needed power generation capacity.
The utility impact analysis is contained in chapter 14 of the TSD.
The proposed standards also are likely to result in environmental
benefits in the form of reduced emissions of air pollutants and
greenhouse gases associated with energy production. DOE reports the
emissions impacts from today's standards, and from each TSL it
considered, in section V.B.6 of this notice and chapter 15 of the TSD.
DOE also reports estimates of the economic value of emissions
reductions resulting from the considered TSLs.
g. Other Factors
EPCA allows the Secretary, in determining whether a standard is
economically justified, to consider any other factors that the
Secretary deems to be relevant. For the results of DOE's
[[Page 55798]]
analyses related to other factors, see section V.B.7 of this notice.
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA provides for a
rebuttable presumption that an energy conservation standard is
economically justified if the additional cost to the consumer of
equipment that meets the standard level is less than three times the
value of the first-year energy (and, as applicable, water) savings
resulting from the standard, as calculated under the applicable DOE
test procedure. DOE's LCC and PBP analyses generate values which can be
used to calculate the payback period for consumers of products or
equipment that meet the proposed standards. These analyses include, but
are not limited to, the three-year payback period contemplated under
the rebuttable presumption test. However, DOE routinely conducts a full
economic analysis that considers the full range of impacts to the
consumer, manufacturer, nation, and environment, as required under 42
U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the
basis for DOE to evaluate the economic justification for a potential
standard level (thereby supporting or rebutting the results of any
preliminary determination of economic justification). The rebuttable
presumption payback calculation is discussed in section IV.F.12 of this
NOPR and chapter 8 of the TSD.
IV. Methodology and Discussion
A. Market and Technology Assessment
When beginning an energy conservation standards rulemaking, DOE
develops information that provides an overall picture of the market for
the products concerned, including the purpose of the products, the
industry structure, and market characteristics. This activity includes
both quantitative and qualitative assessments based primarily on
publicly-available information (e.g., manufacturer specification sheets
and industry publications) and data submitted by manufacturers, trade
associations, and other stakeholders. The subjects addressed in the
market and technology assessment for this rulemaking include: (1)
Quantities and types of products sold and offered for sale; (2) retail
market trends; (3) products covered by the rulemaking; (4) equipment
classes; (5) manufacturers; (6) regulatory requirements and non-
regulatory programs (such as rebate programs and tax credits); and (7)
technologies that could improve the energy efficiency of the products
under examination. DOE researched manufacturers of panels, display
doors, non-display doors, and refrigeration equipment. DOE also
identified and characterized small business manufacturers of these
components. See chapter 3 of the TSD for further discussion of the
market and technology assessment.
In the preliminary TSD, DOE presented market performance data.
Typically, DOE's analysis of market data uses catalog and performance
data to determine the number of products on the market at varying
efficiency levels. However, WICF systems and equipment have not
previously been rated for efficiency by manufacturers, nor has an
efficiency metric been established for this equipment. Based on the
available data, DOE presented a sample of equipment at various sizes in
the preliminary TSD and estimated the energy consumption of the
equipment using the preliminary engineering spreadsheet. For
refrigeration equipment in particular, DOE found that, as expected, the
relationship between capacity and energy consumption was roughly
linear.
In a comment on the market performance data DOE presented,
Manitowoc expressed concern that DOE's use of linear trends to
establish the relationship between energy consumption and net capacity
will lead to an overestimation of the potential benefits of
refrigeration system standards. (Manitowoc, No. 0056.1 at p. 2)
DOE presented the market performance data to illustrate its
understanding of the market. In response to Manitowoc's concern, DOE
notes that the benefits of the rule are not derived from the estimates
of market performance data but are determined from the LCC analysis and
NIA. DOE seeks market performance data to help inform DOE's analysis.
1. Definitions Related to Walk-In Coolers and Freezers
DOE proposes to amend the definition of display door and to adopt
definitions for passage and freight door in order to clarify the
boundaries separating these equipment classes. The display door
definition was modified to permit transparent doors used for the
passage of people to be categorized as display doors rather than as
non-display passage doors. DOE is proposing to define transparent
passage doors as a type of display door because transparent passage
doors are generally constructed in the same manner and with the same
materials as transparent reach-in doors. DOE proposes to include
definitions for non-display passage and freight doors in order to
clarify the distinction between the two types of doors. Non-display
passage doors are typically smaller than freight doors and are designed
for passage of people and small machines, whereas non-display freight
doors are larger than passage doors and designed for the passage of
large machines like forklifts.
a. Display Doors
As described in section III.B of this notice, DOE established a
definition for display door in the test procedure. 76 FR 33631 (June 9,
2011). DOE is now proposing to amend this definition to include all
doors that are comprised of 75 percent or more glass or other
transparent material. This amendment is intended to classify passage
doors that are mostly comprised of glass as display doors because the
utility and construction of glass passage doors more closely resembles
that of a display door. DOE proposes to define a display door as one
that ``(1) is designed for product display; or (2) has 75 percent or
more of its surface area comprised of glass or another transparent
material.'' DOE requests comment on this proposed definition.
b. Freight Doors
DOE is proposing to separate non-display doors into two equipment
classes, passage doors and freight doors. DOE proposes to define
freight doors in order to clarify the distinction between these two
equipment classes and remove any ambiguity about which energy standards
apply to a given door. The two types of doors are constructed
differently--for example, freight doors tend to have more structural
support because they are bulkier--and warrant different standards for
each type. DOE is proposing a definition of freight doors that would
account for the fact that these doors are typically larger than passage
doors and are used to allow large machines, like forklifts, into walk-
ins. Specifically, DOE proposes to define a freight door to mean ``a
door that is not a display door and is equal to or larger than 4 feet
wide and 8 feet tall.'' DOE based these proposed dimensions on the
standard size of a walk-in panel, which is 4 feet wide by 8 feet tall.
In DOE's estimation doors used for the passage of people small machines
would be less than the standard size of a walk-in panel and therefore
all other doors would be freight doors. DOE requests comment on its
proposed definition.
c. Passage Doors
DOE proposes a definition of passage doors to differentiate passage
doors from
[[Page 55799]]
freight doors and display doors. Passage doors are mostly intended for
the passage of people and small machines like hand carts and not for
product display. DOE proposes to define this term to mean ``a door that
is not a freight or display door.'' DOE requests comment on this
proposed definition.
2. Equipment Included in This Rulemaking
a. Panels and Doors
As mentioned in section III.B.1, DOE identified three types of
panels used in the walk-in industry: Display panels, floor panels, and
non-floor panels. Based on its research, DOE determined that display
panels, typically found in beer caves (walk-ins used for the display
and storage of beer or other alcoholic beverages often found in a
supermarket) make up a small percentage of all panels currently present
in the market. Therefore, because of the extremely limited energy
savings potential currently projected to result from amending the
requirements that these panels must meet, DOE is not proposing
standards for walk-in display panels in this NOPR. Display panels,
however, must still follow all applicable design standards already
prescribed by EPCA, as discussed in section II.B.1 of this notice.
DOE is also not proposing to require the installation of walk-in
cooler floor panels. DOE did not consider including walk-in cooler
floor panels in its analysis because of their complex nature. Through
manufacturer interviews and market research, DOE determined that,
unlike walk-in freezers, the majority of walk-in coolers are made with
concrete floors and do not use insulated floor panels. The entity that
installs the cooler floor is considered the floor's manufacturer and is
responsible for testing and complying with a walk-in cooler floor
standard. If DOE were to require that all walk-in coolers to be
equipped with floor panels, the onus of complying with this requirement
would likely fall on entities that do not specialize in constructing
walk-in coolers, and the accompanying burden in using these components
and certifying compliance with the appropriate standards would likely
be costly and difficult for that entity to fulfill. Therefore, at this
time, it is DOE's view that requiring the use of floor panels--along
with the accompanying compliance costs--would present an undue burden
to those entities that would be responsible for meeting these
requirements. For these reasons, DOE is not proposing to require walk-
in coolers to have floor panels, nor is DOE proposing energy efficiency
standards for cooler floor panels. (DOE is, however, proposing energy
efficiency standards for walk-in freezer floor panels and notes that
EPCA requires floor insulation of at least R-28 for walk-in freezers.
(42 U.S.C. 6313(f)(1)(D)).)
DOE also identified two types of doors in the walk-in market,
display doors and non-display doors, which are discussed in section
III.B.2 of this NOPR. All types of doors will be subject to the
performance standards proposed in this rulemaking.
b. Refrigeration System
DOE defines the refrigeration system of a walk-in as the mechanism
(including all controls and other components integral to the system's
operations) used to create the refrigerated environment in the interior
of the walk-in cooler and freezer, consisting of either (1) a packaged
system where the unit cooler and condensing unit are integrated into a
single piece of equipment, (2) a split system with separate unit cooler
and condensing unit sections, or (3) a unit cooler that is connected to
a multiplex condensing system. 76 FR at 33631.
DOE based its preliminary results used in today's proposal on an
analysis of storage coolers and freezers. DOE did not analyze blast
freezer walk-ins, which are designed to quickly freeze food and then
store it at a specified holding temperature. American Panel commented
that blast freezer performance differs from storage freezer performance
due to the large product loads experienced with this specialized
equipment. (American Panel, No. 0048.1 at p. 4) Heatcraft added that
blast freezer refrigeration systems' energy consumption would be higher
than that of storage freezers and that they require wider fin spacing
because of a higher rate of frost accumulation. (Heatcraft, No. 0058.1
at p. 1)
DOE agrees with American Panel and Heatcraft that blast freezer
refrigeration systems have different energy characteristics from
storage freezers, but questions whether they would necessarily have a
lower rated efficiency. DOE is not proposing to include blast freezers
in this rulemaking analysis because they make up a small percentage of
walk-ins currently present in the market. DOE requests comment on
whether blast freezer refrigeration systems would have difficulty
complying with DOE's refrigeration efficiency standards and, if so, to
direct DOE to (and supply it with) any test procedure data supporting
this conclusion. DOE proposes to apply the same standards to blast
freezer refrigeration systems as to storage freezer refrigeration
systems, unless DOE finds that blast freezer refrigeration systems
would have difficulty complying with DOE's standards. Otherwise, DOE
will consider excluding blast freezers from coverage under this
rulemaking, although they would still have to comply with the already
statutorily-prescribed standards in EPCA.
Regarding the particular refrigerant to be used in the analysis,
DOE analyzed refrigeration equipment using R404A, a hydrofluorocarbon
(HFC) refrigerant blend, in the preliminary analysis. Heatcraft
supported DOE's approach to use only HFC refrigerants in the analysis,
but also suggested that DOE consider lower global warming potential
(GWP) refrigerants--such as R134a, R407A, or R407C--in the analyses as
well because of shifts in the marketplace towards these products, even
though these refrigerants may have lower efficiencies. (Heatcraft, No.
0069.1 at p. 3)
DOE used R404A in its analysis for this NOPR because it is widely
used currently in the walk-in industry. DOE appreciates Heatcraft's
suggestion to analyze alternative refrigerants, especially those with a
lower GWPs given the interest by many manufacturers to use these
alternatives, and requests comment on the extent of the use or likely
phase-in of lower GWP refrigerants and asks manufacturers to submit
data related to the ability of the equipment (either existing or
redesigned) using these refrigerants to meet the proposed standard, as
well as the cost of such equipment.
3. Equipment Classes
a. Panels and Doors
In the preliminary analysis, DOE proposed to divide the envelope
into two separate equipment classes: display and non-display walk-ins
(that is, walk-ins with and without glass). Display walk-ins are walk-
ins that have doors for display purposes, are typically made with
glass, and are inherently less efficient than walk-ins without glass
because glass is not as insulative as the insulation material used in
non-display walk-ins (typically polyurethane or polystyrene).
Interested parties commented on the need to separate display and
non-display walk-ins into two different equipment classes. Nor-Lake and
AHRI agreed with the equipment classes proposed by DOE, and AHRI
commented that the equipment classes represent the most common walk-in
[[Page 55800]]
configurations. (Nor-Lake, No. 0049.1 at p. 1; AHRI, No. 0055.1 at p.
2) Manitowoc stated that classification of envelopes into storage and
display types is appropriate as it may allow for different performance
levels for certain components. (Manitowoc, No. 0056.1 at p. 2) However,
CrownTonka contended that it was unnecessary to have two equipment
classes for display and non-display walk-ins and that separate classes
for coolers and freezers are adequate. (CrownTonka, No. 0057.1 at p. 1)
ASAP and SCE opined that one equipment class is sufficient and that the
difference between non-display and display doors could be accounted for
through a weighted average of the opaque and glass surface areas.
(ASAP, Public Meeting Transcript, No. 0045 at p. 70; SCE, Public
Meeting Transcript, No. 0045 at p. 79) However, NEAA, NPCC and
Manitowoc countered that there should not be a single metric for both
display and non-display doors because it would not account for the
unique utility offered by display walk-ins (i.e., permitting the
display of stored items). (NEAA and NPCC, Public Meeting Transcript,
No. 0045 at p. 76; Manitowoc, Public Meeting Transcript, No. 0045 at p.
78) NEAA and NPCC stated that, if DOE were to separate display and non-
display walk-ins into two different classes, DOE should carefully
define the boundary between the two classes. (NEAA and NPCC, Public
Meeting Transcript, No. 0045 at p. 77) NEAA and NPCC also suggested
that, as an alternative to having one equipment class for display and
non-display walk-ins with a single performance metric, DOE should move
to component level-based classes with separate performance metrics.
(NEAA and NPCC, Public Meeting Transcript, No. 0045 at p. 76)
Interested parties also submitted comments about the names of the
equipment classes. NEAA and NPCC stated that if DOE has two separate
equipment classes for display and non-display walk-ins, DOE should
carefully define the boundary between the two classes. (NEAA and NPCC,
Public Meeting Transcript, No. 0045 at p. 77) Kysor stated that the
class names DOE suggested were confusing and offered an alternative--
``coolers with glass doors'' instead of ``display coolers''--to help
clarify the difference between the two separate equipment classes.
(Kysor, Public Meeting Transcript, No. 0045 at p. 78)
In light of the component level standards described in section
III.A, DOE proposes to create separate equipment classes for panels,
display doors, and non-display doors. These different items comprise
the main components of a walk-in envelope. DOE proposes separate
classes for panels, display doors, and non-display doors because each
component type has a different utility to the consumer and possesses
different energy use characteristics.
In the preliminary analysis, DOE also considered the possibility of
creating separate classes for walk-in coolers and walk-in freezers
because EPCA specifically divides walk-in equipment into coolers (above
32[emsp14][deg]F) and freezers (at or below 32[emsp14][deg]F), (42
U.S.C. 6311(20)), and prescribes unique design requirements for each.
(42 U.S.C. 6313(f)(1)(C)-(D)(3)) DOE has continued to apply this
approach in its analysis.
Panels
DOE has placed panels into two equipment classes: Freezer floor
panels and non-floor panels (also called structural panels). DOE
understands that freezer floor panels and structural panels serve two
different utilities. Freezer floor panels, which are panels used to
construct the floor of a walk-in, must often support the load of small
machines like hand carts and pallet jacks on their horizontal faces.
Non-floor panels or structural panels, which include panels used to
construct the ceiling or wall of a walk-in, provide structure for the
walk-in. Because of their different utilities, the two classes of
panels are constructed differently from each other and use different
amounts of framing material, which affects the panels' energy
consumption.
Structural panels are further divided into two more classes based
on temperature--i.e., cooler versus freezer panels. Cooler structural
panels are rated with their internal faces exposed to a temperature of
35 [deg]F, as called for in the test procedure final rule. Freezer
structural panels are used in walk-in freezers and rated with its
internal face exposed to a temperature of -10 [deg]F, as required by
the test procedure final rule. 76 FR at 21606; 10 CFR 431.303. EPCA
also requires walk-in freezer panels to have a higher R-value than
walk-in cooler panels. These differences result in different amounts of
insulating foam between these panel types and affect the panel's U-
value.
Doors
DOE has distinguished between two different door types used in
walk-in coolers and freezers: Display doors and non-display doors. DOE
proposed separate classes for display doors and non-display doors to
retain consistency with the dual approach laid out by EPCA for these
walk-in components. (42 U.S.C. 6313(f)(1)(C) and (3)) Non-display doors
and display doors also serve separate purposes in a walk-in. Display
doors contain mainly glass in order to display products or objects
located inside the walk-in. Non-display doors function as passage and
freight doors and are mainly used to allow people and products to be
moved into and out of the walk-in. Because of their different
utilities, display and non-display doors are made up of different
material. Display doors are made of glass or other transparent
material, while non-display doors are made of highly insulative
materials like polyurethane. The different materials found in display
and non-display doors significantly affect their energy consumption.
DOE divided display doors into two equipment classes based on
temperature differences: cooler and freezer display doors. Cooler
display doors and freezer display doors are exposed to different
internal temperature conditions, which affect the total energy
consumption of the doors. In the test procedure final rule, DOE
established an internal rating temperature of 35 [deg]F for walk-in
cooler display doors and -10 [deg]F for walk-in freezer display doors.
76 FR at 21606; 10 CFR Part 431, Subpart R, Appendix A, Section 5.3.
DOE also separated non-display doors into two equipment classes,
passage and freight doors. Passage doors are typically smaller doors
and mostly used as a means of access for people and small machines,
like hand carts. Freight doors typically are larger doors used to allow
access for larger machines, like forklifts, into walk-ins. The
different shape and size of passage and freight doors affects the
energy consumption of the doors. Both passage and freight doors are
also separated into cooler and freezer classes because, as explained
for display doors, cooler and freezer doors are rated at different
temperature conditions. A different rating temperature impacts the
door's energy consumption.
In the preliminary analysis, DOE did not consider outdoor envelopes
as a separate equipment class. Walk-ins located outdoors have very
similar features to walk-ins located indoors, and DOE could not
identify any additional design options that improved the energy
consumption only of outdoor walk-ins. The Joint Utilities, NEEA and
NPCC, CrownTonka, Nor-Lake, and Hill Phoenix stated that DOE should
differentiate equipment classes by their external environment. (Joint
Utilities, No. 0061.1 at p. 5; NEEA and NPCC, No. 0059.1 at p. 6;
CrownTonka, Public Meeting Transcript, No. 0045 at p. 81;
[[Page 55801]]
Nor-Lake, No. 0049.1 at p. 2; Hill Phoenix, No. 0066.1 at p. 2) The
Joint Utilities requested that DOE evaluate cost-effective insulation
levels for outdoor walk-ins, and stated that there would be a loss in
energy savings if DOE did not consider region-specific insulation
levels. (Joint Utilities, Public Meeting Transcript, No. 0045 at pp. 80
and 82) Nor-Lake contested DOE's claim that walk-ins designed as
outdoor units include no additional features that impact energy
consumption, stating that the ambient temperature and product load will
change the energy consumption for both the indoor and outdoor units.
(Nor-Lake, No. 0049.1 at p.2) Hill Phoenix recommended a separate
equipment class for outdoor walk-ins because outdoor walk-ins must have
thicker panels to withstand environmental conditions. (Hill Phoenix,
No. 0066.1 at p. 2) American Panel observed that a walk-in located
outdoors has an added benefit in that no building space was constructed
to house the walk-in, which is a significant energy savings not
considered in the preliminary analysis. (American Panel, No. 0048.1 at
p. 3)
Some commenters described how DOE could include equipment classes
that capture the external conditions. SCE suggested that DOE set a
series of different conditions by the location of the wall such as an
outdoor, indoor, or demising wall (i.e., a dividing wall to separate
spaces) between a cooler and a freezer space. (SCE, Public Meeting
Transcript, No. 0045 at pp. 80 and 82-83) NEEA and NPCC recommended
changing the equipment classes to indoor cooler, indoor freezer,
outdoor cooler, and outdoor freezer. (NEEA and NPCC, No. 0059.1 at p.
6)
Other interested parties agreed with DOE's assertion that it was
unnecessary to consider outdoor walk-ins as a separate equipment class.
Kysor explained that the envelope would be designed for whatever
ambient conditions it may be subjected to, and that adding additional
performance requirements would be unnecessary. (Kysor, Public Meeting
Transcript, No. 0045 at p. 80) Manitowoc stated that there should not
be any classification based on external environments as there are times
when the envelope is exposed to both internal and external conditions.
(Manitowoc, Public Meeting Transcript, No. 0045 at p. 82)
DOE is not proposing to include any panel or door equipment class
that accounts for the different external environmental conditions that
a walk-in could experience in real world applications. DOE does not
find outdoor and indoor walk-in envelope components to have distinct
utilities. Components for outdoor walk-ins and indoor walk-ins are
generally constructed with the same design and materials and serve the
same purpose. In response to Nor-Lake's comment about DOE's assumption
about additional features, DOE clarifies that while the difference in
outdoor temperatures affects the real world energy consumption of the
walk-in envelope, DOE was referring to design features, such as
different types of insulation, which differ from the design options
found on indoor walk-ins and improve the energy efficiency of the
outdoor walk-in. As to Hill Phoenix's comment that a panel facing
external conditions requires more insulation, DOE notes that panels
with thicker insulation already surpass the baseline panel
specifications, which would make it easier for these types of panels to
meet the standards in today's proposal.
Hill Phoenix also recommended that DOE divide envelopes into
factory assembled step-in style walk-ins and larger construction-based
walk-ins. (Hill Phoenix, No. 0066.1 at p. 1) Because it is not
proposing standards for walk-in envelopes, but rather for the panels
and doors that are components of the envelopes, DOE has not adopted
Hill Phoenix's recommendation in today's proposal. DOE has, however,
separated into different equipment classes the components typically
found in factory-assembled walk-ins, such as passage doors and floor
panels, and those components found in large construction-based walk-
ins, such as freight doors. DOE believes this approach will achieve the
objective of the Hill Phoenix recommendation, namely that the proposed
standards reflect the different energy use characteristics of factory-
assembled and construction-based walk-ins.
Table IV-1 lists the equipment classes DOE proposes to create in
this NOPR. In the table below, medium temperature refers to cooler
equipment and low temperature refers to freezer equipment. The column
entitled ``Class'' lists the codes that will be used to abbreviate each
equipment class, and will be used throughout the NOPR.
Table IV-1--Equipment Classes for Panels and Doors
------------------------------------------------------------------------
Product Temperature Class
------------------------------------------------------------------------
Structural Panel................ Medium............ SP.M
Low............... SP.L
Floor Panel..................... Low............... FP.L
Display Door.................... Medium............ DD.M
Low............... DD.L
Passage Door.................... Medium............ PD.M
Low............... PD.L
Freight Door.................... Medium............ FD.M
Low............... FD.L
------------------------------------------------------------------------
b. Refrigeration Systems
In the preliminary analysis, DOE considered dividing walk-in
refrigeration systems into six equipment classes based on key physical
characteristics that affect equipment efficiency: (1) The type of
condensing unit (i.e., whether the system has a dedicated condensing
unit or is connected to a multiplex system), (2) the operating
temperature, and (3) the location of the walk-in (i.e., indoors or
outdoors). In this NOPR, DOE also proposes to differentiate
refrigeration system classes based on capacity. DOE discusses the four
proposed class differentiations below.
Type of Condensing Unit
Due to the significant impact of the condensing unit on the overall
energy consumption of the walk-in (as much as 90 percent), the
preliminary analysis differentiated between two different condensing
unit types: dedicated condensing systems and multiplex condensing
systems. In a dedicated condensing system, only one condensing unit
(consisting of one or more compressors and condensers) serves a single
walk-in. A multiplex condensing system consists of a rack of
compressors usually located in a mechanical room, a large condenser or
condensers usually located on the roof, and several unit coolers or
evaporators belonging to various types of refrigeration equipment,
including walk-ins. The only part of a multiplex condensing system that
would be covered under the proposed standard would be a unit cooler in
a walk-in--a ``unit cooler connected to a multiplex condensing
system.'' The compressor and condenser of a multiplex system would not
be covered under the walk-in standard because they serve equipment
other than walk-ins. Furthermore, DOE would be unable to attribute the
portion of energy use related to only the walk-in, at the point of
manufacture of the compressor and condenser of the multiplex system.
DOE received several comments about the classification of
condensing types. AHRI, Nor-Lake and Manitowoc agreed with DOE's
equipment classes proposed in the preliminary analysis, while the Joint
Utilities suggested redesignating
[[Page 55802]]
the multiplex and dedicated equipment classes as remote and self-
contained, respectively. (AHRI, Public Meeting Transcript, No. 0045 at
p. 74, Nor-Lake, No. 0049.1 at p. 1, Manitowoc, No. 0056 at p. 2,
Manitowoc, Public Meeting Transcript, No. 0045 at p. 73, Joint
Utilities, Public Meeting Transcript, No. 0045 at p. 71) The Joint
Utilities suggested regulating condensing units in a manner similar to
that used by DOE for commercial refrigeration equipment, which, in
their view, would result in coverage of most of the condensing units
serving the walk-in industry. (Joint Utilities, No. 0061.1 at p. 11,
12) The Joint Advocates suggested that DOE conduct a separate
rulemaking for condensing units. (Joint Advocates, No. 0070.1 at p. 3)
They added that DOE should reduce the number of refrigeration types to
self-contained and unit coolers only, while the Joint Utilities
recommended against including remote condensing units as part of this
rulemaking. (Joint Advocates, No. 0070.1 at p. 3, Joint Utilities, No.
0045 at p. 22)
DOE believes the refrigeration systems covered by the two classes
of equipment, dedicated condensing and multiplex condensing, accurately
represent the range of refrigeration equipment used in walk-in coolers
and freezers. Although the proposed classes differ from the classes
designated in the commercial refrigeration equipment rulemaking, there
are key differences between commercial refrigeration equipment
refrigeration systems and walk-in refrigeration systems. The Joint
Advocates and Joint Utilities refer to two types of refrigeration
systems commonly used with commercial refrigeration equipment: ``self-
contained'' (meaning the entire refrigeration system is built into the
case) and ``remote condensing'' (meaning the unit cooler is built into
the case, but the whole case is connected to a central system of
compressors and condensers, called a ``rack'' or ``multiplex condensing
system'', connected to most or all of the refrigeration units in a
building). ``Remote condensing'', however, can also refer to a
configuration in which the unit cooler is connected to a dedicated
(i.e., only serving that one unit) compressor and condenser that are
located somewhere away from the unit cooler. This configuration is rare
for commercial refrigeration equipment, but comprises a large
proportion of walk-in refrigeration system applications.
To avoid confusion over the different configurations for walk-ins
and commercial refrigeration equipment that can be classified as
``remote condensing'', DOE is not proposing to classify walk-in
refrigeration systems as ``remote condensing'' and ``self-contained''.
Also, DOE does not agree that the compressor and condenser parts should
not be covered under the walk-in coolers and freezers rulemaking.
Instead, DOE is proposing to include dedicated condensing units in the
rule, even if remotely located, because these units could be viewed as
part of the walk-in as long as they are connected only to that
particular walk-in and not to other refrigeration equipment. For
systems where the walk-in is connected to a multiplex condensing system
that runs multiple pieces of equipment, the compressor and condenser
would not be covered because they are not exclusively part of the walk-
in.
In consideration of the above, DOE proposes to create two classes
of refrigeration systems: dedicated condensing and multiplex
condensing. DOE believes that dedicated remote condensing units
represent a substantial opportunity for energy savings in a regulation
for walk-in components because the configuration of a dedicated remote
condensing unit is widespread in several market segments, such as
restaurants. Manufacturers can optimize the dedicated remote condensing
unit with the unit cooler to take advantage of certain conditions, such
as low ambient outdoor temperatures.
DOE does not propose to create separate classes for dedicated
packaged systems (where the unit cooler and condensing unit are
integrated into a single piece of equipment) and dedicated split
systems (with separate unit cooler and condensing unit sections).
Packaged systems are potentially more efficient than split systems
because they do not experience as much energy loss in the refrigerant
lines. However, because packaged systems comprise a small share of the
refrigeration market, DOE currently believes that little additional
energy savings could be achieved by considering them as a separate
class. Accordingly, DOE is not proposing to consider the creation of a
separate packaged systems class.
DOE also notes that its proposed standards for dedicated condensing
systems are based on an analysis of split systems. DOE requests comment
on its proposal not to consider dedicated packaged systems and
dedicated split systems as separate classes and whether this proposal
would unfairly disadvantage any manufacturers.
Operating Temperature
The second physical characteristic that DOE proposes as a basis for
dividing refrigeration systems into equipment classes is the operating
temperature. EPCA divides walk-in equipment into coolers (above
32[emsp14][deg]F) and freezers (at or below 32[emsp14][deg]F) (42
U.S.C. 6311(20)) Using this distinction, DOE is proposing to categorize
refrigeration systems as low or medium temperature systems based on the
temperature profiles of their unit coolers. The medium (M) and low (L)
temperature units are differentiated by their operating temperatures,
which are greater than 32[emsp14][deg]F (for coolers) and less than or
equal to 32[emsp14][deg]F (for freezers). In response to DOE's
discussion of these classes in the preliminary analysis, Ingersoll Rand
suggested that any walk-in with defrost be rated as a freezer
regardless of the operating temperature. (Ingersoll Rand, No. 0053.1 at
p. 1) DOE has not adopted these suggestions because doing so would
conflict with the statutory distinction created by Congress that relies
on operating temperature to distinguish between walk-in coolers and
freezers. See 42 U.S.C. 6311(2) (treating walk-ins as separate
equipment based on whether they are coolers or freezers).
Furthermore, applying the rating conditions for low temperature
refrigeration systems is unlikely to enable a tester to accurately
measure the efficiency of a medium temperature refrigeration system.
Requiring a refrigeration system with defrost to be rated at the low
temperature rating conditions even if it is designed to operate closer
to the medium temperature rating conditions could lead to inaccurate
equipment ratings for such equipment. In certain cases, applying
temperature ratings in this manner may not permit this type of
equipment to be rated at low temperature rating conditions if it is not
designed to operate at those conditions.\14\
---------------------------------------------------------------------------
\14\ For example, most medium temperature unit coolers are
designed to operate between 15[emsp14][deg]F and 45[emsp14][deg]F,
and would not be able to operate at the low temperature rating
condition of -10[emsp14][deg]F.
---------------------------------------------------------------------------
Location of the Walk-In
The third physical characteristic DOE considered is the location of
the condensing unit (i.e., indoor or outdoor), which also affects the
energy consumption of dedicated condensing systems. Indoor
refrigeration systems generally operate at fixed ambient temperatures,
while outdoor refrigeration systems experience varying temperatures
through the year. This change in temperature affects the performance of
the refrigeration system by requiring it to operate more during
[[Page 55803]]
warmer conditions and less during colder ones. Accordingly, the test
procedure has one ambient rating condition for indoor systems and three
ambient rating temperatures for outdoor systems.
In the preliminary analysis, DOE considered creating separate
classes for refrigeration systems with indoor (I) and outdoor (O)
condensing units because of their different energy consumption
characteristics. Outdoor condensing units can also implement a wide
variety of design options to run more efficiently at low ambient
temperatures. (In contrast, DOE did not consider indoor and outdoor
envelope components as belonging to separate classes partly because of
the absence of available options for improving efficiency based on the
ambient temperature. See section IV.A.3.a for details.) Following the
preliminary analysis, DOE did not receive any comments regarding the
indoor and outdoor condensing unit classes, and therefore proposes the
same differentiation in this NOPR.
Refrigeration Equipment Size
In the preliminary analysis, DOE did not consider different
equipment classes based on refrigeration equipment size. Heatcraft
suggested adding sub-categories to the proposed equipment classes,
stating that the size of refrigeration systems varies with envelope
size. (Heatcraft, No. 0069.1 at p. 1) Manitowoc commented that small
sized equipment would struggle to meet minimum standards if DOE based
the metric on a larger size, largely due to the efficiency difference
of each system size. (Manitowoc, Public Meeting Transcript, No. 0044 at
p. 118)
DOE is not proposing to base refrigeration system classes on
envelope size because it is taking a component-level approach that sets
standards for the refrigeration system independent of the envelope. In
reaching this tentative decision, DOE examined the ability of various
sized equipment to meet a proposed standard. For the NOPR analysis, DOE
analyzed a wider range of equipment sizes than it did for the
preliminary analysis, as described later in section IV.C.1.b. As a
result of this expanded analysis, DOE observed that small sized
equipment may have difficulty meeting an efficiency standard that is
based on an analysis of large equipment, as Manitowoc noted. DOE found
that this result was primarily due to a lack of availability of the
more efficient compressor types (e.g., scroll compressors) at lower
capacities. Additionally, certain design options, mainly controls,
generally have a fixed cost, but their benefit decreases with lower
capacities, so they are less cost-effective for lower-capacity
equipment. Therefore, DOE proposes one equipment class for high-
capacity equipment and another for low-capacity equipment within the
dedicated condensing category (because the compressor is covered only
for DC systems). DOE has tentatively chosen 9,000 Btu/h as the capacity
threshold for small- and large-capacity equipment based on the
efficiency characteristics of available compressors, among other
factors. See chapter 3 for details. DOE requests comment on the
capacity threshold between the two capacity classes for dedicated
condensing systems.
Proposed Classes
Using the proposed combinations of condensing unit types, operating
temperatures, location, and size, ten equipment classes are possible
for walk-in cooler or freezer refrigeration systems. DOE believes that
these ten classes accurately represent the refrigeration units used in
the walk-in market today.
Table IV-2 lists the equipment classes for refrigeration equipment
that DOE is proposing in this NOPR. The column entitled ``Class'' lists
the codes that will be used to abbreviate each equipment class, and
will be used throughout the NOPR.
Table IV-2--Equipment Classes for Refrigeration Equipment
----------------------------------------------------------------------------------------------------------------
Operating Condenser Refrigeration
Condensing type temperature location capacity (Btu/h) Class
----------------------------------------------------------------------------------------------------------------
Dedicated..................... Medium........... Indoor........... < 9,000 DC.M.I, < 9,000
>= 9,000 DC.M.I, >= 9,000
Outdoor.......... < 9,000 DC.M.O, < 9,000
>= 9,000 DC.M.O, >= 9,000
Low.............. Indoor........... < 9,000 DC.L.I, < 9,000
>= 9,000 DC.L.I, >= 9,000
Outdoor.......... < 9,000 DC.L.O, < 9,000
>= 9,000 DC.L.O, >= 9,000
Multiplex..................... Medium........... ................. ................. MC.M
Low.............. ................. ................. MC.L
----------------------------------------------------------------------------------------------------------------
4. Technology Assessment
In a technology assessment, DOE identifies technologies and designs
that could be used to improve the energy efficiency or performance of
covered equipment. For the preliminary analysis, DOE conducted a
technology assessment to identify all technologies and designs that
could be used to improve the energy efficiency of walk-ins or walk-in
components. DOE described these technologies in chapter 3 of the
preliminary TSD.
DOE received several comments in response to its preliminary list
of technology options. NEEA and NPCC recommended that DOE include
modulating condenser fan controls in its analysis because there are
significant potential energy savings from this technology. (NEEA and
NPCC, No. 0059.1 at p. 8) Emerson agreed and noted that higher-
efficiency compressors often require modulating fan controls to realize
the full benefit of the higher-efficiency compressors. (Emerson, Public
Meeting Transcript, No. 0045 at p. 90) The Joint Utilities pointed out
that DOE did not include variable speed controls for condenser fans.
(Joint Utilities, No. 0061.1 at p.10) In addition, NEEA and NPCC
recommended that DOE include liquid suction heat exchangers in its
analysis because there are significant potential energy savings from
this technology. (NEEA and NPCC, No. 0059.1 at p. 8)
In response to the recommendation that DOE consider condenser fan
controls, DOE has added condenser fan controls as a design option
because it determined through further analysis that they could be an
effective means of saving energy. As to NEEA and NPCC's recommendation
that DOE include liquid suction heat exchangers, DOE also considered
liquid suction heat exchangers in the technology
[[Page 55804]]
assessment because this technology could potentially be used to save
energy. However, DOE screened this option from further consideration
because further examination indicated that it would be unlikely to
yield significant energy savings under the rating conditions used in
setting standards for walk-in equipment. See chapters 3, 4, and 5 of
the TSD for more details on the technologies considered in the
analysis.
B. Screening Analysis
DOE uses four screening criteria to determine which design options
are suitable for further consideration in a standards rulemaking.
Namely, design options will be removed from consideration if they (1)
are not technologically feasible; (2) are not practicable to
manufacture, install, or service; (3) have adverse impacts on product
utility or product availability; or (4) have adverse impacts on health
or safety. 10 CFR 430, subpart C, appendix A, sections (4)(a)(4) and
(5)(b).)
1. Technologies That Do Not Affect Rated Performance
In the preliminary analysis TSD, DOE proposed to screen out the
following technologies because they do not improve energy efficiency:
non-penetrative internal racks and shelving, air and water infiltration
sensors, humidity sensors, and heat flux sensors.
For the reasons stated in the test procedure final rule, DOE's test
procedure establishes metrics to test the energy consumption or energy
use of walk-in components and does not include heat load caused by
infiltration. See 76 FR at 21594-21595. As a result, DOE included
additional infiltration-related technologies in the following list of
technologies that do not improve rated performance:
Internal racks and shelving that are non-penetrative;
Air and water infiltration sensors;
Extruded polystyrene insulation;
Humidity sensors;
Heat flux sensors;
Door gasketing improvements and panel interface systems;
Automatic door opening and closing systems;
Air curtains;
Strip curtains;
Vestibule entryways; and
Insulation with improved moisture resistance.
In the preliminary analysis, DOE listed hot gas defrost as a
technology that does not improve rated performance of refrigeration
equipment. In response, the Joint Utilities stated that DOE should
include hot gas defrost. (Joint Utilities, Public Meeting Transcript,
No. 0045 at p. 25; Joint Utilities, No. 0061.1 at pp. 3, 7, and 10).
DOE has included hot gas defrost as a design option for multiplex
condensing systems, but not for dedicated condensing systems due to its
lack of effectiveness in improving efficiency. Specifically, for
multiplex condensing systems, the hot gas defrost system utilizes hot
gas generated by the compressor rack. Because at least one of the
compressors in the rack is likely to be running (because the rack also
has to operate with other refrigeration units) no new energy is
consumed to generate the hot gas. In contrast, for dedicated systems,
the condensing unit typically turns off during an electric defrost
cycle. Running the compressor to generate hot gas at a time when it
would normally be off results in energy use that outweighs the energy
saved by using hot gas defrost instead of electric defrost. See
chapters 3 and 5 of the TSD for details.
Also as part of the preliminary analysis, DOE analyzed the envelope
and the refrigeration system separately and did not consider design
options that depend on the interaction between the envelope and the
refrigeration system. SCE suggested that DOE consider control options
that depend on the interaction between envelope components and the
refrigeration system, such as a control that turns off the evaporator
fan when the door is opened. SCE suggested that DOE evaluate such
technologies by establishing a typical, nominal savings value for use
in energy consumption equations. (SCE, Public Meeting Transcript, No.
0045 at p. 25) Similarly, NEEA and NPCC stated that such technological
controls have not been included in the design options. (NEEA and NPCC,
No. 0059.1 at p. 7)
A nominal savings value, as suggested by SCE, would be highly
dependent on many assumptions about the application of the walk-in and
the pairing of the refrigeration system with the walk-in. As a result,
DOE does not believe that it would be reasonable to apply this shared
value to all refrigeration system or door manufacturers because of the
wide variety of equipment produced by these entities for walk-in
applications. Moreover, DOE's proposed component level approach
eliminates the need to consider design options whose efficacy depends
on the interaction between different components.
DOE also did not consider design options whose benefits would not
be captured by the test procedure, such as economizer cooling.
Economizer cooling consists of directly venting outside air into the
interior of the walk-in when the outside air is as cold as or colder
than the interior of the walk-in. This technique relieves the load on
the refrigeration system when a pull-down load (i.e., a load due to
items brought into the walk-in at a higher temperature than the
operating temperature and must then be cooled to the operating
temperature) is necessary. However, the test procedure does not include
a method for accounting for economizer cooling, as it does not specify
conditions for air that would be vented into the walk-in, nor does it
provide a method for measuring the energy use of the economizer.
Therefore, any benefits from including an economizer on a WICF would
not be captured by the test procedure.
2. Screened-Out Technologies
a. Panels and Doors
In the preliminary analysis, DOE screened out the following
technologies for envelopes: revolving doors, energy storage systems,
fiber optic natural light, non-electric anti-sweat systems, and
automatic insulation deployment systems. DOE did not receive comments
regarding any of the screened-out technologies, and will continue to
exclude them from this rulemaking. DOE has also screened out additional
technologies as part of its proposal to regulate the components of the
envelope separately (i.e., display doors, non-display doors, and
panels.) See chapter 4 of the TSD for more details on the screened-out
technologies.
b. Refrigeration
In the preliminary analysis, DOE screened out the following
technologies for refrigeration systems: Higher-efficiency evaporator
fan motors, improved evaporator coil, three-phase motors, and
economizer cooling. In response to DOE's request for comment on the
screening analysis, American Panel, AHRI and CrownTonka agreed with
this approach to screen out these technologies. (American Panel, Public
Meeting Transcript, No. 0045 at p. 98; AHRI. Public Meeting Transcript,
No. 0045 at p. 99; CrownTonka, No. 0057.1 at p. 1) Emerson, however,
disagreed with DOE's decision to screen out economizer cooling because
there are potential energy savings under certain circumstances.
(Emerson, Public Meeting Transcript, No. 0045 at p. 100) Also,
Heatcraft disagreed with the exclusion of phase motor technology
because three-phase motors are the dominant motor type in the larger
walk-in envelopes that are a part of this rulemaking. (Heatcraft No.
0069.1 at p. 2) Manitowoc remarked that there are
[[Page 55805]]
other ways to achieve an effective economizer cooling cycle and
encouraged DOE to investigate other options to improve cycle
efficiency, but did not provide any specific recommendations.
(Manitowoc, Public Meeting Transcript, No. 0045 at p. 92)
DOE continues to screen out three-phase motor technology. The use
of three-phase motor technology generally provides higher energy
savings as compared to single-phase motors. Three-phase power is
commonly used to power large motors and heavy electrical loads;
however, it is not available for all businesses, particularly small
business consumers of walk-ins. DOE did not consider three-phase motor
technology as a design option based on utility to the consumer, one of
the four screening criteria. In addition, use of three-phase motor
technology may also be impracticable to install and service given the
lack of three-phase power for some businesses. DOE did find that, as
Heatcraft noted, very large refrigeration systems typically use three-
phase power, and notes that manufacturers may use three-phase motors to
improve the efficiency ratings of their equipment as the benefit would
likely be captured by the test procedure. However, DOE continued to
screen three-phase motor technology from its analysis for the reasons
discussed above.
DOE also did not consider economizer cooling in its analysis.
Although there are potential energy savings under certain
circumstances, as Emerson mentioned, these energy savings are not
captured by the test procedure, as discussed in section IV.B.1.
Regarding Manitowoc's remark about considering other options to
improve cycle efficiency, DOE did not identify any options to improve
cycle efficiency beyond what was already considered. DOE requests
specific recommendations on how to improve cycle efficiency.
3. Screened-In Technologies
Based on DOE's decision to regulate walk-ins on a component level,
DOE will consider separate technologies for each covered walk-in
component (i.e. panels, display doors, non-display doors, and
refrigeration systems). The remaining technologies that were not
``screened-out'' are called the ``screened-in'' technologies and will
be used to create design options for improving the efficiency of the
walk-in components. The ``screened-in'' technologies for each covered
component include:
Panels
[cir] Insulation thickness
[cir] Insulation material
[cir] Framing material
Display doors
[cir] High-efficiency lighting
[cir] Occupancy sensors
[cir] Improved glass system insulation performance
[cir] Anti-sweat heater controls
Non-display doors
[cir] Insulation thickness
[cir] Insulation material
[cir] Framing material
[cir] Improved window glass systems
[cir] Anti-sweat heat controls
Refrigeration Systems
[cir] Higher efficiency compressors
[cir] Improved condenser coil
[cir] Higher efficiency condenser fan motors
[cir] Improved condenser fan blades
[cir] Condenser fan control
[cir] Ambient sub-cooling
[cir] Improved evaporator fan blades
[cir] Evaporator fan control
[cir] Defrost controls
[cir] Hot gas defrost
[cir] Head pressure control
C. Engineering Analysis
The engineering analysis determines the manufacturing costs of
achieving increased efficiency or decreased energy consumption. DOE has
identified the following three methodologies to generate the
manufacturing costs needed for the engineering analysis: (1) The
design-option approach, which provides the incremental costs of adding
design options to a baseline model to improve its efficiency; (2) the
efficiency-level approach, which provides the relative costs of
achieving increases in energy efficiency levels without regard to the
particular design options used to achieve such increases; and (3) the
cost-assessment (or reverse engineering) approach, which provides
``bottom-up'' manufacturing cost assessments for achieving various
levels of increased efficiency based on detailed data as to costs for
parts and material, labor, shipping/packaging, and investment for
models that operate at particular efficiency levels.
DOE conducted the engineering analyses for this rulemaking using a
combination of the design-option and cost-assessment approaches in
analyzing the U-factor standards for panels, maximum energy use for
non-display doors and display doors, and minimum AWEF for refrigeration
systems. More specifically, DOE identified design options for analysis
and then used the cost-assessment approach to determine the
manufacturing costs and analytical modeling to determine the energy
consumption at those levels. Additional details of the engineering
analysis are in chapter 5 of the NOPR TSD.
1. Representative Equipment
a. Panels and Doors
In presenting the preliminary analysis, DOE proposed three
representative sizes for each envelope equipment class: Small, medium,
and large. American Panel agreed with the sizes that DOE proposed.
(American Panel, No. 0048.1 at p. 4) CrownTonka recommended that the
equipment classes for envelopes be divided into only two sections,
small and medium, because EPCA covers only walk-ins of less than 3,000
square feet, which excludes sizes that are typically considered
``large.'' (CrownTonka, Public Meeting Transcript, No. 0045 at p.111)
Heatcraft agreed that the sizes chosen are small, as all the sizes
considered must be less than 3,000 square feet, and they recommended
that the distribution of envelope sizes include larger sizes
approaching the 3,000 square foot limit, the maximum size limit defined
in the statute. Heatcraft also stated that the selected envelope sizes
will have an effect on the engineering analysis because certain
technologies are utilized at different sizes. (Heatcraft, Public
Meeting Transcript, No. 0045 at p. 111, No. 0058.1 at p. 4) American
Panel suggested that DOE use three sizes and investigate using an extra
large size. (American Panel, Public Meeting Transcript, No. 0045 at p.
114) Manitowoc asserted that DOE did not include a large enough range
of sizes and should consider smaller sized walk-ins to correctly
represent the energy consumption of a given unit. Additionally,
Manitowoc noted that as the walk-in's size increases, there are
different base levels of performance and that if DOE sets the minimum
efficiency based on a larger size, manufacturers will not be able to
make small-sized equipment meeting the standards. (Manitowoc, Public
Meeting Transcript, No. 0045 at pp. 116 and 118) Hill Phoenix
recommended that the envelope sizes be determined by surface area or
volume. (Hill Phoenix, No. 0066.1 at p. 2) NEEA and NPCC suggested that
DOE establish a standard based on the square feet of panels shipped
each year and use the square footage to determine the energy
consumption of a complete functioning envelope. (NEEA and NPCC, No.
0059.1 at p. 8)
DOE notes that its proposal rests on a component-based approach and
does not include infiltration losses. As a result, the size of the
walk-in envelope does not affect the energy consumption of the
components. In regard to American Panel's and Heatcraft's
[[Page 55806]]
comments about large sized walk-ins, DOE analyzed a large panel size
that it considered to represent the large panels found in the industry.
DOE anticipated the possibility raised by Manitowoc that small panels
might not be able to meet a standard based on the large panel size
previously under consideration and is now considering the adoption of
an approach that considers small, medium, and large sizes. As Hill
Phoenix suggested, DOE determined the size of the panel based on the
panel's surface area. Also, similar to NEEA and NPCC's suggestion, DOE
is proposing a standard for walk-in panels based on the panel's surface
area.
Panels
As explained previously, the engineering analysis for walk-in
panels uses three different panel sizes to represent the variations
within each class. DOE determined the sizes based on market research
and the impact on the test metric U-factor. Table IV-3 shows each
equipment class and the representative sizes associated with that
class. DOE requests comment on the representative sizes used in the
proposed analysis.
Table IV-3--Sizes Analyzed: Panels
----------------------------------------------------------------------------------------------------------------
Representative Representative
Equipment class Size code height (feet) width (feet)
----------------------------------------------------------------------------------------------------------------
SP.M...................................... SML.......................... 8 1.5
MED.......................... 8 4
LRG.......................... 9 5.5
SP.L...................................... SML.......................... 8 1.5
MED.......................... 8 4
LRG.......................... 9 5.5
FP.L...................................... SML.......................... 8 2
MED.......................... 8 4
LRG.......................... 9 6
----------------------------------------------------------------------------------------------------------------
Doors
Similar to the panel analysis, the engineering analyses for walk-in
display and non-display doors both use three different sizes to
represent the differences in doors within each size class DOE examined.
The door sizes were determined using market research. Details are
provided in Table IV-4 for non-display doors and Table IV-5 for display
doors.
Table IV-4--Sizes Analyzed: Non-Display Doors
----------------------------------------------------------------------------------------------------------------
Representative Representative
Equipment class Size code height (feet) width (feet)
----------------------------------------------------------------------------------------------------------------
PD.M...................................... SML......................... 6.5 2.5
MED......................... 7 3
LRG......................... 7.5 4
PD.L...................................... SML......................... 6.5 2.5
MED......................... 7 3
LRG......................... 7.5 4
FD.M...................................... SML......................... 8 5
MED......................... 9 7
LRG......................... 12 7
FD.L...................................... SML......................... 8 5
MED......................... 9 7
LRG......................... 12 7
----------------------------------------------------------------------------------------------------------------
Table IV-5--Sizes Analyzed: Display Doors
----------------------------------------------------------------------------------------------------------------
Representative Representative
Equipment class Size code height (feet) width (feet)
----------------------------------------------------------------------------------------------------------------
DD.M...................................... SML......................... 5.25 2.25
MED......................... 6.25 2.5
LRG......................... 7 3
DD.L...................................... SML......................... 5.25 2.25
MED......................... 6.25 2.5
LRG......................... 7 3
----------------------------------------------------------------------------------------------------------------
b. Refrigeration
In the engineering analysis for walk-in refrigeration systems, DOE
used a range of capacities as analysis points for each equipment class.
The name of each equipment class along with the naming convention was
discussed in section IV.A.3.b. In addition to the multiple analysis
points, scroll, hermetic, and semi-hermetic compressors were also
investigated because different compressor types have different
[[Page 55807]]
efficiencies and costs.\15\ Due to the wide range of capacities
considered for each condenser type, and the availability of compressors
at certain capacities, compressors closely matching the condenser
capacities were examined in terms of their performance at varying
operating temperatures.
---------------------------------------------------------------------------
\15\ Scroll compressors are compressors that operate using two
interlocking, rotating scrolls that compress the refrigerant.
Hermetic and semi-hermetic compressors are piston-based compressors
and the key difference between the two is that hermetic compressors
are sealed and hence more difficult to repair, resulting in higher
replacement costs, while semi-hermetic compressors can be repaired
relatively easily.
---------------------------------------------------------------------------
Table IV-6 identifies, for each class of refrigeration system, the
sizes of the equipment DOE analyzed in the engineering analysis.
Chapter 5 of the NOPR TSD includes additional details on the
representative equipment classes used in the analysis.
Table IV-6--Sizes Analyzed: Refrigeration System
----------------------------------------------------------------------------------------------------------------
Sizes analyzed
Equipment class (Btu/h) Compressors analyzed
----------------------------------------------------------------------------------------------------------------
DC.M.I, < 9,000........................ 6,000 Hermetic, Semi-hermetic.
DC.M.I, >= 9,000....................... 18,000 Hermetic, Semi-hermetic, Scroll.
54,000 Semi-Hermetic, Scroll.
96,000 Semi-Hermetic, Scroll.
DC.M.O, < 9,000........................ 6,000 Hermetic, Semi-hermetic.
DC.M.O, >= 9,000....................... 18,000 Hermetic, Semi-hermetic, Scroll.
54,000 Semi-Hermetic, Scroll.
96,000 Semi-Hermetic, Scroll.
DC.L.I, < 9,000........................ 6,000 Hermetic, Semi-hermetic, Scroll.
DC.L.I, >= 9,000....................... 9,000 Hermetic, Semi-hermetic, Scroll.
54,000 Semi-Hermetic, Scroll.
DC.L.O, < 9,000........................ 6,000 Hermetic, Semi-hermetic, Scroll.
DC.L.O, >= 9,000....................... 9,000 Hermetic, Semi-hermetic, Scroll.
54,000 Semi-Hermetic, Scroll.
72,000 Semi-Hermetic.
MC.M................................... 4,000
9,000
24,000
MC.L................................... 4,000
9,000
18,000
40,000
----------------------------------------------------------------------------------------------------------------
2. Energy Modeling Methodology
In the preliminary analysis, DOE proposed using an energy
consumption model to estimate separately the energy consumption rating
of entire envelopes and entire refrigeration systems at various
performance levels using a design-option approach. DOE developed the
model as a Microsoft Excel spreadsheet. The spreadsheet calculated the
cumulative effect on the energy consumption of adding options above the
baseline.
DOE continues to use a spreadsheet-based model, but is now modeling
panels, display doors, non-display doors, and refrigeration systems
separately because these components are tested separately. As mentioned
above, the purpose of the engineering analysis is to determine the
manufacturing costs of achieving increased efficiency or decreased
energy consumption. DOE assumes that manufacturers will only incur
costs to achieve efficiency gains or energy reductions that are
accounted for in their certified equipment rating. Therefore, the
energy models estimate the performance rating that the manufacturer
would obtain by testing their equipment using the DOE test procedure
because manufacturers are required to rate the components using the
test procedure. The models estimate the energy ratings of baseline
equipment and levels of performance above the baseline associated with
specific design options that are added cumulatively to the baseline
equipment. The model does not account for interactions between
refrigeration systems and envelope components, nor does it address how
a design option for one component may affect the energy consumption of
other components, because such effects are not accounted for in the
test procedure. Component performance results are found in appendix 5A
of the TSD. DOE requests comment on the performance data found in
appendix 5A of the TSD and requests data about the performance of
panels, display doors, or non-display doors and their design options.
a. Refrigeration
The refrigeration energy model calculates the annual energy
consumption and the AWEF of walk-in refrigeration systems at various
performance levels using a design option approach. AWEF is the ratio of
the total heat removed, in Btus, from a walk-in envelope during a one-
year period of use (not including the heat generated by operation of
the refrigeration system) to the total energy input of refrigeration
systems, in watt-hours, during the same period. DOE proposes to base
its standards for the refrigeration system using the AWEF metric and
seeks comment on this approach.
This model was used to analyze specific examples of equipment in
each refrigeration system equipment class. For a given class, the
analysis consists of calculating the annual energy consumption and the
AWEF for the baseline and several levels of performance above the
baseline. See chapter 5 of the TSD for further details about the
analytical models used in the engineering analysis.
For the preliminary analysis, DOE partially relied on refrigeration
catalog information to obtain equipment specifications for its energy
model. Manitowoc and the Joint Utilities believed that catalog
information was not the best source from an analytical standpoint.
Manitowoc observed that catalog information is provided mainly for
sizing equipment and not for representing equipment performance, while
the Joint Utilities pointed out that
[[Page 55808]]
the rating methodology that produced the data in the catalogs could be
different from the rating methodology for walk-ins, which could make
the data inappropriate for analyzing walk-ins. (Manitowoc, Public
Meeting Transcript, No. 0045 at p. 31; Joint Utilities, No. 0061.1 at
p. 3)
In recognition of these comments, DOE conducted further research
into refrigeration system performance and has improved the analysis for
the NOPR in several ways. First, the energy model now calculates system
performance based on a whole-system approach using thermodynamic
principles. The model determines the refrigerant properties (pressure,
temperature, etc.) at each point in the system and these properties,
rather than catalog specifications, are used to calculate refrigeration
capacity. Second, for any catalog information based on specific rating
conditions, DOE ensured the rating conditions were consistent with
those for walk-in refrigeration systems, or adjusted the specifications
accordingly. Third, while it continued to rely on catalog data directly
for some equipment specifications (e.g., typical number of fans and fan
horsepower for units of the sizes analyzed), DOE also surveyed catalogs
from various manufacturers to determine the most representative
specifications for a particular type and size of equipment. See chapter
5 for more details on the refrigeration system energy model and other
enhancements made to its analysis.
The energy consumption calculations in the engineering analysis are
based on calculations in AHRI 1250-2009, the industry test procedure
incorporated by reference in the walk-in test procedure. 76 FR at
33631. These calculations involve the refrigeration system running at a
high load for one-third of the time and a low load for two-thirds of
the time. American Panel noted that the load profile for restaurants
would generally be reversed (i.e., the refrigeration system is sized
for running at a high load two-thirds of the time and a low load one-
third of the time) and requested DOE to adjust the load assumptions
based on the walk-in application. (American Panel, No. 0048.1 at p. 8)
DOE's assumption in the engineering analysis about the
refrigeration load profile was made for purposes of comparing the
performance of different types of refrigeration equipment that have
varying features. Furthermore, the analysis attempts to assess the
impacts of technologies manufacturers might use to improve the
efficiencies of their equipment, including impacts on the efficiency
ratings of the equipment. DOE will base any standards it adopts on the
use of some or all of these technologies, and the DOE test procedure
would serve as the basis for rating equipment and determining
compliance. Therefore, the test procedure calculations are used in the
analysis to determine the efficiency ratings of equipment utilizing the
various technologies on which DOE might base the standards.
However, DOE does not treat the load profile assumptions used in
the engineering analysis as equivalent to the actual duty cycle of
every class or application of refrigeration systems. Rather, where
warranted, DOE evaluates other duty cycle assumptions in its energy use
analysis, which examines the actual energy consumption of the
refrigeration system under a variety of operating conditions and
applications. In the energy use analysis, DOE has adjusted its
assumptions for actual duty cycles based in part on American Panel's
recommendation. See section IV.E.1 and chapter 7 of the TSD for
details.
In the preliminary analysis, DOE analyzed the result of adding
design options cumulatively to the baseline. DOE observed that some
design options (e.g., larger condenser coil) increased the efficiency
of the refrigeration system while also increasing its capacity. To
distinguish between these effects, DOE created a ``normalized energy
consumption'' metric in the preliminary analysis which represented the
energy consumption per unit capacity. DOE expected that the normalized
energy consumption metric would generally be analogous to an efficiency
metric. For example, for two units of the same capacity, the unit with
lower normalized energy consumption would be more efficient because it
would use less energy for the same heat removal capability.
In a comment on the preliminary analysis, American Panel stated
that it was not beneficial for the capacity of a unit to increase
because the refrigeration system must balance the heat load to control
temperature and humidity. (American Panel, Public Meeting Transcript,
No. 0045 at p. 175) After interviewing manufacturers and examining
refrigeration catalogs, DOE observed that manufacturers typically offer
refrigeration systems in specific, discrete capacities while providing
consumers with options for improving system efficiency. DOE reasoned
that manufacturers would likely design their systems for a certain set
of capacities regardless of the efficiency options available and,
consequently, implementing efficiency options on a system would be
unlikely to change the capacity of the system because the manufacturer
would prefer to market the system at the established capacity.
Therefore, DOE agrees with American Panel's assessment and has
implemented its suggestion into the NOPR analysis.
DOE notes that it analyzed six classes of refrigeration systems at
various capacity points, as explained in section IV.C.1.b. When a
design option is added to the baseline, it does not change the capacity
of the unit; instead, other aspects of the system are adjusted to
maintain the capacity at the specified point. See chapter 5 of the TSD
for details.
In the preliminary analysis, DOE considered the effects of adding
design options to the baseline. Some interested parties commented on
the interactive effects of design options. Thermocore stated that there
are substantial differences in performances based on the integrated
system as opposed to considering options separately. (Thermocore,
Public Meeting Transcript, No. 0045 at p. 86) Emerson stated that DOE
must account for how the technologies are combined because the effects
will vary depending on what is already included in the system.
(Emerson, Public Meeting Transcript, No. 0045 at p. 93) AHRI agreed
that efficiency gains due to combinations of certain design options are
not necessarily additive and noted that assessing the aggregate benefit
from combined design options requires rigorous analysis and simulation
of the total system. (AHRI, No. 0055.1 at p. 2)
DOE recognizes that the interactive effects of design options must
be considered because the efficacy of certain design options differs
depending on whether they are analyzed separately or in conjunction
with other design options. DOE has taken a system-based approach to the
refrigeration system energy model that calculates the effect on the
entire system of adding design options. Each efficiency level above the
baseline consists of a design option added cumulatively and the
interactive effects of each new design option on all previously added
design options are considered. In formulating the cost-efficiency
curves, DOE attempted to capture the most cost-effective design option
at each efficiency level, given all previously added design options at
that level. Manufacturers may use any combination of design options to
meet the future energy conservation standard. See chapter 5 of the TSD
for further discussion on the interactive effects of design options.
[[Page 55809]]
Some commenters disagreed with DOE's refrigeration energy modeling
approach. SCE recommended using DOE 2.2R (an expanded version of the
building simulation program DOE 2.2) to directly model certain design
options, such as modulating the fan speed for the on-cycle fan power
for a unit cooler connected to a multiplex system. (SCE, Public Meeting
Transcript, No. 0045 at p. 138) NEEA and NPCC also stated that the
spreadsheet-based model does not adequately evaluate all of the design
options and their combinations, and that DOE should consider using DOE
2.2R for modeling instead. (NEEA and NPCC, No. 0059.1 at p. 9)
DOE 2.2R is designed to simulate the operation of building
refrigeration systems, such as those found in supermarkets,
refrigerated warehouses, and industrial facilities. Although DOE 2.2R
is a powerful simulation tool that can aid in refrigeration system
design, DOE believes it is inappropriate for the energy modeling that
DOE is conducting as part of this rulemaking. This rulemaking is taking
a component-level approach and determining the performance of each
component (the panels, the doors, and the refrigeration system)
separately, whereas DOE 2.2R models the interactions of components that
comprise an entire building. Also, the component performance as modeled
in the engineering analysis must be based on the operating conditions
and calculations contained in the test procedure, which DOE believes is
not consistent with the simulation methodology in DOE 2.2R. To address
the concerns of SCE, NEEA and NPCC that a spreadsheet model would be
inadequate for certain options or combinations of options, DOE has
modified the spreadsheet model to more accurately account for
combinations of design options and interactive effects of design
options within a component. To address the Joint Utilities' concerns
with fan speed modulation, DOE included calculations for fan speed
modulation that are consistent with the test procedure.
Although DOE is not conducting the analysis using DOE 2.2R, DOE
encourages interested parties to submit their own simulation results
from DOE 2.2R modeling and compare them to DOE's engineering results.
3. Cost Assessment Methodology
a. Teardown Analysis
To calculate the manufacturing costs of the different components of
walk-in coolers and freezers, DOE disassembled baseline equipment. This
process of disassembling systems to obtain information on their
baseline components is referred to as a ``physical teardown.'' During
the physical teardown, DOE characterized each component that makes up
the disassembled equipment according to its weight, dimensions,
material, quantity, and the manufacturing processes used to fabricate
and assemble it. The information was used to compile a bill of
materials (BOM) that incorporates all materials, components, and
fasteners classified as either raw materials or purchased parts and
assemblies.
DOE also used a supplementary method, called a ``virtual
teardown,'' which examines published manufacturer catalogs and
supplementary component data to estimate the major physical differences
between equipment that was physically disassembled and similar
equipment that was not. For virtual teardowns, DOE gathered product
data such as dimensions, weight, and design features from publicly-
available information, such as manufacturer catalogs.
The teardown analyses allowed DOE to identify the technologies that
manufacturers typically incorporate into their equipment. The end
result of each teardown is a structured BOM, which DOE developed for
each of the physical and virtual teardowns. DOE then used the BOM from
the teardown analyses as one of the inputs to the cost model to
calculate the manufacturer production cost (MPC) for the product that
was torn down. The MPCs derived from the physical and virtual teardowns
were then used to develop an industry average MPC for each equipment
class analyzed. See chapter 5 of the NOPR TSD for more details on the
teardown analysis.
For display doors and non-display freight doors, limited
information was publicly available, particularly as to the assembly
process and shipping. To compensate for this situation, DOE conducted
physical teardowns for two representative units, one within each of
these equipment classes. DOE supplemented the cost data it derived from
these teardowns with information from manufacturer interviews. The cost
models for panels and for non-display structural doors were created by
using public catalog and brochure information posted on manufacturer
Web sites and information gathered during manufacturer interviews.
For the refrigeration system, DOE conducted physical teardowns of
unit cooler and condensing unit samples to construct a BOM. The
selected systems were considered representative of baseline, medium-
capacity systems, and used to determine the base components and
accurately estimate the materials, processes, and labor required to
manufacture each individual component. From these teardowns, DOE
gleaned important information and data not typically found in catalogs
and brochures, such as heat exchanger and fan motor details, assembly
parts and processes, and shipment packaging.
Along with the physical teardowns, DOE performed several virtual
teardowns of refrigeration units for the NOPR analysis. The complete
set of teardowns helped DOE obtain the baseline average MPC for all
equipment classes proposed.
b. Cost Model
The cost model is one of the analytical tools DOE used in
constructing cost-efficiency curves. DOE derived the cost model from
the teardown BOMs and the raw material and purchased parts databases.
Cost model results are based on material prices, conversion processes
used by manufacturers, labor rates, and overhead factors such as
depreciation and utilities. For purchased parts, the cost model
considers the purchasing volumes and adjusts prices accordingly.
Original equipment manufacturers (OEMs), i.e., the manufacturers of
WICF components, convert raw materials into parts for assembly, and
also purchase parts that arrive as finished goods, ready-to-assemble.
DOE bases most raw material prices on past manufacturer quotes that
have been inflated to present day prices using Bureau of Labor
Statistics (BLS) and American Metal Market (AMM) inflators. DOE
inflates the costs of purchased parts similarly and also considers the
purchasing volume--the higher the volume, the lower the price. Prices
of all purchased parts and non-metal raw materials are based on the
most current prices available, while raw metals are priced on the basis
of a 5-year average to smooth out spikes. Chapter 5 of the NOPR TSD
describes DOE's cost model and definitions, assumptions, data sources,
and estimates.
For panels, non-display doors, and display doors DOE used a
``parameterized'' computational cost model, which allows a user to
manipulate the components parameters such as height and length by
inputting different numerical values for these features to produce new
cost estimates. This parameterized model, coupled with the design
specifications chosen for each representative unit modeled in the
engineering analysis, was used to develop fundamental MPC costs. The
fundamental MPC costs were then
[[Page 55810]]
incorporated into the engineering analysis model where they were
combined with additional costs associated with each design option.
Costs for each design option were calculated based on discussions with
panel, non-display, and display door manufacturers and pricing from
commercially available sources.
As previously mentioned in section IV.B.3, DOE is considering high
efficiency lighting, specifically light-emitting diode (LED) lighting,
as a design option to improve the efficiency of display doors.
Forecasts of the LED lighting industry, including those performed by
DOE, suggest that LED lighting is an emerging technology that will
continue to experience significant price decreases in coming years. For
this reason, in an effort to capture the anticipated cost reduction in
LED fixtures in the analyses for this rulemaking, DOE incorporated
price projections from its Solid State Lighting program into its MPC
values. The price projections for LED lighting were developed using
projections created for the DOE's Solid State Lighting Program's 2012
report, Energy Savings Potential of Solid-State Lighting in General
Illumination Applications 2010 to 2030 (``the energy savings report'').
In the appendix of this report, price projections from 2010 to 2030
were provided in ($/klm) for LED lamps and LED luminaires. DOE analyzed
the models used in the Solid State Lighting program work and determined
that the LED luminaire projection would serve as a proxy for a cost
projection to apply to LEDs on walk-in display doors.
The price projections presented in the Solid State Lighting
program's energy savings report are based on the DOE's 2011 Solid State
Lighting R&D Multi-Year Program Plan (MYPP).\16\ The MYPP is developed
based on input from manufacturers, researchers, and other industry
experts. This input is collected by the DOE at annual roundtable
meetings and conferences. The projections are based on expectations
dependent on the continued investment into solid state lighting by the
DOE.
---------------------------------------------------------------------------
\16\ The DOE Solid-State Lighting Research and Development
Multi-Year Program Plan is a document that outlines DOE's research
goals and planned methodologies with respect to the advancement of
solid-state lighting technologies in the United States. The complete
document is available at: https://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_mypp2011_web.pdf.
---------------------------------------------------------------------------
DOE incorporated the price projection trends from the energy
savings report into its engineering analysis by using the data to
develop a curve of decreasing LED prices normalized to a base year.
That base year corresponded to the year when LED price data were
collected for the NOPR analyses of this rulemaking from catalogs,
manufacturer interviews, and other sources. DOE started with LED cost
data specific to walk-in manufacturers and then applied the anticipated
trend from the energy savings report to forecast the projected cost of
LED fixtures at the time of required compliance with the proposed rule
(2017). These 2017 cost figures were incorporated into the engineering
analysis to calculate the MPC of display doors with LEDs as a design
option. The LCC analysis (section IV.F) was carried out with the
engineering numbers that account for the 2017 cost of LED luminaires.
The reduction in costs of LED luminaires from 2018 to 2030 were taken
into account in the NIA (section IV.G). The cost reductions were
calculated for each year from 2018 and 2030 and subtracted from the
equipment costs in the NIA.
During the preliminary analysis, DOE developed a cost model for the
proposed representative sizes of walk-in envelopes. Panel manufacturers
generally make panels with a combination of raw materials and purchased
parts, and DOE estimated manufacturing process parameters, the required
initial material quantity, scrap, and other factors to determine the
value of each component. DOE then aggregated all parameters related to
manufacture and assembly to determine facility requirements at various
manufacturing scales and the final unit cost.
To more accurately model walk-in costs, DOE used common factory
parameters, which affect the cost of each unit produced (e.g., labor
and fabrication rates). American Panel commented on some of the factors
assumed in the cost model and the resulting values. In particular, in
its view, approximately 1 million square feet of panels are
manufactured per year per manufacturer, and most door manufacturers
produce 1,800 doors per year. Accordingly, these numbers suggest a
total walk-in production volume of well under DOE's initial estimate of
30,000 per year per manufacturer. American Panel believed that
overestimating the amount of panels manufactured per year would cause
the small manufacturers to be at a disadvantage. (American Panel,
Public Meeting Transcript, No. 0045 at p. 14-15; American Panel, No.
0048.1 at pp. 5-6)
Assuming an average walk-in surface area of 500 ft\2\ (roughly
corresponding to an 8-foot by 10-foot walk-in), American Panel's
estimate equates to approximately 2,000 walk-ins per year, per
manufacturer--much lower than DOE's estimate. DOE understands that its
estimate may be more reasonable for a large manufacturer than a small
one and agrees with American Panel that impacts on small manufacturers
may be underestimated in an analysis that assumes a high production
capacity. Thus, DOE has considered particular impacts on small
manufacturers in the MIA by adjusting for their reduced production
capacity as compared to larger manufacturers. See sections IV.I.3.c and
V.B.2.d (Manufacturer Impact Analysis) and VI.B (Regulatory Flexibility
Analysis, which specifically address the impact of the rule on small
business manufacturers).
Additionally, American Panel, citing its own experience, stated
that other DOE cost estimates needed adjusting. Some examples include
the following:
The cost of the tongue and groove design found on panels
should be increased by a factor of 10.8.
The cost of the advanced door sweep should increase by a
factor of 7.8.
The DOE cost per square foot of panel was too high and
actual costs were closer to $0.25 per square foot.
The actual MSP for walk-in cooler envelopes was 70-112
percent lower than the DOE estimate.
The actual MSP for walk-in freezer envelopes was 24-42
percent lower than the DOE estimate. (American Panel, Public Meeting
Transcript, No. 0045 at pp. 14-15; American Panel, No. 0048.1 at pp. 5-
6).
DOE appreciates the efforts made by American Panel in preparing
detailed comments and providing useful information about factory
parameters, material costs, and the resulting manufacturing selling
price for walk-in envelopes. Some of the differences can be explained
based on the parameters used in the cost model, such as the material
costs. DOE particularly appreciates American Panel's comments related
to the costs of certain designs and has taken these costs into
consideration in its analysis by aggregating them with other data DOE
has received through research and confidential manufacturer interviews.
For instance, American Panel's cost per square foot of panel was
particularly useful in helping DOE estimate the costs of certain
materials that make up the panel.
DOE was not, however, able to use some of the cost data--for
example, costs related to infiltration-reducing measures were not used
because DOE is no longer considering infiltration in the analysis.
Also, DOE has not calculated costs related to the assembly of the
entire envelope--for instance, the MSP
[[Page 55811]]
of the envelope--as part of the engineering analysis because of the
component-based approach DOE is proposing to use. Consequently, DOE is
now using the cost model to determine the manufacturer production costs
and manufacturer selling prices of the individual components covered by
the standards.
DOE estimated installation costs for the refrigeration systems and
the envelope components separately as part of the life-cycle cost
analysis. DOE has proposed new manufacturer cost estimates in chapter 5
of the TSD and seeks comment on the new parameters proposed for each
component.
c. Manufacturing Production Cost
Once it finalized the cost estimates for all the components in each
teardown unit, DOE totaled the cost of the materials, labor, and direct
overhead used to manufacture the unit to calculate the manufacturer
production cost of such equipment. The total cost of the equipment was
broken down into two main costs: (1) The full manufacturer production
cost, referred to as MPC; and (2) the non-production cost, which
includes selling, general, and administration (SG&A) costs; the cost of
research and development; and interest from borrowing for operations or
capital expenditures. DOE estimated the MPC at each design level
considered for each equipment class, from the baseline through max-
tech. After incorporating all of the data into the cost model, DOE
calculated the percentages attributable to each element of total
production cost (i.e., materials, labor, depreciation, and overhead).
These percentages were used to validate the data by comparing them to
manufacturers' actual financial data published in annual reports, along
with feedback obtained from manufacturers during interviews. DOE uses
these production cost percentages in the MIA (see section IV.I).
In the preliminary analysis, DOE developed both an envelope cost
and a refrigeration system cost for each equipment class and size using
a manufacturing cost model. See chapter 5 of the preliminary TSD.
American Panel suggested that manufacturer cost should be estimated
using a sample from 40 manufacturers and representative volumes.
(American Panel, Public Meeting Transcript, No. 0045 at p. 312) In
response to American Panel's comment, DOE believes it is infeasible to
sample so many manufacturers because data on manufacturing cost and
representative volumes are not publicly available for most
manufacturers of walk-ins and walk-in components, particularly small,
private companies. Additionally, not all manufacturers were willing to
share cost information with DOE. DOE did hold confidential interviews
with manufacturers, some of whom chose not to share this information.
DOE notes that cost information it did obtain was helpful in enabling
the agency to develop and refine its estimates of manufacturer cost.
The interview process is explained in chapter 12 of the TSD.
d. Manufacturing Markup
DOE uses MSPs to conduct its downstream economic analyses. DOE
calculated the MSPs by multiplying the manufacturer production cost by
a markup and adding the equipment's shipping cost. The production price
of the equipment is marked up to ensure that manufacturers can make a
profit on the sale of the equipment. DOE gathered information from
manufacturer interviews to determine the markup used by different
equipment manufacturers. Using this information, DOE calculated an
average markup for each component of a walk-in. DOE requests comments
on the proposed markups listed in Table IV-7.
Table IV-7--Manufacturer Markups
------------------------------------------------------------------------
Markup
Walk-in component (percent)
------------------------------------------------------------------------
Panels..................................................... 32
Display Doors.............................................. 50
Non-Display Doors.......................................... 62
Refrigeration Equipment.................................... 35
------------------------------------------------------------------------
e. Shipping Costs
In the preliminary analysis TSD, DOE calculated manufacturer
shipping costs assuming that manufacturers include outbound freight as
part of their equipment selling price. In response to DOE's request for
comment on shipping assumptions, American Panel and NEEA and NPCC
remarked that DOE's costs were significantly higher than actual
industry shipping rates. (American Panel, Public Meeting Transcript,
No. 0045 at pp. 15, 142; NEEA and NPCC, No. 0059 at p. 9) Additionally,
American Panel stated that freight costs are typically paid in full by
the customer and not absorbed by the manufacturer who is selling the
equipment. (American Panel, No. 0048.1 at p. 5) Both American Panel and
CrownTonka said that sometimes the freight cost would be included as
part of the selling price and sometimes it would be entirely separate;
i.e., paid by the buyer directly to the freight company. (American
Panel, Public Meeting Transcript, No. 0045 at p. 143; CrownTonka,
Public Meeting Transcript, No. 0045 at p. 144) NEEA and NPCC stated
that freight costs are normally included in the packaged price to
consumers. (NEEA and NPCC, No. 0059.1 at p. 9)
DOE re-evaluated the shipping rates in preparing this NOPR. These
rates were developed by conducting additional research on shipping
rates and by interviewing manufacturers of the covered equipment. For
example, DOE found through its research that most panel, display door,
and non-display door manufacturers use less than truck load freight to
ship their respective components and revised its estimated shipping
rates accordingly. DOE also found that most manufacturers, when
ordering component equipment for installation in their particular
manufactured product, do not pay separately for shipping costs; rather,
it is included in the selling price of the equipment. However, when
manufacturers include the shipping costs in the equipment selling
price, they typically do not mark up the shipping costs for profit, but
instead include the full cost of shipping as part of the price quote.
DOE has revised its methodology accordingly. Please refer to chapter 5
of the TSD for details.
4. Baseline Specifications
a. Panels and Doors
In the preliminary analysis, DOE set the baseline level of
performance to correspond to the most common least efficient component
that is compliant with the standards set forth in EPCA. (42 U.S.C.
6313(f)(1)(3)) DOE determined specifications for each equipment class
by surveying currently available units and models. This approach was
used for the NOPR analyses to determine the baseline units for panels,
display doors, and non-display doors. More detail about the
specifications for each baseline model can be found in chapter 5 of the
TSD.
Because the walk-in market is comprised of panels insulated with
polyurethane and extruded polystyrene, DOE proposed in the preliminary
analysis that the R-value for the baseline insulation used in the walk-
in envelope would be the average of the typical long term thermal
resistance (LTTR) R-values of polyurethane and extruded polystyrene.
CPI opposed the use of an average R-value for extruded polystyrene and
polyurethane because it would affect the accuracy of the normalized
energy consumption calculation for the envelope. (CPI, No.
[[Page 55812]]
0052.1, at p.1) DOE agrees with CPI's concern and is using in the
revised analysis foam-in-place polyurethane as the baseline insulation
for panels and non-display doors. Polyurethane is more commonly used as
panel or non-display door insulation, has a better long term thermal
resistance, and is less expensive than extruded polystyrene. DOE notes
that extruded polystyrene may outperform polyurethane in other
respects, like moisture absorption, which are not captured in the
energy consumption model because they are not included in the test
procedure.
DOE's analysis also uses wood framing members as the baseline
framing material in panels. The analysis assumes the typical wood frame
completely borders the insulation and is 1.5 inches wide. DOE requests
comment on its baseline specifications for walk-in panels, specifically
the assumptions about framing material and framing dimensions.
The baseline display doors modeled in DOE's analysis are based on
the minimum specifications set by EPCA. (42 U.S.C. 6313(f)(3)) DOE
modeled baseline display cooler doors comprised of two panes of glass
with argon gas fill and hard coat low emittance or low-e coating. The
baseline cooler display door requires 2.9 Watts per square foot of
anti-sweat heater wire and does not have a heater wire controller. The
baseline display freezer doors modeled in DOE's analysis consist of
three panes of glass, argon gas, and soft coat low-e coating. Baseline
freezer doors use 15.23 watts per square foot of anti-sweat heater wire
power and require an anti-sweat heater wire controller. DOE also
estimates that each baseline door includes one fluorescent light with
electronic ballasts, with a door shorter than 6.5 feet having a 5-foot
fluorescent bulb and a door equal to or taller than 6.5 feet having a
6-foot fluorescent bulb. DOE requests comment on the baseline
assumptions for display cooler and freezer doors. In particular, DOE
requests data illustrating the energy consumption of anti-sweat heaters
found on cooler and freezer display doors.
DOE's analysis assumes that the baseline non-display doors are
constructed in a similar manner to baseline panels. Therefore, DOE's
analysis uses baseline non-display doors that consist of wood framing
materials 1.5 inches wide that completely border the foamed-in-place
polyurethane insulation. DOE also includes a small window in a non-
display door that conforms to the standards set by EPCA. DOE estimates
that all passage doors have a 2.25 square foot window regardless of the
passage door's size. DOE analyzed two different size windows for non-
display freight doors. The small freight doors have a 2.25 square foot
window and both the medium and large freight doors have a 4-square foot
window. DOE requests comment on the baseline specifications for non-
display doors, and specifically on the size of the windows included in
the baseline doors.
DOE also received comments about the amount of energy savings
attributed to infiltration reduction devices (IRDs) on baseline walk-in
doors. NEEA and NPCC commented that even though EISA requires an
infiltration reduction device on the baseline door, DOE should also
include additional IRDs as a design option. NEEA and NPCC continued to
suggest that DOE should re-evaluate the amount of energy savings
associated with IRDs. (NEEA and NPCC, Public Meeting Transcript, No.
0045 at p. 170) The Joint Utilities also believed that DOE
overestimated the impacts of IRDs in the baseline doors and explained
that overestimating the baseline savings from an IRD affects the amount
of savings achieved by the design options DOE evaluated. (Joint
Utilities, No. 0061.1 at p. 5) DOE agrees with NEEA and NPCC and the
Joint Utilities that a baseline door must have an IRD because this is
required by EPCA. (42 U.S.C. 6313(f)(1)(A)(B)) However, the walk-in
test procedure does not measure energy consumption from door-opening
infiltration so there is no rated energy saving from IRDs and DOE is
not estimating the amount of energy saved from IRDs on baseline doors.
b. Refrigeration
As with panels and doors, DOE set the baseline level of
refrigeration system performance to correspond to components that were
the least efficient but compliant with the standards set forth in EPCA.
See 42 U.S.C. 6313(f)(1)-(3). DOE determined specifications for each
equipment class by surveying currently available models. See chapter 5
of the TSD for more details about the specifications for each baseline
model.
In the preliminary analysis, DOE analyzed several representative
baseline units for refrigeration systems and requested comment on the
characterization of the baseline units. In response to DOE's request
for comment on the representative units analyzed, several stakeholders
expressed concern that the range of refrigeration systems DOE evaluated
was too limited. Heatcraft and the Joint Utilities encouraged DOE to
include larger capacity equipment and different compressor types.
(Heatcraft, No. 0058.1 at pp. 3-4; Heatcraft, No. 0069.1 at p. 2; Joint
Utilities, No. 0061.1 at p. 3) American Panel echoed this concern and
stated that DOE should explore the full range of condensing units and
that WICF envelopes should be paired with different sized refrigeration
systems based on use. (American Panel, No. 0048.1 at pp. 8-9) DOE has
considered these comments and has expanded its analysis to include a
larger range of refrigeration system capacities. DOE has also included
different compressor types in the refrigeration system analysis; see
section IV.C.5.b and chapter 5 of the TSD for details. DOE has not
considered pairing WICF envelopes and refrigeration systems in the
engineering analysis, however, because DOE is applying a component-
based approach.
The preliminary analysis also presented estimated baseline
specifications and costs for the representative units it analyzed.
American Panel remarked that the baseline costs in the engineering
analysis were too low and were not comparable to their data.
Additionally, it stated that the refrigeration load will increase if
the product is not at the same temperature as the walk-in cooler or
freezer. (American Panel, No. 0048.1 at p. 7) Interested parties also
commented on certain baseline unit subcomponents that were not included
in the engineering analysis. American Panel noted that baseline units
could include a downstream solenoid valve that would prevent
refrigerant from migrating to the evaporator and Heatcraft encouraged
DOE to make sure that the amount of refrigerant, piping, and insulation
scale properly with size. (American Panel, No. 0048.1 at p. 7;
Heatcraft, No. 0069.1 at p. 3)
In response to American Panel's comments on refrigeration system
costs, DOE adjusted its cost model as described in section IV.C.3 and
believes its costs are now more representative of typical equipment.
Regarding refrigeration load, DOE does not consider the effect of
different product loads in the engineering analysis because the
engineering analysis is based on the rating conditions; DOE considers
product loads in the energy use analysis as explained in section
IV.E.3. In response to American Panel's and Heatcraft's comments about
subcomponents of refrigeration equipment, the revised analysis now
includes all necessary subcomponents from the manufacturer--i.e., those
subcomponents needed for the unit to operate. The analysis includes a
calculation of refrigerant charge that is
[[Page 55813]]
scaled with the size of the unit, as Heatcraft suggested. DOE has
tentatively decided not to include piping and insulation between the
unit cooler and condensing unit, as it believes these components would
not be supplied by the manufacturer or included in the equipment's MSP,
but by the contractor upon installation of the equipment. DOE requests
comment on this assumption.
In the preliminary analysis, DOE made certain assumptions regarding
saturated evaporator temperature (SET) and saturated condensing
temperature (SCT) that it used in the analysis for freezers and coolers
and indoor and outdoor units. In general, DOE based these temperatures
on an assumed temperature difference (TD) between the coil temperature
and the ambient temperature where the ambient temperature for indoor
and outdoor units was specified by the rating conditions in AHRI 1250-
2009, the test procedure for refrigeration systems. 76 FR at 33631. The
Joint Utilities and Heatcraft both submitted comments about the
temperature set points in the baseline equipment; the Joint Utilities
suggested a condensing temperature control point of 90[emsp14][deg]F
for both freezers and coolers, while Heatcraft recommended different
temperatures for several equipment classes. (Joint Utilities, No.
0061.1 at p. 10; Heatcraft, No. 0069.1 at p. 2)
In determining appropriate temperature set points, DOE considered
information from various sources when formulating its assumptions,
including comments, research, and discussions with manufacturers and
other parties. DOE notes that the ambient temperature for the test
procedure is 90 and 95 [deg]F for indoor and outdoor condensing units,
respectively. Given that the system must maintain a reasonable TD
between the SCT and the ambient temperature, the SCT during the test
procedure would be higher than the 90-95 [deg]F assumption recommended
by the Joint Utilities. Even though the set point during actual use may
be lower, equipment is rated--and evaluated for meeting the standard--
at the test procedure rating points. For these reasons, DOE believes
its SCT assumptions are reasonable for baseline equipment operating at
the rating conditions required for the test procedure. DOE requests
comment on this assumption, particularly whether the TDs for baseline
and higher efficiency equipment are appropriate. See chapter 5 of the
TSD for details.
5. Design Options
a. Panels and Doors
For the preliminary analysis, DOE included the following design
options for the walk-in envelope:
Improved wall, ceiling, and floor insulation
Improved door gaskets and panel interface systems
Electronic lighting ballasts and high-efficiency lighting
Occupancy sensors and automatic door opening and closing
systems
Air curtains and strip curtains
Vestibule entryways
Display and window glass system insulation enhancements
Anti-sweat heater controls and no anti sweat heat systems
In the preliminary analysis, DOE presented tables detailing each
design option, including the cost of implementing each option and a
description of the design option's properties. The discussion below
sets forth comments received on these design options for panels and
doors, as well as DOE's proposed approach in today's NOPR.
Panels
Stakeholders commented on steady state IRDs that DOE initially
considered including as design options for the walk-in envelope. Craig
Industries commented that DOE should consider different caulking
materials as a design option because it is inexpensive and would reduce
infiltration by sealing the joints of walk-ins, but noted that this
design option would conflict with the current National Sanitation
Foundation (NSF) standards. (Craig Industries, No. 0064.1 at p. 3)
American Panel stated that changing the gasketing or joint profile of
an insulated panel would require a new test burden of $20,000, and that
the improved gasketing is not necessarily going to be functional. It
also noted that improved panel interfaces may not mate with existing
walk-in panels, which would prevent manufacturers from supplying
replacement panels. Lastly, in its view, the complex gasketing and
panel interface systems could cause walk-ins to become more difficult
to build. (American Panel, No. 0048.1 at p. 6; American Panel, Public
Meeting Transcript, No. 0045 at p. 121) Hill Phoenix commented that
enhancing the gasketing between panels will not have a significant
impact on the walk-in's energy consumption. In its view, the main heat
load caused by infiltration is from door openings as opposed to steady
state infiltration. (Hill Phoenix, No. 0066.1 at p. 3)
For the reasons stated in the test procedure final rule, the test
procedure promulgated by DOE no longer requires manufacturers to
measure a walk-in's steady-state infiltration. Therefore, design
options for reducing steady state infiltration, including caulking and
improved gasketing, would not impact the rated energy consumption of
any of the walk-in components addressed in this rulemaking. 76 FR
21580, 21595 (April 15, 2011). Furthermore, DOE would screen out any
design options (including caulking) that would be likely to have
significant adverse impacts on the utility of the equipment or had an
adverse impact on health or safety, according to the screening criteria
described in section IV.B.
In the preliminary analysis, DOE considered design options that
increased the baseline insulation thickness and improved insulation
material. The preliminary analysis used a baseline insulation thickness
of 4 inches and analyzed design options with increased insulation
thicknesses of 5 inches, 6 inches, and 7 inches. The baseline panel
insulation R-value was an average of extruded polystyrene and foamed-
in-place polyurethane. The improved insulation materials in the
preliminary analysis were vacuum insulated panel (VIP) insulation and
hybrid insulation, a combination of the baseline material and vacuum
insulated panels.
Many stakeholders commented on the proposed insulation
improvements. American Panel did not agree with the initial costs DOE
initially presented for the increased thicknesses of insulation. In its
view, costs were higher due to the increased difficulty of
manufacturing thicker panels. To accurately reflect this inefficiency,
American Panel suggested DOE increase the cost of labor per panel
because it takes more time to foam the fixture. (American Panel, No.
0048.1 at p. 5) American Panel also remarked that most manufacturers
possess tooling that is adjustable only from 4-6 inches. (American
Panel, Public Meeting Transcript, No. 0045 at p. 121) Hill Phoenix
stated that panel thicknesses above 5.5 inches will have a costly
impact on the manufacturer and end user because manufacturers need to
purchase more equipment to deal with the increased weight and the end-
user will need more floor space to house or site the walk-in. (Hill
Phoenix, No. 0066.1 at p. 3) American Panel criticized the preliminary
analysis for omitting insulating floor panels or an insulation slab
with vertical breaks as design options. American Panel explained that
although the payback period would be longer if these options
[[Page 55814]]
are included, DOE should still consider the long term energy savings
that these options may yield. (American Panel, No. 0048.1 at p. 5)
DOE agrees with American Panel that most manufacturers do not
currently have the tooling to produce panels with more than 6 inches of
insulation. In addition, DOE finds that constructing and handling
panels thicker than 6 inches would be unduly burdensome to the
manufacturer because panels thicker than 6 inches would be very
difficult to handle, store, ship, and produce at typical industry
production volumes. Because panels thicker than 6 inches would not be
practicable to manufacture, DOE screened them out from its analysis.
DOE's NOPR analysis limits the maximum insulation thickness to 6 inches
of foam and DOE does not expect its proposed standard to require panels
thicker than 5 inches (see chapter 5 and appendix 10D of the TSD);
however, the agency requests comment on this assumption in the
analysis. DOE notes Hill Phoenix's comment about the increased labor
cost associated with increasing the panel thickness and proposes to
account for the increased cost of handling large panels in its cost-
efficiency analysis. DOE also agrees with American Panel's comment that
requiring insulated floor panels for walk-in coolers would produce long
term energy savings. However, DOE is not proposing to set a standard
for walk-in cooler floors as explained in section IV.A.2.a of this
notice.
Two stakeholders made comments specifically about VIPs. NanoPore
stated that silica-carbon based core materials have a better lifetime
performance than fiberglass core materials when using vacuum insulated
panels, and noted that VIPs have reached a point of large scale
commercialization. (NanoPore, No. 0067.1 at pp. 1 and 6) However, Hill
Phoenix commented that VIPs are impractical because of the high cost to
the manufacturer, and that vacuum insulated panels would require
additional labor and tooling. (Hill Phoenix, No. 0066.1 at p. 3)
DOE included hybrid insulation (half foam-in-place polyurethane and
half VIP) as a design option to improve the efficiency of walk-in
panels and non-display doors. It did not, however, include VIP
insulation as a design option because DOE cannot definitively conclude
that VIPs have the structural capability of supporting typical walk-in
loads, particularly since VIPs can easily be punctured, which would
cause a loss in thermal insulation (see chapter 5 of the TSD for
details). DOE notes that while NanoPore stressed the benefits of
silica-carbon based VIP, DOE did not specify the type of VIP used in
the engineering analysis in order to maximize manufacturer flexibility
in meeting the proposed standard. DOE agrees with Hill Phoenix that
VIPs are more expensive and may require additional tooling, but DOE
does not find this increased cost would prevent manufacturers from
implementing VIPs. DOE also notes that the high costs of VIPs are
captured in the engineering analysis for panels and non-display doors.
In its engineering analysis for walk-in panels, DOE included design
options which increase the baseline insulation thickness, change the
baseline insulation material from foam-in-place polyurethane to a
hybrid of polyurethane and VIP, change the baseline framing material
from wood to high density polyurethane, and eliminate a structural
panel's framing material. DOE assumed in its analysis that freezer
floor panels retain some type of framing material to maintain
structural integrity because the foam itself may be unable to support
heavy, perpendicular loads--e.g. personnel, machinery, and products--to
the panel's face. DOE also assumed that high density polyurethane
framing materials used in a panel have the same dimensions as the wood
framing materials used in a wood-framed panel. DOE seeks comment on
these panel design options, particularly with respect to the
specifications for high density polyurethane framing materials.
Doors
Stakeholders also commented on design options that would reduce the
infiltration from door openings: namely, automatic door opening and
closing systems, which automatically open and close the door by sensing
when a person is about to pass or has passed through; air curtains and
strip curtains, both of which provide a secondary barrier to air
infiltration when the door is open; and vestibule entryways, which
consist of a series of two doors separated by a space through which one
would pass to enter the walk-in. Hired Hand noted that the engineering
analysis omitted automatic roll-up doors or bi-folding envelope doors,
and that these doors cannot be adequately subsumed under ``automatic
door opening and closing'' (which DOE did include) because this option
does not capture the full benefit of these doors. (Hired Hand, No.
0050.1 at pp. 1-2) American Panel was skeptical that automatic door
opening and closing sensors existed in the industry and did not agree
with DOE's proposed cost of the technology. (American Panel, No. 0048.1
at p. 6) American Panel also stated that a vestibule is not a practical
design option because the cost of the floor space and the layout of
standard stores would be prohibitive to the end user. It noted that the
cost of a vestibule is higher than DOE estimated, and predicted that
the cost for materials and equipment would be well over $2,500.
(American Panel, No. 0048.1 at pp. 3 and 6)
For the reasons stated in its recent final rule, the test procedure
does not include a method for measuring the door opening infiltration
associated with walk-ins. See 76 FR at 21595. Therefore, the energy
consumption caused by door opening infiltration is not accounted for in
the panel, display door, or non-display door engineering analyses, and
design options related to door opening infiltration would not affect
the energy consumption of the walk-in components.
Some stakeholders specifically commented about the strip curtains
design option. NEEA and NPCC stated that strip curtains are already
required by EPCA, and should not be considered a design option, but
that infiltration load could still be reduced by additional IRDs. (NEEA
and NPCC, Public Meeting Transcript, No. 0045 at p. 170; NEEA and NPCC,
No. 0059.1 at p. 8) NEEA, NPCC and Master-Bilt disagreed with DOE's
assumption that strip curtains can reduce the total energy consumption
of a walk-in by half. NEEA and NPCC suggested strip curtains would more
likely reduce the energy consumption by one third, according to a
Pacific Northwest study, and Master-Bilt commented that strip curtains
reduce the compressor load by less than 5 percent according to their
own field tests. (NEEA and NPCC, Public Meeting Transcript, No. 0045 at
p. 152; NEEA and NPCC, No. 0059.1 at p. 8; Master-Bilt, Public Meeting
Transcript, No. 0045 at p. 159; Master-Bilt, No. 0046.1 at p. 1)
American Panel noted that strip curtain manufacturers indicated that
the device achieves a 25 percent reduction in air infiltration, much
lower than DOE's assumption of 90 percent effectiveness. (American
Panel, Public Meeting Transcript, No. 0045 at p. 154; American Panel,
No. 0048.1 at p. 6) Lastly, AHRI also commented that DOE overestimated
the benefit of strip curtains, and that DOE should verify their
assumptions with field data; AHRI did not provide any alternative data
on the benefit of strip curtains. (AHRI, No. 0055.1 at p. 2) As
explained in section IV.B.1 of this document, however, infiltration
devices are no longer included in the engineering analysis.
[[Page 55815]]
Stakeholders also commented on the door lighting design options
presented in the preliminary analysis; specifically, occupancy sensors
that cause the lights to operate only when people are present;
electronic lighting ballasts, which are more efficient than typical
magnetic ballasts; and high-efficiency light-emitting diode (LED)
lighting, a type of lighting that uses semiconducting materials to
produce light and uses less energy per lumen than incandescent or
fluorescent lighting. American Panel stated that LED lighting is not a
viable design option because the LED fixture and bulb payback period is
2.5 years. (American Panel, No. 0048.1 at p. 6) The Joint Utilities
suggested that DOE should add LED lighting with motion controls as a
design option for display cases. (Joint Utilities, Public Meeting
Transcript, No. 0045 at p. 26; Joint Utilities, Public Meeting
Transcript, No. 0045 at p. 89; Joint Utilities, No. 0061.1 at p. 3)
In response to American Panel's concern about the cost of LED
lighting, DOE accounts for the cost of the bulb and fixture when
estimating the total cost of LED lighting. However, DOE has not
automatically eliminated LED lighting from consideration based on
payback period but includes it in the range of design options it is
considering. For more details on the payback period analysis, see
section IV.F. In response to the suggestion from Joint Utilities, a
combined design option with LED lighting and motion control sensors is
not warranted because DOE already includes a lighting sensor and LED
lighting as separate design options in the walk-in display door
engineering analysis. A separate design option for lighting sensors
allows the sensor to be applied to fluorescent as well as LED lighting.
Some stakeholders commented on the anti-sweat heater wire design
option. CrownTonka commented that anti-sweat heater wire should be
applied to non-display freezer doors and any windows in non-display
doors. (CrownTonka, Public Meeting Transcript, No. 0045 at p. 89) Craig
Industries supported the inclusion of self-regulating heater wire and
noted that this wire is readily available and more efficient than other
types of heater wires. (Craig Industries, No. 0064.1 at p. 1) DOE
agrees with CrownTonka and proposes to include anti-sweat heater wire
around the outer edge of non-display freezer doors as well as on the
windows located on non-display doors as design options. In response to
Craig Industries' suggestion, the energy savings from self-regulating
anti-sweat heater wire alone cannot be captured in the proposed
engineering analysis for display and non-display doors because the
energy savings are not captured by the test procedure. The test
procedure credits the manufacturer with energy savings if a
preinstalled timer, control system or other auto-shut-off system is
used in conjunction with anti-sweat heater wire. The credit is called a
percent time off (PTO) credit, which reduces the calculated power
associated with the device. 76 FR 33631, 33635, 33637 (June 9, 2011).
The display door design options used in the analysis include
improved glass packs--where ``glass pack'' refers to the combination of
glass panes, gas fill, and low-emission coatings making up the
transparent part of the door; anti-sweat heater controls for cooler
doors; LED lighting; and lighting sensors that control when the lights
turn on and off. DOE did not analyze anti-sweat heater controls for
freezer display doors because baseline freezer doors are already
required to have a controller to regulate the power consumed by the
anti-sweat heater wire. EISA requires all freezer doors to have an
anti-sweat heater control if the anti-sweat heater wire consumes more
than 7.1 watts per square foot of door opening, and DOE estimated that
baseline display doors consume 15.2 watts per square foot of door
opening. Therefore, baseline display doors already have an anti-sweat
heater wire control system in order to comply with EISA.
As explained previously, the walk-in cooler and freezer test
procedure credits the manufacturer for having a control. The type or
amount of controls does not change the credit nor increase the energy
savings realized by the DOE test procedure. For these reasons, DOE did
not include control systems as a design option. Additionally, DOE did
not consider eliminating anti-sweat heater wire as a separate design
option. The improvements made to the glass pack cause a reduction in
the power draw of the anti-sweat heater wire. In the case of display
cooler doors, the performance of the glass pack is improved enough so
that anti-sweat heater wire is no longer required on the door. DOE also
did not consider higher efficiency ballasts in its analysis because it
found that electronic ballasts already incorporated into baseline units
and DOE is not aware of more efficient ballasts. DOE requests comment
on its analyzed design options and specifically seeks any heat transfer
data for the improved glass packs detailed in chapter 5 of the TSD.
The design options that DOE analyzed in the engineering analysis
for non-display doors include increasing the insulation thickness,
changing the insulation material from baseline to a hybrid of
polyurethane and VIP, changing the baseline framing material from wood
to high density polyurethane, improving the window's glass pack, and
adding an anti-sweat heater wire controller to the door. These options
are more fully described in chapter 5 of the TSD. DOE requests comment
on the non-display door design options it analyzed, particularly with
respect to the cost of the window improvements detailed in chapter 5 of
the TSD.
American Panel suggested that DOE consider low cost methods for
extending the envelope and door lifetimes. (American Panel, No. 0048.1
at p. 9) DOE has not considered options in this analysis that do not
improve the rated performance of the equipment, as described in section
IV.B.1. The purpose of the engineering analysis is to analyze the
manufacturing cost and the performance of the covered equipment as
rated by the test procedure. Examining methods to extend the life of
walk-in equipment, including the impact of such methods on standards
adopted by DOE, would complicate and create a significant impediment to
completion of this rulemaking, without any clear prospect that it would
affect the standards DOE ultimately adopts. For this reason, DOE has
decided not to pursue this issue.
After considering all the comments it received on the design
options, DOE is including the following design options in the NOPR
analysis for panels, display doors, and non-display doors:
Panels
Increased insulation thickness up to 6 inches
Improved insulation material
Improved framing material
Display Doors
High-efficiency lighting
Occupancy sensors
Display and window glass system insulation performance
Anti-sweat heater controls
Non-Display Doors
Increased insulation thickness up to 6 inches
Improved insulation material
Improved panel framing material
Display and window glass system insulation performance
Anti-sweat heater controls
No anti-sweat systems
b. Refrigeration
In the preliminary analysis, DOE included the following design
options for the walk-in refrigeration system:
High-efficiency compressors
[[Page 55816]]
Improved condenser coil
High-efficiency condenser fan motors
Improved condenser fan blades
Improved evaporator coil
Improved evaporator fan blades
Evaporator fan controls
Floating head pressure
Defrost controls
The preliminary analysis contained tables detailing each design
option, including the cost of implementing each option and a
description of the design option's properties. The discussion below
sets forth comments received on these design options for refrigeration
systems, as well as DOE's proposed approach in today's NOPR.
One option DOE considered was high-efficiency compressors. For
example, DOE suggested using scroll compressors to represent the
performance associated with higher efficiency compressors in walk-in
applications. In response, Master-Bilt and Heatcraft commented that
scroll compressors are not necessarily more efficient than other
compressor types and are limited by their application and the prevalent
conditions in which the compressor operates. (Master-Bilt, Public
Meeting Transcript, No. 0045 at p. 1; Heatcraft, No. 0058.1 at p. 2)
Heatcraft also stated that with increasing horsepower, fewer compressor
types are available. (Heatcraft, No. 0069.1 at p. 1) The Joint
Utilities added that for larger walk-in units, semi-hermetic
compressors are more efficient than scroll types--except at low
temperatures where, in their view, scroll compressors are more often
utilized--but they did not provide information supporting the same. In
addition, the Joint Utilities stated that hermetic compressors hold an
added cost advantage over semi-hermetic compressors. (Joint Utilities,
No. 0061.1 at pp. 6 and 10) With regard to the types of compressors
used in the food service market, American Panel suggested that hermetic
compressors were dominant and stated that semi-hermetic compressors'
high initial cost made them less prevalent generally. (American Panel,
No. 0048.1 at p. 9)
DOE conducted additional research on available compressors and
found that the prevalence of some compressor types varied at certain
sizes. DOE also ensured that its analysis accounted for the effect that
different applications and conditions may have on the relative
efficiency of compressor types. In particular, the NOPR analysis
includes an evaluation of a wide range of refrigeration capacities, and
DOE has separately evaluated the different compressor types available
at each capacity point. DOE believes that this modified analysis
adequately captures the performance of each compressor type at each
size and set of operating conditions.
To obtain data on compressor performance, DOE's preliminary
analysis relied on manufacturer Web sites and related product
specification sheets and did not consider the effect of the return gas
conditions. The compressor data were based on return gas conditions
under which the individual compressors were rated. The Joint Utilities
stated that the return gas conditions were inconsistent with the
typical operating conditions of walk-ins. (Joint Utilities, Public
Meeting Transcript, No. 0045 at p. 27 and No. 0061.1 at p. 11) In
consideration of the Joint Utilities' comment, DOE investigated the
effect of the return gas conditions on compressor performance and has
updated the compressor characteristics using return gas conditions that
are consistent with the rating conditions in AHRI 1250-2009, which are
different from the rating conditions for individual compressors. The
conditions are contained within AHRI 1250-2009 itself, which DOE has
incorporated into its test procedure. 76 FR at 33631.
After considering the stakeholder comments and conducting further
research, DOE expanded its initial compressor range beyond scroll
compressors and hermetic compressors to now include semi-hermetic
compressors in the list of compressor options in order to capture most
of the market share. This was done specifically due to the varying
compressor efficiencies at different operating temperatures, and the
lack of availability of certain compressor types at all capacity
ranges. For example, it is difficult to obtain hermetic compressors at
capacities exceeding 30,000 Btu/h, so manufacturers may be more likely
to use semi-hermetic compressors at these capacities as a lower-cost
alternative to scroll compressors.
The preliminary TSD discusses the evaporator and condensing coil
baseline and improved efficiency as coil size increases. In that
analysis, DOE selected increased coil size as a design option because
increasing the coil size corresponds to a drop in temperature
difference, which would increase compressor capacity and result in
lower normalized energy consumption.
DOE received several comments about heat exchanger coil size and
the associated savings. The Joint Utilities, Manitowoc and Heatcraft
commented that the analysis did not consider an increase in fan power
with an increase in coil size. (Joint Utilities, Public Meeting
Transcript, No. 0045 at p. 27 and No. 0061.1 at p. 6; Manitowoc, No.
0056.1 at p. 2; Heatcraft, No. 0058.1 at pp. 2 and 3) American Panel
stated that increasing condenser coil size would also require an
increase in evaporator coil size, while Manitowoc suggested that the
coil heat transfer equation should use log-mean temperature. (American
Panel, No. 0048.1 at p. 6; Manitowoc, No. 0056.1 at p. 2)
After carefully considering these comments, DOE modified its
analysis by increasing fan power proportionally to coil size. DOE found
through its analysis, however, that as coil size increases, the
decrease in compressor power far exceeds the increase in fan power,
which ultimately decreases the net energy consumption. As a result, DOE
retained increased coil size as a design option in its analysis. DOE
agrees with Manitowoc's comment that using log mean temperature
difference is a more accurate way to calculate heat transfer because
this method accounts for changes in air temperature and refrigerant
temperature across the refrigerant coil rather than assuming that these
temperatures are constant. DOE's analysis had used a simplified form of
the heat transfer equations in the preliminary analysis, but now
includes a log mean temperature difference in its analysis for the
NOPR. In response to American Panel's comment about requiring an
increase in evaporator coil with condenser coil, DOE has taken a
complete system modeling approach in analyzing the refrigeration
system's performance to capture any effects on the evaporator
conditions from condenser coil changes. At this point, DOE believes
that increasing the coil size of the condenser does not necessarily
require an increase in coil size for the evaporator because the
manufacturer would balance other aspects of the system to maintain the
same capacity. DOE requests comment on this assumption, particularly
from manufacturers who currently utilize larger condenser coils.
Condenser Fan Motors
In chapter 5 of the preliminary TSD, DOE discussed more efficient
condenser fan motors as a viable design option. EPCA requires that
walk-in condenser fan motors of less than 1 horsepower must use
permanent split capacitor motors, electronically commutated motors, or
three-phase motors. (42 U.S.C. 6313(f)(1)(F)) Permanent split capacitor
(PSC) motors are less expensive and less efficient than electronically-
commutated (EC) motors and are currently used by the majority of
manufacturers. DOE also assumed the
[[Page 55817]]
same motor efficiencies for PSC and EC motors that were assumed in the
ANSI/ARI Standard 1200-2006--that is, 29 percent and 66 percent
respectively. (The analysis screened out three-phase motors as a design
option based on utility to the consumer, as explained in section
IV.B.2.b, although manufacturers may still use this technology to
improve the overall efficiency of the equipment they manufacture.)
DOE received comments about the assumed efficiency of fan motors.
Manitowoc commented that DOE's assumed efficiency for PSC motors was
too low and should be about 50 percent, while Heatcraft stated that PSC
motor efficiency would likely be between 45 and 55 percent, three-phase
motor efficiency would be approximately 80 percent, and EC motor
efficiency would range from 60 to 90 percent. (Manitowoc, No. 0056.1 at
p. 2; Heatcraft, No. 0058.1 at p. 2 and No. 0069.1 at p. 2) The Joint
Utilities suggested that the methodology of determining input power
from efficiency ratings for small motors was inaccurate. (Joint
Utilities, No. 0061.1 at p. 8) Heatcraft provided a list of parts to be
added to the engineering analysis. (Heatcraft, No. 0069.1 at p. 1)
DOE has considered the suggestions of Manitowoc and Heatcraft
regarding motor efficiency and has changed its assumptions for PSC
motors to 50 percent and EC motors to 75 percent after researching
currently available motors. Additionally, regarding comments received
from Heatcraft about three-phase motors, DOE did not include three-
phase motors as a design option or as part of the design of smaller
baseline equipment due to adverse utility to the consumer and
impracticability to manufacture, install and service, because many
consumers do not have three-phase power sources; however, DOE assumed
that larger baseline equipment would use three-phase motors. See
section IV.B.2.b for more details. DOE also included in its analysis
the fan motor parts Heatcraft identified after evaluating teardown data
and conducting further analysis of those parts. In response to the
Joint Utilities' comment that DOE should not determine input power from
efficiency ratings, DOE has used this method as its best estimate for
motor power consumption. DOE has not identified a more accurate
methodology for determining input power and requests feedback on this
issue.
Chapter 5 of the preliminary TSD presented several fan blade
options for the evaporator and condenser fan blade design option.
Responding to these options, Heatcraft suggested the inclusion of swept
fan blades as they are more aerodynamic and reduce vibrations and noise
that result in inefficiencies. In addition, it also suggested that
motor efficiency is independent from fan blade efficiency because more
efficient fan blades do not result in high efficiencies for motors and
vice versa. Rather, the efficiency of each component is due to its own
intrinsic characteristics. After considering Heatcraft's comment, DOE
is continuing to treat the motor and fan blade options separately.
The preliminary analysis examined evaporator fan controls as a
design option. The impacts of fan controls were analyzed consistent
with the test procedure requirement that ``controls shall be adjusted
so that the greater of a 25 percent duty cycle or the manufacturer
default is used for measuring off-cycle fan energy. For variable-speed
controls, the greater of 25 percent fan speed or the manufacturer's
default fan speed shall be used for measuring off-cycle fan energy.''
Because of this requirement, DOE set a 75 percent reduction in off-
cycle fan energy as the energy savings achieved for the fan control
technology option. DOE did not differentiate between modulated fan
controls and variable speed fan controls in the preliminary analysis.
DOE received comments both on its characterization of the fan control
design option and on the energy results for that design option. NEEA
and NPCC expressed concern that DOE's analysis caused the evaporator
fan control option to appear less cost-effective compared to other
design options, possibly indicating that DOE underestimated its
potential energy savings. (NEEA and NPCC, No. 0059.1 at p. 7) The Joint
Utilities cited studies indicating that fan speed control is one of the
most, if not the most, cost-effective design option for many
refrigeration systems. (Joint Utilities, Public Meeting Transcript, No.
0045 at p. 28; No. 0061.1 at pp. 2 and 6) The Joint Utilities also
criticized DOE's initial approach of not distinguishing between fan
cycling and fan speed control. They indicated that the approach taken
by DOE overly simplified the analysis, which then yielded considerably
smaller projected savings for multiplex systems. Because of the
complexity of the size ranges and system variations of these units, a
more detailed analysis than the single design option used in the
preliminary analysis is, in their view, required to sufficiently
evaluate the potential energy savings from using a fan control system.
They recommended that an analysis of fan speed controls include the
benefit of operating at reduced fan speeds for the majority of the time
the system operates. (Joint Utilities, No. 0061.1 at pp. 6 and 9) NEEA
and NPCC agreed with DOE's approach insofar as fan controls that adjust
envelope interior temperature conditions should be applied to every
walk-in. (NEEA and NPCC, No. 0059.1 at p. 7)
Some interested parties also cautioned DOE about the unintended
consequences of implementing different types of fan controls. The Joint
Utilities stated that a fan duty-cycling control strategy would be
unacceptable in many applications because of the increased likelihood
of uneven temperatures and the related concern for perishable products.
(Joint Utilities, No. 0061.1 at p. 9) Zero Zone stated that variable
speed evaporator fan motors could prevent the walk-in from maintaining
the desired product temperature. (Zero Zone, No. 0051.1 at p. 1)
American Panel stated that if fan controls cause the compressor to run
for longer periods, energy consumption will increase because the
compressor draws more power than the fans. American Panel also
recommended that DOE ensure that whatever standards it may propose,
that air defrost evaporators still be able to defrost ice build-up on
refrigeration coils during off-cycle periods using lower fan speeds.
(American Panel, No. 0048.1 at p. 7)
One interested party commented on DOE's assumed cost of the fan
control option. The Joint Utilities stated that the assumed cost of
$300 for fan control would likely be lower, particularly for small
walk-ins, because the EC motors have inherent variable speed capability
and the microcontrollers used to control these motors can provide the
required voltage signal to control the EC motors. (Joint Utilities, No.
0061.1 at p. 9)
To address these concerns, DOE has made several changes to its fan
control analysis. DOE is now considering both modulated (fan cycling)
and variable speed controls as potential design options. Modulated fan
controls cycle the fans at 50 percent runtime at 100 percent speed when
the compressor is off, while variable speed controls set the fan speed
to 50 percent of maximum speed at 100 percent runtime when the
compressor is off. DOE's analysis applies the commonly used fan power
laws, which describe the relationship between power and speed during a
fan's operation. A reduction in fan speed causes a reduction in fan
power to the third power. For example, reducing speed to 50 percent of
full speed reduces the power to 12.5 percent of full power. Thus,
variable speed controls
[[Page 55818]]
would be expected to save more energy than modulated fan controls for
the particular control strategies analyzed.
DOE applied both modulated fan controls and variable speed fan
controls as a design option for all classes analyzed. DOE did not,
however, consider controls that respond to specific box conditions
because, as stated in the test procedure final rule, the impact of
these controls would not be captured using the component-level
approach, which analyzes refrigeration systems separately from envelope
components. DOE notes that, as a result of the enhancements made to its
analytical approach, the NOPR analysis indicates that modulated and
variable speed fan controls would likely be among the primary options
to improve walk-in refrigeration system efficiency.
DOE appreciates the concerns about fan controls raised by American
Panel, the Joint Utilities, and Zero Zone. DOE's research does not
indicate that air defrost would be adversely affected by fan controls.
Therefore, air defrost would likely still be adequate with reduced fan
speed. To address commenters' concerns about the potential effects of
fan controls on food safety, DOE estimates that the outcome of using
such controls would be equivalent to an overall 50 percent decrease in
runtime (for a cycle control) or a 50 percent decrease in speed (for a
variable-speed control) and has tentatively concluded that the impact
of the controls it analyzed will be limited and not affect the
maintenance of safe food temperatures. See chapter 5 for details. DOE
requests comment from interested parties as to whether food
temperatures would be adequately maintained in the specific control
cases it has analyzed and, if not, what an appropriate control strategy
would be. DOE seeks any data that interested parties can provide to
show the relationship between fan controls and food temperatures. DOE
also seeks information as to whether additional components are
necessary to ensure food temperature, such as extra thermostats located
in certain areas of the walk-in. To address American Panel's comment
about compressor runtime, DOE does not expect compressor runtime to
increase from the inclusion of fan control implementation because the
fans run at full speed while the compressor is running and fan speed or
cycling controls are activated only when the compressor is off. DOE
also does not expect controls to increase the amount of time the
compressor is off because the compressor cycles on based on the walk-
in's interior temperature, which DOE believes will not be significantly
affected by the fan control strategy modeled in the analysis.
Defrost Controls
In the preliminary analysis, DOE evaluated several defrost control
options available in the market. DOE considered using time-initiated,
time-terminated defrost as the baseline. The design option involved a
generic defrost control that would result in half as many defrosts per
day. Heatcraft and American Panel doubted whether existing defrost
controls could achieve the 50 percent reduction in defrosts assumed in
the preliminary analysis. (American Panel, No. 0048.1 at p. 7;
Heatcraft, No. 0058.1 at p. 4) In addition, Heatcraft, American Panel
and the Joint Utilities suggested DOE replace time termination with
temperature termination in the base case. (Heatcraft, No. 0058.1 at p.
4; American Panel, No. 0048.1 at p. 7; Joint Utilities, Public Meeting
Transcript, No. 0045 at p. 26) Heatcraft and the Joint Utilities also
noted that defrost time should be dependent on system size to account
for the greater surface area of larger units and suggested that the
baseline defrost control strategy be a time-initiated, temperature-
terminated scheme, which is the industry standard. (Heatcraft, No.
0058.1 at pp. 3-4; Joint Utilities, No. 0061.1 at p. 3)
In response to comments received about defrost control, DOE's
analysis now applies a temperature-terminated defrost approach for all
defrost control schemes (baseline or higher). The defrost cycle ends
once the coil temperature reaches 45[emsp14][deg]F. For the defrost
design option, DOE is continuing to apply a generic defrost control
that would reduce the number of defrosts per day. The magnitude of the
reduction is set at 40 percent, which is less than the 50 percent level
originally assumed in the preliminary analysis. DOE chose this reduced
level because it would result in significant energy savings while still
maintaining adequate defrost capability. Further details about the
defrost control parameters are found in chapter 5 of the TSD.
Floating Head Pressure
In the preliminary analysis, DOE also considered floating head
pressure as a design option. With floating head pressure, the
compressor pressure and the saturated condensing temperature (SCT)
float down to the minimum level at which the compressor can operate.
DOE assumed that floating head pressure would allow the SCT to float
down to 70[emsp14][deg]F. DOE also assumed that the SCT would decrease
at the same rate as the ambient temperature such that the system would
maintain the same temperature difference (TD) between the SCT and the
ambient air. This change resulted in a predicted reduction in energy
consumption because compressors generally run more efficiently at a
lower SCT. The capacity of the system was related to the SCT and the
TD.
Some interested parties commented on DOE's assumptions relating to
floating head pressure. Heatcraft disagreed with DOE's assumption that
the TD would be constant as SCT decreases and stated that the TD
increases as SCT decreases. To illustrate its point, Heatcraft
calculated the TD of a system at an SCT of 115[emsp14][deg]F and again
at an SCT of 70[emsp14][deg]F and found that the ratio of the condenser
TD between these two SCT conditions would be approximately 1.19, not
1.0 (where a ratio of 1.0 would correspond to no change in TD as SCT
decreases). This value was calculated using the total heat of rejection
(THR) of the condenser. (Heatcraft, No. 0058.1 at p. 4) The Joint
Utilities had several comments relating to the implementation of
floating head pressure. They recommended that DOE account for the
additional fan power required for floating head pressure, and stated
that varying the speed of condenser fans as part of a floating head
pressure control has effects on the system such as more stable
operation of the expansion valve and less likelihood of compressor
damage due to liquid refrigerant reaching the compressor. (Joint
Utilities, No. 0061.1 at pp. 6 and 10) The Joint Utilities also
identified two different head pressure control types that have an
impact on projected energy savings: fan control or fan cycling and a
condenser valve to maintain the minimum condensing temperature. (Joint
Utilities, No. 0061.1 at p. 10) Finally, the Joint Utilities pointed
out that if a lower initial or baseline SCT value is assumed, the
estimated savings for floating head pressure will be less. (Joint
Utilities, No. 0061.1 at p. 10)
To account for the suggestions made by commenters, DOE has
implemented changes to its NOPR analysis of floating head pressure.
First, DOE investigated the control methods identified by the Joint
Utilities. In the current model used for the NOPR analysis, fan
modulation is implemented in the baseline to maintain a fixed head
pressure. When floating head pressure is implemented, a valve and
accompanying controls are added to maintain a minimum condensing
temperature. Regarding the comments on fan power submitted by the Joint
Utilities, DOE agrees that at lower ambient temperatures, the
[[Page 55819]]
required fan airflow is higher when floating head pressure is
implemented because the TD is smaller. DOE's current energy model
calculates the fan power necessary to maintain adequate heat transfer
when floating head pressure is implemented. DOE assumed that condenser
fans would be modulated in the baseline; variable speed condenser fans
are considered as a separate design option. DOE's model calculates the
energy savings of variable speed condenser fans with or without
floating head pressure implemented. The energy model does not capture
increased stability in the expansion valve or the reduced possibility
of compressor damage because the energy model attempts to capture the
performance as rated by the test procedure, and for the reasons stated
in the test procedure final rule, the test procedure established by DOE
is designed to rate only certain aspects of the equipment--e.g., AWEF
and capacity. 76 FR 21580, 21597-21598 (April 15, 2011).
DOE also assumes that a system tested by the manufacturer would
likely be a new system, which is unlikely to experience decreased
stability in the expansion valve; therefore, DOE did not capture
expansion valve stability in the energy model. The energy model also
does not capture long-term compressor damage because DOE assumes the
test procedure would be performed at the point of manufacture of the
equipment, and would therefore not capture such damage to the
compressor. Compressor replacement is, however, addressed in the life
cycle cost analysis (see section IV.F.6). Any additional benefits that
accrue due to reduced maintenance are also not captured in the
engineering analysis.
DOE also acknowledges the Joint Utilities' observation that the
savings for the floating head pressure option depends on the baseline
SCT and DOE's energy modeling confirms their assertion that the
floating head pressure option would appear to save less energy if the
baseline SCT were lower. However, DOE chose certain baseline SCT values
for each class that would be realistic considering the equipment rating
conditions, as explained in section IV.C.4.b. To address Heatcraft's
comment that TD would increase with decreasing SCT, DOE analyzed the
total heat of rejection of sample systems using the specified
temperatures in the test procedure and found an average TD ratio
corresponding to each compressor type analyzed. DOE implemented the TD
ratio in the engineering analysis. See chapter 5 of the TSD for more
details on the floating head pressure design option. DOE requests
comment on its assumptions and implementation of this option,
particularly regarding the cost to implement various floating head
pressure control schemes and the energy savings that would be achieved.
Refrigeration Summary
After considering all the comments it received on the design
options, DOE is including the following design options in the NOPR
analysis:
Higher efficiency compressors
Improved condenser coil
Higher efficiency condenser fan motors
Improved condenser and evaporator fan blades
Ambient sub-cooling
Evaporator and condenser fan control
Defrost control
Hot gas defrost
Head pressure control
Each design option is explained in detail in chapter 5 of the TSD.
6. Cost-Efficiency Results
a. Panels and Doors
In the preliminary analysis, DOE plotted total energy consumption
in kilowatt-hours per day versus the increasing cost of representative
walk-in envelopes. Because DOE is proposing to set component level
standards, each of the three main products that make up walk-in
envelopes have independent cost-efficiency curves. For panels, DOE
measured the U-factor, a measure of thermal conductivity expressed in
British thermal units per hour-square foot-Fahrenheit (Btu/h-ft\2\-F);
that is, the heat conducted through the panel per unit time, per square
foot of panel surface area, per degree Fahrenheit. A lower U-factor
corresponds to less heat conducted through the panel, indirectly
decreasing the energy use of the walk-in because the refrigeration
system does not have to expend additional energy to remove heat from
the walk-in. DOE plotted the decrease in U-factor versus the increase
in cost of a single panel. For non-display doors and display doors, DOE
plotted energy consumption in kWh/day versus the increasing cost of an
individual non-display door. For a more detailed description of the
engineering analysis results, see appendix 5A of the TSD.
b. Refrigeration
In the preliminary analysis, DOE chose refrigeration system sizes
that best represented the market, but did not attempt to match the
refrigeration systems to any particular envelope in the engineering
analysis. DOE received several comments on the preliminary analysis
regarding matching the refrigeration system to the envelope size.
American Panel suggested that, because of their interdependence,
refrigeration and walk-in size should be analyzed together. (American
Panel, Public Meeting Transcript, No. 0045 at p. 115) NEEA, NPCC,
Heatcraft, and American Panel recommended that the refrigeration system
size match the envelope size. (NEEA and NPCC, No. 0059.1 at p. 9,
Heatcraft, No. 0069.1 at p. 1, American Panel, No. 0048.1 at p. 4)
DOE is proposing to regulate the refrigeration system as an
individual component in accordance with its proposed component-level
approach, and is also analyzing the individual components of an
envelope (panels and doors), rather than the entire envelope. For these
reasons, DOE did not attempt to match refrigeration systems with any
particular envelope size. Rather, DOE chose refrigeration system sizes
for the analysis that capture the range of systems that might be used
in a walk-in.
In the preliminary analysis, DOE plotted the cost-efficiency data
points using normalized energy consumption for its engineering
analysis. AHRI recommended using AWEF and commented that the normalized
values favor design options, which, in its view, do not necessarily
reduce energy consumption. The Joint Utilities believed that non-
normalized values would be helpful to understand the analyses. (AHRI,
No. 0055.1 at pp. 2-3; Joint Utilities, Public Meeting Transcript, No.
0045 at p. 171) Consistent with the test procedure final rule and
AHRI's suggestion, DOE is using AWEF to construct its cost-efficiency
curves. See 76 FR 21597-21598, 10 CFR 431.302.
In chapter 5, Appendix A of the preliminary TSD, DOE provided cost-
efficiency curves for all the equipment classes. Numerous stakeholders
requested that DOE provide more detail about the methodology behind the
cost efficiency curves because they are concerned about the accuracy of
these curves. (Emerson, Public Meeting Transcript, No. 0045 at p. 165;
AHRI, Public Meeting Transcript, No. 0045 at p. 169 and No. 0055.1 at
p. 2,4; Manitowoc, No. 0056.1 at p. 2 and Public Meeting Transcript,
No. 0045 at p. 125) Additionally, Manitowoc suggested that a broader
view of the industry's costs and sizes is required to improve the
accuracy of the results (Manitowoc, Public Meeting Transcript, No. 0045
at p. 162)
DOE appreciates the stakeholder comments and notes that it has
updated
[[Page 55820]]
its initial cost-efficiency curves based on changes to its analysis.
DOE has provided more detail in this NOPR and the NOPR TSD about the
calculation methodology used in the engineering analysis, particularly
due to the publication of the test procedure final rule. DOE also
updated its analysis with the most recent pricing data related to the
costs of materials and purchased parts and adjusted the projected
energy savings of certain design options as detailed in section
IV.C.5.b.
c. Numerical Results
Table IV-8, Table IV-9, Table IV-10, and Table IV-11 present cost-
efficiency data for panels, display doors, non-display doors, and
refrigeration systems, respectively. For refrigeration systems, because
of the large number of analysis points, DOE presents results for only
one type of system, DC.L.O, in this notice. See appendix 5A of the TSD
for complete cost-efficiency results.
Table IV-8--Cost-Efficiency Results for Panels
--------------------------------------------------------------------------------------------------------------------------------------------------------
Efficiency level
Class/size ------------------------------------------------------------------------------------------
Baseline 1 2 3 4 5 6
--------------------------------------------------------------------------------------------------------------------------------------------------------
SP.M.SML............................ Cost [$]............... $54 $58 $61 $67 $73 $86 $231
U-factor [Btu/h-ft-F].. 0.082 0.046 0.040 0.032 0.027 0.024 0.011
SP.M.MED............................ Cost [$]............... $153 $159 $165 $179 $192 $229 $615
U-factor [Btu/h-ft-F].. 0.061 0.043 0.038 0.030 0.025 0.024 0.011
SP.M.LRG............................ Cost [$]............... $240 $247 $256 $276 $296 $354 $951
U-factor [Btu/h-ft-F].. 0.056 0.042 0.037 0.030 0.025 0.024 0.011
SP.L.SML............................ Cost [$]............... $56 $61 $67 $73 $86 $231 ...........
U-factor [Btu/h-ft-F].. 0.073 0.040 0.032 0.027 0.024 0.011 ...........
SP.L.MED............................ Cost [$]............... $159 $165 $179 $192 $229 $615 ...........
U-factor [Btu/h-ft-F].. 0.053 0.038 0.030 0.025 0.024 0.011 ...........
SP.L.LRG............................ Cost [$]............... $249 $256 $276 $296 $354 $951 ...........
U-factor [Btu/h-ft-F].. 0.050 0.037 0.030 0.025 0.024 0.011 ...........
FP.L.SML............................ Cost [$]............... $85 $93 $97 $104 $111 $270 ...........
U-factor [Btu/h-ft-F].. 0.071 0.041 0.036 0.030 0.025 0.018 ...........
FP.L.MED............................ Cost [$]............... $176 $190 $195 $209 $222 $566 ...........
U-factor [Btu/h-ft-F].. 0.059 0.039 0.035 0.029 0.024 0.015 ...........
FP.L.LRG............................ Cost [$]............... $301 $322 $331 $353 $374 $973 ...........
U-factor [Btu/h-ft-F].. 0.054 0.039 0.035 0.028 0.024 0.014 ...........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV-9--Cost-Efficiency Results for Display Doors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Efficiency level
Class/size ------------------------------------------------------------------------------------------
Baseline 1 2 3 4 5 6
--------------------------------------------------------------------------------------------------------------------------------------------------------
DD.M.SML............................ Cost [$]............... $277 $274 $340 $423 $544 $710 $1,375
Energy Use [kWh/day]... 2.50 1.74 0.98 0.84 0.68 0.58 0.38
DD.M.MED............................ Cost [$]............... $357 $354 $420 $530 $651 $870 $1,751
Energy Use [kWh/day]... 2.91 2.15 1.14 0.96 0.80 0.66 0.40
DD.M.LRG............................ Cost [$]............... $470 $478 $544 $692 $813 $1,108 $2,291
Energy Use [kWh/day]... 3.76 2.78 1.43 1.18 0.99 0.81 0.46
DD.L.SML............................ Cost [$]............... $509 $506 $627 $793 $960 $1,375 ...........
Energy Use [kWh/day]... 5.22 4.34 4.14 2.73 2.02 1.66 ...........
DD.L.MED............................ Cost [$]............... $643 $640 $761 $980 $1,202 $1,751 ...........
Energy Use [kWh/day]... 6.47 5.58 5.39 3.49 2.56 2.08 ...........
DD.L.LRG............................ Cost [$]............... $831 $839 $1,135 $1,432 $1,553 $2,291 ...........
Energy Use [kWh/day]... 8.54 7.40 4.83 3.57 3.36 2.70 ...........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV-10--Cost-Efficiency Results for Non-Display Doors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Efficiency level
Class/size ---------------------------------------------------------------------------------------------
Baseline 1 2 3 4 5 6 7 8 9
--------------------------------------------------------------------------------------------------------------------------------------------------------
PD.M.SML........................... Cost [$]............. $180 $184 $210 $214 $222 $273 $281 $487 $655 .......
Energy Use [kWh/day]. 0.30 0.27 0.22 0.22 0.21 0.17 0.16 0.04 0.02 .......
PD.M.MED........................... Cost [$]............. $210 $214 $240 $245 $255 $306 $316 $522 $741 .......
Energy Use [kWh/day]. 0.32 0.28 0.24 0.23 0.22 0.18 0.17 0.05 0.03 .......
PD.M.LRG........................... Cost [$]............. $265 $270 $296 $303 $316 $368 $381 $587 $904 .......
[[Page 55821]]
Energy Use [kWh/day]. 0.36 0.31 0.27 0.25 0.24 0.20 0.19 0.06 0.04 .......
PD.L.SML........................... Cost [$]............. $235 $240 $291 $342 $351 $359 $425 $553 $728 .......
Energy Use [kWh/day]. 7.08 6.96 6.52 6.26 6.23 6.20 6.07 6.01 5.98 .......
PD.L.MED........................... Cost [$]............. $265 $270 $322 $373 $383 $393 $459 $587 $814 .......
Energy Use [kWh/day]. 7.82 7.69 7.25 6.99 6.95 6.92 6.79 6.72 6.67 .......
PD.L.LRG........................... Cost [$]............. $322 $328 $380 $431 $445 $459 $524 $653 $978 .......
Energy Use [kWh/day]. 9.03 8.88 8.43 8.18 8.11 8.07 7.94 7.88 7.79 .......
FD.M.SML........................... Cost [$]............. $356 $362 $388 $398 $417 $469 $489 $694 $1,119 .......
Energy Use [kWh/day]. 0.39 0.35 0.30 0.28 0.26 0.22 0.21 0.08 0.05 .......
FD.M.MED........................... Cost [$]............. $574 $581 $647 $662 $692 $738 $768 $860 $1,225 $1,899
Energy Use [kWh/day]. 0.65 0.60 0.46 0.44 0.40 0.36 0.34 0.31 0.25 0.19
FD.M.LRG........................... Cost [$]............. $719 $727 $793 $813 $853 $898 $938 $1,029 $1,394 $2,296
Energy Use [kWh/day]. 0.73 0.66 0.53 0.49 0.45 0.41 0.38 0.35 0.29 0.21
FD.L.SML........................... Cost [$]............. $416 $423 $474 $526 $546 $566 $632 $760 $1,194 .......
Energy Use [kWh/day]. 10.25 10.08 9.63 9.38 9.29 9.23 9.10 9.03 8.92 .......
FD.L.MED........................... Cost [$]............. $679 $688 $753 $845 $875 $905 $997 $1,225 $1,911 .......
Energy Use [kWh/day]. 13.71 13.49 12.58 12.13 11.99 11.90 11.67 11.55 11.35 .......
FD.L.LRG........................... Cost [$]............. $828 $838 $904 $995 $1,035 $1,075 $1,167 $1,394 $2,310 .......
Energy Use [kWh/day]. 15.62 15.36 14.45 14.00 13.81 13.69 13.45 13.34 13.06 .......
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV-11--Cost-Efficiency Results for Refrigeration Systems
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Efficiency level
Class/size -----------------------------------------------------------------------------------------------------------------------
Baseline 1 2 3 4 5 6 7 8 9 10 11 12
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
DC.L.O HER*............................. Cost [$]...................... $1591 $1616 $1641 $1671 $1745 $1749 $1760 $1798 $1848 $1898 $2058 ....... .......
6 kBtu..................................
AWEF Btu/Wh................... 2.40 2.62 2.81 2.97 3.30 3.31 3.34 3.43 3.56 3.62 3.65 ....... .......
DC.L.OHER 9 kBtu........................ Cost [$]...................... $1720 $1745 $1770 $1800 $1876 $1881 $1919 $1969 $1980 $2144 $2194 ....... .......
AWEF Btu/Wh................... 2.91 3.10 3.27 3.47 3.86 3.87 3.96 4.07 4.09 4.38 4.44 ....... .......
DC.L.O SCR 6 kBtu....................... Cost [$]...................... $1838 $1863 $1888 $1918 $1992 $1996 $2034 $2084 $2095 $2250 $2300 ....... .......
AWEF Btu/Wh................... 2.86 3.14 3.39 3.70 4.07 4.09 4.24 4.44 4.48 4.79 4.89 ....... .......
DC.L.O SCR 9 kBtu....................... Cost [$]...................... $1944 $1969 $1999 $2024 $2100 $2105 $2143 $2193 $2204 $2381 $2531 $2581 .......
AWEF Btu/Wh................... 3.70 3.98 4.35 4.64 5.11 5.13 5.28 5.48 5.52 5.86 6.15 6.25 .......
DC.L.O SCR 54 kBtu...................... Cost [$]...................... $6938 $6968 $7018 $7068 $7188 $7288 $7312 $7362 $7512 $7594 $10312 $10337 $11062
AWEF Btu/Wh................... 4.09 4.44 4.92 5.38 5.93 6.27 6.34 6.43 6.58 6.64 7.77 7.78 7.91
DC.L.O SEM 6 kBtu....................... Cost [$]...................... $2095 $2120 $2145 $2175 $2248 $2253 $2291 $2341 $2352 $2402 $2555 ....... .......
AWEF Btu/Wh................... 2.47 2.69 2.90 3.15 3.48 3.50 3.60 3.74 3.77 3.84 3.93 ....... .......
DC.L.O SEM 9 kBtu....................... Cost [$]...................... $2270 $2295 $2320 $2350 $2426 $2430 $2468 $2518 $2666 $2677 $2727 ....... .......
AWEF Btu/Wh................... 2.78 2.96 3.12 3.40 3.77 3.78 3.86 3.96 4.28 4.30 4.36 ....... .......
DC.L.O SEM 54 kBtu...................... Cost [$]...................... $7776 $7806 $7856 $7906 $8006 $8129 $8208 $8258 $8340 $11254 $11720 $11804 .......
AWEF Btu/Wh................... 3.36 3.63 3.99 4.32 4.74 5.24 5.36 5.43 5.47 6.37 6.52 6.54 .......
DC.L.O SEM 72 kBtu...................... Cost [$]...................... $9772 $9802 $9877 $9952 $10075 $10175 $10225 $10304 $10427 $11091 $13999 $14083 .......
AWEF Btu/Wh................... 3.41 3.70 4.11 4.50 4.96 5.36 5.44 5.53 5.58 5.79 6.71 6.72 .......
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
* HER indicates a hermetic compressor, SCR indicates a scroll compressor, and SEM indicates a semi-hermetic compressor.
D. Markups Analysis
This section explains how DOE developed the distribution channel
and supply chain markups to determine installed costs for the end-users
of refrigeration systems and envelope components.
In the preliminary analysis, DOE described different distribution
channels for the two broadly defined segments of the WICF market: the
food sales (grocery) segment and the food service segment for the
purposes of
[[Page 55822]]
calculating markups. In the food sales segment, the refrigeration
systems are predominantly unit coolers connected to multiplex
condensing systems. In the food service and convenience store market
segment, the refrigeration systems are mostly dedicated condensing
systems. DOE acknowledged that walk-in units may also be assembled in
the field, with key components sourced from different vendors through
different channels. However, in the preliminary analysis, DOE conducted
the markups analysis on complete walk-in systems and did not apply
separate markups for different components. Consequently, DOE assumed in
the preliminary analysis that the refrigeration system and the envelope
followed identical distribution channels even if they were manufactured
by a different set of manufacturers.
One interested party recommended that DOE include an additional
distribution channel. Heatcraft commented that the refrigeration system
manufacturers often sell directly to the envelope manufacturers, who
integrate the refrigeration systems with the envelopes and then sell
the assembled units. (Heatcraft, Public Meeting Transcript, No. 0045 at
p. 187) Heatcraft identified this market segment as OEMs and observed
that this important channel of distribution was not considered by DOE,
even though 50 percent of the refrigeration system business is
distributed through the OEM market segment.
The revised NOPR analysis uses component-level standards for
specific envelope components and for the refrigeration systems. Because
of this component-level standards approach, DOE conducts all the key
analysis steps separately for the refrigeration systems and the
selected envelope components in the NOPR analysis. As part of this
approach, DOE includes a distinct OEM distribution channel in the
markup analysis. Based on interviews with several manufacturers, DOE
estimates that the percentage share of the aggregate shipments of
refrigeration systems attributable to the OEM segment of the market is
55 percent for all dedicated condensing refrigeration systems, similar
to the 50 percent share indicated by Heatcraft.
Another interested party commented on the relative shares of the
different market segments DOE identified. In the preliminary analysis,
DOE estimated that for walk-ins with dedicated condensing units, 50
percent of aggregate sales were for the food service segment and the
remaining 50 percent were for the convenience and small grocery stores
segment. American Panel commented that for walk-in equipment sold with
dedicated condensing equipment, the share of the food service segment
across the two broad market segments should be 80 percent and the share
of the convenience and small grocery stores segment should be 20
percent. (American Panel, No. 0048.1 at p. 8) In the NOPR, DOE revised
its shipment analysis as described in chapter 9 of the TSD and noted
that for the walk-ins with dedicated condensing equipment, the relative
shares for the food service segment and the convenience and small
grocery stores segment are now 78 percent and 22 percent, respectively,
compared to 50 percent each for these two segments estimated in the
preliminary analysis. These new values closely match the percentage
shares indicated by American Panel.
Several interested parties commented on the shares of different
distribution channels across the market segments that DOE previously
applied. In the preliminary analysis, DOE indicated that the percentage
share of the aggregate shipments of refrigeration systems through
refrigeration wholesalers was 15 percent for multiplex equipment and
57.5 percent for dedicated condensing equipment on an average basis for
all the market segments. Heatcraft stated that the percentage share of
the aggregate shipments of refrigeration systems through the
refrigeration wholesalers is 50 percent. (Heatcraft, Public Meeting
Transcript, No. 0045 at p. 284) Based on information gathered through
interviews with manufacturers of refrigeration systems, DOE has revised
its estimates for the percentage share of the aggregate shipments of
refrigeration systems through wholesalers. For the NOPR, DOE revised
these estimates to 42 percent for dedicated condensing systems and 45
percent for the unit coolers connected to a multiplex condensing
system.
In the preliminary analysis, DOE assumed that the share of
electronic commerce (E-commerce) resellers in the food service market
for dedicated condensing systems is 10 percent. American Panel
commented that this figure was too high and should be 1 percent or, at
most, 2 percent. (American Panel, Public Meeting Transcript, No. 0045
at p. 195 and No. 0048.1 at p. 8) Manitowoc pointed out that E-commerce
resellers often represent food service equipment distributors selling
to territories outside the specific territory assigned to them by the
manufacturer and that their sales could be considered distributor
sales. In its view, if this aspect is considered, then the share of the
E-commerce business estimated by DOE in the preliminary analysis is too
high. (Manitowoc, Public Meeting Transcript, No. 0045 at p. 195) NEEA
and NPCC reinforced the observations made by American Panel and
Manitowoc, and suggested that DOE adjust the markup analysis
accordingly. (NEEA and NPCC, No. 0059.1 at p. 9) DOE agrees with
Manitowoc's observation that the E-commerce share of total sales is
essentially composed of sales through the distributor segment and,
therefore, there is no need to identify this channel of distribution
separately. As a result of this observation, DOE did not identify this
as a separate distribution channel in the NOPR analysis.
American Panel noted that the distribution channel shares described
by DOE for walk-ins with dedicated condensing equipment sold in the
food service market segment are accurate for the national accounts and
distributors under the current economic situation, but it expected to
see the market share of the national chains increase to 20 percent with
the economy improving in the next 2 to 3 years. (American Panel, Public
Meeting Transcript, No. 0045 at p. 144) American Panel also pointed out
that, for walk-ins with dedicated condensing equipment sold to the food
service segment, the market share for contractors should be 5 percent
instead of 10 percent. (American Panel, Public Meeting Transcript, No.
0045 at p. 194) In the NOPR markup analysis, DOE has factored American
Panel's estimates and revised the corresponding market shares to 10
percent for the national chains and 5 percent for the contractors.
Regarding the values of the markup multipliers presented in chapter
6 of the preliminary TSD, several interested parties commented on the
methodology for arriving at the multiplier. AHRI stated that, when
multiple-stage markups (manufacturer, distributor, dealer, and
contractor) are estimated separately and multiplied to estimate the
overall markups, the errors in the different stages are compounded in
the final result. (AHRI, No. 0055.1 at p. 3) AHRI suggested that DOE
avoid compounding errors and instead use retail prices in the analysis.
DOE notes that the current methodology of the markup analysis is
standardized in DOE's economic analysis in its energy conservation
rulemaking activities. A retail price analysis is not feasible, because
a representative sample of direct end-user prices is difficult to
obtain from distributors and contractors because pricing data are
considered business-sensitive. Furthermore, these
[[Page 55823]]
parties often use aggregate markups on the entire contract and separate
markups for labor and/or equipment installations cannot be established.
Therefore, DOE continues to use a markup analysis in this NOPR.
Craig Industries commented that the mechanical contractor may not
always purchase envelope components from the distributor, but can
purchase them directly from the manufacturers and, therefore, the
baseline markup for the mechanical contractor should not include the
distributor markup. (Craig Industries, No. 0064.1 at p. 1) In the NOPR,
DOE is proposing component-level standards for the envelope components
and has revised the markup analysis accordingly. DOE assumes that the
general contractors would purchase the envelope components directly
from the manufacturer, and hence, did not include the markup
percentages of the distributors in the estimated overall markups for
sales through the contractor channel in the NOPR analysis.
Regarding the values of the markup multipliers presented in chapter
6 of the preliminary TSD, American Panel commented that the markup
multiplier values were too high and should correspond to approximately
10-12 percent of the markup. (American Panel, Public Meeting
Transcript, No. 0045 at p. 201) American Panel also questioned DOE's
assumption that the markup multipliers for unit coolers connected to
multiplex systems would be substantially lower than the multipliers for
the dedicated condensing equipment, when both types of equipment move
through the same channel of distribution. (American Panel, No. 0048.1
at p. 8) In response to the first comment, DOE notes that the markup
multipliers obtained in the revised analysis are consistent with the
markup multipliers derived for other refrigeration products that often
share the same distribution channels with walk-in coolers and freezers.
Therefore, DOE considers the markup multipliers to be representative of
the industry. Regarding the second comment, DOE notes that the overall
markup multipliers depend not only on the channels through which the
products are sold, but also on the relative shares of sales of the
distribution channels. Because unit coolers connected to multiplex
condensing systems are predominantly used in food sales, and a larger
percentage of such equipment is sold directly to contractors, the
equipment would be expected to have lower weighted average markup
multipliers. The NOPR analysis uses weighted average baseline markup
multipliers for multiplex and non-multiplex equipment of 1.43 and 1.51,
respectively.
One interested party commented on DOE's data sources. NEEA and NPCC
recommended that, in view of the several comments DOE received on the
markup analysis and ongoing restructuring and consolidation of the food
retailing industry, DOE should obtain manufacturer assistance in re-
crafting the markup estimates for each distribution channel. (NEEA and
NPCC, No. 0059.1 at p. 9) In the NOPR analysis, DOE has revised many of
its estimates of the shares of individual channels based on comments
received from interested parties. Given their general reliability, in
estimating the markup multipliers in specific distribution channels,
DOE uses data from trade associations and economic census data from the
U.S. Census Bureau. The NOPR analysis relies on the most recently
available data to derive the markup multipliers.
Table IV-12 shows the overall weighted average baseline and
incremental markups for sales of refrigeration systems and envelope
components. Chapter 6 and appendix 6A of the TSD provide complete
details of the methodology and data used in the estimation of the
markup multipliers.
Table IV-12--Overall Markup Multipliers for All Equipment Classes
------------------------------------------------------------------------
Markup multipliers
Equipment class -------------------------------
Baseline Incremental
------------------------------------------------------------------------
DC.M.I *................................ 1.51 1.19
DC.L.I *
DC.M.O *................................ 1.51 1.19
DC.L.O *
MC.M.................................... 1.43 1.25
MC.L
SP.M.................................... 1.16 1.09
SP.L
DD.M.................................... 1.41 1.29
DD.L
PD.M.................................... 1.16 1.09
PD.L
FD.M.................................... 1.16 1.09
FD.L
------------------------------------------------------------------------
* For DC refrigeration systems, markups apply to both capacity ranges.
E. Energy Use Analysis
The energy use analysis estimates the annual energy consumption of
refrigeration systems serving walk-ins and the energy consumption that
can be directly ascribed to the selected components of the WICF
envelopes. These estimates are used in the subsequent LCC and PBP
analyses (chapter 8 of the TSD) and NIA (chapter 10 of the TSD).
In the preliminary analysis, DOE estimated the annual energy
consumption for a complete theoretical walk-in consisting of an
envelope and a matched refrigeration system, each at a specific
efficiency level, using a set of assumptions for product loading, duty
cycle, and other associated conditions. In the NOPR, DOE is proposing
energy consumption standards separately for the refrigeration systems
and a selected set of envelope components: Panels, non-display doors,
and display doors. Consequently, DOE revised the methodology for
estimating the annual energy consumption to reflect the new approach.
A key change from the preliminary analysis methodology for
estimating the annual energy consumption is that in the NOPR analysis,
DOE is no longer matching the refrigeration systems to specific
envelope sizes. The estimates for the annual energy consumption of each
analyzed representative refrigeration system (see section IV.C.2) were
reached by assuming that (1) the refrigeration system is sized such
that it follows a specific daily duty cycle for a given number of hours
per day at full rated capacity, and (2) the refrigeration systems
produce no additional refrigeration effect for the remaining period of
the 24-hour cycle. These assumptions are consistent with the present
industry practice for sizing refrigeration systems. This methodology
assumes that the refrigeration system is paired with an envelope that
generates a load profile such that the rated hourly capacity of the
paired refrigeration system, operated for the given number of run hours
per day, produces adequate refrigeration effect to meet the daily
refrigeration load of the envelope with a safety margin to meet
contingency situations. Thus, the annual energy consumption estimates
for the refrigeration system depends on the methodology adopted for
sizing, the implied assumptions and the extent of oversizing. The
sizing methodology adopted in this NOPR analysis is further discussed
later in this section.
For the envelopes, the estimates of product and infiltration loads
are no longer used in estimating energy consumption in the analysis
because these factors are not intended to be mitigated by any of the
component standards. DOE calculated only the transmission loads across
the envelope components under test procedure conditions and combined
that with the annual energy efficiency ratio (AEER) to arrive at the
annual refrigeration energy consumption associated with the specific
component. AEER is a ratio of the net amount of heat removed from
[[Page 55824]]
the envelope in Btu by the refrigeration system and the annual energy
consumed in watt-hours using bin temperature data specified in AHRI
1250-2009 to calculate AWEF. The annual electricity consumption
attributable to any envelope component is the sum of the direct
electrical energy consumed by electrically-powered sub-components
(e.g., lights and anti-sweat heaters) and the refrigeration energy,
which is computed by dividing the transmission heat load traceable to
the envelope component by the AEER metric, where the AEER metric
represents the efficiency of the refrigeration system with which the
envelope is paired.
In the preliminary analysis, DOE estimated aggregate refrigeration
loads of three sizes of complete WICF envelopes in each of the four
envelope classes (i.e., storage and display coolers and freezers.) In
the NOPR, given the component-level approach, DOE estimated the annual
energy consumption per unit of the specific envelope components by
calculating the transmission load of the component over 24 hours under
the test procedure conditions, and then calculating the annual
refrigeration energy consumption attributed to that component by
applying an appropriate AEER value.
1. Sizing Methodology for the Refrigeration System
In the preliminary analysis, DOE calculated the required size of
the refrigeration system for a given envelope by assuming that the
rated capacity of the refrigeration system would be adequate to meet
the refrigeration load of a walk-in cooler or freezer during the high-
load condition. The load profile of WICF equipment that DOE used
broadly followed the load profile assumptions of the industry test
procedure for refrigeration systems--AHRI 1250-2009, Standard for
Performance Rating of Walk-In Coolers and Freezers (``AHRI 1250-
2009''). As noted earlier, that protocol was incorporated into DOE's
test procedure. 76 FR 33631 (June 9, 2011).
As a result, the DOE test procedure incorporates an assumption
that, during a 24-hour period, a WICF refrigeration system experiences
a high-load period of 8 hours corresponding to frequent door openings,
product loading events, and other design load factors, and a low-load
period for the remaining 16 hours, corresponding to a minimum load
resulting from conduction, internal heat gains from non-refrigeration
equipment, and steady-state infiltration across the envelope surfaces.
During the high-load period, the ratio of the envelope load to the net
refrigeration system capacity is 70 percent for coolers and 80 percent
for freezers. During the low-load period, the ratio of the envelope
load to the net refrigeration system capacity is 10 percent for coolers
and 40 percent for freezers. The relevant load equations correspond to
a duty cycle for refrigeration systems, where the system runs at full
design point refrigeration capacity for 7.2 hours per day for coolers
and 12.8 hours per day for freezers. Specific equations to vary load
based on the outdoor ambient temperature are also specified.
DOE received several comments on its duty cycle assumptions in the
preliminary analysis. American Panel pointed out that the average
envelope load hourly distributions for low and high loads used by DOE
in the preliminary analysis represented a light loading condition and
should be reversed, implying that a typical refrigeration system would
experience 16 hours of high load and 8 hours of low load per day,
rather than DOE's assumptions of 8 hours and 16 hours for high and low
load, respectively. (American Panel, Public Meeting Transcript, No.
0045 at p. 212) For the restaurant market segment in particular,
American Panel noted that the high-load and low-load periods would both
typically be 12 hours each. (American Panel, No. 0048.1 at p. 8)
American Panel also commented that its own heat load calculations use
18 hours of maximum refrigeration system run time for the freezers and
noted that this is the industry standard. (American Panel, No. 0048.1
at p. 3) Manitowoc and Heatcraft, however, agreed with DOE's
assumptions of the hourly load distributions for the high-load and low-
load periods, which are consistent with AHRI 1250-2009. (Manitowoc,
Public Meeting Transcript, No. 0045 at p. 215; Heatcraft, Public
Meeting Transcript, No. 0045 at p. 213) NEEA and NPCC noted that the
duty cycle assumptions for the energy use analysis were credible and
did not recommend any changes to this part of the analysis. (NEEA and
NPCC, No. 0059.1 at p. 10) AHRI also commented that the assumptions
made by DOE to calculate the duty cycle are acceptable for the
analysis. (AHRI, No. 0055.1 at p. 3) Manitowoc noted that the envelope
load assumptions are not supported with measurements from real life
walk-in monitoring but are based on conservative sizing practices
followed by the industry to ensure that even in worst-case situations,
the walk-in will maintain the necessary temperature. (Manitowoc, No.
0056.1 at p. 3)
In light of the comments received from American Panel on current
industry sizing practices, and Manitowoc's comment that actual duty
cycles differ from the AHRI test procedure conditions, DOE tentatively
concludes that the duty cycle assumptions of AHRI 1250-2009 should not
be used for the sizing purposes because they may not represent the
average conditions for WICF refrigeration systems for all applications
under all conditions. DOE recognizes that test conditions are often
designed to effectively compare the performance of equipment with
different features under the same conditions.
For the energy use analysis, DOE revisited the duty cycle issue and
found that the current industry practice for sizing the refrigeration
system is based on providing a 10 percent safety margin multiplier to
the calculated aggregate refrigeration load over a 24-hour daily cycle
and assuming a nominal run time of 16 hours for coolers and 18 hours
for freezers for sizing the refrigeration system. DOE's key assumption
in the preliminary analysis of equating the refrigeration capacity to
the high-box load is not practiced in the industry and DOE has made no
attempt to model the peak load. The nominal run time varies only in
special situations--such as when freezers use hot gas defrost or when
the temperature of the evaporator coil is higher than 32[emsp14][deg]F.
Consequently, DOE adopted the industry practice described above for
calculating the energy use and load characterization.
In this NOPR, DOE proposes a nominal run time of 16 hours per day
for coolers and 18 hours per day for freezers to calculate the capacity
of a ``perfectly'' sized refrigeration system. A fixed oversize factor
is then applied to this size to calculate the actual runtime. With the
oversize factor applied, DOE assumes that the runtime of the
refrigeration system is 13.3 hours per day for coolers and 15 hours per
day for freezers at full design point capacity. The reference outside
ambient temperatures for the design point capacity conform to the AHRI
1250-2009 conditions incorporated into the DOE test procedure and are
95[emsp14][deg]F and 90[emsp14][deg]F for refrigeration systems with
outdoor and indoor condensers, respectively.
DOE notes that the AHRI assumptions for high-load and low-load
conditions were supported by some interested parties and acknowledges
that the distribution of high-load and low-load hour assumptions could
be relevant to the equipment energy consumption. DOE has observed,
however, that the high-load situation is not taken into account by the
industry in its standard sizing methods and would not represent
[[Page 55825]]
current industry practices. Thus, for the NOPR analysis, DOE has
revised its sizing methodology to be consistent with its understanding
of the current industry practice. DOE requests comment on the sizing
methodology.
2. Oversize Factors
American Panel commented that DOE's preliminary analysis
assumptions regarding duty cycle and sizing conflicted with the
prevalent practice in the industry, which resulted in considerable
oversizing of the refrigeration systems when paired with a given
envelope. Oversizing leads to higher first cost estimates for the
refrigeration equipment and distorts the LCC and PBP results because
the energy savings are not commensurate with the first costs. American
Panel further commented that because the refrigeration systems examined
as part of the preliminary analysis are poorly matched to the
envelopes, no meaningful conclusion can be drawn from the accompanying
LCC, PBP, and NIA results. (American Panel, No. 0048.1 at p. 8 and p.
11) Regarding the annual energy calculations presented in chapter 7 of
the TSD, American Panel did not believe that DOE properly matched the
refrigeration systems and envelopes--which yielded an estimated 8 hours
or less of runtime per day. In its view, this preliminary estimate is
incorrect. (American Panel, No. 0048.1 at p. 9) American Panel also
submitted additional documentation demonstrating its own methodology
for matching the selected refrigeration system capacity to the
estimated heat load of a walk-in expressed in Btu/h. (American Panel,
No. 0048.1 at p. 9) DOE investigated further and found that the load
calculation manuals and sizing software of several refrigeration system
manufacturers supported American Panel's recommendation on the approach
to sizing.
As stated previously, DOE observed that the typical and widespread
industry practice for sizing the refrigeration system is to calculate
the daily heat load on the basis of a 24-hour cycle and divide by 16
hours of runtime for coolers and 18 hours of runtime for freezers. DOE
also found that it is customary in the industry to allow for a 10
percent safety margin to the aggregate 24-hour load resulting in 10
percent oversizing of the refrigeration system.
In the preliminary analysis, DOE considered a scaled mismatch
factor in addition to the oversizing related to its duty cycle
assumptions. DOE recognized that an exact match for the calculated
refrigeration capacity may not be available for the refrigeration
systems available in the market because most refrigeration systems are
mass-produced in discrete capacities. The capacity of the best matched
refrigeration system is likely to be the nearest higher capacity
refrigeration system available. This consideration led DOE to develop a
scaled mismatch factor that could be as high as 33 percent for the
smaller refrigeration system sizes, and was scaled down for the larger
sized units. In the preliminary analysis, DOE applied this mismatch
oversizing factor to the required refrigeration capacity at the high-
load condition to determine the required capacity of the refrigeration
system to be paired with a given envelope.
DOE received multiple comments regarding the mismatch factor.
Manitowoc pointed out that the mismatch factors used by DOE in the
preliminary analysis are high. DOE assumed that compressors are
available only in capacity increments of 6000 Btu/h but Manitowoc noted
that compressors are available at capacity increments of 2000 Btu/h and
1500 Btu/h for medium- and low-temperature systems, respectively.
(Manitowoc, No. 0056.1 at p. 3; Manitowoc, Public Meeting Transcript,
No. 0045 at p. 220 and p. 222) American Panel pointed out that the
maximum mismatch factor could be 15 percent. (American Panel, Public
Meeting Transcript, No. 0045 at p. 220) Heatcraft stated that DOE's
assumption that the sizes of refrigeration systems available in the
market are at 0.5-ton intervals is not applicable for larger sized
systems. For sizes from 5-10 horsepower, the compressors are available
in 2.5-horsepower intervals, and for sizes from 10-30 horsepower,
compressors are available in 5-horsepower intervals. (Heatcraft, No.
0069.1 at p. 2)
Based on these comments, DOE recalculated the mismatch factor
because compressors for the lower capacity units are available at
smaller size increments than what DOE assumed in the preliminary
analysis. DOE also agrees with Manitowoc that for larger sizes, the
size increments of available capacities are higher than size increments
available for the lower capacities. DOE further noted as part of the
revised analysis that under current industry practice, if the exact
calculated size of the refrigeration system with a 10 percent safety
margin is not available in the market, the user may choose the closest
matching size even if it has a lower capacity, allowing the daily
runtimes to be somewhat higher than their intended values. The designer
would recalculate the revised runtime with the available lower capacity
and compare it with the target runtime of 16 hours for coolers and 18
hours for freezers and, if this value falls within acceptable limits,
then the chosen size of the refrigeration system is accepted and there
is no mismatch oversizing.
DOE further examined the data of available capacities in published
catalogs of several manufacturers and noted that the range of available
capacities depends on compressor type and manufacturer. Furthermore,
because smaller capacity increments are available for units in the
lower capacity range and larger capacity increments are available for
units in the higher capacity range, the mismatch factor is generally
uniform over the range of equipment sizes. For the NOPR, DOE
tentatively concluded from these data that a scaled mismatch factor
linked to the target capacity of the unit may not be applicable, but
that the basic need to account for discrete capacities available in the
market is still valid. To this end, DOE is now applying a uniform
average mismatch factor of 10 percent over the entire capacity range of
refrigeration systems.
3. Product Load
The NOPR analysis does not include an explicitly modeled product
load to determine the annual energy consumption. Instead, the annual
energy consumption estimates for the refrigeration systems are based on
industry practice duty cycle assumptions. This approach does not
require any explicit modeling of the product load. However, for the
shipment analysis of refrigeration systems, DOE expressed annual
shipments and stocks in terms of installed refrigeration capacity (Btu/
h). The shipments of the refrigeration system were linked to the
shipments of envelopes, which required DOE to estimate the required
refrigeration capacity for the units shipped. DOE included several
assumptions about product loads in these calculations. These
assumptions are discussed in the relevant section on shipment (Section
IV.G of this NOPR).
4. Other Issues
DOE received one comment on the issue of the interaction of
building air-conditioning systems with WICF systems installed within
them. Ingersoll Rand stated that envelope improvements may not lead to
significant energy savings because the load on the refrigeration
systems of the WICF unit would be replaced by the load on the building
air-conditioning system. DOE did not account for the
[[Page 55826]]
difference in overall energy use that could be directly attributed to
the improvement of envelope components on the whole building cooling
load and, correspondingly, any space-cooling energy impacts. At the
same time, any envelope component improvements may also result in a
decrease in the use of heating energy within the buildings. This impact
on building heating and cooling loads would only occur for WICF units
located indoors. The relative cooling-energy-use penalty to heating-
energy-use benefit is a function of the climate of the region in which
the building is located, the building type and size, and the placement
of the WICF units within the building. The relative monetary benefits
are also a function of the relative heating and cooling fuel costs. The
quantification of the relative benefits impact would have required an
extensive analysis of building climate-control performance, which is
both unnecessary and outside the scope framed by Congress.
For the refrigeration systems, DOE calculated the annual energy
consumption for all six classes of refrigeration systems at various
capacity points with all available compressor options and at all
efficiency levels for which results of engineering analysis were
available. The annual energy consumption results were used as inputs to
the LCC and PBP analyses. Based on the results of the LCC analysis, DOE
selected the most cost-efficient combination of compressors and other
components at a given AWEF level for a specific capacity point.
Fourteen efficiency options were selected from the entire range of
available AWEF values for each capacity point analyzed. To simplify
further analysis, however, DOE chose two points from a set of four or
five capacity points in each of the four dedicated condensing equipment
classes, and one for each of the two multiplex condensing equipment
classes. DOE used the shipment data to derive a shipment weighted AEER
value for each TSL option for the refrigeration system. For the
envelope components, DOE estimated the associated refrigeration energy
at each of the TSL options and each level of efficiency of the
components. The units of analysis were the unit area for the panels and
each whole door for the doors. DOE added the direct electrical energy
consumed for each of the doors at different efficiency levels to the
refrigeration energy to arrive at the total annual energy consumption.
The annual energy consumption results for the components were used as
inputs to the LCC and PBP analyses for the components. Chapter 7 of the
TSD shows the annual average energy consumption estimates by equipment
class and efficiency level for both the refrigeration system and the
components.
F. Life-Cycle Cost and Payback Period Analyses
DOE conducts LCC and PBP analyses to evaluate the economic impacts
of potential energy conservation standards for walk-ins on individual
consumers--that is, buyers of the equipment. As stated previously, DOE
adopted a component-based approach for developing performance standards
for walk-in coolers and freezers. Consequently, the LCC and PBP
analyses were conducted separately for the refrigeration system and the
envelope components: panels, non-display doors, and display doors.
The LCC is defined as the total consumer expense over the life of a
product, consisting of purchase, installation, and operating costs
(expenses for energy use, maintenance, and repair). To calculate the
operating costs, DOE discounts future operating costs to the time of
purchase and sums them over the lifetime of the product. The PBP is
defined as the estimated number of years it takes consumers to recover
the increased purchase cost (including installation) of a more
efficient product. The increased purchase cost is derived from the
higher first cost of complying with the higher energy conservation
standard. DOE calculates the PBP by dividing the increase in purchase
cost (normally higher) by the change in the average annual operating
cost (normally lower) that results from the standard.
NEEA and NPCC suggested that, when estimating equipment lifetimes,
DOE should consider both the economic and physical lifetimes of WICF
equipment. (NEEA and NPCC, No. 0559.1 at p. 11) The physical lifetime
refers to the duration before the equipmen